# docs_fts_content

c1: EFTA00021968
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021968.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
United States V. Ghislaine Maxwell
20 Cr. 330 (AJN)
Testifying Witness 3500 Material
11/6/2021
3502
Date
Description
Attorney
Produced to Defense
3502-001
2021.02.01
Notes from phone call
2021.04.23
3502-002
2021.02.01
Testimony disclosure
2021.04.23
3502-003
2021.03.03
Notes from phone call
2021.04.23
3502-004
2021.04.09
Interview notes
2021.04.23
3502-005
2021.04.21
Interview notes
2021.04.23
3502-006
Resume
2021.04.23
3502-007
Contract for services
2021.04.23
3502-008
2021.10.21
Notes
2021.10.25
3502-009
2021.10.24
Notes
2021.10.25
3502-010
2006
Article
2021.10.25
3502-011
2009
Article
2021.10.25
3502-012
2010
Article
2021.10.25
3502-013
2014
Article
2021.10.25
3502-014
2015
Article
2021.10.25
3502-015
2015
Article
2021.10.25
3502-016
2015
Article
2021.10.25
3502-017
2016
Article
2021.10.25
3502-018
2017
Article
2021.10.25
3502-019
2018
Article
2021.10.25
3502-020
2018
Article
2021.10.25
3502-021
2019
Article
2021.10.25
3502-022
2020
Article
2021.10.25
3502-023
2021
Article
2021.10.25
3502-024
2021
Article
2021.10.25
3502-025
2021.10.25
Notes
2021.10.25
3502-026
2020
Article
2021.11.06
3502-027
2020
Article
2021.11.06
3502-028
2021.10.29
Notes
2021.11.06
3502-029
2021.10.31
Notes
2021.11.06
3502-030
2021.11.01
Notes
2021.11.06
3502-031
2021.11.02
Notes
2021.11.06
3502-032
2009
Article
2021.11.06
3502-033
2020
Article
2021.11.06
3502-034
2021
Article
2021.11.06
3502-035
2021.11.03
Notes
2021.11.06
3502-036
2021.11.04
Notes
2021.11.06
3503
Date
Description
Attorney
Produced to Defense
Steve Flatley
3503-001
Curriculum vitae
2021.09.15
3503-002
31E-NY-3027571
2021.10.11
3503-003
2021.08.25
Notes
2021.10.11
3503-004
2019.08.09
Email
2021.10.11
3503-005
2019.08.20
Email
2021.10.11
3503-006
2019.08.23
Email
2021.10.11
3503-007
2019.09.04
Email
2021.10.11
3503-008
2019.09.09
Email
2021.10.11
3503-009
2019.09.16
Email
2021.10.11
3503-010
2019.09.30
Email
2021.10.11
3503-011
2019.10.21
Email
2021.10.11
3503-012
2019.11.12
Email
2021.10.11
3503-013
2020.02.10
Email
2021.10.11
3503-014
2020.03.02
Email
2021.10.11
3503-015
2020.03.03
Email
2021.10.11
3503-016
2020.03.04
Email
2021.10.11
3503-017
Attachment to email
2021.10.11
3503-018
2020.03.18
Email
2021.10.11
3503-019
2020.03.31
Email
2021.10.11
3503-020
2020.04.07
Email
2021.10.11
3503-021
2020.05.12
Email
2021.10.11
3503-022
2020.05.14
Email
2021.10.11
3503-023
Attachment to email
2021.10.11
3503-024
2020.05.29
Email
2021.10.11
3503-025
Attachment to email
2021.10.11
3503-026
2020.06.17
Email
2021.10.11
3503-027
2020.06.17
Email
2021.10.11
3503-028
2020.06.19
Email
2021.10.11
3503-029
2020.06.19
Email
2021.10.11
3503-030
2020.06.20
Email
2021.10.11
3503-031
2020.06.23
Email
2021.10.11
3503-032
Attachment to email
2021.10.11
3503-033
2020.07.07
Email
2021.10.11
3503-034
2020.07.07
Email
2021.10.11
3503-035
2020.07.13
Email
2021.10.11
3503-036
Attachment to email
2021.10.11
3503-037
2020.07.13
Email
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
1
EFTA00021968

=== Page 2 ===
3503-038
Attachment to email
2021.10.11
3503-039
2020.07.13
Email
2021.10.11
3503-040
Attachment to email
2021.10.11
3503-041
2020.07.13
Email
2021.10.11
3503-042
2020.07.14
Email
2021.10.11
3503-043
2020.07.14
Email
2021.10.11
3503-044
2020.07.14
Email
2021.10.11
3503-045
2020.07.15
Email
2021.10.11
3503-046
2020.07.15
Email
2021.10.11
3503-047
2020.07.20
Email
2021.10.11
3503-048
Attachment to email
2021.10.11
3503-049
2020.07.20
Email
2021.10.11
3503-050
2020.07.21
Email
2021.10.11
3503-051
2020.07.22
Email
2021.10.11
3503-052
2020.07.23
Email
2021.10.11
3503-053
Attachment to email
2021.10.11
3503-054
2020.07.23
Email
2021.10.11
3503-055
Attachment to email
2021.10.11
3503-056
2020.07.24
Email
2021.10.11
3503-057
Attachment to email
2021.10.11
3503-058
2020.07.24
Email
2021.10.11
3503-059
2020.07.26
Email
2021.10.11
3503-060
2020.07.27
Email
2021.10.11
3503-061
2020.07.27
Email
2021.10.11
3503-062
2020.07.27
Email
2021.10.11
3503-063
2020.07.28
Email
2021.10.11
3503-064
2020.07.28
Email
2021.10.11
3503-065
2020.08.03
Email
2021.10.11
3503-066
2020.08.04
Email
2021.10.11
3503-067
Attachment to email
2021.10.11
3503-068
2020.08.04
Email
2021.10.11
3503-069
2020.08.19
Email
2021.10.11
3503-070
2020.10.02
Email
2021.10.11
3503-071
Attachment to email
2021.10.11
3503-072
Attachment to email
2021.10.11
3503-073
2020.10.05
Email
2021.10.11
3503-074
2020.10.08
Email
2021.10.11
3503-075
2020.10.08
Email
2021.10.11
3503-076
2020.10.09
Email
2021.10.11
3503-077
2020.10.09
Email
2021.10.11
3503-078
2020.10.12
Email
2021.10.11
3503-079
2020.10.13
Email
2021.10.11
3503-080
2020.10.14
Email
2021.10.11
3503-081
2020.10.15
Email
2021.10.11
3503-082
2020.10.15
Email
2021.10.11
3503-083
2020.10.16
Email
2021.10.11
3503-084
2020.10.16
Email
2021.10.11
3503-085
2020.10.19
Email
2021.10.11
3503-086
2020.10.19
Email
2021.10.11
3503-087
2020.10.20
Email
2021.10.11
3503-088
2020.10.21
Email
2021.10.11
3503-089
2020.10.21
Email
2021.10.11
3503-090
2020.10.23
Email
2021.10.11
3503-091
2020.10.26
Email
2021.10.11
3503-092
Attachment to email
2021.10.11
3503-093
2020.10.26
Email
2021.10.11
3503-094
Attachment to email
2021.10.11
3503-095
2020.10.26
Email
2021.10.11
3503-096
Attachment to email
2021.10.11
3503-097
2020.10.26
Email
2021.10.11
3503-098
Attachment to email
2021.10.11
3503-099
Attachment to email
2021.10.11
3503-100
Attachment to email
2021.10.11
3503-101
Attachment to email
2021.10.11
3503-102
2020.10.26
Email
2021.10.11
3503-103
Attachment to email
2021.10.11
3503-104
Attachment to email
2021.10.11
3503-105
2020.10.27
Email
2021.10.11
3503-106
2020.10.27
Email
2021.10.11
3503-107
2020.10.29
Email
2021.10.11
3503-108
2021.04.30
Email
2021.10.11
3504
Date
Description
Attorney
Produced to Defense
3504-001
2003.10.05
Palm Beach Police Report
2021.10.11
3504-002
2003.10.05
Palm Beach Police Report
2021.10.11
3504-003
2005.11.09
Palm Beach Police Report
2021.10.11
3504-004
2005.11.10
Palm Beach Police Report
2021.10.11
3504-005
2005.11.10
PBPD recording
2021.10.11
3504-006
2005.11.10
Letter
2021.10.11
3504-007
2005.11.17
Driver information
2021.10.11
3504-008
2005.11.21
Palm Beach Police Report
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
2
EFTA00021969

=== Page 3 ===
3504-009
2005.11.21
sworn statement
2021.10.11
3504-010
2005.11.21
sworn statement
2021.10.11
3504-011
2005.11.21
sworn statement
2021.10.11
3504-012
2006.05.01
Palm Beach Police Report
2021.10.11
3504-013
2006.05.01
Palm Beach Police Report
2021.10.11
3504-014
2006.05.01
Palm Beach Police Report
2021.10.11
3504-015
2006.08.26
Palm Beach Police Report
2021.10.11
3504-016
2006.10.20
Memorandum
2021.10.11
3504-017
2006.12.04
Driver information
2021.10.11
3504-018
2006.12.04
Criminal history check
2021.10.11
3504-019
2007.02.01
Letter
2021.10.11
3504-020
2007.12.11
Letter
2021.10.11
3504-021
2009.09.08
Deposition, Volume I
2021.10.11
3504-022
2009.09.08
Deposition, Volume II
2021.10.11
3504-023
2016.06.01
Deposition Exhibit 1
2021.10.11
3504-024
2016.06.01
Deposition Exhibit 2
2021.10.11
3504-025
2016.06.01
Deposition Exhibit 3
2021.10.11
3504-026
2016.06.01
Deposition Exhibit 4
2021.10.11
3504-027
2016.06.01
Deposition Exhibit 5
2021.10.11
3504-028
2016.06.01
Deposition Exhibit 6
2021.10.11
3504-029
2016.06.01
Deposition Exhibit 7
2021.10.11
3504-030
2016.06.01
Deposition transcript
2021.10.11
3504-031
2016.09.15
Sworn Affidavit
2021.10.11
3504-032
2019.07.13
Interview 302
2021.10.11
3504-033
2019.07.13
Notes
2021.10.11
3504-034
2020.02.19
Interview 302
2021.10.11
3504-035
2020.02.19
Notes
2021.10.11
3504-036
2020.06.28
Grand jury transcript
2021.10.11
3504-037
2020.09.28
Notes
2021.10.11
3504-038
2021.03.29
Grand jury transcript
2021.10.11
3504-039
2021.06.08
Notes
2021.10.11
3504-040
2021.06.24
Notes
2021.10.11
3504-041
2021.07.14
Notes
2021.10.11
3504-042
Criminal history check
2021.10.11
3504-043
Criminal history check
John Reynolds
2021.10.11
3505
Date
Description
Attorney
Produced to Defense
2006.12.14
Driver information
2021.10.11
3505-002
2007.05.08
Transcript
2021.10.11
3505-003
2007.06.07
Letter
2021.10.11
3505-004
2007.07.03
Driver information
2021.10.11
3505-005
2007.08.07
Interview 302
2021.10.11
3505-006
2007.08.07
Notes
2021.10.11
3505-007
2007.08.07
Property receipt
2021.10.11
3505-008
2007.08.28
Declaration
2021.10.11
3505-009
2007.09.07
Driver information
2021.10.11
3505-010
2007.09.07
Criminal history check
2021.10.11
3505-011
2007.09.07
Driver information
2021.10.11
3505-012
2007.09.07
Criminal history check
2021.10.11
3505-013
2007.09.07
Criminal history check
2021.10.11
3505-014
2007.09.07
Search records
2021.10.11
3505-015
2007.09.07
Criminal history check
2021.10.11
3505-016
2007.09.07
Criminal history check
2021.10.11
3505-017
2008.01.10
Letter
2021.10.11
3505-018
2008.03.18
Transcript
2021.10.11
3505-019
2008.06.19
submission to DAG
2021.10.11
3505-020
2008.06.30
Letter
2021.10.11
3505-021
2008.07.10
Letter
2021.10.11
3505-022
2008.07.10
Letter
2021.10.11
3505-023
2008.09.02
Letter
2021.10.11
3505-024
2008.12.05
Letter
2021.10.11
3505-025
2009.02.09
Complaint
2021.10.11
3505-026
2009.02.13
Plaintiff response
2021.10.11
3505-027
2009.03.23
Plaintiff notice
2021.10.11
3505-028
2009.06.17
Letter
2021.10.11
3505-029
2009.06.17
Letter
2021.10.11
3505-030
2009.08.13
Transcript
2021.10.11
3505-031
2009.08.31
Transcript
2021.10.11
3505-032
2009.08.31
Summary report
2021.10.11
3505-033
2009.09.10
Medical records
2021.10.11
3505-034
2009.10.20
Questionaire
2021.10.11
3505-035
2009.10.21
Transcript
2021.10.11
3505-036
2009.10.21
Medical examination
2021.10.11
3505-037
2009.10.24
Notes
2021.10.11
3505-038
2009.11.06
Plaintiff's Notice
2021.10.11
3505-039
2009.11.09
Medical records
2021.10.11
3505-040
2009.11.13
Medical report
2021.10.11
3505-041
2009.12.02
Plaintiff's Notice
2021.10.11
3505-042
2009.12.03
Response
2021.10.11
3505-043
2009.12.04
Deposition
2021.10.11
3505-044
2009.12.04
Deposition
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
3
EFTA00021970

=== Page 4 ===
3505-045
2009.12.04
Deposition Exhibit
2021.10.11
3505-046
2009.12.04
Deposition Exhibit
2021.10.11
3505-047
2009.12.04
Deposition Exhibit
2021.10.11
3505-048
2009.12.09
Notes
2021.10.11
3505-049
2009.12.18
Settlement Resolution Notice
2021.10.11
3505-050
2010.10.14
Arrest report
2021.10.11
3505-051
2011.03.12
FBI Report
2021.10.11
3505-052
2011.03.12
FBI Report
2021.10.11
3505-053
2011.04.20
Arrest report
2021.10.11
3505-054
2011.11.16
Arrest report
2021.10.11
3505-055
2012.02.28
Arrest report
2021.10.11
3505-056
2012.09.30
Arrest report
2021.10.11
3505-057
2013.03.07
Arrest report
2021.10.11
3505-058
2014.02.26
Transcript
2021.10.11
3505-059
2019.03.19
Interview 302
2021.10.11
3505-060
2019.03.19
Notes
2021.10.11
3505-061
2019.07.23
Email
2021.10.11
3505-062
2019.08.07
Email
2021.10.11
3505-063
2019.08.23
Email
2021.10.11
3505-064
2020.02.25
Email
2021.10.11
3505-065
2020.03.10
Email
2021.10.11
3505-066
2020.07.07
Email
2021.10.11
3505-067
2020.07.16
Email
2021.10.11
3505-068
2020.07.17
Interview 302
2021.10.11
3505-069
2020.07.17
Notes
2021.10.11
3505-070
2020.07.17
Email
2021.10.11
3505-071
Attachment to email
2021.10.11
3505-072
Attachment to email
2021.10.11
3505-073
2020.08.11
Notes
2021.10.11
3505-074
2020.08.11
Interview 302
2021.10.11
3505-075
2020.08.11
Notes
2021.10.11
3505-076
2021.01.19
Interview 302
2021.10.11
3505-077
2021.01.19
Notes
2021.10.11
3505-078
2021.01.20
Criminal history check
2021.10.11
3505-079
2021.01.20
Interview 302
2021.10.11
3505-080
2021.01.20
Notes
2021.10.11
3505-081
2021.01.21
Interview 302
2021.10.11
3505-082
2021.01.21
Notes
2021.10.11
3505-083
2021.01.21
Exhibit to notes
2021.10.11
3505-084
2021.01.28
Email
2021.10.11
3505-085
2021.03.29
Grand Jury presentation
2021.10.11
3505-086
2021.03.29
Transcript
2021.10.11
3505-087
2021.04.18
Email
2021.10.11
3505-088
2021.06.07
Notes
2021.10.11
3505-089
2021.06.09
Notes
2021.10.11
3505-090
2021.06.23
Notes
2021.10.11
3505-091
2021.06.24
Notes
2021.10.11
3505-092
2021.07.13
Notes
2021.10.11
3505-093
2021.08.16
Notes
2021.10.11
3505-094
2021.08.19
Email
2021.10.11
3505-095
2021.08.19
Text message
2021.10.11
3505-096
2021.08.19
Text message
2021.10.11
3505-097
2021.08.26
Notes
2021.10.11
3505-098
Notes
2021.10.11
3505-099
Notes
2021.10.11
3505-100
Answers to Interrogatories
2021.10.11
3505-101
Criminal history check
2021.10.11
3505-102
Criminal history check
2021.10.11
3505-103
Plaintiff's Response
2021.10.11
3505-104
Plaintiff's Notice
2021.10.11
3505-105
Photographs
2021.10.11
3505-106
Answers to Interrogatories
2021.10.11
3505-107
Criminal history check
2021.10.11
3505-108
2021.10.27
Notes
2021.11.06
3505-109
2021.10.15
Voicemail
Jack Scarola
2021.11.06
3506
Date
Description
Attorney
Produced to Defense
3505-001
2009.11.06
Deposition transcript
2021.10.11
3505-002
2021.06.23
Interview 302
2021.10.11
3505-003
2021.06.23
Exhibit to notes
2021.10.11
3505-004
2021.06.23
Notes
2021.10.11
3505-005
2021.07.13
Notes
2021.10.11
3505-006
2021.07.15
Notes
2021.10.11
3505-007
2021.08.24
Text messages
2021.10.11
3505-008
2021.08.24
Text messages
2021.10.11
3505-009
2021.08.27
Notes
2021.10.11
3505-010
Criminal history check
2021.10.11
3505-011
Criminal history check
2021.10.11
3505-012
Criminal history check
2021.10.11
3505-013
Criminal history check
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
4
EFTA00021971

=== Page 5 ===
3505-014
Text messages
2021.10.11
3507
Date
Description
Attorney
Produced to Defense
3507-001
2006.01.11
Memorandum
2021.10.11
3507-002
2006.07.13
Palm Beach Police Report
2021.10.11
3507-003
2006.12.04
Criminal history check
2021.10.11
3507-004
2007.01.11
Interview 302
2021.10.11
3507-005
2007.01.19
Memorandum
2021.10.11
3507-006
2007.02.02
Interview 302
2021.10.11
3507-007
2007.02.02
Notes
2021.10.11
3507-008
2007.02.02
Exhibit to notes
2021.10.11
3507-009
2007.05.22
Transcript
2021.10.11
3507-010
2007.07.30
Declaration
2021.10.11
3507-011
2010.02.16
Transcript
2021.10.11
3507-012
2021.09.27
Interview 302
2021.10.11
3507-013
2021.09.27
Notes
2021.10.11
3507-014
Criminal history check
2021.10.11
3507-015
Criminal history check
2021.10.11
3507-016
Notes
2021.11.06
3508
Date
Description
Attorney
Produced to Defense
3508-001
2021.09.02
Interview 302
2021.10.11
3508-002
2021.09.02
Notes
2021.10.11
3508-003
2021.10.18
Notes
2021.10.25
3509
Date
Description
Attorney
Produced to Defense
2019.09.19
Interview 302
2021.10.11
3509-002
2019.09.19
Notes
2021.10.11
3509-003
2019.11.14
Interview 302
2021.10.11
3509-004
2019.11.14
Notes
2021.10.11
3509-005
2019.12.17
Interview 302
2021.10.11
3509-006
2019.12.17
Notes
2021.10.11
3509-007
2020.01.17
Complaint
2021.10.11
3509-008
2020.02.27
Interview 302
2021.10.11
3509-009
2020.02.27
Notes
2021.10.11
3509-010
2020.03.20
Email
2021.10.11
3509-011
2020.04.03
Notes
2021.10.11
3509-012
2020.06.03
Email
2021.10.11
3509-013
2020.06.08
Email
2021.10.11
3509-014
2020.06.08
Email
2021.10.11
3509-015
2020.06.26
Email
2021.10.11
3509-016
2020.06.28
Transcript
2021.10.11
3509-017
2020.07.12
Email
2021.10.11
3509-018
2020.08.03
Email
2021.10.11
3509-019
2020.08.03
Email
2021.10.11
3509-020
2021.03.23
Interview 302
2021.10.11
3509-021
2021.03.23
Notes
2021.10.11
3509-022
2021.08.17
Notes
2021.10.11
3509-023
2021.09.02
Interview 302
2021.10.11
3509-024
2021.09.02
Notes
2021.10.11
3509-025
2021.09.14
Notes
2021.10.11
3509-026
2021.10.21
Notes
2021.10.11
3509-027
Text messages
2021.10.11
3509-028
2021.10.13
Notes
2021.10.25
3509-029
2021.10.14
Notes
2021.10.25
3509-030
2021.08.18
Email
2021.11.06
3509-031
2021.10.27
Documentation of services
2021.11.06
3509-032
2021.11.01
Notes
2021.11.06
3509-033
2021.11.03
Notes
2021.11.06
3509-034
Notes
2021.11.06
3509-035
Notes
Robert Glassman
2021.11.06
3510
Date
Description
Attorney
Produced to Defense
3510-001
2020.01.14
Interview 302
2021.10.11
3510-002
2020.01.14
Notes
2021.10.11
3510-003
2020.06.28
Grand jury transcript
2021.10.11
3510-004
2021.05.03
Notes
2021.10.11
3510-005
2021.08.30
Interview 302
2021.10.11
3510-006
2021.08.30
Notes
2021.10.11
3510-007
2021.08.31
Interview 302
2021.10.11
3510-008
2021.08.31
Notes
2021.10.11
3510-009
2021.09.01
Text messages
2021.10.11
3510-010
Text messages
2021.10.11
3510-011
Text messages
2021.10.11
3511
Date
Description
Attorney
Produced to Defense
3511-001
2021.07.30
Email
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
5
EFTA00021972

=== Page 6 ===
3511-002
2021.08.05
Email
2021.10.11
3511-003
Attachment to email
2021.10.11
3512
Date
Description
Attorney
Produced to Defense
3512-001
2003.10.15
Palm Beach Police Report
2021.10.11
3512-002
Palm Beach Police Report
2021.10.11
3512-003
Palm Beach Police Report
2021.10.11
3512-004
2021.05.19
Notes
2021.10.11
3512-005
2021.06.08
Notes
2021.10.11
3512-006
2021.07.13
Notes
2021.10.11
3513
Date
Description
Attorney
Produced to Defense
3513-001
1995.11.07
Letter
2021.10.11
3513-002
2019.08.27
Interview 302
2021.10.11
3513-003
2019.08.27
Notes
2021.10.11
3513-004
2019.08.27
Transcript
2021.10.11
3513-005
2019.09.19
Interview 302
2021.10.11
3513-006
2019.09.19
Notes
2021.10.11
3513-007
2019.09.20
Email
2021.10.11
3513-008
2019.10.03
FBI Report
2021.10.11
3513-009
2019.12.15
Interview 302
2021.10.11
3513-010
2019.12.15
Notes
2021.10.11
3513-011
2019.12.15
Exhibit to Notes
2021.10.11
3513-012
2019.12.15
Exhibit to Notes
2021.10.11
3513-013
2019.12.15
Exhibit to Notes
2021.10.11
3513-014
2019.12.15
Exhibit to Notes
2021.10.11
3513-015
2019.12.15
Exhibit to Notes
2021.10.11
3513-016
2019.12.15
Exhibit to Notes
2021.10.11
3513-017
2019.12.15
Exhibit to Notes
2021.10.11
3513-018
2019.12.15
Exhibit to Notes
2021.10.11
3513-019
2019.12.15
Exhibit to Notes
2021.10.11
3513-020
2019.12.15
Exhibit to Notes
2021.10.11
3513-021
2019.12.15
Exhibit to Notes
2021.10.11
3513-022
2019.12.27
Email
2021.10.11
3513-023
2019.12.28
Email
2021.10.11
3513-024
2020.06.28
Transcript
2021.10.11
3513-025
2020.07.13
Letter
2021.10.11
3513-026
2020.07.14
Email
2021.10.11
3513-027
2020.07.14
Transcript
2021.10.11
3513-028
2020.12.15
Email
2021.10.11
3513-029
2021.03.29
Transcript
2021.10.11
3513-030
2021.06.30
Criminal history report
2021.10.11
3513-031
2021.07.27
Interview 302
2021.10.11
3513-032
2021.07.27
Notes
2021.10.11
3513-033
2021.07.28
Notes
2021.10.11
3513-034
2021.07.29
Notes
2021.10.11
3513-035
2021.08.24
Notes
2021.10.11
3513-036
2021.08.24
Email
2021.10.11
3513-037
2021.09.01
Interview 302
2021.10.11
3513-038
2021.09.01
Notes
2021.10.11
3513-039
2021.09.01
Exhibit to Notes
2021.10.11
3513-040
2021.09.02
Notes
2021.10.11
3513-041
2021.09.02
Interview 302
2021.10.11
3513-042
2021.09.02
Exhibit to Notes
2021.10.11
3513-043
2021.09.02
Exhibit to Notes
2021.10.11
3513-044
2021.09.02
Exhibit to Notes
2021.10.11
3513-045
2021.09.03
Notes
2021.10.11
3513-046
2021.10.06
Criminal history report
2021.10.11
3513-047
NYS ovs Application
2021.10.11
3513-048
NYS ovs Application
2021.10.11
3513-049
NYS OVS Application
2021.10.11
3513-050
Text messages
2021.10.11
3513-051
Text messages
2021.10.11
3513-052
Text messages
2021.10.11
3513-053
2019.09.05
Email
2021.10.25
3513-054
Attachment to email
2021.10.25
3513-055
2019.10.03
Email
2021.10.25
3513-056
2019.10.03
Email
2021.10.25
3513-057
2019.10.04
Email
2021.10.25
3513-058
2019.10.15
Email
2021.10.25
3513-059
2021.10.24
Notes
Brad Edwards, Brittany
2021.10.25
3513-060
2021.10.27
Documentation of services
Henderson
2021.11.06
3514
Date
Description
Attorney
Produced to Defense
2006.11.15
Interview 302
2021.10.11
3514-002
2006.11.15
Notes
2021.10.11
3514-003
2007.07.30
Declaration
2021.10.11
3514-004
2019.07.15
Transcript
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
6
EFTA00021973

=== Page 7 ===
3514-005
2019.08.27
Transcript
2021.10.11
3514-006
2019.09.28
Interview 302
2021.10.11
3514-007
2019.09.28
Notes
2021.10.11
3514-008
2019.09.29
Email
2021.10.11
3514-009
2019.09.29
Email
2021.10.11
3514-010
2019.10.28
Email
2021.10.11
3514-011
2019.11.12
Complaint
2021.10.11
3514-012
2020.05.09
Notes
2021.10.11
3514-013
2020.06.28
Transcript
2021.10.11
3514-014
2020.07.14
Transcript
2021.10.11
3514-015
2020.12.15
Email
2021.10.11
3514-016
2020.12.15
Letter
2021.10.11
3514-017
2021.03.29
Transcript
2021.10.11
3514-018
2021.05.11
FBI Report
2021.10.11
3514-019
2021.06.29
FBI Report
2021.10.11
3514-020
2021.06.29
FBI Report
2021.10.11
3514-021
2021.06.30
Criminal history report
2021.10.11
3514-022
2021.06.30
Criminal history report
2021.10.11
3514-023
2021.07.26
Interview 302
2021.10.11
3514-024
2021.07.26
Notes
2021.10.11
3514-025
2021.07.29
Notes
2021.10.11
3514-026
2021.09.17
Interview 302
2021.10.11
3514-027
2021.09.17
Notes
2021.10.11
3514-028
2021.09.17
Exhibit to notes
2021.10.11
3514-029
2021.09.17
Exhibit to notes
2021.10.11
3514-030
2021.09.18
Notes
2021.10.11
3514-031
Photographs
2021.10.11
3514-032
Photographs
2021.10.11
3514-033
Photographs
2021.10.11
3514-034
Photographs
2021.10.11
3514-035
Photographs
2021.10.11
3514-036
Photographs
2021.10.11
3514-037
Photographs
2021.10.11
3514-038
Photographs
2021.10.11
3514-039
Photographs
2021.10.11
3514-040
2019.10.15
Email
2021.10.11
3514-041
Photograph
2021.10.11
3514-042
2008.03.17
Search Warrant
2021.10.11
3514-043
2008.03.17
Search Warrant
Sigrid McCawley
2021.10.11
3515
Date
Description
Attorney
Produced to Defense
3515-001
2020.08.24
Interview 302
2021.10.11
3515-002
2020.08.24
Notes
2021.10.11
3515-003
2021.05.06
Notes
2021.10.11
3515-004
Text messages
2021.10.11
3515-005
Text messages
2021.10.11
3515-006
Text messages
2021.10.11
3515-007
2021.11.03
Notes
2021.11.06
3516
Date
Description
Attorney
Produced to Defense
3516-001
2020.12.18
Interview 302
2021.10.11
3516-002
2021.01.13
Interview 302
2021.10.11
3516-003
2021.01.13
Notes
2021.10.11
3516-004
2021.03.29
Transcript
2021.10.11
3516-005
2021.06.07
Notes
2021.10.11
3516-006
2021.06.22
Notes
2021.10.11
3516-007
2021.07.12
Notes
2021.10.11
3516-008
2021.07.16
Email
2021.10.11
3516-009
2021.07.16
Email
2021.10.11
3516-010
Criminal history report
2021.10.11
3516-011
Criminal history report
2021.10.11
3516-012
Criminal history report
2021.10.11
3516-013
Criminal history report
2021.10.11
3516-014
Search records
2021.10.11
3516-015
Criminal history report
John Diaz
2021.10.11
3517
Date
Description
Attorney
Produced to Defense
3517-001
2006.08.17
Criminal history report
2021.10.11
3517-002
2006.08.17
Interview 302
2021.10.11
3517-003
2006.08.17
Exhibit to 302
2021.10.11
3517-004
2021.06.30
Interview 302
2021.10.11
3517-005
2021.06.30
Notes
2021.10.11
3517-006
2021.06.30
Exhibit to notes
2021.10.11
3517-007
2021.07.14
Notes
2021.10.11
3517-008
Text messages
2021.10.11
3517-009
Notes
2021.10.11
3517-010
2021.11.03
Notes
2021.11.06
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
7
EFTA00021974

=== Page 8 ===
3518
Date
Description
Attorney
Produced to Defense
3518-001
2019.09.16
Notes
2021.10.11
3518-002
2021.09.24
Notes
2021.10.11
3518-003
2021.09.27
Notes
2021.10.11
3518-004
2021.09.27
Email
2021.10.11
3518-005
Attachment to Email
2021.10.11
3518-006
Attachment to Email
2021.10.11
3518-007
Attachment to Email
2021.10.11
3518-008
Attachment to Email
2021.10.11
3518-009
Attachment to Email
2021.10.11
3518-010
Voicemail
2021.10.11
3518-011
Voicemail
2021.10.11
3519
Date
Description
Attorney
Produced to Defense
2021.04.26
Notes
2021.10.11
3519-002
Criminal history check
2021.10.11
3520
Date
Description
Attorney
Produced to Defense
3520-001
2019.07.06
FBI 302
2021.10.11
3520-002
2019.07.06
Text message
2021.10.11
3520-003
2019.07.06
Text message
2021.10.11
3520-004
2019.07.06
Text message
2021.10.11
3520-005
2019.07.11
FBI 302
2021.10.11
3520-006
2019.07.11
FBI 302
2021.10.11
3520-007
2019.07.12
FBI 302
2021.10.11
3520-008
2019.07.15
Email
2021.10.11
3520-009
2019.07.15
Email
2021.10.11
3520-010
2019.07.31
FBI 302
2021.10.11
3520-011
2019.08.02
FBI 302
2021.10.11
3520-012
2019.08.02
Email
2021.10.11
3520-013
2019.08.13
Notes and email
2021.10.11
3520-014
2019.09.17
Email
2021.10.11
3520-015
2020.05.22
Email
2021.10.11
3520-016
2021.04.29
Notes
2021.10.11
3520-017
2021.06.10
Email
2021.10.11
3520-018
Notes
2021.10.11
3520-019
2021.11.02
Notes
2021.11.06
3521
Date
Description
Attorney
Produced to Defense
3521-001
2021.01.29
FBI 302
2021.10.11
3521-002
2021.01.29
Notes
2021.10.11
3521-003
2021.11.02
Notes
2021.11.06
3521-004
2021.11.02
Notes
2021.11.06
Date
Description
Attorney
Produced to Defense
3522-001
2003.10.05
Palm Beach Police Department report
2021.10.11
3522-002
2005.09.23
Palm Beach Police Department report
2021.10.11
3522-003
2005.11.07
Palm Beach Police Department report
2021.10.11
3522-004
2006.09.29
Grand Jury records
2021.10.11
3522-005
2021.05.09
Email
2021.10.11
3522-006
2021.05.20
Notes
2021.10.11
3522-007
2021.06.08
Notes
2021.10.11
3522-008
2021.07.15
Notes
2021.10.11
3522-009
Voicemail
2021.10.11
3523
Date
Description
Attorney
Produced to Defense
3523-001
2006.01.27
T-Mobile records
2021.10.11
3523-002
2006.01.30
Driver information
2021.10.11
3523-003
2006.02.13
Palm Beach Police Department report
2021.10.11
3523-004
2006.08.15
FBI 302
2021.10.11
3523-005
2006.08.15
Notes
2021.10.11
3523-006
2016.06.03
Deposition transcript
2021.10.11
3523-007
2016.06.03
Deposition exhibit
2021.10.11
3523-008
2016.06.03
Deposition exhibit
2021.10.11
3523-009
2016.06.03
Deposition exhibit
2021.10.11
3523-010
2016.06.03
Deposition exhibit
2021.10.11
3523-011
2016.06.03
Deposition exhibit
2021.10.11
3523-012
2016.06.03
Deposition exhibit
2021.10.11
3523-013
2016.06.03
Deposition exhibit
2021.10.11
3523-014
2016.06.03
Deposition exhibit
2021.10.11
3523-015
2016.06.03
Deposition exhibit
2021.10.11
3523-016
2019.07.06
FBI 302
2021.10.11
3523-017
2020.02.07
Proffer agreement
2021.10.11
3523-018
2020.02.07
FBI 302
2021.10.11
3523-019
2020.02.07
Notes
2021.10.11
3523-020
2020.06.28
Grand jury transcript
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
8
EFTA00021975

=== Page 9 ===
3523-021
2020.07.17
Declaration
2021.10.11
3523-022
2021.03.29
Grand jury transcript
2021.10.11
3523-023
2021.07.30
Notes
2021.10.11
3523-024
2021.08.17
Notes
2021.10.11
3523-025
2021.08.18
Notes
2021.10.11
3523-026
Flight logs
2021.10.11
3523-027
Flight logs
2021.10.11
3523-028
Notes
2021.10.11
3523-029
Notes
Brendan Quigley
2021.10.11
3524
Date
Description
Attorney
Produced to Defense
3524-001
2006.08.01
Records search
2021.10.11
3524-002
2006.12.04
Records search
2021.10.11
3524-003
2007.01.23
W2
2021.10.11
3524-004
2007.02.14
Letter
2021.10.11
3524-005
2007.05.23
Employment records
2021.10.11
3524-006
2010.03.15
Deposition transcript
2021.10.11
3524-007
2019.07.06
FBI 302
2021.10.11
3524-008
2019.07.09
Notes
2021.10.11
3524-009
2019.07.12
FBI 302
2021.10.11
3524-010
2019.07.12
Notes
2021.10.11
3524-011
2019.09.10
FBI 302
2021.10.11
3524-012
2019.09.10
Notes
2021.10.11
3524-013
2021.05.14
FBI 302
2021.10.11
3524-014
2021.05.14
Notes
2021.10.11
3524-015
2021.05.14
Proffer agreement
2021.10.11
3524-016
2021.08.20
FBI 302
2021.10.11
3524-017
2021.08.20
Notes
2021.10.11
3524-018
2021.09.30
Notes
2021.10.11
3524-019
2021.10.01
Proffer agreement
2021.10.11
3524-020
2021.10.01
Notes
2021.10.11
3524-021
Criminal history check
2021.10.11
3524-022
Criminal history check
2021.10.11
3524-023
2007.08.31
Letter
2021.10.11
3524-024
2021.10.27
Notes
Joseph Nascimento
2021.11.06
3525
Date
Description
Attorney
Produced to Defense
3525-001
2021.09.21
Notes
2021.10.11
3525-002
2021.09.21
Email
2021.10.11
3525-003
2021.09.21
Voicemail
2021.10.11
3526
Date
Description
Attorney
Produced to Defense
3526-001
2021.09.22
Notes
2021.10.11
3526-002
2021.09.22
Notes
2021.10.11
3527
Date
Description
Attorney
Produced to Defense
3527-001
2006.11.27
FBI 302
2021.10.11
3527-002
2006.11.27
W2
2021.10.11
3527-003
2009.10.15
Deposition transcript
2021.10.11
3527-004
2019.07.09
FBI 302
2021.10.11
3527-005
2020.10.07
FBI 302
2021.10.11
3527-006
2020.10.07
Notes
2021.10.11
3527-007
2020.10.07
Exhibit for proffer
2021.10.11
3527-008
2020.10.07
Proffer agreement
2021.10.11
3527-009
2020.11.12
FBI 302
2021.10.11
3527-010
2020.11.12
Notes
2021.10.11
3527-011
2020.11.12
Proffer agreement
2021.10.11
3527-012
2021.08.04
Notes
2021.10.11
3527-013
2021.08.16
Notes
2021.10.11
3527-014
2020.08.17
Notes
2021.10.11
3527-015
Various notes
Glen McGorty
2021.10.11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
9
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From:
(USANYS)"
To:
(USANYS)"
Subject:
Date: Fri, 07 Feb 2020 17:04:26 +0000
Attachments: Safe_Horizon_As_a_result_of_this_new_law.docx
EFTA00020573


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From:
To:
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: RE: Epstein priv review -- 1B72 released and update
Date: Tue, 03 Nov 2020 22:39:11 +0000
Embedded: RE:_Epstein_priv_review__1B72_released_and_update.msg
Sender:
Subject: RE: Epstein priv review -- 1B72 released and update
Message-Id:
<SN5P110MB03363F89C4CDB4B32B4A70768A110@SN5P110MB0336.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
Cc:
Cc:
Cc:
Cc:
Cc:
Cc:
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From:
"
)"
To:
Cc:
)"
)"
Subject: Maxwell - RTC
Date: Thu, 30 Sep 2021 14:50:26 +0000
Importance: Normal
Attachments: Maxwell_RTC_v11.docx
Hi
I hope all's well! Attached is a draft of our RTC in the Maxwell case. If you have time to look at it, we'd love any
comments you might have.
In terms of timing, we have to file a joint proposed RTC on October 27, so we are thinking of sending this to the defense a
week or so before that.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
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=== Page 1 ===
AIRCRAFT PURCHASE AGREEMENT
THIS AIRCRAFT PURCHASE AGREEMENT (this "Agreement") is entered into as
of
April
16.
2021, by and between HYPERION AIR, LLC, a U.S. Virgin Islands limited liability
company, whose address is 9053 Estate Thomas, Suite 101. St. Thomas, U.S. Virgin Islands
("Seller"), and Industrial Integrity Solutions, LLC, a New Mexico limited liability company, whose
address is 2151 E. Convention Center Way, Ste. 222, Ontario, CA 91764-5496 ("Purchaser").
RECITATIONS:
Subject to the terms and conditions set forth in this Agreement, Seller desires to sell,
transfer, and deliver to Purchaser, and Purchaser desires to purchase from Seller, one used 2008
Keystone (Sikorsky) model S-76C++ helicopter, bearing manufacturer's serial number 760750, and
currently registered with the United States Federal Aviation Administration (the "FAA") as N722JE,
together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing
Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems,
furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is
more particularly described on Exhibit A, and also including all airframe, engine and accessory
logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and
paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the
"Aircraft").
NOW, THEREFORE, in consideration of the mutual promises and covenants herein
contained, and other good and valuable consideration, the parties hereto agree as follows:
1.
Purchase Price; Payment. Seller agrees to sell, and Purchaser agrees to
purchase, the Aircraft for a total purchase price of One Million Eight Hundred Thousand U.S. Dollars
(US $1,800,000) (the "Purchase Price"), which shall be paid by Purchaser to Seller as follows:
(a) Purchaser shall wire transfer a deposit in the amount of One Hundred
Thousand U.S. Dollars (US $100,000.00) (the "Deposit") to AIC Title Service, LLC, Oklahoma
City, Oklahoma, as escrow agent (the "Escrow Agent"), which Deposit shall be held in escrow and
disbursed at the Closing (as hereinafter defined and described) pursuant to the conditions and
requirements set forth in this Agreement; and
(b) The balance of the Purchase Price in the amount of One Million Seven
Hundred Thousand U.S. Dollars (US$1,700,000) (the "Purchase Price Balance") shall be paid at the
Closing, said Purchase Price Balance to be wire transferred (as and when provided in Section 4(c)
hereof) prior to the Closing into the Special Escrow Account (as defined below) of the Escrow
Agent for its disbursement to Seller at the Closing upon the satisfaction of the conditions and
requirements set forth in this Agreement.
1.1 Establishment of Special Escrow Account. The Deposit has been wire transferred
to the general escrow account of the Escrow Agent maintained at JP Morgan Chase Bank N.A., 100
N. Broadway Avenue, Suite 401, Oklahoma City, OK 73102. Upon the execution of this
Agreement, the Escrow Agent shall promptly cause the Deposit to be transferred to, and maintained
in, a special escrow account at said Bank created and maintained solely and exclusively for the
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=== Page 2 ===
purpose of this transaction (the "Special Escrow Account"); and the Escrow Agent shall thereupon
provide Seller and Purchaser with the number of the Special Escrow Account and any other
information pertinent thereto. The Deposit shall be held in escrow by the Escrow Agent in the
Special Escrow Account, and shall be refundable to Purchaser unless the same becomes
nonrefundable in accordance with the express provisions of this Agreement. The Escrow Agent
shall not place or hold any funds in the Special Escrow Account except for the funds received in
connection with this transaction (namely, the Deposit and the Purchase Price Balance).
2.
Condition of the Aircraft.
(a)
At the time of Seller's delivery to Purchaser of the Aircraft at the Closing, the
Aircraft will be delivered to Purchaser: (a) with good and marketable title, free and clear of all liens
and encumbrances, (b) with complete and continuous log books and maintenance records, (c) in an
airworthy condition, subject, however, to the matters listed on Exhibit A-1, with a valid FAA standard
airworthiness certificate, (d) subject to the matters listed on Exhibit A-1, with all airworthiness
systems functioning in normal working order in accordance with the manufacturer's Operations
Manual, (e) in compliance with the mandatory portions of all FAA airworthiness directives and
mandatory service bulletins that have been issued with respect to the Aircraft with due dates on or
prior to closing, (f) with all applicable remaining manufacturer's and/or vendor's warranties duly
assigned by Seller to Purchaser, provided that such warranties are assignable and that any cost of
assignment shall be borne solely by Purchaser, and (h) current, as of closing, on the manufacturer's
recommended inspection and maintenance programs with all hourly, cycle and calendar inspections
required under such program complied with without deferral. The Aircraft shall be deemed to be in
"Delivery Condition" if it complies with the foregoing requirements.
3.
Pre-Purchase Inspection.
(a)
Purchaser, or its agent, shall have a right to perform a pre-purchase inspection
of the Aircraft in accordance with this Section 3 (the "Pre-Purchase Inspection") at the Banyan FBO
facility located at the Fort Lauderdale Executive Airport KFXE (the "Inspection Facility"). The
Aircraft and its technical records have already been positioned at the Inspection Facility and are
currently available for the Pre-Purchase Inspection as soon as Purchaser makes arrangements for the
Pre-Purchase Inspection.
(b)
The Pre-Purchase Inspection will be performed on behalf of Purchaser and at
Purchaser's sole cost and expense in order to determine whether or not the Aircraft conforms to the
Delivery Condition as provided in Section 2 of this Agreement.
(c)
Purchaser shall cause the Pre-Purchase Inspection to be commenced at the
Inspection Facility as soon as is reasonably practicable after the parties execute this Agreement, but
in any event by no later than five (5) days after such execution
(d)
The scope and duration of the Pre-Purchase Inspection shall be as provided on
Exhibit B hereto, incorporated by this reference as if fully provided herein.
(e)
During the Pre-Purchase Inspection, Purchaser shall be entitled, to conduct an
initial flight test of no more than sixty (60) minutes in duration to be flown by the Seller's pilots with
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up to three (3) representatives of Purchaser accompanying the flight. All procedures to be adopted
during such flight test shall be those that are reasonably requested by the Purchaser and agreed to by
Seller prior to the commencement of such flight test or, if arising out of a condition or circumstance
occurring during said flight test, those that may be reasonably requested by the Purchaser and agreed
to by Seller during said flight test, subject, however, at all times to the discretion of the chief pilot
who shall have absolute operational discretion and control over the Aircraft.
(f)
Purchaser shall, in its sole discretion, accept or reject the Aircraft by not later
than five (5) business days following the completion of the Pre-Purchase Inspection and the issuance
of a written inspection report from the Purchaser's agent (the "Inspection Report"), copies of which
shall be made available to the Seller. Any difference, discrepancy or defect in the Aircraft from any
of the Delivery Condition requirements in Section 2 hereof that cause the Aircraft not to be in
airworthy condition is referred to in this Agreement as a "Discrepancy". The Inspection Report shall
note thereon each Discrepancy, if any, found during the Pre-Purchase Inspection (including, without
limitation, during the test flight) and include written estimates of the costs to repair each Discrepancy
so noted. At Purchaser's discretion, Purchaser shall accept the Aircraft in its "as-is", "where-is" and
"with all faults" condition ("Unconditional Acceptance"), or reject the Aircraft ("Rejection").
Purchaser's Unconditional Acceptance of the Aircraft shall be evidenced by Purchaser's issuance to
Seller, with a copy to the Escrow Agent, of a Certificate of Technical Acceptance in the form of
Exhibt C attached hereto (the "Certificate of Technical Acceptance"). If there are one or more
Discrepancies which cause Purchaser in its discretion to issue a Rejection, then, within such three (3)
business day period, Purchaser shall deliver to Seller, with a copy to the Escrow Agent, written notice
of Purchaser's termination of this Agreement in the form of Exhibit D hereof (a "Termination
Notice").
(g)
If Purchaser timely issues a Termination Notice in accordance with Section
3(f), the Escrow Agent shall refund the Deposit to Purchaser, whereupon all further obligations of
Seller and Purchaser pursuant to this Agreement shall cease, except those relating to expenses and
confidentiality as provided in Sections 12(n) and (o) hereof.
(h)
If Purchaser issues a Certificate of Technical Acceptance indicating
Purchaser's Unconditional Acceptance of the Aircraft, Purchaser shall wire transfer the Purchase
Price Balance to Escrow Agent as provided in Section 1 hereof, and the parties shall proceed with
Closing as hereinafter provided.
4.
Closing and Delivery
(a) The closing of this transaction ("the Closing") and delivery of the Aircraft to
Purchaser shall take place at Fort Lauderdale Executive Airport KFXE, Florida ("the Closing Place")
by not later than the Closing Date (as hereinafter defined), unless the parties subsequently agree upon
a later date in writing, in which case such agreed upon date shall be deemed the "Closing Date". The
Closing shall take place three (3) business days after: (i) Purchaser's delivery of the Certificate of
Technical Acceptance indicating Purchaser's Unconditional Acceptance of the Aircraft in accordance
with Sections 3(f) and (h) hereof; and (iv) confirmation from the Escrow Agent that the Escrow Agent
has received the Purchase Price Balance from Purchaser and all Escrow Documents (as defined
below), but in no event shall the Closing take place later than April 20, 2021 (the "Closing Date").
Seller and Purchaser hereby acknowledge that the passing of title, possession and delivery of the
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Aircraft shall take place within the state in which the Closing Place is located. The fuel costs and the
expenses of Seller's flight crew in flying the Aircraft from the Inspection Facility to the Closing Place
shall be the sole responsibility of and paid for by Purchaser.
(b)
At least 5 days prior to Closing Escrow Agent shall search FAA records and
verify aircraft title is free and clear of all recorded liens, claims and encumbrances.
(c)
Prior to the Closing, the following deliveries shall be made to the Escrow
Agent by the responsible party indicated:
(i)
At least two (2) days prior to the Closing Date, Seller shall deliver the
following to Escrow Agent:
(A)
A Warranty Bill of Sale in the form attached hereto as Exhibit E
transferring title to the Aircraft to Purchaser duly executed by an authorized
representative or the manager of Seller, with his or her title shown, but undated
(the "Warranty Bill of Sale"); and
(B)
An FAA Form Bill of Sale AC 8050-2 in proper form for
recordation at the FAA Civil Aircraft Registry to transfer title to the Aircraft
to Purchaser duly executed by an authorized representative or the manager of
Seller, with his or her title shown, but undated ("FAA Bill of Sale").
(ii)
Purchaser shall:
(A)
On or before the Closing Date but prior to Closing, wire transfer
the Purchase Price Balance into the Special Escrow Account of the Escrow
Agent; and
(B)
At least two (2) days prior to the Closing Date, deliver to the
Escrow Agent an Application for Aircraft Registration (AC Form 8050-1) for
the Aircraft duly executed by an authorized representative or the manager of
Purchaser, but undated (the "Application for Registration").
The documents described in subparagraphs (i) and (ii) of this Section 4(b) are
hereinafter referred to collectively as the "Escrow Documents".
(d)
Prior to the Closing Date, each of Seller, Purchaser and the Escrow Agent shall
notify each of the others in writing (either by correspondence, fax or e-mail) of the name or names
and telephone number of each representative of the respective parties which is to participate in the
conference call to be conducted in connection with the Closing (hereinafter the "Closing Conference
Call"). The Closing Conference Call shall be originated by Purchaser on the Closing Date on or
about 10:00 a.m., U.S. Central Daylight Time, so as to complete the Closing, including the filing of
the Escrow Documents with the FAA Registry in Oklahoma City, Oklahoma, prior to the closing of
that office on the Closing Date.
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(e)
At the Closing, and after the representatives of each of Seller, Purchaser and
the Escrow Agent have announced their respective attendance on the Closing Conference Call, then
the following shall occur:
(i)
If (A) the records of the FAA then reflect that Seller is the record owner
of the airframe of the Aircraft and that said airframe and the two (2)
engines of the Aircraft are free and clear of all recorded liens, claims
and encumbrances, and (B) the Escrow Agent has not otherwise
received notice of any other lien, claim or encumbrance asserted by any
third party with respect to the Aircraft, then the Escrow Agent shall so
advise the participants on the Closing Conference Call and then, but
only then, the Escrow Agent shall immediately wire the Purchase Price
to Seller in accordance with wire transfer instructions which shall be
provided to the Escrow Agent by Seller prior to the Closing Date, and
simultaneously file with the FAA Registry for recordation, the FAA
Bill of Sale, the Application for Registration and any other necessary
Escrow Documents and, upon such filings being accomplished, shall
then notify each of the participants on the Closing Conference Call of
the time of filing of each such Escrow Documents. If the records of
the FAA reflect there to be any lien on the Aircraft or Engines, this
purchase agreement will be terminated, and the Escrow Agent shall
refund the Deposit to Purchaser, whereupon all further obligations of
Seller and Purchaser pursuant to this Agreement shall cease, except
those relating to expenses and confidentiality as provided in Sections
12(n) and (o) hereof.
(ii)
Immediately following the above, the following shall occur at the
Closing Place:
(A)
Seller's representative shall deliver possession of the Aircraft to
Purchaser; and
(B)
Purchaser shall execute and deliver to Seller a Delivery Receipt
in the form attached hereto as Exhibit F.
(f)
Following completion of the Closing as prescribed above, the Escrow Agent
shall mail the Warranty Bill of Sale to the address specified by Purchaser.
(g)
If all of the conditions and requirements specified in this Section 4 are not
satisfied on or before the Closing Date (or such later date as Seller and Purchaser may agree upon in
writing and provide to the Escrow Agent), then subject to the provisions of Section 9 hereof, with
which the Escrow Agent shall comply, the Escrow Agent shall do the following:
(i)
the Escrow Agent shall retain the Escrow Documents and the Purchase Price
in escrow until Seller and Purchaser furnish the Escrow Agent with a written agreement which gives
the Escrow Agent instructions for payment of said funds and release of the Escrow Documents, or, if
the Escrow Agent is not furnished with such a written agreement, the Escrow Agent shall retain the
Purchase Price and the Escrow Documents in escrow until the Escrow Agent is ordered to pay said
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funds and release the Escrow Documents in accordance with the final order of a court of competent
jurisdiction.
5.
Fee of Escrow Agent. The fee of the Escrow Agent (which fee also includes
any out-of-pocket expenses incurred by the Escrow Agent) for performing its duties specified herein
shall be paid by each of Purchaser and Seller in equal portions. Their respective portions of said fee
shall be paid by them to the Escrow Agent as and when required by the Escrow Agent. In addition
to its duties specified above, the duties of the Escrow Agent shall also include delivering a written
preliminary title and lien report with respect to the Aircraft, and also a written post-closing title and
lien report with respect to the same to each of Purchaser and Seller.
6.
Taxes. Purchaser shall be responsible for and shall pay, or reimburse Seller
for, any and all sales, excise, gross receipts, use, personal property, transfer or similar taxes,
assessments or duties including interest or penalties imposed thereon and any costs incurred in
defense of the nonpayment thereof, including reasonable attorney's fees and expenses, arising out of,
or incurred in connection with, the sale and delivery of the Aircraft to Purchaser or the use, ownership,
possession, maintenance or operation of the Aircraft after the Closing, but specifically excluding any
income, capital gains or other similar taxes based on the income of Seller or personal property or
other similar taxes assessed or based upon Seller's ownership or use of the Aircraft prior to the Closing
(which shall be Seller's responsibility). Each party hereto will be responsible for researching its own
tax position in relation to the transactions contemplated hereby, and neither shall be deemed to have
relied on any advice provided by the other party or such party's advisors and tax professionals. The
provisions of this Section 6 shall survive Closing. The Parties have agreed that the Closing Place will
be at Fort Lauderdale Executive Airport KFXE, Florida. Purchaser will provide Seller with
completed Form GT-500002 to qualify for the fly-away sales tax exemption in the state of Florida
and will fully comply with all requirements of Florida's fly-away sales tax exemption. Provided that
Purchaser delivers this notarized form to Seller and fully complies with such requirements, Purchaser
will not be required to pay any sales taxes resulting from this transaction.
7.
(a)
Seller's Representations and Warranties. Seller hereby represents and
warrants to Purchaser the following:
(i)
Seller has good and marketable title to the Aircraft and on the
Closing Date Seller will convey to Purchaser good and marketable title to the Aircraft free and clear
of any and all leases, liens, claims, rights to purchase and encumbrances of any kind or nature.
(ii)
Seller is a limited liability company duly organized, validly
existing, and in good standing under the laws of the United States Virgin Islands. Seller has full
corporate power and authority to enter into this Agreement and the documents to be delivered
hereunder, to carry out its obligations hereunder, and to consummate the transaction contemplated
thereby. The execution, delivery and performance by Seller of this Agreement and the documents to
be delivered hereunder and the consummation of the transactions contemplated hereby have been
duly authorized by all requisite corporate action on the part of Seller.
(iii)
No broker, finder or investment banker will be entitled to any
brokerage, finder's or other fee or commission in connection with the transactions contemplated by
this Agreement based upon arrangements made by or on behalf of Seller; provided, however, that
Equus Global Aviation has been engaged by Seller as a broker for the Aircraft pursuant to a separate
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agreement between Seller and said broker which governs the terms and conditions upon which any
compensation may be due from Seller to said broker upon the sale of the Aircraft, and Purchaser shall
not be responsible for any such compensation pursuant to such agreement.
(a)
Purchaser's Representations and Warranties. Purchaser hereby
represents and warrants to Seller the following:
(i)
Purchaser is a limited liability company duly organized, validly
existing, and in good standing under the laws of New Mexico. Purchaser has full corporate power
and authority to enter into this Agreement and the documents to be delivered hereunder, to carry out
its obligations hereunder, and to consummate the transaction contemplated thereby. The execution,
delivery and performance by Purchaser of this Agreement and the documents to be delivered
hereunder and the consummation of the transactions contemplated hereby have been duly authorized
by all requisite corporate action on the part of Purchaser.
(ii) No broker, finder or investment banker is entitled to any
brokerage, finder's or other fee or commission in connection with the transactions contemplated by
this Agreement based upon arrangements made by or on behalf of Purchaser.
8.
LIMITATION OF WARRANTIES.
EXCEPT
FOR
THE
REPRESENTATIONS AND WARRANTIES OF SELLER EXPRESSLY SET FORTH IN
SECTION 7 HEREOF OR IN THE WARRANTY BILL OF SALE (THE "EXPRESS CONTRACT
WARRANTIES"), THE AIRCRAFT AND EACH PART THEREOF IS BEING SOLD TO
PURCHASER HEREUNDER IN ITS "AS IS, WHERE IS" CONDITION AND "WITH ALL
FAULTS" EFFECTIVE AT THE CLOSING. EXCEPT FOR THE EXPRESS CONTRACT
WARRANTIES, NEITHER SELLER NOR ITS AGENTS, REPRESENTATIVES OR
EMPLOYEES MAKE ANY WARRANTIES, EXPRESS OR IMPLIED, OF ANY KIND OR
NATURE WHATSOEVER TO PURCHASER. WITHOUT LIMITING THE GENERALITY OF
THE FOREGOING DISCLAIMER OF REPRESENTATIONS AND WARRANTIES, THERE IS
(I) NO WARRANTY BY SELLER, ITS AGENTS, REPRESENTATIVES OR EMPLOYEES AS
TO THE AIRWORTHINESS OR PHYSICAL CONDITION OF THE AIRCRAFT; (II) NO
IMPLIED WARRANTY BY SELLER, ITS AGENTS, REPRESENTATIVES OR EMPLOYEES
OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OF THE AIRCRAFT;
(III) NO IMPLIED WARRANTY BY SELLER, ITS AGENTS, REPRESENTATIVES OR
EMPLOYEES ARISING FROM COURSE OF PERFORMANCE, COURSE OF DEALING OR
USAGE OF TRADE; AND (IV) NO WARRANTY BY SELLER, ITS AGENTS,
REPRESENTATIVES OR EMPLOYEES AGAINST PATENT INFRINGEMENT OR THE LIKE.
IN NO EVENT SHALL EITHER PARTY HERETO BE LIABLE FOR ANY SPECIAL,
INCIDENTAL OR CONSEQUENTIAL DAMAGES OF ANY KIND.
9.
Purchaser's Breach and Remedies.
(a)
Failure by Purchaser to pay the Purchase Price at Closing in accordance with
this Agreement, to deliver any Closing documents required by this Agreement, or any other failure or
refusal by Purchaser to perform any of its obligations under this Agreement, or any material
misrepresentation by Purchaser pursuant to this Agreement, shall, upon the actual or offered
performance by Seller of all its obligations, and the failure by Purchaser to cure such failure within
seven (7) days after Seller gives Purchaser notice of such failure, constitute a breach of this Agreement
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=== Page 8 ===
by Purchaser. Except as otherwise provided, the parties hereto expressly agree that in the event of
such breach as a result of which the Closing does not take place, the Deposit shall be forfeited by
Purchaser, and the Deposit shall be distributed by the Escrow Agent to Seller as liquidated damages
and as its sole and exclusive remedy, all other remedies in such event, including but not limited to
incidental and consequential damages, being hereby waived by Seller. The limitation of Seller's
remedies as set forth in this Section 9(a) shall not be construed to limit or otherwise adversely affect
Seller's post-closing remedies should the Closing occur, for breach of any express warranties by
Purchaser set forth in this Agreement or the breach of any post-closing obligations of Purchaser set
forth in this Agreement.
(b)
If either party hereto commences a legal proceeding to enforce any of the
provisions of this Agreement, the prevailing party in such action shall also have the right to recover
reasonable attorneys' fees and costs from the other party to be fixed by the court in that same legal
proceeding, notwithstanding any limiting provisions contained in Section 9(a) above.
10. Seller's Indemnification Regarding Title. Seller hereby agrees to defend,
indemnify, and hold harmless Purchaser, its members, managers, officers, employees, agents,
representatives, successors, and assigns, from and against any and all losses, liabilities, expenses,
charges, fees, claims, causes of action, damages, obligation, judgments, and other costs, including but
not limited to, reasonable attorneys' fees, arising out of or resulting Purchaser having to defend
against a challenge by any third party to Purchaser's interest in the Aircraft.
11.
Performance, Force Majeure and Risk of Loss. Notwithstanding anything to the
contrary, the following shall apply:
(a)
In the event that the Aircraft is destroyed or damaged prior to the Closing Date,
this Agreement may be terminated in its entirety by either party without liability to the other party,
except that the Purchase Price and the Application for Registration, if already delivered to the Escrow
Agent, shall be promptly returned to Purchaser, and the FAA Bill of Sale and the Warranty Bill of
Sale, if already delivered to the Escrow Agent, shall be promptly returned to Seller.
(b)
Neither Seller nor Purchaser shall be responsible for any delay beyond the
Closing Date due to any cause beyond its control, including but not limited to the following causes:
civil wars, insurrections, strikes, riots, fires, floods, explosions, earthquakes, any act of government
or governmental priorities, allocations, regulation, orders affecting materials, act of God, act of the
public enemy, failure of transportation, epidemics, or labor trouble causing slowdown or interruption
of work.
(c)
Exclusive care, custody and control of the Aircraft and all risks of loss, damage
or destruction to the Aircraft from any cause whatsoever, including but without limiting the generality
of the foregoing, risks of damage to or loss or destruction of the Aircraft and liability to third parties
for property damages, personal injury or death, shall pass to and be assumed by Purchaser upon the
filing of the FAA Bill of Sale with the FAA and delivery of the Aircraft to Purchaser in accordance
with the provisions of this Agreement. Upon delivery of the Aircraft to Purchaser hereunder, Seller
disclaims and shall be fully relieved of, and Purchaser shall assume and, effective as of the completion
of the Closing, hereby assumes, all responsibility in connection with, the Aircraft and all risks incident
to ownership, maintenance, repair, use and modification thereof. Upon such delivery, Purchaser
hereby indemnifies and holds harmless Seller, its managers, members, employees and agents from
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=== Page 9 ===
and against any and all liability arising out of the care, custody, use and/or control of the Aircraft at
all times from and after such delivery. The provisions of this Section 11(c) shall survive the Closing.
12.
Other Matters.
(a)
Each party hereto agrees to execute and deliver such additional documents and
take such further actions as may be reasonably requested by the other party hereto to fully effectuate
and carry out the purposes of this Agreement.
(b)
Except as expressly provided herein, the provisions of this Agreement which
by their terms are to be performed and observed after the Closing, and the several representations,
warranties and agreements of the parties herein contained, shall survive the Closing.
(c)
This Agreement sets forth the entire understanding of the parties hereto with
respect to the subject matter hereof and supersedes any and all prior agreements, arrangements and
understandings relating to the subject matter hereof. No representation, promise, inducement or
statement of intention has been made by either party which is not embodied in this Agreement, and
neither party shall be bound by, or be liable for, any alleged representation, promise, inducement, or
statement of intention not embodied herein.
(d)
This Agreement may be executed in one or more counterparts, and all such
counterparts shall constitute one and the same instrument.
(e)
No modification or amendment of this Agreement shall be binding unless it is
in writing and signed by each of the parties hereto.
(f)
All notices required or permitted hereunder shall be in writing and, except as
may otherwise be provided herein, shall be deemed to be given when delivered personally, or within
three (3) business days after mailing, if mailed by registered or certified mail, return receipt requested,
postage prepaid, or on the date of transmission, if sent by facsimile or e-mail (and written
confirmation of transmission is provided), addressed to the other party for whom it is intended at the
address, facsimile number, or email address set forth below, or to such other address as hereafter may
be designated in writing by either party hereto to the other party hereto:
If to Seller:
HYPERION AIR. LLC
c/o
5300 West Atlantic Avenue, Suite 602
Delray Beach, Florida 33484
Fax:
Email:
If to Purchaser:
INDUSTRIAL INTEGRITY SOLUTIONS, LLC
2151 E. Convention Center Way, Ste. 222
Ontario, CA 91764-5496
9
EFTA00022704

=== Page 10 ===
Email:
(g)
Any signatures on this Agreement may be transmitted via facsimile or e-mail
(in pdf format), which signatures shall be deemed originals for all purposes if transmitted in
accordance with Section 12(f) above.
(h)
Neither any failure nor any delay on the part of either party hereto in exercising
any right hereunder shall operate as a waiver thereof, nor shall any single or partial waiver or exercise
of any right hereunder preclude any other future single or partial waiver or exercise of any right
hereunder. No waiver hereof shall be effective unless it is writing signed by the party hereto to be
charged with the same and then it shall only be effective as to the specific matter and in the specific
instance stated in such writing.
(i)
The descriptive headings of the several sections of this Agreement are inserted
for convenience only and do not constitute a part of this Agreement.
(j)
This Agreement shall be construed and enforced in accordance with the laws
of the U.S. Virgin Islands, excluding its conflicts of laws rules, and, to the extent applicable, the laws
of the United States of America.
(k)
If any clause, provision or section of this Agreement is found by any court of
competent jurisdiction to be invalid or unenforceable for any reason whatsoever, such invalidity or
unenforceability shall not in itself affect the remaining clauses, provisions and sections hereof, so
long as the rights or obligations of the parties hereto shall not be materially and adversely affected
thereby.
(1)
All payments provided for in this Agreement are to be made in United States
Dollars.
(m)
Purchaser and Seller (for purposes of this clause, the "Indemnifying Party")
each agree to indemnify and hold the other harmless in respect of any claims for brokerage fees,
finders fees, agent's commissions or other similar payments or forms of compensation which may be
made against the other party as a result of any contracts, understandings, arrangements, agreements
or other actions of the Indemnifying Party in connection with the purchase or sale of the Aircraft.
(n)
Except as otherwise expressly provided in this Agreement, each of Seller and
Purchaser shall bear its own costs and expenses (including, but not limited to, the fees of its legal and
tax advisors), incurred in the drafting and the negotiation of this Agreement and in connection with
the Closing.
(o)
Each of the parties hereto agree that the terms and provisions of this
Agreement, including, but not limited to, the fact that discussions and negotiations have been
conducted by the parties hereto, shall be deemed to be strictly confidential and shall not be disclosed
to any third parties other than the parties respective employees, attorneys, accountants, tax advisors
or other representatives for the purposes of effectuating the purchase and sale of the Aircraft
contemplated by this Agreement, and except as may be required in connection with any aapllicable
10
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=== Page 1 ===
From: "postmaster@msgsvr.voip.usa.doj.gov" <postmaster@msgsvr.voip.usa.doj.gov>
To:
Cc:
Subject: Voice Message Attached from
EPSTEIN CONROY
Date: Thu, 04 May 2017 20:43:00 +0000
Attachments:
20170504_164300.wav
Time: May 4, 2017 4:43:00 PM
Click attachment to listen to Voice Message
EFTA00022131


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: Re: Epstein NY property
Date: Thu, 16 Jul 2020 14:07:46 +0000
Sure
Sent from my iPhone
On Jul 16, 2020, at 10:05 AM,
wrote:
works for me
From: Weinstein, Marc A.
Sent: Thursday, July 16, 2020 10:04
To:
is
>;
Cc: Andrew Tomback
Subject: Epstein NY property
Alex, Alison, and Maurene:
Would you have time for a call today for an update on the NY property? If so, would something between 1:00-1:45
work?
Thanks,
Marc
Marc A. Weinstein | Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor I New York, NY 10004-1482
Office
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.
EFTA00020664


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=== Page 1 ===
From:
To:
Subject: FW: Activity in Case 1:20-mj-00132-AJ USA V. Maxwell Miscellaneous Filing
Date: Thu, 02 Jul 2020 19:20:11 +0000
Attachments: Maxwell_Public_Access_Findings__DN-2.pdf
FYI.
From: ecf_bounce@nhd.uscourts.gov<ecf_bounce@nhd.uscourts.govz>
Sent: Thursday, July 2, 2020 3:16 PM
To: nef@nhd.uscourts.gov
Subject: Activity in Case 1:20-mj-00132-AJ USA V. Maxwell Miscellaneous Filing
This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this
e-mail because the mail box is unattended.
***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. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply.
U.S. District Court
District of New Hampshire
Notice of Electronic Filing
The following transaction was entered on 7/2/2020 at 3:15 PM EDT and filed on 7/2/2020
Case Name:
USA V. Maxwell
Case Number:
1:20-mj-00132-AJ
Filer:
Document Number: 2
Docket Text:
Public Access Findings as to Ghislaine Maxwell. So Ordered by Magistrate Judge Andrea K.
Johnstone. (bt)
1:20-mj-00132-AJ-1 Notice has been electronically mailed to:
CaseView.ECF@usdoj.gov
USANH.ECFCriminal@usdoj.gov, USANH.ECFDocket@usdoj.gov
1:20-mj-00132-AJ-1 Notice, to the extent appropriate, must be delivered conventionally to:
The following document(s) are associated with this transaction:
EFTA00021837

=== Page 2 ===
Document description:Main Document
Original filename:n/a
Electronic document Stamp:
[STAMP dcecfStamp_ID=1045603718 [Date=7/2/2020] [FileNumber=2213179-0]
[79c87216f1a6f73fb3c4a5802af26a10821b5ab8466cda30dbeae546111338cf96f5
73786b0fb78548c10c207db200dbc34118c7a9192dcee24fe03861208506]]
EFTA00021838


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=== Page 1 ===
From:
"
To:
Bcc: "USAHUB-USAJournal111"
Subject: RE: SDNY investigation
Date: Wed, 30 Sep 2020 17:58:44 +0000
Embedded: RE:_SDNY_investigation.msg
Sender:
Subject: RE: SDNY investigation
Message-Id:
<BYAPR11MB2550F605AF550F0A3AC5EFCF98330@BYAPR11MB2550.namprd11.prod.outlook.com>
Recipient:
EFTA00020888


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=== Page 1 ===
From:
(USANYS)"
To: USAEO-Foreign Travel
Cc:
)"
(USANYS)"
Subject: ECC package - AUSA
ECC ackage
Date: Fri, 24 Jan 2020 15:42:24 +0000
Importance: High
Attachments:
-_ECC_package_2.3.20.pdf
Hi RMP,
Please see the attached ECC request package for
If required, please inform the traveler how to determine who the POC is for this trip.
Hi
Please let EOUSA know if you have checked to see if a visa is required for your destination.
View the state dept. link for the country you are traveling to visa link for the country you are traveling to.
Visa policies may be found on the Department of State's website or on the website hosted by each country 's embassy.
https://travel.state.gov/content/passports/en/country.html
Traveler, Consult EOUSA usaeo.foreign.travel@usdoj.gov mailbox to obtain a visa for you.
To provide sufficient time for the State Dept. to issue the authorization letter and for the foreign government to process the visa
request, it is recommended that visa request package be submitted to EOUSA's RMP Travel.
Staff 15 business days prior to the proposed date of departure.
Thank you
From:
Sent: Friday, January 24, 2020 10:39 AM
To:
(USANYS)
is
Cc:
(USANYS)
Subject: RE: Sorry One more thing - EOUSA also needs your OIA approval email. Thanks
We have reached out to OIA and are awaiting their approval. We'll send it as soon as we have it.
From:
(USANYS)
Sent: Friday, January 24, 2020 10:39 AM
To:
is
Cc:
(USANYS)
Subject: Sorry One more thing - EOUSA also needs your OIA approval email. Thanks
Sorry, One more thing - EOUSA also needs your OIA approval email. Thanks
From:
Sent: Friday, January 24, 2020 10:39 AM
To:
(USANYS)
is
Cc:
(USANYS)
Subject: RE: Sorry One more thing - EOUSA also needs your OIA approval email. Thanks
We have reached out to OIA and are awaiting their approval. We'll send it as soon as we have it.
EFTA00020859

=== Page 2 ===
From:
(USANYS)
Sent: Friday, January 24, 2020 10:39 AM
To:
is
Cc:
(USANYS)
Subject: Sorry One more thing - EOUSA also needs your OIA approval email. Thanks
Sorry, One more thing - EOUSA also needs your OIA approval email. Thanks
From:
Sent: Friday, January 24, 2020 10:33 AM
To:
(USANYS)
is
Subject: RE: Questionnaire - Hi We also need this one ASAP. Thanks
Attached is my questionairre
From:
(USANYS)
Sent: Friday, January 24, 2020 10:32 AM
To:
is
Subject: Questionnaire - Hi We also need this one ASAP. Thanks
Importance: High
EFTA00020860


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=== Page 1 ===
From:
To:
Subject: RE: Epstein -- travel approval form
Date: Fri, 31 Jan 2020 18:08:51 +0000
Totally understand, and next week would be fine - let me know if it's helpful to set a time, and otherwise l'll touch base
midweek if we haven't connected by then.
And thanks very much re: the memo.
From:
Sent: Friday, January 31, 2020 12:53
To:
Cc:
Subject: RE: Epstein -- travel approval form
Already signed and sent upstairs
I will do my best to ensure signature immediately.
Re: this afternoon: it may be best to kick it to next week. If some time develops before 3, I'll let you know, but right now
it is iffy.
From:
Sent: Friday, January 31, 2020 12:21 PM
To:
Cc:
Subject: Epstein -- travel approval form
We dropped off the Sweden travel memo for you - we were unexpectedly significantly delayed in getting OIA approval,
but it finally came this morning, so with apologies for the short turnaround, hoping to get Office and final DOJ approval
this afternoon. Thank you!
And separately, if you still wanted to meet up today, I'll be around until about 3:00, but I'm also flexible next week if that's
easier.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00021058


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=== Page 1 ===
From:
To:
Subject: FW: travel approval request
Date: Tue, 28 May 2019 14:21:26 +0000
Importance: Normal
Thanks for clarifying
I've forwarded the info to
and Budget Admins since I wouldn't be able to approve refunds
for personal credit cards.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Tuesday, May 28, 2019 10:04 AM
To:
Subject: RE: travel approval request
To clarify, the cancelled trip was a long-scheduled personal trip. Because of the work travel scheduled for this week, I had
to cancel my outbound personal travel flight, and I was charged $100 for that cancellation (which I paid for personally).
I'm just wondering if that's reimbursable because I wouldn't have been charged that fee if it wasn't for the work trip I now
am going on this week.
thanks,
From:
Sent: Tuesday, May 28, 2019 09:49
To:
Subject: RE: travel approval request
Just a quick question regarding the cancelled trip for this Thursday (5/30/19). Was this trip booked through CWT by phone
or online? If either scenario, I'll need the cancelled record locator to see if it's refundable, and ask them to send me a
document stating it was refunded to your government travel card. Thanks.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Sunday, May 26, 2019 2:31 PM
To:
Subject: FW: travel approval request
EFTA00023234

=== Page 2 ===
Hi
I have a trip scheduled for this week that just got final approval late Friday night, so I made reservations on E2 this
weekend and wanted to let you know in case you need to do things for authorization and/or if you want to consolidate
the reservations (unfortunately I couldn't figure out how to do everything together so ended up with three different
reservations-I'm sorry about that!).
Because I had a previously-scheduled trip to San Francisco on this Thursday,
approved my second leg flight to go
straight there (rather than coming back to NYC). The reservations I made are:
Tuesday, May 28, flight from LGA to PBI
-
JetBlue, departing 1:27 p.m. (arriving 4:25 p.m.)
Tuesday, May 28, hotel in West Palm Beach
-
Hilton West Palm Beach, from May 28 to May 30
Thursday, May 30, flight from PBI to SFO (with layover in ATL)
-
Delta, departing 5:30 a.m. (arriving ATL at 7:12 a.m., departing ATL at 8:10 a.m.) arriving SFO at 10:22 a.m.
If these need to be canceled and re-booked as one itinerary, that's totally fine, I just didn't want to wait until the day
before to at least make the reservations.
Last question is, I had to cancel my New York to San Francisco flight previously scheduled for Thursday morning (because
there were no flights late enough to be after our final interviews in Florida on Wednesday, or early enough to get me back
to New York on Thursday) which incurred a $100 cancellation fee. Is it possible to be reimbursed for that?
Please let me know if any questions at all, apologies again for any inconvenience, and thanks as always.
From:
Sent: Friday, May 24, 2019 21:24
To:
Cc:
Subject: Re: travel approval request
Approved
Sent from my iPad
On May 24, 2019, at 7:21 PM,
wrote:
-- I have previously-scheduled travel to San Francisco next Thursday for a wedding, and the way our victims have
asked to schedule our meetings for our Florida trip, there's no flight back to New York after we expect the interviews to
end on Wednesday (so I couldn't get back to NYC to catch my Thursday morning flight). Is it permissible for me to just
book the second leg of the work trip straight to San Francisco, rather than back to New York? I'd have to take a 5:30
a.m. flight but that way we could do the interviews with all the victims we'd like to meet with. Sorry for any
inconvenience but wanted to check - thank you!
From:
)
Sent: Friday, May 24, 2019 16:01
EFTA00023235

=== Page 3 ===
To:
Subject: RE: travel approval request
Thanks
- have a great weekend.
From:
Sent: Friday, May 24, 2019 15:55
To:
Cc:
is
Subject: Re: travel approval request
All approved.
Sent from my iPad
On May 24, 2019, at 2:57 PM,
wrote:
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling
allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will
either be me and
or
and
but we wanted to ask for permission now either way so we weren't
doing it super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
EFTA00023236

=== Page 4 ===
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors
for sexual activity,
and I would like to please request permission to travel for approximately three days next
week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday
night and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West
Palm Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return
on Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00023237


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=== Page 1 ===
From: "McGorty, Glen"
To:
)"
)"
Cc: "Zelenko, Daniel"
>, "Giffuni, Danielle"
(USANYS)"
Subject: RE: Wednesday's WebEx
Date: Wed, 11 Nov 2020 18:52:46 +0000
Thanks
This is helpful. We will see you tomorrow.
Glen G. McGorty Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Wednesday, November 11, 2020 1:43 PM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Glen,
We will be joined by two FBI agents who are focusing on the CBP topics that we have previously discussed. I expect one
of those agents will take the lead on questioning Mr.
The topics we expect to cover include:
The identities of any CBP employees Mr.
recalls interacting with Jeffrey Epstein in the Virgin Islands.
Any steps Mr.
recalls any CBP employees in the Virgin Islands taking to help Epstein and those traveling with
Epstein to enter the country, including any steps that allowed Epstein or those traveling with him to avoid
processing that travelers would normally undergo.
Any favors Mr.
recalls Epstein doing for CBP employees in the Virgin Islands, such as trips to Epstein's island.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00020825

=== Page 2 ===
From:
Sent: Tuesday, November 10, 2020 1:16 PM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
Subject: RE: Wednesday's WebEx
just wanted to circle back with you in advance of Thursday's meeting. We want
to be fully prepared, so
if there is any more granularity on this topic (or any additional topic or topics), please let us know.
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Monday, October 26, 2020 6:19 PM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Thanks very much, Glen. Let's plan for 1pm on Thursday, 11/12. I will circulate a WebEx invitation shortly.
We expect to ask Mr.
about his interactions with
the U.S. Customs and Border Protection
employee who worked in Saint Thomas and who had Mr.
listed as a contact in his phone. I expect we will ask for
an approximate timeline of when Mr.
met and interacted with
the nature of those interactions, and any
interactions
may have had with Epstein (to the best of Mr.
knowledge).
Best,
Assistant United States Attorney
Southern District of New York
EFTA00020826

=== Page 3 ===
From:
Sent: Monday, October 26, 2020 11:58 AM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
Subject: RE: Wednesday's WebEx
-
Sorry for the delay. Looks like we can do between 11 a.m. and 2 p.m. on Tuesday, 11/10, or any time on Thursday, 11/12.
Let us know if anything in that range will work.
So as to make sure Mr.
is prepared, can you give us an overview of what you expect to cover?
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
I
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Thursday, October 22, 2020 10:33 AM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
>;
(USANYS)
^
Subject: RE: Wednesday's WebEx
External Email
Glen,
As I believe we mentioned when we last spoke, we would like to schedule time for a second interview with Mr.
via
WebEx. Are there any days the week of November 9th when your team and Mr.
would be available? We would
expect this proffer to be much shorter than our first, and certainly no more than two hours at most.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00020827

=== Page 4 ===
From:
Sent: Friday, October 9, 2020 4:42 PM
To:
Cc: Zelenko, Daniel
>; Giffuni, Danielle
(USANYS)
is
Subject: RE: Wednesday's WebEx
Hi Glen,
Thanks very much. I'm attaching the fully executed copy.
Thanks,
From:
Sent: Thursday, October 8, 2020 9:31 AM
To:
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
is
Subject: RE: Wednesday's WebEx
Hi all.
Attached please find the signed proffer agreement. It was nice seeing everyone yesterday.
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com I Web Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Monday, October 5, 2020 4:14 PM
To:
Cc: Zelenko, Daniel
>; Giffuni, Danielle
>;
(USANYS)
is
)
Subject: RE: Wednesday's WebEx
External Email
EFTA00020828

=== Page 5 ===
Hi Glen,
Not a problem at all -- I've added everyone to the calendar invitation. Please let us know if any other tech issues crop up,
and we'd be happy to work through them.
Thanks,
From:
Sent: Monday, October 5, 2020 12:48 PM
To:
is
>;
(USANYS)
Cc: Zelenko, Daniel
is
>; Giffuni, Danielle
>;
Morrissey, Josh
Subject: Wednesday's WebEx
Thanks for sending the WebEx invitation for Wednesday's meeting to me. For whatever reason, the system is not
permitting me to forward the invite, so I would ask that you separately invite those copied on this e-mail: Dan, Danielle
and Mr.
but also Josh Morrissey who is in our IT group and will make sure we are good to go for our meeting.
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com I Web Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
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=== Page 1 ===
OFFICIAL RECORD
Intake (Rev. 5-23-17)
Document
signed
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Intake
Date: 08/15/2020
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Drafted By:
Date/Time Received: 07/13/2020 08:02 PM EDT
Details:
Date Submitted: 07/12/2020 07:06:53 PM ET
Transaction Number: 07A23145-D0C9-43BC-902C-CC880D9B498D
Threat To Life: False
Submitted Text:
When I was 6-8 years old and living at
in Surrey, UK, I was drugged at night and driven
by my father,
to pedophile ring "parties". The main house I was taken to is located behind
Thorpe Green, at the end of a private road. Hurst Farm Livery Stables is next door. In the driveway of this
house, I was hit by a dark blue car with a personalised license plate ending in
, driven by Prince
Andrew. I was not taken to hospital, but I suffered permanent injuries to my ribs, hip and leg on my right
side. The car's hood figurine broke off in my hand on impact and I later buried it near my home, so it could
still be recoverable as evidence. After I was hit by the car, I woke up to Prince Andrew
In that house, I was also
I have medical records of the resulting infection. I once ran away
from the house naked, and made it to the Irish Traveller community down the road (GPS: 51.405369,
0.546576). I remember seeing and speaking to a man, so I think that there may be Irish Travellers living in
the area who could corroborate what goes on there.
I was also taken to another house that | later
recognised as Frogmore Cottage when its refurbishment was in the news in 2018. There, I was restrained on
a table and tortured with electrical shocks by Ghislaine Maxwell and surrounded by watching men. I
remember seeing Prince Andrew's face.
I tried to sneak out.
Maxwell caught me and beat me with the bristle end of a broom.
She also threatened me, saying that I "deserved to die" and hit me in the face with the broom,
breaking my nose. I was only taken to the hospital for the broken nose after a rugby match, so that the
injury could be blamed on that.
UNCLASSIFIED
EFTA00020457

=== Page 2 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/15/2020
Violation: Other
Violation Questions
What was the exact crime that occurred?: Human trafficking and sexual assault against minors
When did the crime/incident occur? (Please provide an approximate date and time): 1994-1996
Where did the crime/incident occur? (Please provide the specific location/address if possible): Frogmore
Cottage, Windsor SL4 2JG, United Kingdom / Egham, TW20 8QL GPS Coordinates: 51.403800, -0.551690 /
Palm Beach, Florida
Complainant Information
First Name:
Middle Name:
Last Name:
Age:
DOB:
Additional Info:
Type: Cell
Phone:
Extension: n/a
Account:
Type: Residential
Address:
City:
State:
Zip:
UNCLASSIFIED
2
EFTA00020458

=== Page 3 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/15/2020
Country: United States
Subject Information
First Name: Ghislaine
Middle Name:
Last Name: Maxwell
Age: 58
DOB:
Additional Info: During this time frame, I also went on yearly vacations with my family to Florida, staying at
my grandparent's house in Vero Beach. I remember on one occasion being driven by my father over an hour
away to a mansion with a gated driveway and a large rectangular swimming pool. I was molested by a man
that I later recognised as Epstein when he was in the news. He
). He took pornographic photographs of me in a skirt.
Around late 2012, I had not yet fully processed all these memories, but I reported my father to the police
after seeing a text from G. Maxwell on his phone saying: "I have two children", and being triggered by it. I
believe it's possible that my father may have been involved in procurement for the pedophile ring even
then, because he made visits to several local schools and a disabled children's home (the White Lodge
Centre). In the end, he was not arrested and the case was not investigated. As a result, he was able to
destroy a lot of evidence, such as photographs. Releasing Ghislaine Maxwell on bail would lead to the same
outcome.
I am willing to testify, and provide evidence and/or more detailed descriptions of events.
Other ring members
UNCLASSIFIED
3
EFTA00020459

=== Page 4 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/15/2020
My father's best friend - -
My father's 'secret accountant' - he lives in the house between
GPS Coordinates:
I heard my rapist from Frogmore Cottage at his house
during a "party" on a Saturday in the Summer of 2018.
How is Contact Known: I was a victim of human trafficking by her pedophile ring.
Type: Other
Address:
City:
Zip:
Witness Information
First Name:
Middle Name:
Last Name:
Age: 31
DOB:
Additional Info: I also remember another victim being
She is a year younger than me, so she may have been as young as 5 years-old at the time. Afterwards, she
was taken out of an affluent private primary school and sent to the worst school in the area,
That was where I first recognised her, even though we had supposedly never met. She was
put in a class two years ahead, and then went to the same Secondary School as me
-
)
a year before I did. We have never once spoken.
How is Contact Known:
is the daughter of
and my childhood friend. I remember
was at some of the parties with me, and I remember us once hiding behind a drape together.
However, we have never discussed it, so I don't know what she remembers.
UNCLASSIFIED
4
EFTA00020460

=== Page 5 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/15/2020
Type: Other
Address:
City:
Zip:
Remote IP:
Remote Host: api.fbi.gov
Http Referrer: https://www.fbi.gov/tips
User Browser:
Latitude:
Longitude:
Country: US
Region:
City:
Postal Code: 91387
Timezone: -07:00
UNCLASSIFIED
5
EFTA00020461


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=== Page 1 ===
The Decision Procedure and Penalties manual
Chapter 7
Statement of policy on
interviews conducted on
behalf of overseas and EEA
regulators
EFTA00022302

=== Page 2 ===
DEPP 7 : Statement of policy on
Section 7.2 : Interviews
interviews conducted on behalf
of overseas and EEA
7.2
Interviews
Appointment of investigator and confidentiality of information
7.2.1
G
Under section 169(1)(b) and section 131FA of the Act, the FCA may appoint
an investigator to investigate any matter at the request of an overseas
regulator or EEA regulator. The powers of the investigator appointed by the
FCA (referred to here as the 'FCA's investigator') include the power to
7
require persons to attend at a specified time and place and answer questions
(the compulsory interview power).
7.2.2
G
Where the FCA appoints an investigator in response to a request from an
overseas regulator or EEA regulator it may, under section 169(7) or section
131FA of the Act, direct him to permit a representative of that regulator to
attend and take part in any interviews conducted for the purposes of the
investigation. The FCA may only give a direction under section 169(7) or
section 131FA if it is satisfied that any information obtained by an overseas
regulator or EEA regulator as a result of the interview will be subject to the
safeguards equivalent to those contained in Part XXIII (Public Record,
Disclosure of Information and Cooperation) of the Act.
7.2.3
G
Part XXIII of the Act contains restrictions on the disclosure of confidential
information. The restrictions are subject to exceptions contained in
regulations made by the Treasury under section 349.
Policy on use of investigative powers
7.2.4
G
The FCA's policy on how it will use its investigative powers, including its
power to appoint investigators, in support of overseas regulators and EEA
regulators, is set out in the FCA's Enforcement Guide (EG).
Use of direction powers
7.2.5
G
The FCA may need to consider whether to use its direction power at two
stages of an investigation:
(1) at the same time that it considers the request from the overseas
regulator or EEA regulator to appoint investigators;
(2) after it has appointed investigators, either at the request of the
overseas regulator or EEA regulator or on the recommendation of the
investigators.
DEPP 7/2
www.handbook.fca.org.uk
Release 53
Aug 2020
EFTA00022303

=== Page 3 ===
DEPP 7 : Statement of policy on
Section 7.2 : Interviews
interviews conducted on behalf
of overseas and EEA
7.2.6
G
Before making a direction under section 169(7) or section 131FA the FCA will
discuss and determine with the overseas regulator or EEA regulator how this
statement of policy will apply to the conduct of the interview, taking into
account all the circumstances of the case. Amongst other matters, the FCA
will at this stage determine the extent to which the representative of the
overseas regulator or EEA regulator will be able to participate in the
interview. The overseas regulator or EEA regulator will be notified of this
determination on the issuing of the direction.
7.2.7
G
The direction will contain the identity of the representative of the overseas
regulator or EEA regulator that is permitted to attend any interview and the
role that he will play in the interview. If the FCA envisages that there will be
more than one interview in the course of the investigation, the direction
may also specify which interview(s) the representative is allowed to attend.
Conduct of interview
7.2.8
G
In circumstances where an interview is to be conducted as part of the
7
investigation, the FCA's investigator will have conduct of the interview. In
general, the FCA's investigators will be employees of the FCA, but in
appropriate cases the FCA may appoint persons who are not its employees.
In those cases, the FCA may choose to require that an FCA employee is
present at the interview and may choose to appoint that person as an
investigator.
7.2.9
G
The FCA's investigator will act on behalf of the FCA and under its control. He
may be instructed to permit the representative of the overseas regulator or
EEA regulator to assist in the preparation of the interview. Where the FCA
considers it appropriate, it may permit the representative to attend and ask
questions of the interviewee in the course of the interview. The interview
will be conducted according to the terms of the direction and the
notification referred to in
DEPP 7.2.6 G.
7.2.10
G
If the direction does permit the representative of an overseas regulator or
EEA regulator to attend the interview and ask the interviewee questions, the
FCA's investigator will retain control of the interview throughout. Control of
the interview means the following will apply:
(1) The FCA's investigator instigates and concludes the interview,
introduces everyone present and explains the procedure of the
interview. He warns the interviewee of the possible consequences of
refusing to answer questions and the uses to which any answers that
are given can and cannot be put. The FCA's investigator will always
ask preliminary questions, such as those establishing the identity of
the interviewee.
(2) The FCA's investigator determines the duration of the interview and
when, if at all, there should be any breaks in the course of it.
(3) The FCA's investigator has responsibility for making a record of the
interview. The record should note the times and duration of any
breaks in the interview and any periods when the representative of
the overseas regulator or EEA regulator was either present or not
present.
Release 53
Aug 2020
www.handbook.fca.org.uk
DEPP 7/3
EFTA00022304

=== Page 4 ===
DEPP 7 : Statement of policy on
Section 7.2 : Interviews
interviews conducted on behalf
of overseas and EEA
(4) Where the FCA's investigator considers it appropriate, he may either
suspend the interview, ask the overseas representative to leave the
interview, or terminate the interview and reschedule it for another
occasion. In making that decision he will bear in mind the terms of
the direction, any agreement made with the overseas regulator or
EEA regulator as to the conduct of the interview and the contents of
this statement of policy.
7.2.11
G
The FCA will in general provide written notice of the appointment of an
investigator to the person under investigation pursuant to the request of an
overseas regulator or EEA regulator. Whether or not the interviewee is the
person under investigation, the FCA's investigator will inform the
interviewee of the provisions under which he has been appointed, the
identity of the requesting authority and general nature of the matter under
investigation. The interviewee will also normally be informed if a
representative of the overseas regulator or EEA regulator is to attend and
take part in the interview. Notification of any of these matters may not be
provided in advance of the interview if the FCA believes that the
7
circumstances are such that notification would be likely to result in the
investigation being frustrated.
7.2.12
G
The interviewee will normally be given a copy of the direction issued under
section 169(7) or section 131FA in advance of the interview unless to do so
would be likely to result in the investigation being frustrated. The
interviewee will also be provided with a copy of this statement of policy.
7.2.13
G
The FCA's investigator will determine the venue and timing of the interview.
The interviewee will be notified of the venue and timing of the interview in
advance and in writing.
7.2.14
G
When the FCA's investigator has exercised the compulsory interview power,
at the outset of the interview the interviewee will be given an appropriate
warning. The warning, amongst other things, must state that the
interviewee is obliged to answer all questions put to them during the
interview, including any put by the representative of the overseas regulator
or EEA regulator. It will also state that in criminal proceedings or
proceedings for market abuse the FCA will not use as evidence against the
interviewee any information obtained under compulsion during the
interview.
7.2.15
G
The FCA's investigator may decide which documents or other information
may be put to the interviewee, and whether it is appropriate to give the
interviewee sight of the documents before the interview takes place. Where
the overseas regulator or EEA regulator wishes to ask questions about
documents during the interview and the FCA's investigator wishes to inspect
those documents before the interview, he will be given the opportunity to
do so. If the FCA's investigator wishes to inspect them and has not been able
to do so before the interview, he may suspend the interview until he has had
an opportunity to inspect them.
7.2.16
G
When the FCA's investigator has exercised the compulsory interview power,
the FCA's investigator will require the person attending the interview to
DEPP 7/4
www.handbook.fca.org.uk
Release 53
Aug 2020
EFTA00022305

=== Page 5 ===
DEPP 7 : Statement of policy on
Section 7.2 : Interviews
interviews conducted on behalf
of overseas and EEA
answer questions. Where appropriate, questions may also be posed by the
representative of the overseas regulator or EEA regulator. The interviewee
will also be required to answer these questions. The FCA's investigator may
intervene at any stage during questioning by the representative of the
overseas regulator or EEA regulator.
Language
7.2.17
G
Interviews will, in general, be conducted in English. Where the interviewee's
first language is not English, at the request of the interviewee arrangements
will be made for the questions to be translated into the interviewee's first
language and for his answers to be translated back into English. If a
translator is employed at the request of the representative of the overseas
regulator or EEA regulator then the translation costs will normally be met by
the overseas regulator or EEA regulator. Where interviews are being
conducted in pursuance of an EU law obligation these costs will be met by
the FCA. In any event, the meeting of costs in relation to translators and,
where applicable, the translation of documents will always be agreed in
advance with the overseas regulator or EEA regulator.
7
Tape-recording
7.2.18
G
All compulsory interviews will be tape-recorded. The method of recording
will be decided on and arranged by the FCA's investigator. Costs will be
addressed similarly to that set out in the preceding paragraph. The FCA will
not provide the overseas regulator or EEA regulator with transcripts of the
tapes of interviews unless specifically agreed to, but copies of the tapes will
normally be provided where requested. The interviewee will be provided
with a copy of tapes of the interview but will only be provided with
transcripts of the tapes or translations of any transcripts if he agrees to meet
the cost of producing them.
Representation
7.2.19
G
The interviewee may be accompanied at the interview by a legal adviser or a
non-legally qualified observer of his choice. The costs of any representation
will not be met by the FCA. The presence at the interview of a representative
of the overseas regulator or EEA regulator may mean that the interviewee
wishes to be represented or accompanied by a person either from or familiar
with that regulator's jurisdiction. As far as practical the arrangements for the
interview should accommodate this wish. However, the FCA reserves the
right to proceed with the interview if it is not possible to find such a person
within a reasonable time or no such person is able to attend at a suitable
venue.
7.2.20
G
In relation to the publication of investigations by overseas regulators or EEA
regulators, the FCA will pursue a policy similar to the policy that relates to its
own investigations.
Release 53
Aug 2020
www.handbook.fca.org.uk
DEPP 7/5
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
,
)"
Subject: Federal court moves to unseal Jeffrey Epstein documents | Miami Herald
Date: Tue, 12 Mar 2019 00:40:55 +0000
Importance: Normal
Looks like the summary judgment motion and exhibits will be public soon.
https://www.miamiherald.com/latest-news/article227411649.html
Sent from my iPhone
EFTA00020791


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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From:
Date: October 28, 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:
West Palm Beach FL 33411
Witness TelNos (mobile):
Witness e-mail:
Witness Needed to Appear in SDNY on
Date: November 14, 2021
Time: 12 p.m.
Witness Needed to Appear for:
Trial ( )
Date:
Grand Jury ( )
Date:
Trial/GJ Prep (X)
Date: November 14 and 15, 2021
Estimated Dates Witness will Arrive: November 13 or 14, 2021
Depart: November 15, 2021
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
rev. 2019.11.19
EFTA00023123

=== Page 2 ===
kennel fees for pets
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
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
EFTA00023124


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=== Page 1 ===
From:
)"
To:
)"
Cc:
(USANYS)"
Subject: Re: laptop for MDC
Date: Mon, 02 Nov 2020 19:59:34 +0000
As king as we are clear we don't know the timeline for this, that sounds fine to me.
Sent from my iPhone
On Nov 2, 2020, at 2:29 PM,
)
wrote:
Good with me emailing the defense to let them know we are working on getting a laptop?
From:
(USANYS)
Sent: Monday, November 2, 2020 2:04 PM
To:
Cc:
(USANYS)
is
is
(USANYS)
>
Subject: RE: laptop for MDC
The laptop purchase request went to
this morning. We need to verify some of the spec to ensure we purchased
one that will work for your needs and was available. I will follow up with
to get a delivery date.
Once we receive it we will need a day or two to configure and install the software. Friday maybe a tight date to make.
Let you know when I know more.
From:
Sent: Monday, November 2, 2020 12:20 PM
To:
(USANYS)
Cc:
(USANYS)
V.
Subject: Re: laptop for MDC
Hi
Hope you're doing well. Has the laptop arrived? The warden has approved our request to give the defendant this laptop,
and we would like to have it ready by the end of the week if at all possible. If you have any questions, I can be reached at
anytime today. Thanks so much for your help with this project.
Best,
Sent from my iPhone
On Oct 28, 2020, at 2:44 PM,
(USANYS)
wrote:
It sure we will research one tonight and place the order tomorrow. It depends on availability and delivery. Do we have
a copy of the data that goes with the drive?
EFTA00020899

=== Page 2 ===
Also with the ever changing policies in BOP, can you confirm that they will allow her to have a laptop. Not sure the
rules at MDC.
Sent from my iPhone
On Oct 28, 2020, at 2:22 PM,
)
wrote:
Perfect, thanks so much. How long would you estimate that will take?
From:
(USANYS)
Sent: Wednesday, October 28, 2020 2:20 PM
To:
Cc:
)
is
(USANYS)
Subject: RE: laptop for MDC
We will spec out a laptop to purchase for this case.
From:
Sent: Wednesday, October 28, 2020 2:09 PM
To:
(USANYS)
Cc:
)
is
(USANYS)
Subject: RE: laptop for MDC
Thanks so much.
From:
(USANYS)
Sent: Wednesday, October 28, 2020 2:06 PM
To:
Cc:
)
is
(USANYS)
Subject: RE: laptop for MDC
Let me discuss with Ed the best options. get back to you shortly.
From:
Sent: Wednesday, October 28, 2020 1:58 PM
To:
(USANYS)
Cc:
)
is
(USANYS)
Subject: laptop for MDC
Hi
I hope you're doing well. Because of some discovery accessibility issues we're having in the Ghislaine Maxwell case,
we would like to provide a clean laptop to Maxwell in MDC for discovery review purposes. The laptop need only
permit review of standard files - word, pdf, .tif, .xls, etc. All other capabilities and programs can be disabled. I
understand we did something similar in the Avenatti case, and we'd like to do the same here. Would that be
possible? It would be a huge help to us if you could possibly prep and provide us with a laptop for this purpose.
Thanks so much-
EFTA00020900


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Epstein estate
Date: Wed, 08 Jul 2020 14:59:47 +0000
Thanks, I can join too.
Sent from my iPhone
On Jul 8, 2020, at 10:45 AM,
wrote:
This works for me, and the more the merrier but also happy to handle if that's useful.
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.
EFTA00021792


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=== Page 1 ===
From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:22:03 +0000
Inline-Images: image001.png
Thanks!
From:
Sent: Thursday, July 2, 2020 1:25 PM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congratulations!
From
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA JUSTITIA OF NOFFICE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
EFTA00021826

=== Page 2 ===
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00021827

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00021828


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=== Page 1 ===
From:
"
To:
Cc:
Subject: two communications from individuals who may have JE information
Date: Thu, 10 Oct 2019 22:31:49 +0000
Attachments: 9178914696_20191010_153452.wav
Consistent with passing along all tips that somehow come to us, attached please find a voicemail I received earlier today.
Separately, yesterday I got a call from an attorney named Blair Fellows, who said that she has a client named Joan Werth who has
information about Epstein--I didn't get into the substance (because no witness) and said I would pass along her contact information,
which is
thanks,
Original Message
From: postmaster@voip.usa.doj.gov <postmaster@voip.usa.doj.gov>
Sent: Thursday, October 10, 2019 15:35
To:
Cc:
Subject: Voice Message Attached from 9178914696 -
Time: Oct 10, 2019 3:34:52 PM
Click attachment to listen to Voice Message
EFTA00020910


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=== Page 1 ===
From:
To:
Subject: RE: Out of money
Date: Thu, 10 Sep 2020 19:51:16 +0000
Great, thank you.
Original Message
From:
Sent: Thursday, September 10, 2020 3:51 PM
To:
Subject: RE: Out of money
He already told me that he will find the 10K for Maxwell.
Original Message
From:
Sent: Thursday, September 10, 2020 3:50 PM
To:
Subject: RE: Out of money
It's about 10k.
Original Message
From:
Sent: Thursday, September 10, 2020 3:39 PM
To:
Cc:
Subject: RE: Out of money
says we are seriously out of money. That said, he also said he'll deal with the emergencies. And Maxwell is
on his radar. So depending on how much money we are talking about, there will be some play in the joints.
Original Message
From:
Sent: Thursday, September 10, 2020 3:38 PM
To:
Cc:
Subject: FW: Out of money
Do you know if there is any play in the joints on this? We were hoping to hire an SDFL vendor immediately to
start work on scanning the SDFL Epstein stuff and to help process the OPR Epstein stuff. Would prefer not to put
that off until October if possible.
Original Message
From:
Sent: Thursday, September 10, 2020 2:48 PM
To:
Cc:
EFTA00023016

=== Page 2 ===
Subject: Out of money
We are out of money through the end of the fiscal. Everything new will have to wait.
Sent from my iPad
EFTA00023017


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: Re: disclosure update
Date: Wed, 31 Jul 2019 21:05:40 +0000
so sorry, we are stuck in transit. Can I call you when I am back at my desk? It should be within the next half
hour. Apologies.
Sent from my iPhone
On Jul 31, 2019, at 2:00 PM,
wrote:
Yes-5pm works. Call my cell:
From:
Sent: Wednesday, July 31, 2019 12:20 PM
To:
Cc:
Subject: RE: disclosure update
Thanks-it's possible we'll still be in a meeting at 4:30. Would it be possible to speak at 5 instead? If not, we can plan
for 4:30 and let you know if we need to reschedule.
Thanks,
From:
Sent: Wednesday, July 31, 2019 11:18 AM
To:
Cc:
Subject: RE: disclosure update
Yes-would 4:30pm today work?
EFTA00021743

=== Page 2 ===
From:
Sent: Tuesday, July 30, 2019 6:20 PM
To:
Cc:
Subject: disclosure update
Hi
Do you have a few minutes for a quick call tomorrow afternoon? We are making a disclosure that relates to your client in
connection with our discovery obligations to Epstein's counsel, and we wanted to briefly make you aware of it.
Thanks,
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00021744


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=== Page 1 ===
From:
"
)"
To:
)"
)"
,
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: FW: Please see annexed Epstein Victim Letter
Date: Tue, 10 Nov 2020 18:00:37 +0000
Embedded: FW:_Please_see_annexed_Epstein_Victim_Letter.msg
Sender:
Subject: FW: Please see annexed Epstein Victim Letter
Message-Id:
<BN3P110MB0484CB6606278B42FB83E645EDE90@BN3P110MB0484.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
To:
EFTA00020834


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=== Page 1 ===
From: Gloria Allred
To:
)"
Subject: RE: Call this week
Date: Thu, 26 Mar 2020 19:49:40 +0000
Inline-Images: image001.png; image002.png
Yes. I will contact Ms.
I was confused, because I am not in litigation for her. Thanks.
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
GLORIAALLRED
2020
Best Lawyers RECOGNIZED BY
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's
of Fame - 2019
From:
) <
Sent: Thursday, March 26, 2020 12:45 PM
To:
Cc:
is
Subject: Re: Call this week
Gloria,
Thanks for speaking with us just now. The individuals we mentioned are
F and
Thanks,
Sent from my iPhone
On Mar 26, 2020, at 10:16 AM,
wrote:
Thank you.
Allred, Maroko & Goldberg
EFTA00023132

=== Page 2 ===
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's
of Fame - 2019
From:
Sent: Thursday, March 26, 2020 7:12 AM
To:
Cc:
is
Subject: Re: Call this week
We can use the below conference line:
Dial-in:
Code: 933571
Thank you,
On Mar 25, 2020, at 8:55 PM,
wrote:
I would be happy to send a Zoom number to you or feel free to send me a conference number to call.
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's
of Fame - 2019
From:
Sent: Wednesday, March 25, 2020 5:53 PM
To:
Cc:
is
)
Subject: Re: Call this week
Thanks very much. 3pm EST works for us. What number should we call?
Best,
EFTA00023133

=== Page 3 ===
On Mar 25, 2020, at 8:21 PM,
wrote:
Yes. What time tomorrow is better for you, 3 P.M. e.s.t. or 4P.M. e.s.t.?
Allred, Maroko & Goldberg
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.png>
Inducted into National Women's
of Fame - 2019
From:
Sent: Wednesday, March 25, 2020 1:55 PM
To:
Cc:
is
Subject: Call this week
Gloria,
Would you have time for a call with the SDNY Epstein team tomorrow or Friday? We would like to provide you with a
bit of an update and discuss some of your clients in particular.
Hope you are staying safe and healthy.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED
THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
EFTA00023134

=== Page 4 ===
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
EFTA00023135


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=== Page 1 ===
From:
)"
To:
Cc:
ivity
Date: Mon, 25 Mar 2019 23:00:23 +0000
Importance: Normal
Could we please load the documents in the following folder into Relativity for US V. Epstein (USAO # 2018R01618):
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY investigation\Subpoena
Returns\Boies Schiller\2019-03-04, Boies Schiller first subpoena response
In terms of structure, we'd like to create a folder identified as "Subpoena Returns" (at the same level as "FBI Case File" is
currently), and in a subfolder within Subpoena Returns, a folder titled "BSF returns," and within that a subfolder identified
as "BSF first production" that the docs in the above link can be deposited into (including any additional subfolders). Does
that work?
Please let me know if any questions or if any other information would be helpful, and if you could please let us know
when it's all uploaded?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00020780


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 12, 2020
VIA EMAIL
Jeffrey S. Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, CO 80203
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Mr. Pagliuca:
The Government writes in response to your letter dated August 9, 2020 requesting to use
discovery materials produced by the Government in the above-referenced criminal case bearing
Bates Nos. SDNY_GM_00000834 through SDNY_GM_00000962 (the "Unsealing Materials") to
litigate a civil lawsuit.
As an initial matter, the Government notes that it remains unclear whether you make this
request in your capacity as defense counsel to Ms. Maxwell in the above-referenced criminal case,
or in your capacity as her attorney in a separate civil matter. If the former, the Government
maintains that the "Confidential" designation of the Unsealing Materials is appropriate because
they pertain to an ongoing grand jury investigation and because Chief Judge Colleen McMahon
and Magistrate Judge Sarah Netburn have ordered that the Unsealing Materials remain under seal.
The only exceptions to those sealing orders are the permission contained in Chief Judge
McMahon's April 9, 2019 Order (Bates Nos. SDNY_GM_00000904 through SDNY_GM_
00000905), namely that the Order itself may be provided to Boies Schiller & Flexner LLP, and,
pursuant to separate permissions the Government has obtained in connection with its discovery
obligations, that the entirety of the Unsealing Materials may be provided to Ms. Maxwell as
discovery in the above-referenced criminal case. Moreover, as noted above, the Unsealing
Materials relate to an ongoing grand jury investigation, and their public disclosure at this stage
risks interference with that investigation. Indeed, because those materials remain under seal, the
Government has refrained, as it must, from publicly responding to your baseless accusations of
malfeasance in the civil litigation-accusations you now know to be false.
Moreover, the Protective Order issued by Judge Alison J. Nathan in the above-referenced
criminal case expressly provides that any and all discovery material produced to the defendant by
the Government, regardless of designation, "[s]hall be used by the Defendant or her Defense
Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding
or any purpose other than the defense of this action." (Protective Order, ECF No. 36, dated July
EFTA00021902

=== Page 2 ===
Page 2
30, 2020, 1(a), 10(a), 14(a) (emphasis added)). The Government notes that counsel for Ms.
Maxwell consented to that limitation when negotiating the Protective Order in the criminal case.
Accordingly, regardless of designation, the Protective Order expressly prohibits use of any
discovery materials produced by the Government in the above-referenced criminal case in any
civil case.
To the extent you make this request in your capacity as counsel to Ms. Maxwell in civil
litigation, the appropriate mechanism for obtaining these materials from the Government would
be a request for records through the Freedom of Information Act or through a Toughy request, to
the extent such materials are obtainable through either process, in the same manner as any other
litigant seeking to use records from a federal criminal investigation in a civil case. If you wish to
make such a request, the undersigned can refer you to the appropriate Assistant United States
Attorney in our office's Civil Division, who will process your request.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
By:
Went me
/
/
Assistant United States Attorneys
Southern District of New York
Tel:
EFTA00021903


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=== Page 1 ===
OFFICIAL RECORD
Intake (Rev. 5-23-17)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Intake
Date: 08/24/2020
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Drafted By:
Date/Time Received: 08/24/2020 05:13 PM EDT
Details:
On 08/24/2020, at 11:34:48 AM Eastern Time,
, Home
telephone number
,
Email account
,
Residential address
,
Internet Protocol (IP) address
,
which resolves to North Port, Florida 34287, submitted an
online tip to the FBI National Threat Operations Center (NTOC) via
tips.fbi.gov, regarding a video in relation to Jeffrey Epstein.
Date Submitted: 08/24/2020 11:34:48 AM ET
Transaction Number: 69F5232F-3BF7-4FFA-AF52-2503E10185FF
Threat To Life: False
Submitted Text:
Watched a disturbing video which came up and supposedly was a confession
/ minor child confession who worked for Ebstein involving a murder of
woman.
Violation: Other
UNCLASSIFIED
EFTA00020497

=== Page 2 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/24/2020
Violation Questions
What was the exact crime that occurred?: Epstein worker confession in a
video
When did the crime/incident occur? (Please provide an approximate date
and time) : Today 8/24/20
Where did the crime/incident occur? (Please provide the specific
location/address if possible) : Unknown
Complainant Information
First Name:
Middle Name:
Last Name:
Age:
DOB:
Additional Info:
Type: Home
Phone:
Extension:
Account:
Type: Residential
Address:
City:
UNCLASSIFIED
2
EFTA00020498

=== Page 3 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/24/2020
Zip:
Country: United States
Victim Information
First Name:
Middle Name:
Last Name:
Age:
DOB:
Additional Info:
Type: Other
Address:
City:
Zip:
Remote IP:
Remote Host: api.fbi.gov
Http Referrer: https://www.fbi.gov/wanted/operation-legend
User Browser: Mozilla/5.0 (iPhone; CPU iPhone OS 12 4 8 like Mac OS X)
AppleWebKit/605.1.15 (KHTML, like Gecko) Version/12.1.2 Mobile/15E148
UNCLASSIFIED
3
EFTA00020499

=== Page 4 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/24/2020
Safari/604.1
Latitude:
Longitude:
Country: US
Region: Florida
City: North Port
Postal Code: 34287
Timezone: -04:00
UNCLASSIFIED
4
EFTA00020500


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=== Page 1 ===
From:
(USANYS)"
To:
(ODAG) (JMD)"
Subject: Update
Date: Tue, 03 Sep 2019 22:32:38 +0000
Importance: Normal
Not much to report.
In Epstein, interviews planned for today in Florida were postponed due to weather.
In MCC, two inmates across from Epstein's cell were supposed to be interviewed. One declined the interview and the
other had nothing of interest to contribute. He slept through the night and only saw the activities in the morning after
Epstein was found in his cell.
Feel free to call me if you have any questions.
United States Attorney's Office
Southern District of New York
EFTA00023225


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=== Page 1 ===
From:
To:
Subject: RE: [EXTERNAL] Good morning
Date: Tue, 23 Nov 2021 14:11:06 +0000
no comment
From:
Sent: Tuesday, November 23, 2021 9:08 AM
To:
Subject: Fwd: [EXTERNAL] Good morning
Sent from my iPhone
Begin forwarded message:
From: "Katersky, Aaron"
Date: November 23, 2021 at 9:02:35 AM EST
To:
Subject: [EXTERNAL] Good morning
Nice note about the trial
For a preview piece I am going to write about Maxwell's most prominent public accuser,
not being part
of this case; no charges based on her allegations and not expect to be a witness for Gov. And also
not being on witness list;
Assume no comment but any issues there?
EFTA00021049


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=== Page 1 ===
From:
)"
To:
)"
)"
(NY) (FBI)"
Subject: RE: Epstein investigation
Date: Mon, 15 Jul 2019 17:54:49 +0000
Importance: Normal
Great, thanks.
Original Message
From:
Sent: Monday, July 15, 2019 1:54 PM
To:
(FBI)
Subject: RE: Epstein investigation
Sounds good, thanks.
Original Message
From:
)
Sent: Monday, July 15, 2019 1:54 PM
To:
i
(NY) (FBI)
Subject: RE: Epstein investigation
Sorry, forgot about both of those things. Let's say tomorrow at 3:30?
Original Message
From:
)
Sent: Monday, July 15, 2019 1:53 PM
To:
(NY) (FBI)
Subject: RE: Epstein investigation
/
I'm going to be in Florida for a witness interview on Wednesday. But tomorrow works.
Original Message
From:
)
Sent: Monday, July 15, 2019 1:51 PM
To:
(NY) (FBI)
i
)
Subject: RE: Epstein investigation
I have a doctor's appointment Wednesday at 10:30 so if it's possible to do tomorrow at 11:00 or 3:30, Wednesday
at 3:30, or Thursday after 4, I could do any of those times. Or if it ends up being Wednesday at 11:00, I'll get the
notes after.
EFTA00021428

=== Page 2 ===
Original Message
From:
)
Sent: Monday. July 15. 2019 13:49
To
(NY) (FBI)
Subject: FW: Epstein investigation
Wednesday at 11 work for everyone?
Original Message
From: Michael Bachner
Sent: Monday, July 15, 2019 1:42 PM
To:
Cc:
;
)
Subject: RE: Epstein investigation
Hi
Tomorrow or Wednesday at 11 or 3:30. Thursday any time after 11:30 to 4.
https://www.actl.com/
Michael Bachner, Esq.
Bachner & Associates, PC
39 Broadway, Suite 1610
New York, NY 10006
www.bhlawfirm.com
CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic
Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally privileged. If you
are not the intended recipient, you are hereby notified that any retention, dissemination, distribution, or copying
of this communication is strictly prohibited. Please reply to the sender that you have received the message in
error and then delete it. Thank you.
Original Message
From:
) [mailto:
Sent: Monday, July 15, 2019 12:50 PM
To: Michael Bachner
Cc:
)
Subject: Re: Epstein investigation
Hi Michael,
EFTA00021429

=== Page 3 ===
Apologies for the delay. Would you please let us know what times would work for you and
in the next
two or three days? We'll then figure out a time when we can all meet.
Thank you,
On Jul 11, 2019, at 10:43 PM, Michael Bachner
wrote:
Hello
6 o'clock is somewhat late. The client lives in
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
[X]
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information,
which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or
the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any
dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this
communication by error, please immediately notify the sender by e-mail and delete this email from your system.
Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 11, 2019, at 9:01 PM,
)
<mailto:
wrote:
Michael,
Would 7/16 at around 6pm work for the reverse proffer in our office at 1 St. Andrews?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
<mailto:
EFTA00021430

=== Page 4 ===
From: Michael Bachner
Sent: Thursday, July 11, 2019 12:26 PM
To:
<mailto:
Cc:
)
<mailto:
)
<mailto:
Subject: Re: Epstein investigation
Regarding the reverse proffer, We are available next week from the 15-18. I have a 2 o'clock meeting in my
office on the 16th and 17th that should last an hour. So I can meet with you on those days at 11 or 1030 in the
morning if that works. Please let me know
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information,
which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or
the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any
dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this
communication by error, please immediately notify the sender by e-mail and delete this email from your system.
Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 10, 2019, at 11:20 AM, Michael Bachner
wrote:
Sure.
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information,
which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or
the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any
dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this
communication by error, please immediately notify the sender by e-mail and delete this email from your system.
Nothing in this email should be construed as a legal opinion or tax advice.
EFTA00021431

=== Page 5 ===
On Jul 10, 2019, at 11:08 AM,
<mailto:
wrote:
Mike,
I think it would be useful to get a better understanding of your position-it would be helpful for us to know, for
example, how much time you propose to take to evaluate matters, and whether we can provide any additional
information that might be useful for that process of evaluation. That likely will affect our determination
regarding the grand jury appearance, at which we would expect, were we to call
to ask her a number
of questions we would expect to argue to the court do not implicate a fifth amendment privilege-i.e., that she
couldn't simply blanket invoke. Would it be useful to discuss via phone?
thanks,
From: Michael Bachner
Sent: Wednesday, July 10, 2019 10:25
To:
<mailto:
Cc:
)
<mailto:
)
<mailto:
Subject: Re: Epstein investigation /
Dear Counsel:
I met with
and I need time to evaluate matters. Regarding the subpoena to testify before the Grand
Jury on
we hereby notify you that if called as a witness
would invoke her Fifth Amendment
privilege against compelled self-incrimination. Please let me know if you will require her to invoke in person or
whether this communication suffices and no appertaining will be required.
Yours truly,
Michael Bachner
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York. NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD026.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information,
which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or
the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any
dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this
communication by error, please immediately notify the sender by e-mail and delete this email from your system.
Nothing in this email should be construed as a legal opinion or tax advice.
EFTA00021432

=== Page 6 ===
On Jul 9, 2019, at 11:43 AM,
<mailto:
wrote:
Mr. Bachner,
Following up on our conversation earlier this morning, we wanted to provide you with the additional information
and materials we discussed. In the first instance, so that you have full contact info for the team, please feel free to
reach out to any of us at any time; we're all available via email or at the following phone numbers:
Additionally, attached are the non-prosecution agreement, previously publicly filed in civil proceedings in
Florida, and a blank version of our standard proffer agreement, both as discussed.
As we mentioned, please don't hesitate to reach out with any questions, and we look forward to setting a time to
speak again after you're able to confer with
thank you.
Assistant U.S. Attorney
Southern District of New York
<blank proffer agreement.pdf>
<Epstein NPA, dated 2007-09-24.pdf>
EFTA00021433


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=== Page 1 ===
From: "Weinstein, Marc A."
To:
Cc: Andrew Tomback
Subject: Epstein - false warranty deed
Date: Mon, 09 Nov 2020 21:42:29 +0000
Attachments: OR_31849_39_WD.pdf
Attached is the warranty deed filed for the Palm Beach property which we believe to be fabricated. As mentioned, we
understand there has been a similar deed filed for the New Mexico property.
Best regards,
Marc
Marc A. Weinstein | Partner
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.
EFTA00020833


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
Cc:
(USANYS) [Contractor]"
(USANYS)"
Subject: Barr Seized on Epstein Case as Doubts Mounted About Justice Dept.
Date: Fri, 23 Aug 2019 20:00:08 +0000
Barr Seized on Epstein Case as Doubts Mounted About Justice Dept.
NYT
By Katie Benner
8/23/19
Attorney General William P. Barr was at home in his study, working on a speech, when the call came from his chief
of staff: Jeffrey Epstein, the financier accused of sex trafficking who had connections to an array of political power
players, had died in federal prison.
Mr. Barr immediately knew that he would be engulfed in a scandal. The prison had promised to keep Mr. Epstein
under constant surveillance until he could be tried on charges of sexually abusing dozens of underage girls. With his
accusers now robbed of their day in court, the Justice Department, which oversees the Bureau of Prisons, looked
incompetent at best. And as Mr. Barr scrambled for answers, unfounded conspiracy theories took root, casting an
additional pall over the matter and threatening the public's faith in the department.
Over multiple briefings an hour, Mr. Barr spent that Saturday angrily grilling his deputies. He directed the F.B.I. to
investigate Mr. Epstein's apparent suicide and the department's inspector general to look for lapses in protocol. After
the Bureau of Prisons confirmed the death and the F.B.I. inquiry that morning, Mr. Barr issued a statement,
surprising officials who believed the bureau would have the last word. "Mr. Epstein's death," he said, "raises serious
questions that must be answered."
Attorneys general rarely follow up on inmate deaths, but Mr. Barr has continued to bird dog the investigation into
how one as high-profile as Mr. Epstein could have died in federal care, evidence of how serious the matter is for the
Justice Department. This account of his search for answers is based on interviews with six people involved in the
investigation into Mr. Epstein's death, most of whom spoke on the condition of anonymity to describe internal
department discussions.
Mr. Barr is personally overseeing the four federal inquiries into the matter and is briefed on them multiple times a
day. In less than two weeks, he suspended the two prison employees who guarded Mr. Epstein the night he died,
transferred the warden and found a new permanent director for the Bureau of Prisons. He stayed apprised of the
autopsy and was alerted that the coroner would officially rule the death a suicide. And federal prosecutors in New
York have subpoenaed more than a dozen prison officials and employees as the fast-moving investigation into Mr.
Epstein's death intensifies.
That a tabloid-ready scandal could present any danger to Mr. Barr, one of the most politically shrewd and influential
Trump cabinet members, speaks to the swirl of unresolved questions surrounding Mr. Epstein's short time in prison
and the intense public interest in the case, itself fueled by how poorly the department handled an earlier sex
trafficking investigation into Mr. Epstein and by the conspiracy theories about the financier's powerful acquaintances,
including President Trump and former President Bill Clinton, that festered even before he died.
EFTA00020787

=== Page 2 ===
"Bill's skill set is to doggedly get to the bottom of facts and makes decisions based on them," said Paul T. Cappuccio,
a key adviser to Mr. Barr when he first served as attorney general under President George Bush. "For anyone to try
to draw anything more political or conspiratorial from this situation seems unfounded."
Mr. Barr's close handling of the case also underscores the toll that a nearly three-year war on the Justice
Department's credibility - waged chiefly by Mr. Trump when he attacked the Russia investigation - has taken. Mr.
Barr has publicly defended the coroner's ruling of suicide, even as some of the public and Mr. Epstein's own lawyers
reject it. And in the wake of Mr. Epstein's death, the president amplified a baseless conspiracy theory that his
political enemies were involved.
"Public confidence in the independence and integrity of high-profile federal criminal investigations is giving way to
wild-eyed conspiracy theories propagated by the president himself," said Christopher Hunter, a fellow at the Atlantic
Council and former F.B.I. agent and prosecutor who served in the Obama and Bush administrations.
Before Mr. Epstein died, Mr. Barr seemed to have put his greatest initial challenge as attorney general behind him.
He had delivered the Mueller report on Russia to the public, one of the most politically divisive Justice Department
investigations since Watergate. Accusations that he misrepresented the findings to benefit Mr. Trump had begun to
fade from the public consciousness, and much of official Washington had moved on to new outrages and concerns.
Mr. Epstein's death prompted an unexpected challenge to Mr. Barr's credibility. The Justice Department has faced
accusations that it mishandled an earlier investigation into the financier by making a deal in 2008 that allowed Mr.
Epstein to elude federal charges and serve prison time from his office. It also shielded his six known co-conspirators.
That deal led to the resignation last month of the labor secretary, R. Alexander Acosta, who had brokered the
agreement while serving as United States attorney in Miami.
To quell renewed furor over the deal, the Justice Department opened an internal review. Prosecutors in Manhattan
had also opened a new sex trafficking investigation, but Mr. Epstein's connections with powerful figures all over the
world prompted skepticism that charges would ever be filed. Even Mr. Barr had chance ties to Mr. Epstein: His old
law firm, Kirkland & Ellis, had worked with Mr. Epstein on the Miami deal, and decades earlier, Mr. Barr's father had
hired Mr. Epstein to teach at Dalton, the elite private school in Manhattan.
But in July, Manhattan prosecutors charged Mr. Epstein with sex trafficking, putting the financier behind bars while
he awaited trial. Thirty-three days later, Mr. Epstein, 66, was found dead in his cell.
From the moment he learned that Mr. Epstein had killed himself, Mr. Barr has been largely consumed by the inner
workings of the prison where Mr. Epstein was housed, the Metropolitan Correctional Center in Manhattan.
Mr. Barr knew that Mr. Epstein - a high-profile and politically connected prisoner - could pose a problem,
especially after he was found unconscious in his cell last month in a possible suicide attempt. But within a week,
prison officials determined that he could be taken off suicide watch, and they assured the Justice Department that he
would be monitored around the clock and be placed with a cellmate, whose presence could deter self-harm.
It is not clear whether "appropriate oversight from Justice Department leadership was brought to bear before
Epstein committed suicide to make sure that the Bureau of Prisons was meeting its responsibilities," said David
Laufman, a former Justice Department official.
"The attorney general or the deputy attorney general's office should have communicated directly and forcefully with
bureau leadership to ensure that it was dedicating maximum resources and oversight to prevent Epstein from doing
harm to himself," Mr. Laufman said.
After Mr. Epstein killed himself, Mr. Barr moved to quell doubt that the department would seek justice.
He immediately determined that prison employees and the warden had broken protocol several times. Mr. Epstein's
cellmate had been removed. The employees overseeing him had stopped their regular checks into his cell the night he
EFTA00020788

=== Page 3 ===
died, even though prison supervisors and officials knew that he was to be constantly watched. And the prison had
yet to officially determine whether he had earlier tried to commit suicide.
Mr. Barr put on leave the two employees who were responsible for watching over Mr. Epstein the night he died and
moved the warden, Lamine N'Diaye. And when he asked Kathleen Hawk Sawyer last Friday to return to run the
Bureau of Prisons - a job he had appointed her to in 1992, during his first stint as attorney general - she was
impressed by the amount of detail he had gathered about Mr. Epstein's death and the conditions at the prison where
he died, according to a person with knowledge of the conversation who was not authorized to share details.
Ms. Sawyer told Mr. Barr that she took the job in large part because she believed she would have Mr. Barr's support
to make difficult decisions necessary to address the Epstein case and the bureau's continuing struggles with staff and
funding shortages, prison violence and workplace discrimination issues at its 120 facilities, according to the person.
Mr. Barr has not shied away from publicly commenting on the Epstein case. Two days after the suicide, Mr. Barr said
that "serious irregularities at this facility" demanded "accountability," and that the Justice Department would pursue
Mr. Epstein's co-conspirators.
On Wednesday, Mr. Barr defended the coroner's report, saying that he had seen nothing to contradict it. And he said
that the department could soon "report to Congress" a fuller picture of those irregularities and that the results had
been delayed by witnesses who would not speak without union and legal representatives.
Mr. Barr unfairly painted the jail employees as uncooperative, said Eric Young, the president of the union that
represents federal prison workers, adding that the department has refused to grant immunity to workers involved in
the Epstein inquiry, which he said was typical in similar federal investigations.
But even as Mr. Barr closes in on a definitive account of the failings that led to Mr. Epstein's suicide, questions
remain. The Bureau of Prisons has not yet said whether security cameras in the cell block showed anyone entering
and leaving Mr. Epstein's cell in the hours before he died. And it is still not clear why the prison broke promises to
regularly check on Mr. Epstein and keep him with a cellmate.
EFTA00020789


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=== Page 1 ===
From:
To:
Subject: Read: RE: US V. Epstein
Date: Wed, 24 Jul 2019 12:29:06 +0000
EFTA00021660


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=== Page 1 ===
From:
To:
Bcc:
Subject: FW: Epstein priv review -- 1B72 released and update
Date: Tue, 03 Nov 2020 22:11:37 +0000
Embedded: FW:_Epstein_priv_review__IB72_released_and_update.msg
Sender:
Subject: FW: Epstein priv review -- 1B72 released and update
Message-Id:
<SN5P110MB0542A49AAEE04E7250908BF292110@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
EFTA00021116


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=== Page 1 ===
From:
Subject: RE: joint letter
Date: Sun, 07 Nov 2021 19:40:28 +0000
Attachments: 2021-11-08_joint_letter_regarding_juror_questionnaires_(with_juror_s).docx;
2021.11.07_Defense_&_Govt_Objection_Lists.xlsx
Hey
- the draft letter is attached, with all four categories filled in with the respective juror numbers. I'm also
attaching the Excel sheet, containing defense and government objections, that contains all four lists in four different
sheets. This Excel sheet is also saved on the shared in the jury selection folder.
If anything needs to be edited, l'll be around for a bit longer today but I'm unavailable later this afternoon/evening, after
3:30pm today.
Cooper have kindly offered to handle any edits tonight when I'm offline,
so I can loop them in if necessary.
Thanks so much!
From
Subject: joint letter
Hi
Thanks so much for all you're doing today, really appreciate it. Attached is a draft of the joint letter for today with the four
categories. Could you please fill those in after you've had a chance to enter all the data from the defense? I'm fine with
charts in each of the four questions (essentially just one row of cells with juror numbers). Also fine with bullet points.
Whichever is easiest.
Whenever you're at point when you have a sense of the timeline for this, that would be helpful to know - we'll need to
send this to the defense with ample time to review for accuracy, so hoping to do that later this afternoon.
Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00021979


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=== Page 1 ===
From:
"
)"
To: Brad Edwards
,
Brittany Henderson
Cc:
)"
(USANYS)"
)"
Subject: RE: Response re Rule 17(c) subpoena
Date: Tue, 23 Nov 2021 01:20:52 +0000
Attachments: 2021.11.22_Order_re_Rule_17_subpoenas.pdf
Hey Brad, Brittany,
Attached is the Court's order on the motions.
From:
Sent: Monday, November 22, 2021 7:28 PM
To: Brad Edwards
>; ; Brittany Henderson
Cc:
is
is
Subject: Response re Rule 17(c) subpoena
Brad, Brittany,
Attached is Maxwell's response to the motions to quash her Rule 17(c) subpoena.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00021032


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=== Page 1 ===
From: "Sahni, Anjan"
To:
)"
Cc:
)"
>, "Stoddart, Allison"
Subject: Re:
entities subpoenas
Date: Mon, 09 Sep 2019 13:15:03 +0000
Thanks. Speak with you soon.
On Sep 9, 2019, at 9:05 AM,
)
wrote:
EXTERNAL SENDER
Sure, give us a call at 10:15. Talk with you then.
On Sep 9, 2019, at 09:00, Sahni, Anjan
wrote:
Thanks
We can call you at the number below. If it's possible to do 10:15, that would be great.
Best,
Anjan
On Sep 6, 2019, at 7:24 PM,
)
wrote:
EXTERNAL SENDER
That works for us. Please let us know if there's a number we should call you at, otherwise we'll be reachable then at
thanks,
From: Sahni, Anjan
Sent: Friday, September 06, 2019 19:16
To:
Cc:
is
>; Stoddart,
Allison
Subject: Re:
entities subpoenas
Thanks
10am on Monday?
On Sep 6, 2019, at 2:34 PM,
wrote:
EXTERNAL SENDER
EFTA00020672

=== Page 2 ===
Anjan,
We unfortunately have a meeting starting imminently that we expect may go a couple hours. We could do anytime
before noon on Monday, though, if there's a time then that works for you?
thanks,
From: Sahni, Anjan
Sent: Friday, September 06, 2019 12:00
To:
Cc:
is
>; Stoddart,
Allison
Subject: RE:
entities subpoenas
Many thanks,
Would later this afternoon work for a call? Might 3pm or 4pm work?
Thanks,
Anjan
From:
Sent: Wednesday, September 4, 2019 7:47 PM
To: Sahni, Anjan
Cc:
is
Subject: RE:
entities subpoenas
EXTERNAL SENDER
Anjan,
Very good to hear from you, and I apologize for the delay in replying to your voicemail from Friday - I was on trial
last week so have spent the past couple days digging out from under piles of emails and voicemails. But we'd be
happy to speak with you regarding the subpoenas to the
entities in connection with the Epstein
investigation. We had been in touch with Steve D'Allessandro, who was very helpful, but he also mentioned that
they might bring in outside counsel.
If you let us know a couple times that would work for you tomorrow or Friday-and I'm copying my colleagues
and
who are also working on the case-we'll get a quorum on our side and finalize a time. And
please let us know if any other information would be useful in the interim.
thanks,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 1 of 70
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-Marra/Johnson
JANE DOE #1 and JANE DOE #2
V.
UNITED STATES
/
JANE DOE 1 AND JANE DOE 2'S REPLY TO INTERVENOR EPSTEIN'S BRIEF
IN OPPOSITION TO PROPOSED REMEDIES
Bradley J. Edwards
Edwards Pottinger LP
Paul G. Cassell
Pro Hac Vice
* This daytime business address is provided for identification and correspondence purposes
only and is not intended to imply institutional endorsement by the University of Utah.
EFTA00022546

=== Page 2 ===
Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 2 of 70
TABLE OF CONTENTS
INTRODUCTION
1
THIS CASE MUST BE DECIDED ON THE AGREED PREMISE THAT THE NPA ONLY
COVERS THE U.S. ATTORNEY'S OFFICE FOR THE SOUTHERN DISTRICT OF FLORIDA.
3
DISCUSSION
6
I. INTERVENOR EPSTEIN HAS RECEIVED PROCEDURAL DUE PROCESS THROUGH
AN OPPORTUNITY TO BE HEARD AND SUBMIT EVIDENCE ON ISSUES PERTAINING
TO REMEDIES.
6
A.
As an Intervenor, Epstein Has Received Procedural Due Process
6
B.
The Court's Findings About Epstein Counsel's Awareness of Concealment of the Non-
Prosecution Agreement are Well-Supported and Unchallenged
10
1.
Through Counsel, Epstein Was a Party to the Illegal Concealment of the Non-
Prosecution Agreement
10
2.
Evidence Exists that the Epstein Defense Team Acted in Bad Faith.
18
3.
The USAO-SDFL Was Not Authorized to Extend Epstein Immunity Without First
Conferring with his Victims.
23
II. THE
CVRA
AUTHORIZES
RESCISSION
AS
A
REMEDY.
26
A.
The CVRA Authorizes Rescission as a Remedy.
26
B.
The Victims Are Not Time-Barred Under the CVRA.
28
III. PRINCIPLES OF CONTRACT LAW SUPPORT A RESCISSION REMEDY.
34
A.
Under the CVRA, Contract Law Principles Require Rescission
34
B.
The Civil Releases Signed by Jane Doe 1 and 2 Did Not - and Could Not - Waive
their CVRA Claims Against the Government
40
IV. THE DOCTRINES OF EQUITABLE AND JUDICIAL ESTOPPEL ARE INAPPLICABLE.
45
A.
Jane Doe 1 and 2 Have Not Violated Any CVRA Requirement in Handling Their
Petition.
45
B.
Congress Has Not Added Doctrines of Estoppel to the CVRA.
46
C.
Epstein Has Failed to Satisfy the Elements of the Equitable Estoppel Doctrine
48
D.
Epstein Has Failed to Satisfy the Elements of the Judicial Estoppel Doctrine
50
i
EFTA00022547

=== Page 3 ===
Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 3 of 70
V. ALLEGED PRINCIPLES OF "SUBSTANTIVE DUE PROCESS" DO NOT PRECLUDE
RESCISSION REMEDIES
53
VI. SEPARATION OF POWERS DOES NOT PREVENT THE COURT FROM EXERCISING
ITS STATUTORY POWER TO ENFORCE THE CVRA.
59
VII. THE VICTIMS' REQUEST FOR DECLARATORY RELIEF (REMEDY #2)
IMMEDIATELY BECOMES RIPE UPON THE GRANTING OF A RESCISSION (REMEDY
#1).
61
VIII. THE COURT IS AUTHORIZED TO HOLD A PUBLIC HEARING WITH THE VICTIMS
IN THIS CASE.
62
IX. ADOPTION OF EARLIER PLEADINGS BY REFERENCE
63
X. THE COURT SHOULD EXPEDITE ITS RULING ON REMEDIES AND ON THE
VICTIMS' RIGHTS TO BE TREATED WITH FAIRNESS AND TO NOTICE
63
XI. REQUEST
FOR
A
HEARING
(IF
NECESSARY)
65
CONCLUSION
65
ii
EFTA00022548

=== Page 4 ===
Case 9:08-cv-80736-KAM Document 466 Entered on FLSD Docket 07/23/2019 Page 4 of 70
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-
JANE DOE #1 and JANE DOE #2
V.
UNITED STATES
/
JANE DOE 1 AND JANE DOE 2'S REPLY TO INTERVENOR EPSTEIN'S BRIEF IN
OPPOSITION TO PROPOSED REMEDIES
COME NOW Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through
undersigned counsel, having previously provided a submission on proposed remedies (DE 458)
and in light of Intervenor Epstein's Brief in Opposition (DE 463) (hereinafter cited as "Epstein
Remedies Br."), to now reply to Epstein in support of their submission on proposed remedies. For
the reasons explained in their earlier submissions (see, e.g., DE 458 and 464) and below, the Court
should reject the Intervenor Epstein's arguments and grant Jane Doe 1 and Jane Doe 2 the various
remedies their seek to enforce and protect their rights under the Crime Victims' Rights Act
(CVRA) - including rescission of the non-prosecution agreement.
INTRODUCTION
As Jane Doe 1 and 2 explained in their earlier submissions, this case involves deception of
dozens of Florida victims of an international sex trafficking organization - the organization led by
1 As discussed below, Epstein was granted "limited" intervention in this case to address
remedies. Since remedies are now at issue, Epstein has full intervention rights and will be
referenced throughout this reply as "Intervenor Epstein."
1
EFTA00022549

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Intervenor Epstein. The Government² and Epstein reached a secret non-prosecution agreement
(NPA) and then concealed that agreement until it was firmly in place - and the victims lost any
opportunity to object. This secret justice for Epstein and his co-conspirators has led to a national
outcry about unfairness and unequal treatment of the wealthy and powerful in the criminal justice
system.
This Court has previously determined that Jane Doe 1 and 2's CVRA rights to confer with
prosecutors were violated through the machinations of prosecutors and Epstein. This Court then
called for briefing on the appropriate remedy for that violation. DE 454. Jane Doe 1 and 2 have
proposed rescission of the NPA's "immunity" provisions, which have prevented victims from
conferring with prosecutors in the USAO-SDFL about prosecuting Epstein for the crimes he
committed in Florida against them. Epstein claims that this remedy is not available to this Court.
But the Court has previously held that it is a permissible remedy and nothing that Epstein raises
should cause the Court to reverse course. The NPA's immunity provisions were founded in
illegality - specifically, their concealment from the victims - something that Epstein well knew
and, indeed, specifically sought. Accordingly, this Court can and should rescind the immunity
provisions as the appropriate remedy for the victims. Rescission will vindicate Jane Doe 1 and 2's
CVRA rights, by permitting them to confer with prosecutors in this district about obtaining federal
prosecution here - against Epstein and all of his coconspirators.
Epstein has little to say about the other remedies that the Jane Does seek, and accordingly
the Court should (for reasons articulated earlier) grant those remedies as well.
2 References to the "Government" in this case should be generally understood to refer to
the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL), which is currently
being represented by the U.S. Attorney's Office for the Northern District of Georgia.
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THIS CASE MUST BE DECIDED ON THE AGREED PREMISE THAT THE NPA
ONLY COVERS THE U.S. ATTORNEY'S OFFICE FOR THE SOUTHERN DISTRICT
OF FLORIDA.
For many years, this case has been litigated on the premise that the NPA negotiated by
Epstein with prosecutors in the Southern District of Florida only precludes his prosecution in the
Southern District of Florida. Indeed, the NPA's plain terms directly limit the agreement to "this
District." See NPA at 2 (noting that the agreement was signed "on the authority of R. Alexander
Acosta, United States Attorney for the Southern District of Florida" and requires that "prosecution
in this District for [various federal offenses] shall be deferred" and that no federal prosecution of
Epstein "will be instituted in this District"). This is consistent with the statute creating the Office
of U.S. Attorney, which allows each U.S. Attorney to prosecute offenses only "within his district."
28 U.S.C. $ 547.
In light of this plain language, the NPA has no application to prosecutors in other judicial
districts, such as the Southern District of New York. See United States V. Fernandez, No. 17-CR-
167 (JMF), 2017 WL 6372783 at *2 (S.D.N.Y. 2017) ("The Second Circuit has squarely held that
"[w]hen the express terms of a plea agreement set forth promises by 'the Government,'
the
plea agreement binds only the office of the United States Attorney for the district in which the plea
is entered unless it affirmatively appears that the agreement contemplates a broader restriction, or
unless there is evidence to show that a prosecutor is attempting to evade its own obligations under
the plea agreement by transferring a prosecution to another office" (citing United States V.
Salameh, 152 F.3d 88, 120 (2d Cir. 1998)).
The fact that the USAO-SDFL's agreement with Epstein applies only to the Southern
District of Florida has been made explicitly throughout this litigation - without any objection from
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Intervenor Epstein. See, e.g., DE 205-6 at 30 (". the USAO-SDFL did not bargain away the
possibility of federal criminal charges being instituted in other districts based on alleged sexual
acts that Epstein committed against [Jane Doe 1 and 2]. Such charges can still potentially be
pursued in other districts, such as the Southern District of New York "); DE 205-2 at 8-9 ("a
number of districts outside the Southern District of Florida (e.g., the Southern District of New
York .) share jurisdiction and venue with the Southern District of Florida over potential federal
criminal charges based on the alleged sexual acts committed by Epstein against [Jane Doe 1 and
2]. Epstein is thus subject to potential prosecution for such acts in those districts."); see also DE
464 at 13 n.4 ("The NPA negotiated by attorneys in the Southern District of Florida obviously only
precluded prosecution in the Southern District of Florida"). Several of the remedies the victims
have proposed are clearly predicated on this long-standing assumption. For example, the victims
have sought documents about the investigation regarding Epstein conducted by FBI-Miami
(remedy #10), education in the U.S. Attorney's Office for the Southern District of Florida (remedy
#14), and sealed remedies involving other U.S. Attorney's Offices (remedy #18). The victims
would have crafted all of these proposed remedies (and others) differently if they had any
suggestion from Epstein that this case involved immunity that extended nationwide.
Moreover, other important aspects of this case have involved the predicate that this case
concerned Epstein's federal crimes subject to prosecution in this District. For example,
Government notifications to crime victims about this case have apparently only gone to Epstein
victims in this District.
Intervenor Epstein's factual "background" section of his brief only makes clearer that the
NPA at issue in this case does not have any nationwide reach. As Epstein's "background" section
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argues, the negotiations between the U.S. Attorney's Office for the Southern District of Florida
(USAO-SDFL) and Epstein's high-powered legal team focused on the defense claim that this case
"was, at heart, a local sex abuse case." Epstein Remedies Br. at 15 (quoting former First Assistant
U.S. Attorney Jeffrey Sloman). Indeed, one of the experts that Intervenor Epstein hired
represented to the Justice Department during discussions about the NPA that "[t]his is a case about
purely local activity, involving local actors, and affecting local interests and thus, should be
handled by local authorities." Id. at 15. In other words, according to Epstein's defense attorneys
at the time that the NPA was under consideration, this was not a case "present[ing]
multijurisdictional obstacles" beyond the ability of "States and localities" to confront. Id. at 16.
This Court has previously ruled that this case is to be decided based on a possible CVRA
rights violation "of Jane Doe 1, Jane Doe 2, and all 'other similarly situated victims" (DE 324 at
9), where all the victims under contemplation have been victimized by Epstein through federal
crimes subject to prosecution here. Ultimately, as Epstein himself puts it, this case involves "the
exercise of discretion by federal prosecutors in the Southern District of Florida." Id. at 18.
It is common knowledge that Intervenor Epstein is currently being prosecuted by federal
prosecutors in the Southern District of New York. The NPA in this case has no connection to or
bearing on that prosecution there - and the Court should craft remedies for the victims in this
District for the violations of rights that occurred here.
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DISCUSSION
I.
INTERVENOR EPSTEIN HAS RECEIVED PROCEDURAL DUE PROCESS
THROUGH AN OPPORTUNITY TO BE HEARD AND SUBMIT EVIDENCE ON
ISSUES PERTAINING TO REMEDIES.
A.
As an Intervenor, Epstein Has Received Procedural Due Process.
Intervenor Epstein begins his arguments with a procedural claim that he has somehow been
denied "procedural due process" in this matter. Epstein Remedies Br. at 14-19. His argument is
difficult to understand. More than six years ago, Epstein filed a motion for "limited intervention"
in this case, seeking to "intervene in these proceedings when and if they reach the stage at which
the Court will consider what remedy to order if it finds that the government violated the [victims']
rights under the CVRA." DE 207 at 1. As Epstein explained in his motion, this Court had earlier
ruled that "rescission relief" was an available remedy in this case. Id. Accordingly, Epstein had
"clear and compelling interest[s] in opposing any remedy that would entail rescission of his non-
prosecution agreement with the government," and these interests were "personal to him and would
not be adequately represented by the government should the Court determine that a CVRA
violation occurred and that rescission or re-opening of the non-prosecution agreement was one of
the remedial options under consideration." Id. The victims did not oppose his intervention. DE
209 at 3-4. And the Court duly granted Epstein's intervention motion. DE 246 at 1 (order allowing
Epstein "to intervene with regard to any remedy issue concerning the non-prosecution
agreement").
Of course, this Court subsequently found a violation of the victims' CVRA rights, squarely
posing remedial issues. And the Court thereafter asked for submissions on how to proceed to
determine appropriate remedies, receiving briefing on scheduling from the two victims and the
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USAO-SDFL - and from Epstein. In his scheduling brief, Epstein explained that "[r]egarding the
mechanism for determining remedy, neither party disputes that Mr. Epstein has a right to be heard
Mr. Epstein respectfully submits that he should be given an opportunity to file a response to
the substantive legal briefs of the parties on the issue of remedy within 30 days after [the victims']
brief is filed, before the Court permits the taking of any evidence in this matter." DE 453 at 2.
Thereafter, the Court established a briefing schedule that essentially tracked what Epstein
proposed, and specifically allowed Epstein to "file affidavits or declarations in support of his
position." See DE 454 at 2.
In the wake of all this, Intervenor Epstein now broadly asserts that "summary judgment
was granted against the government, not Mr. Epstein" and that, therefore, "there can be no remedy
that prejudices him." DE 463 at 25. But the legal support for this claim is a mystery. It was
Epstein himself who proposed limited intervention as the appropriate procedural device to allow
him to be heard in this case. And obviously Epstein has had full notice and opportunity to be heard
on remedy issues, including an opportunity to submit any relevant evidence he wants and to
challenge any finding that he believes are inaccurate. As Epstein's own authority makes clear, the
key requirement for due process is whether a litigant has "received a 'full and fair' opportunity to
litigate [his] claims." Parklane Hosiery Co., Inc. V. Shore, 439 U.S. 322, 332 (1979). Epstein
raises no suggestions that he has been denied that opportunity here.
Epstein does point to the fact that the Eleventh Circuit has previously ruled in this case that
he is not "an ordinary litigant." Jane Doe 1 V. United States, 749 F.3d 999, 1005 (11th Cir. 2014).
But that ruling, which involved the disclosure of certain correspondence, is of no relevance now.
The Eleventh Circuit was simply describing this Court's earlier ruling on intervention. Indeed, the
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Eleventh Circuit made clear it was fully approving this Court's approach of allowing Epstein to
raise remedial issues at the end of the case:
The victims argue that Epstein has made himself an ordinary litigant through his
intervention, but we disagree.
[T]he district court has granted Epstein limited
intervention to challenge only the disclosure of his attorneys' correspondence and
any remedy that involves the non-prosecution agreement. Epstein's only
opportunity to challenge the disclosure order is now because there will not be an
adverse judgment against him or his attorneys. The district court instead will enter
any judgment against either the victims or the United States. And, even if the victims
succeed in their petition to rescind the non-prosecution agreement, Epstein can
challenge only that remedy, not the judgment against the United States. The victims
intend to use the correspondence from Epstein's attorneys to prove that the United
States violated the Act, which is an issue separate from the kind of relief necessary
to remedy that violation. And it is all the more likely that the district court would
fashion a remedy that does not involve the non-prosecution agreement, if the district
court were to conclude that rescission is unavailable, which might then bar an
appeal by Epstein of that remedy.
749 F.3d at 1005-06 (emphasis added). Plainly when it ruled in 2014, the Eleventh Circuit foresaw
a situation where Epstein might need to challenge a rescission remedy during a remedial phase of
this case - which is precisely what has happened.
The very purpose of allowing a person to intervene in a case is to ensure "that a single set
of factual findings will bind" the intervenor and the other parties. Huff V. Commissioner of IRS,
743 F.3d 790, 797 (11th Cir. 2014). And the "fundamental requirement of due process is the
opportunity to be heard 'at a meaningful time and in a meaningful manner." Reams V. Irvin, 561
F.3d 1258, 1263 (11th Cir. 2009) (quoting Mathews V. Eldridge, 424 U.S. 319, 333 (1976)). Here
Epstein argues that he has been "deprived
of the ability to contest numerous allegations and
stipulations at the liability phase." Epstein Remedies Br. at 28. This is simply untrue. Epstein
was free to challenge all allegations (and alleged "stipulations") from the liability phase, to the
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extent that they had any bearing on remedy. Indeed, this Court made clear that Intervenor Epstein
could "file affidavits or declarations in support of his position." See DE 454 at 2.
Epstein complains, for example, about the fundamental premise of this case: that Jane Doe
1 is a "crime victim" covered by the Crime Victims' Rights Act (CVRA). Epstein argues that this
is not possible, because there are no pending federal charges against Epstein in this District. But
this Court has already cited evidence and explained the reasons for concluding that Jane Doe 1
was a victim of a federal crime committed by Epstein in the Southern District of Florida. 359
F.Supp.3d at 1204. If Epstein wanted to challenge that finding, all he had to do was file an
affidavit, under oath, to that effect. He chose not to do so - and due process hardly precludes
continuing to move forward in this case on the basis of an unchallenged and factually supported
finding made long ago.
Moreover, if taken seriously, Epstein's position would sap the CVRA of much of its value.
This Court has already held that exercising CVRA rights is possible before criminal charges are
formally filed, noting that 18 U.S.C. § 3771(d)(3) provides that "the CVRA's enumerated rights
'shall be asserted in the district court in which a defendant is being prosecuted for the crime or, if
no prosecution is underway, in the district court in the district in which the crime occurred." Does
V. United States, 817 F.Supp.2d 1337, 1342 (S.D. Fla. 2011) (quoting 18 U.S.C. $ 377(d)(3)
(emphasis added)). This Court explained that the CVRA's language allows CVRA's rights to "be
enforced before a prosecution is underway id. (emphasis added) - i.e., to be "enforced" in
this Court. Of course, the Crime Victims Rights Act creates rights for "crime victims," which in
Epstein's (erroneous) view can never exist until a formal indictment is filed. Epstein's argument
would essentially eviscerate the CVRA's pre-charging protections and should be rejected.
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B.
The Court's Findings About Epstein Counsel's Awareness of Concealment of
the Non-Prosecution Agreement are Well-Supported and Unchallenged.
1.
Through Counsel, Epstein Was a Party to the Illegal Concealment of
the Non-Prosecution Agreement.
Intervenor Epstein also argues that his defense counsel "acted in good faith." Epstein
Remedies Br. at 30. But he never defines what he means by "good faith." Rather than debating
how to characterize the actions of the defense team, the salient factual issue is this Court's specific
findings that the Government decided "to conceal the existence of the NPA and mislead the victims
to believe that federal prosecution was still a possibility." 359 F.Supp.3d at 1219. And the Court
has also previously found that "Epstein's counsel was aware that the Office was deliberately
keeping the NPA secret from the victims and, indeed, had sought assurances to that effect." Id. at
1208 (citing DE 407 at 1 48 (emphasis added)).
While Intervenor Epstein quibbles over the accuracy of these findings, one preliminary
point is important: Epstein does not offer any factual evidence to the contrary. For instance, even
though this Court invited Epstein to provide any affidavits or declarations in support of his position
(DE 454 at 2), Epstein offered nothing. Nor did Epstein challenge the admissibility of evidence
that Jane Doe 1 and 2 have previously provided. As a result, in attacking this finding, Epstein can
only rely on the existing evidence.
Epstein's main point appears to be not that this Court was wrong in finding that the NPA
was concealed from the victims through misleading statements, but rather that this Court was
technically incorrect about when the concealment began. Thus, Epstein argues (in bold face type)
that "nowhere in the record is there any evidence that Mr. Epstein's counsel, prior to September
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24, 2007, urged the government not to consult with [the victims] about the government's
intentions." Epstein Remedies Br. at 31 (emphasis reorganized).
The Court will immediately notice the hedged and negative proposition that Epstein
defends - i.e., Epstein does not argue that the Court's conclusion about concealment is somehow
incorrect but merely that no record evidence exists to prove the point. But record evidence
obviously demonstrates that Epstein and his lawyers signed the NPA, which itself provided that
"[t]he parties anticipate that this agreement will not be made part of any public record. If the
United States received a Freedom of Information Act request or any compulsory process
commanding the disclosure of the agreement, it will provide notice to Epstein before making that
disclosure." NPA at 13 (emphasis added). This Court noted this provision as part of its factual
findings. 359 F.Supp.3d at 1208. The NPA's plain language thus makes clear both that Epstein
knew the NPA was being concealed and, by requiring that notice go to him before disclosure, that
it was at Epstein's insistence that this provision is included. After all, the Government would have
no reason to bind itself to an undertaking to provide special notice to Epstein.
Perhaps recognizing that is difficult to contest that he sought the concealment provision,
Epstein quickly falls back to the position that his lawyers "never conditioned his agreement to the
NPA on non-disclosure to victims of the intended resolution." Epstein Remedies Br. at 31. To be
sure, it may be impossible to say exactly how the negotiations proceeded and what was a vital
"condition" for either side. Many of the important details were hammered out in unrecorded, face-
to-face meetings between prosecutors and defense attorneys. And for reasons that Epstein never
explains, his attorneys were discussing with prosecutors how to meet "off campus" to finalize the
agreement. See DE 361 at 14 (line prosecutor writes to defense counsel that "[m]aybe we can set
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a time to meet. If you want to meet 'off campus' somewhere, that is fine"). Indeed, the
documentary evidence in this case makes clear that at least one additional meeting was held off
campus between the Government and Epstein. Id.
But while the Court may never know precisely what Epstein "conditioned" his agreement
on, it is quite reasonable to conclude that Epstein was "seeking assurances" that the agreement
would not be disclosed - or, at the very least, not disclosed without an opportunity for him to
object. Indeed, the record makes clear that it was Epstein's lawyers who first asked about whether
the NPA would be made public. DE 361 at 15. And, as the NPA was being executed, defense
counsel followed up again with the line prosecutor, specifically requesting that she "do whatever
you can to keep [the NPA] from becoming public." 359 F.Supp.3d at 1207.
Moreover, even before the NPA was signed, uncontested documentary evidence shows that
Epstein was working to conceal what happened from the victims. For example, as the Court noted
in its findings, the line prosecutor and Epstein's counsel were working together to "avoid the
press." 359 F.Supp.3d at 1206. These documents pertain to events before the NPA was executed
on September 24, 2007, proving that Epstein's defense attorneys sought to have the NPA
concealed in advance of its signing. Given that concealment of the NPA necessarily meant that
the victims were being denied their right to confer, Epstein clearly became a party to the CVRA
violation even before the NPA was executed.
But it is hardly necessary to the Court's CVRA findings that Epstein have been involved
in concealing the NPA before it was signed. The NPA was not actually consummated until months
later, in June 2008. And by being party to - and surely instigator of - that extended concealment,
Epstein was responsible for the CVRA violations.
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If there is any doubt on this point, it only reinforces the victims' motion that it should
receive all records associated with the negotiations, including information about the Government's
deliberations. Given that both the Government and now Epstein are making representations about
what occurred during the negotiations, there is every reason for finding a waiver of work product
and other protections, and a compelling need for disclosing all documents about what happened.
See generally Jane Doe 1 and 2's Motion for Finding of Waiver of Work Product and Similar
Protections and for Production of Documents, DE 414 (currently pending before the Court per DE
464 at 14).³
Epstein also points to internal Justice Department regulations, arguing that they show that
the CVRA was technically inapplicable in this case. Epstein Remedies Br. at 21. But to the extent
that those guidelines failed to extend victims' rights during the pre-charging process, those
guidelines were simply illegal - as this Court ruled long ago. Does V. United States, 817 F.Supp.2d
1337, 1341 (S.D. Fla. 2011).
Epstein also fails to fully describe what the Justice Department regulations required the
Justice Department to do during the investigative stage of a case. The 2005 Attorney General
Guidelines for Victim and Witness Assistance (hereinafter "2005 A.G. Victim Guidelines"4) to
which he refers required the FBI to "provide the victim with the earliest possible notice concerning
the status of the investigation of the crime, to the extent that it is appropriate and will not interfere
3
In an effort to comply with the Court's scheduling order - and to provide consolidated
briefing - Jane Doe 1 and 2 have not filed a separately docketed motion for production of the
materials, instead explaining in their briefs the grounds for production. If the Court believes that
a separate motion is necessary to raise this issue, Jane Doe 1 and 2 would respectfully request
leave be permitted to rapidly file such a motion.
4 A full copy of the 2005 Guidelines is available in Justice Department archives at
https://www.justice.gov/sites/default/files/olp/docs/ag_guidelines2012.pdf.
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with the investigation." 2005 A.G. Victim Guidelines at p. 25, Part IV.A.3.a.3 (citing 42 U.S.C.
§ 10607(c)(3)A)⁵) (emphasis added)). Presumably, this requirement that the FBI keep victims
informed is why Epstein and the prosecutors were discussing meeting privately "off campus," as
a normal "on campus" meeting would have involved FBI agents and others Justice Department
employees (e.g., victim-witness coordinators) who would have been obligated by these regulations
to provide Epstein's victims with more information about what was happening.
Epstein also refers to a 2010 opinion of the Justice Department's Office of Legal (OLC),
which concluded that the CVRA did not extend rights until the filing of formal charges. Epstein
Remedies Br. at 32. Of course, the OLC opinion did not exist in 2007-08, when USAO-SDFL and
Epstein were concealing the NPA. Moreover, it is unsurprising to find that the Justice Department
would be staking out a very narrow (but unsupportable) position on its legal obligations under the
law. Cf. Paul G. Cassell, Nathanael J. Mitchell & Bradley J. Edwards, Applying the Crime Victims'
Rights Act Before Criminal Charges are Filed, 104 J. CRIM. L. & CRIMINOLOGY 59, 76-77 (2014)
("OLC's analysis is unpersuasive.").
But this debate over legal application of the CVRA in pre-charging situations is ultimately
wide of the mark as an attack on the Court's findings regarding the CVRA violation here. The
USAO-SDFL had made its own determination that the CVRA did, indeed, apply in this case - and
was telling victims that they had CVRA rights well before the NPA was ever signed. As this Court
has previously found, as early as March 2007, the USAO-SDFL sent official notices to Epstein
victims informing them that they had rights under the CVRA. For example, on about June 7, 2007,
5 This statute has since been superseded by other victim enactments and has accordingly
been repealed.
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FBI agents delivered a standard CVRA notification letter to Jane Doe 1. 359 F.Supp.2d at 1205.
In this letter, the USAO-SDFL promised that it would "make its 'best efforts' to protect Jane Doe
1's [CVRA] rights, including 'the reasonable right to confer with the attorney for the United States
in
the case Id. Jane Doe 1 "relied on those representations and believed that the government
would protect those rights and keep her informed about the progress of the case." Id. Nowhere in
his response does Epstein claim that his counsel were unaware of this approach.
This issue about the Justice Department's guidelines has already been evaluated by this
Court. As this Court explained in granting summary judgment:
Nor did the Justice Department guidelines create an exemption from the CRVA's
statutory requirements. Although the Government points to guidelines that
conflicted with the requirements of the CVRA (by restricting CVRA rights until
after a formal indictment), the Court is not persuaded that the guidelines were the
basis for the Government's decision to withhold information about the NPA from
the victims. If that had been the case, the Government would not have sent the
victim letters telling them that they had rights protected under the CVRA. Nor
would they have told Epstein's attorneys that it had obligations to notify the
victims. In any event, an agency's own "interpretation" of a statute cannot
supersede the language chosen by Congress." Mohasco Corp. V. Silver, 447 U.S.
807, 825 (1980).
Given that the USAO-SDFL had told the victims that the CVRA applied, it was obligated
to confer with them and treat them fairly. Epstein does not argue (much less provide evidence)
that his extensive legal team was unaware that the USAO-SDFL was following CVRA
requirements. Thus, the record fully supports the conclusion that, through his many lawyers,
Epstein was aware that the CVRA was in play and that, as a result of his pressure, the Government
was not conferring with his victims.
Even more important, Epstein cannot point to anything in Justice Department policy
requiring that a non-prosecution agreement be concealed from victims, much less permitting
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prosecutors to mislead victims. While Epstein claims that he was simply asking USAO-SDFL to
"follow its own national guidelines," Epstein Remedies Br. at 22, he was in fact asking for a clear
departure from standard procedures. Indeed, the USAO-SDFL has admitted that "Epstein's
counsel convinced the [Office] that (contrary to standard Government practice) Epstein should be
permitted to provide input into any message being delivered, and ultimately that the victims should
not be told anything 'until after Epstein pleas." DE 361 at 5-6 (citing Exhibit 25) (emphasis
added). And, as this Court has previously explained, "Particularly problematic was the
Government's decision to conceal the existence of the NPA and mislead the victims to believe that
federal prosecution was still a possibility. When the Government gives information to victims, it
cannot be misleading." 359 F.Supp.3d at 1219.
After the NPA was signed, Epstein concedes that he was involved in the notifications to
victims. Thus, Epstein points to a letter sent by his counsel, on December 6, 2007, indicating that
he did not object some form of notice being given to the alleged victims." Epstein Remedies Br.
at 32 (citing DE 403-15:3). But as even a quick glance that letter makes clear, the "form of notice"
that Epstein had in mind was very limited - indeed, Epstein's counsel was proposing that it merely
be sent by the State Attorney and presumably would not mention the federal non-prosecution
provisions. DE 403-15:3-4. Moreover, that same letter makes clear that Epstein was strenuously
seeking an opportunity to review victim notices from the government. Id. at 3. Accordingly, when
just a few weeks later the Government began circulating "misleading" notices, the record plainly
supports the conclusion that Epstein had seen and approved the notices - and Epstein advances no
argument (or evidence) to the contrary.
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Remarkably, despite all this evidence that Epstein was pressuring the USAO-SDFL not to
discharge its statutory obligation to confer with the victims, Epstein attempts to claim that "federal
law enforcement's decision to not [confer] with [the victims] was made, not for Mr. Epstein's
benefit, but rather to protect their own prosecutorial interests." Epstein Remedies Br. at 23. The
basis for this claim is selected excerpts from an affidavit of the line prosecutor. Id. (citing DE 403-
18). The fact that Epstein, joined by the USAO-SDFL, are both now using this affidavit discussing
internal deliberations of the Office only confirms that work product and other protections have
been waived over documents regarding those deliberations. See generally Jane Doe 1 and 2's
Motion for Finding of Waiver of Work Product and Similar Protections and for Production of
Documents, DE 414.⁶ Once again, the victims reassert their motion that they are entitled to see
those documents, to be in position to challenge the USAO-SDFL's arguments about benign
intentions - and now Epstein's similar claims. See DE 464 at 14 (reasserting DE 414).
Moreover, Epstein fails to fully discuss what the line prosecutor's affidavit essentially
admits. The affidavit only attempts to provide an explanation for failing to disclose the NPA's
financial compensation provisions. See, e.g., DE 403-19 at 10-11 9 21 (claiming that disclosure
would have subjected victims to cross-examination). But the affidavit never explains why the
most significant feature of the non-prosecution agreement was being concealed from the victims
- i.e., the fact that the agreement would lead to Epstein's non-prosecution. As a result, through its
6 Waiver by the Government is also further demonstrated by the press conference held by
then-Labor Secretary R. Alexander Acosta on July 10, 2019. Before the Washington press corps
and a global television audience, Acosta discussed the substance of the affidavit and deliberations
by the USAO-SDFL on the case. See https://www.c-span.org/video/?462479-1/labor-secretary-
defends-handling-epstein-plea-deal-amid-calls-resignation Indeed, the affidavit was part of the
"press packet" Acosta handed out.
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silence, the affidavit concedes what is glaringly obvious: That due to Epstein's pressure, the
USAO-SDFL was hiding from the victims that Epstein had already secured a signed agreement
providing immunity from federal prosecution in Florida to him (and all "potential co-conspirators"
for good measure).
This Court has already discussed the point, noting that, in January 2008, when the USAO-
SDFL sent notices to the victims counseling "patience," the Office "had bound itself to the terms
of the NPA unless Epstein failed to comply with the terms. It was a material omission for the
Government to suggest to the victims that they have patience relative to investigation about which
it had already bound itself not to prosecute." 359 F.Supp.3d at 1221. Obviously, the notices to
the victims could have been written differently to avoid a "material omission." But it was clearly
due to Epstein's efforts that the immunity provisions were being concealed to avoid a firestorm of
controversy that would have occurred if that fact was disclosed publicly.
2.
Evidence Exists that the Epstein Defense Team Acted in Bad Faith.
Epstein further asserts that the existing "record conclusively refutes any bad faith" on the
part of his counsel. Epstein Remedies Br. at 20. But the victims have also previously made well-
supported allegations of bad faith actions. In their summary judgment motion, for example, Jane
Doe 1 and 2 alleged that on February 1, 2007, the Epstein defense team sent a 24-page letter to the
Office, which "falsely stated: "Epstein did not know or believe any women were under 18 years of
age.' It also contained other deceptive factual and legal arguments about Epstein's culpability."
DE 361 at 10 (citing Exhibit 43) (emphasis added). Jane Doe 1 and 2 further alleged that, on July
6, 2007, Epstein's lawyers sent a 23-page letter to USAO-SDFL which "falsely claimed that 'Mr.
Epstein never targeted minors'
"
DE 361 at 11 (citing Exhibit 47) (emphasis added). Jane
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Doe 1 and 2 also alleged that Epstein's lawyers were discussing with the prosecutors a disposition
that would make it difficult for a judge to know what was really happening. DE 361 at 14 (citing
Exhibit 7). And Jane Doe 1 and 2 also alleged that Epstein and government lawyers were using
private, home e-mail address to conduct some of their discussions - and noted that no emails sent
to or from any home e-email addresses of prosecutors has every been produced. DE 361 at 15.
Jane Doe 1 and 2 reassert all of these thus-far uncontested factual claims and ask that the
Court accept them as part of deciding the basis for crafting an appropriate remedy. Epstein has
not challenged any of these facts proffered by Jane Doe 1 and 2. If Epstein wants this case to be
decided based on how his legal team acted, he needs to provide affidavits or other evidence of its
conduct - and he has not done so.
Even more significantly with regard to the alleged "bad faith" of Epstein's defense team is
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3.
The USAO-SDFL Was Not Authorized to Extend Epstein Immunity
Without First Conferring with his Victims.
Epstein also argues that the NPA is "a legal agreement." Epstein Remedies Br. at 25. By
this he apparently means that, if one looks merely at the four corners of the document, no provision
is, on its face, illegal. But as Jane Doe 1 and 2 have explained earlier, it is well accepted that a
contract or other agreement can be illegal based on the way in which it was formed. See Victims'
Remedy Reply to the Gov't, DE 464 at 27. Indeed, the Eleventh Circuit has clearly held that the
manner in which an agreement is formed can render an otherwise-valid agreement unenforceable.
In San Pedro V. United States, 79 F.3d 1065 (11th Cir. 1996), the Eleventh Circuit held that in
order for any provision in a plea agreement to be enforceable, "there must have been a valid,
binding agreement in the first instance Id. at 1068. In San Pedro, a defendant sought to
block a deportation proceeding by immigration authorities, arguing that a promise by prosecutors
of transactional immunity included a promise of nondeportation. Id. at 1067-68. In that case, as
in this one, it could have been argued that a promise of nondeportation was "a legal agreement."
But, nonetheless, the promise was unenforceable because, the Eleventh Circuit explained, the
prosecutor who made the commitment was not authorized to do so. Id. at 1070. In particular, "the
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United States Attorney and the AUSAs who negotiated the plea agreement with San Pedro did not
have the authority to promise that he would not be deported." Id. at 1072.
So too here. Prosecutors were simply not authorized to offer Epstein immunity until they
had conferred with Epstein's victims. Accordingly, the NPA's immunity provisions were not part
of a "valid, binding agreement in the first instance." 79 F.3d at 1068. And thus, Epstein is not
entitled to take advantage of the non-prosecution provisions, at least with respect to crimes against
Jane Doe 1 and 2 and any other victim who desires to have him prosecuted.
In their remedy briefing, Jane Doe 1 and 2 have asked for "partial" rescission of the
immunity provisions - that is, rescission of the immunity provisions for only those victims who
seek rescission. DE 464 at 17-30. In response, Epstein could have theoretically made an argument
for the NPA's "total rescission." Indeed, the victims have previously discussed this issue in
responding to the briefing of the USAO-SDFL, explaining that the Office itself lacked "standing"
to advance a request for total rescission. Id. at 30. The victims then explained that Epstein would
have standing to advance such a "total" rescission argument - if he wanted to. Id. And after this
briefing - explicitly noting that Epstein would need to advance such an argument for total
rescission - Epstein has not done so.
Presumably the reason that Epstein is not asking for total rescission of his NPA with the
USAO-SDFL is that it would eliminate what is reportedly his main defense to recent sex trafficking
charges in the Southern District of New York - that somehow an agreement with the U.S. Attorney
for the Southern District of Florida blocking prosecution in "this District" prevents federal
prosecutors in New York from prosecuting crimes committed there. But the Court need not reach
any conclusion about Epstein's motives for declining to ask for total rescission. In light of this
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sequence of events, Epstein has clearly waived any right to seek total rescission of the NPA. And
- as the victims predicted (DE 464 at 30-31) - the case as presented to this Court now boils down
to either upholding an illegal agreement or partially rescinding it.
Given the choice between the only two options presented to it (at least that this time¹²), this
Court's duty is clear. Congress has instructed that "[i]n any court proceeding involving an offense
against a crime victim, the court shall ensure that the crime victim is afforded the rights described
in [the CVRA]." 18 U.S.C. $ 3771(b)(1) (emphasis added). This Court also previously held that
"[w]hile Epstein was within his rights to attempt to persuade higher authorities with the
Department of Justice to overrule the prosecutorial decisions of the U.S. Attorney's Office in the
Southern District of Florida, the CVRA was designed to give victims the same opportunity to
attempt to affect prosecutorial decisions before they became final." 359 F.Supp.3d at 1221
(emphasis added). While the victims have asked for partial rescission to give them the "same
opportunity" that Epstein's high-powered legal team had to "attempt to affect prosecutorial
decisions" in this District, Epstein fails to provide any other alternative. Thus, partial rescission
of the NPA's immunity provisions is the only remedial option before the Court that comes close
to permitting the Court to discharge its obligation to "ensure" that victims are afforded their rights.
18 U.S.C. $ 3771(b)(1). It is only after rescission of the immunity provisions pertaining to them
that Jane Doe 1 and 2 will receive "the full unfettered exercise of their conferral rights at a time
that will enable [them] to exercise those rights meaningfully." DE 189 at 9 (citing U.S. V. BP
Products North America, Inc., 2008 WL 501321 at *14 (S.D. Tex. 2008)); see also Kenna V. United
12 Jane Doe 1 and 2 continue to assert their position that, if partial rescission is not possible
for some reason, then total rescission is required. DE 464 at 30-36.
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States District Court, 435 F.3d 1011, 1017 (9th Cir. 2006) (when trial court denied a victim his
right to give a statement at the defendant's sentencing, the trial court must be "cognizant that the
only way to give effect to [the victim's] right to speak
is to vacate the sentence and hold a new
sentencing hearing"). Any other conclusion would require the Court to approve the illegal bargain
struck by Epstein and the USAO-SDFL. After the passage of the CVRA, the Court is simply not
permitted to approve a violation of crime victims' rights.
II.
THE CVRA AUTHORIZES RESCISSION AS A REMEDY.
Intervenor Epstein next argues that the "CVRA itself" precludes a rescission remedy.
Epstein Remedies Br. at 27-33. The Court has already ruled to the contrary, and nothing in
Epstein's legal arguments should cause the Court to reverse course.
A.
The CVRA Authorizes Rescission as a Remedy.
Intervenor Epstein's first argument is a purely legal argument - that the CVRA's plain
language somehow restricts the Court from rescinding provisions in the NPA as a remedy in this
case. But Epstein's argument ultimately boils down to the proposition that a provision that
contains a limitation on a victim making "a motion to re-open a plea or sentence" (18 U.S.C. §
3771(d)(5) (emphasis added)) somehow restricts the ability of a victim to make a motion regarding
a right to confer regarding a non-prosecution agreement. To the contrary, as this Court has held,
the fact that the CVRA permits re-opening of pleas and sentences in some circumstances, fully
confirms that a non-prosecution agreement can likewise be reopened. Moreover, in attempting to
apply the limitations contained in $ 3771(d)(5), Epstein quickly produces a non-sequitur. The
limitations he cites apply during a court "proceeding" - i.e., the victim must have asserted "the
right to be heard before or during the proceeding at issue." An NPA can be drafted and signed
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before any "proceeding" is held. It is for this reason that the CVRA (as it existed in 2007-08¹³)
required an objection during a "proceeding" as a prerequisite to re-opening a plea or sentence -
but not for an NPA.
Moreover, distinguishing between a non-prosecution agreement (negotiated outside of the
court processes) and "plea" and "sentence" makes considerable sense. As this Court explained,
an "NPA entered into without notice has a more damaging impact on victims than a plea agreement
entered into without notice. When a plea agreement is entered into without notice, the victim will
at least have an opportunity to provide input to a judge at sentencing. Once an NPA is entered into
without notice, the matter is closed and the victims have no opportunity to be heard regarding any
aspect of the case." 359 F.Supp.3d at 1220 n.7 (emphasis added).
Unable to provide a logical explanation for his position, Epstein claims that two CVRA
appellate decisions support him. But both decisions dealt with a separate issue - whether crime
victims seeking to overturn a district court decision denying enforcement of their rights in appellate
courts had to shoulder the heavy burden traditionally associated with the "mandamus" relief. See
U.S. V. Monzel, 641 F.3d 58, 532-33 (D.C. Cir. 2011) (discussing 18 U.S.C. § 3771(d)(3) and
holding crime victims had to satisfy high mandamus standards); United States V. Hunter, 548 F.3d
1308, 1315 (10th Cir. 2008) (same). Interestingly, Congress has since essentially overruled both
of those decisions. See 18 U.S.C. § 3771(d)(3) (2015 amendment) (making clear that crime victims
13 Aware of the Government and Epstein's secret maneuvering in this case, in 2015
Congress amended the CVRA in order to codify this Court's earlier rulings here and ensure that
victims received timely notice of any NPA. 18 U.S.C. $ 3771(a)(9). In codifying this right, it
would be hard to imagine that Congress wanted to create for victims a hollow right - one that
could never be enforced in any way - which is the logical implication of Epstein's position.
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need only satisfy "ordinary" standards of appellate review). But, in any event, these decisions
discussing appellate issues provide no useful guidance here.
B.
The Victims Are Not Time-Barred Under the CVRA.
Intervenor Epstein also argues that rescission relief is somehow "time-barred." Epstein
Remedies Br. at 40. Epstein relies upon a provision in the CVRA that states that "[t]he district
court shall take up and decide any motion asserting a victim's right forthwith." DE 463 at 40
(citing 18 U.S.C. § 3771(d)(3) (emphasis added)). Epstein, however, has waived any right to
complain about delay in this case. The Court will recall that back in 2013, Epstein and his lawyers
tried to assert an alleged "plea negotiation" privilege over various documents. After this Court
denied their assertion (DE 188) - and denied their motion for a stay pending appeal (DE 206) -
Epstein and his lawyers succeeded in obtaining an Eleventh Circuit stay of proceedings in this case
for months. They represented to the Eleventh Circuit that "[t]here will be no prejudice to [the
victims] from waiting until an appellate court can address the critically important issues at stake
here." Motion for Stay Pending Appeal, Jane Does V. United States, No. 13-12923 (11th Cir. July
12, 2013). Having declined to raise - either with this Court or the appellate court - any need for
a "forthwith" ruling then, Epstein cannot belatedly raise such a claim years later.
In any event, relief in this case is not time barred. The CVRA's provision requiring this
Court to "take up and decide any motion asserting a victim's right forthwith," 18 U.S.C. $
3771(d)(3), is undoubtedly designed to ensure that victims can obtain immediate relief when they
need it. For example, if a trial is taking place without the presence of the victim, a victim might
require immediate relief, as otherwise any opportunity for the victim to attend might permanently
disappear. Cf. 18 U.S.C. $ 3771(d)(5) (a victim cannot obtain the remedy of a "new trial").
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In this case, this Court acted expeditiously and did take up and decide Jane Doe 1 petition
(later joined by Jane Doe 2) within just four days of its filing. On July 7, 2008, when counsel for
Jane Doe 1 began to learn that a secret, non-prosecution agreement might be in the works, they
filed an "emergency" petition for enforcement of the Crime Victims' Rights Act. DE 1. Two days
later, on July 9, 2008, the USAO-SDFL responded. And just two days later, on the morning of
July 11, 2008, this Court held a hearing.
During the hearing, victims' counsel discussed what he understood to be a plea deal of
some sort that was then under negotiation. As counsel explained: "it is my understanding and
belief that the agreement with the federal government and with the U.S. Attorney's Office wasn't
signed on that day [i.e., June 30, 2008]. So it is still my belief, I could be wrong, but that that
agreement hasn't been completed as of this time." See Tr. (July 11, 2008) at 5-6 (emphasis added).
Victims' counsel went on to say that, if the Court were make the assumption that an agreement
had already been reached, then the Court should "[o]rder that the agreement that was negotiated is
invalid and it is illegal as it did not pertain to [or uphold] the rights of the victim[s]." Id. at 6.
Thereafter, the Government disclosed that it had, in fact, reached a secret agreement with Epstein
months earlier. Id. at 8.
Victims counsel then pushed to have the agreement invalidated. The Court explored the
posture of the case, deciding that the issues no longer required any "emergency" treatment because
Epstein had entered into the NPA long ago:
THE COURT: In view of the fact that this agreement has already been
consummated, and you want me to set it aside, as opposed to something that's about
to occur, would you agree that-- and I have done this very quickly because of the
petition and your allegation that something was about to happen. I'm not blaming
you.
MR. EDWARDS: I was mistaken.
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THE COURT: I'm not blaming you for doing that. In view of what you
know now, is there any need to treat this as an emergency that has to be decided by
tomorrow?
MR. EDWARDS: I can't think of any reason in light of what we just heard
[i.e., that the NPA had been signed eight or nine months earlier].
THE COURT: Mr. Lee, do you have anything else you wanted to add? Does
either side think I need to take evidence about anything? If I do, since this is not an
emergency anymore, I can probably find a more convenient time to do that. I don't
have the time today to take evidence. But if you do believe that I should take
evidence on this issue.
MR. EDWARDS: It may be best if I conferred with the U.S. Attorney's
Office on that and we can make a decision whether it is necessary or whether Your
Honor deemed it was necessary for you to make a decision.
THE COURT: I want to know what your respective positions are because it
may be something in terms of having a complete record, and this is going to be an
issue that's is going to go to the Eleventh Circuit, [it] may be better to have a
complete record as to what your position is and the government's is as to what
actions were taken.
And because it is not an emergency, I don't have to do
something quickly, we can play it by ear and make this into a more complete record
for the court of appeals.
See Tr. (July 11, 2008) at 25-26.
As this recitation of events makes clear, the Court fully discharged its duty to "take up and
decide" a victim's motion "forthwith." Acting quickly, the Court held a hearing less than four
days after the petition was filed and decided, with the agreement of both parties to the action (i.e.,
Jane Doe 1 and 2 and the USAO-SDFL) that the appropriate course of action was to develop a full
evidentiary record of the events surrounding the NPA and whether the victims were entitled to
invalidation of the agreement secretly reached months earlier.
Given his vast resources, Epstein was likely aware that all this was happening that same
day. In any event, the record is clear that the USAO-SDFL quickly notified Epstein of these
proceedings, because disclosure of Epstein's then-secret NPA was involved. Id. at 30. As noted
above, the NPA directly provided that, if the USAO-SDFL was going to disclose the agreement,
it was required to "provide notice to Epstein before making that disclosure." NPA at p. 5 9 13.
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So if Epstein had thought that, after July 11, 2008, some quicker resolution of the matter was
required, he was certainly free to press this point. He made no such argument - which must be
regarded as a deliberate waiver of any right to a more rapid decision that he may have had. To be
sure, Epstein was serving his jail sentence at that time. But issues surrounding unwinding a
sentence were always going to exist in this case after Epstein pled guilty on June 30, 2008, because
his jail sentence started then. Having these issues decided more quickly was something that
Epstein could have sought - but did not.
After setting an initial hearing within four days of the petition's filing, the Court continued
move this case along, setting a hearing on August 25, 2008, to resolve the issue of whether the
NPA would be turned over to the victims. During the hearing, the USAO-SDFL put on the record
that they had notified Epstein of the proceedings. Tr. (Aug. 25, 2008) at 8. Epstein, however, did
not ask to formally participate in the hearing. Nor did he ask to have the issues under litigation -
including potential invalidation of the NPA - be decided more rapidly. The Court made further
decisions about how best to proceed, including ordering disclosure of the secret NPA to the
victims. 14
Thereafter, of course, extended litigation has ensued in this case. A good summary of the
events between August 2008 and October 2010 is found in Docket Entry 41, in which Jane Doe 1
and 2 explained that during the summer of 2008, they had been told by the Government that it
would work with the victims to put together an agreed stipulation of facts. The victims then
14 During the hearing, victims' counsel speculated that rescission of the NPA might not be
in the victims' best interests. DE 27 at 4. Of course, that statement was made before counsel had
even seen the entire NPA - and after the document's release, counsel moved forward seeking
rescission.
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provided a set of facts, after which the Government reversed course and decided that it did not
want to discuss what had happened. See DE 41 at 2-3 (citing DE 19 at 2). Because of the
Government's decision not to work with Jane Doe 1 and 2 to develop a factual record, the victims
had to attempt to secure that information from other sources - an effort that proved to be an arduous
process. DE 41 at 3. Ultimately, on June 30, 2010, Jane Doe 1 and 2 were able to secure some
correspondence between Epstein and the Government regarding the NPA's negotiation -
correspondence proving that there "had been an orchestrated decision to deny them their rights."
DE 41 at 1; see also DE 39 at 3-4. And thereafter in this case, the USAO-SDFL (and Epstein in
some instances) proceeded to raise one objection after another, producing years of delay.
While Epstein was obviously aware of this case - and that the ultimate objective was
(among other things) invalidation of the NPA - he did not move to intervene in the case until
September 2, 2011 (DE 93), and even then he sought only "limited" intervention with regard to
remedy.
In arguing that relief for the victims is now somehow "time-barred," Epstein refers to the
effects of "missing a deadline." DE 463 at 42. In this case, the victims have missed no deadline.
As soon as they had an inkling about a secret plea deal, Jane Doe 1 and 2 filed an emergency
petition for review. And this Court has missed no deadline. It held a hearing on the initial petition
in less than four days and took up and decided how the victims' petition would be handled.
Thereafter, the proceedings unfolded in accordance with scheduling sought by the two parties.
And Epstein has never raised a peep about any of this scheduling - until his filing two weeks ago.
Moreover, it is more than a little ironic to see Epstein complaining that issues regarding
the NPA have not been resolved more quickly. Of course, it was Epstein himself who set in motion
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all the events designed to keep the NPA concealed from the victims. If he had not persuaded the
Government to deviate from its standard practice of keeping victims fully informed, all the issues
surrounding the NPA could have been presented before he pled guilty in state court. Of course, it
was precisely to keep that court - and the victims - from learning about the NPA that Epstein
arranged to have the NPA shrouded in secrecy. Any passage of time in litigating these issues is
directly attributable to Epstein's maneuverings.
Finally, even if the Court were to conclude that somehow the "forthwith" deadline in this
case had been missed, that fact would not allow it to refuse to enforce Jane Doe 1 and 2's CVRA
rights now. The U.S. Supreme Court has explored a similar question of a missed deadline in
connection with restitution for crime victims. Dolan V. United States, 560 U.S. 605 (2010),
involved the effect of a district court missing a 90-day deadline for awarding restitution. Dolan
held that the restitution statute's primary purpose was "to ensure that victims of a crime receive
full restitution." Id. at 612. In setting a 90-day requirement, "the statute seeks speed primarily to
help the victims of crime and only secondarily to help the defendant." Id. at 613.
Of course, in this case, precisely the same focus on victims exists. Naturally, the purpose
of the Crime Victims' Rights Act is to help crime victims. And the reason Congress required that
rulings should be "forthwith" was to help victims. As Senator Kyl explained, "[t]he enforcement
provisions of this bill ensure that never again are victim's rights provided in word but not in
reality." 150 Cong. Rec. S4260-01 (Apr. 22, 2004). It would invert the purposes of the statute to
allow a criminal like Epstein to take advantage of a "forthwith" enforcement provision added to
help victims. And, indeed, the CVRA blocks his attempt, providing that "[a] person accused of
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the crime may not obtain any form of relief under this chapter." 18 U.S.C. $ 3771(d)(1) (emphasis
added).
Finally, to the extent that the "forthwith" provision has some application to Epstein, he
could have brought that claim to the attention of this Court long ago. As the Supreme Court noted
in connection with the 90-day requirement in Dolan, a defendant who is worried about the need
for prompt action "can usually avoid additional delay simply by pointing to the statute and asking
the court to grant a timely hearing." 560 U.S. at 616. The same thing is true in this case. Epstein
could have, at any time, simply pointed to the "forthwith" provision and asked for a quick hearing.
He did not do so. As in Dolan, reading the CVRA to require Epstein to have raise this argument
imposes on him only a "small cost" relative "to the prospect of depriving innocent crime victims"
of their CVRA rights. Id.
III.
PRINCIPLES OF CONTRACT LAW SUPPORT A RESCISSION REMEDY.
Intervenor Epstein next argues that "principles of contract law" preclude a rescission
remedy to enforce the victims' CVRA rights. Epstein's Remedy Br. at 33-36. The USAO-SDFL
had raised a similar contract law argument and, to avoid duplicative briefing, Jane Doe 1 and 2
simply incorporate by reference their previous responses. DE 464 at 19-26. But a few additional
words are appropriate in response to Epstein's specific claims.
A.
Under the CVRA, Contract Law Principles Require Rescission.
Epstein begins by citing a series of Florida state law cases. Epstein Remedies Br. at 33-
34. But Epstein never provides the legal predicate for his argument - that is, why this Court should
decide this case under Florida contact law. To the contrary, this case is controlled by an Act of
Congress, setting out federally protected rights for crime victims. In the Crime Victims' Rights
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Act, Congress has directed that this Court "shall ensure" that victims' CVRA rights are fully
protected. 18 U.S.C. $ 3771(b)(1). Even if Florida contract law were to the contrary (a point Jane
Doe 1 and Jane Doe 2 disprove below), the only way this Court can "ensure" the protection of Jane
Doe 1 and 2's right to confer about prosecuting Epstein's (and his coconspirators') sex crimes in
the Southern District of Florida is to rescind the immunity provisions. As this Court has explained,
rescission of these provision is required so that the victims can have "the full unfettered exercise
of their conferral rights at a time that will enable the victims to exercise those rights meaningfully."
DE 189 at 9.
Congress did not expect that victims' rights might be stripped away through contract law
principles. To the contrary, as Senator Kyl explained, "it is the clear intent and expectation of
Congress that the district
courts will establish procedures that will allow for a prompt
adjudication of any issues regarding the assertion of a victim's right, while giving meaning to the
rights we establish." 150 Cong. Rec. 22953 (Oct. 9, 2004) (statement of Sen. Kyl) (emphases
added). Accordingly, this Court's remedial task is not to ensure that the NPA conforms to ill-
defined contract law "principles" but rather to give meaning to the rights of victims to confer with
the USAO-SDFL. To put it bluntly, a congressional command simply takes precedence over any
"principles" of contract law that Epstein can cite.
But if anything, standard contract law principles support Jane Doe 1 and 2's request for a
rescission remedy. This Court has held that "[p]ublic policy empowers this Court to decline
enforcement of a contract" that is contrary to law. Neiman V. Provident Life & Accident Ins. Co.,
217 F.Supp.2d 1281, 1286 (S.D. Fla. 2002) (citing United Paperworkers Int'l Union V. Misco,
Inc., 484 U.S. 29, 42 (1987)). Thus, as this Court has explained, under "Florida law, a contract
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that violates public policy is void and unenforceable." Neiman, 217 F.Supp.2d at 1286 (citing
Harris V. Gonzalez, M.D., 789 So.2d 405, 409 (Fla. 4th DCA 2001)).
Here, the Court would violate "public policy" - indeed, an Act of Congress, i.e., the Crime
Victims' Rights Act, 18 U.S.C. $ 3771 - to uphold the NPA's immunity provisions, which prevent
the victims from being able to exercise their CVRA right to confer with the USAO-SDFL. The
public policy Congress announced in the CVRA invalidates practices whereby victims "were kept
in the dark by prosecutors too busy to care
and by a court system that simply did not have place
for them." 150 Cong Rec. 7296 (April 22, 2004) (statement of Sen. Feinstein). The CVRA
demands that the Court award a rescission remedy in response to the prosecutors and Epstein
keeping the victims "in the dark."
Intervenor Epstein complains that a rescission remedy would violate contract law, because
rescission does not restore him to the "status quo." Epstein Remedies Br. at 34. After all, Epstein
notes, he has now served his jail time under the agreement. Id. But it can equally be said that not
imposing a rescission remedy fails to restore Jane Doe 1 and 2 to the "status quo" to which they
were entitled. Under the CVRA, they were entitled to confer with the prosecutors before any
immunity deal was struck with Epstein. The Court is thus faced with a choice - it can either protect
Epstein's (illegally obtained) immunity deal; or it can give Jane Doe 1 and 2 (and other victims)
the CVRA rights Congress has conferred on them. This Court must act to protect the statutorily
protected rights of victims rather than ill-defined "principles" of contract law that Epstein finds
useful.
Epstein also contends that a rescission remedy is akin to "reformation of a contract,"
Epstein Remedies Br. at 45, and thus must "conform" to the intention of the parties to the NPA.
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But, of course, the NPA was affirmatively concealed from the victims. It is precisely because the
NPA was clandestine that this Court must now rescind its immunity provisions. It was never the
intention of the victims to extend immunity to Epstein. Thus, reformation principles are
inapplicable.
Epstein also rattles the sword that a rescission remedy would somehow imperil financial
payments that he has previously made to his victims under the NPA. Epstein Remedies Br. at 34-
35. Many victims - including Jane Doe 1 and 2 - did not receive any financial benefits from the
NPA. Instead, they negotiated other financial terms without relying on the NPA. So, Epstein
would have no basis for seeking return of any moneys he paid them. But even with regard to
victims who relied on the financial provisions of the NPA, the "partial" rescission remedy that
Jane Doe 1 and 2 seek would not call into question Epstein's payments. The NPA's financial
provisions can only be invalidated if someone asks for them to be invalidated. Jane Doe 1 and 2
have not asked for that remedy. And neither did the USAO-SDFL, who would in any event lack
"standing" to make such a request. See DE 464 at 27-28. Intervenor Epstein is the only party to
the NPA who could ask for total rescission of the agreement - and he has declined to do. 15 Thus,
as noted above, the Court's choice is between either (1) affirming an illegal agreement or (2)
rescinding provisions that block certain victims from being able to exercise their CVRA rights -
the partial rescission remedy Jane Doe 1 and 2 lay out. Between those two choices, the Court must
clearly act to protect the victims. Cf. Neiman, 217 F.Supp.2d at 1286 (refusing to enforce contract
provision where doing so "would validate a
[provision] founded in illegality").
15 Epstein does refer, at one point, to the "government's view" that financial payments
might be placed at risk through a rescission remedy. Epstein Remedies Br. at 35. But he never
adopts that argument or ask this Court to adopt a "total rescission" remedy.
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Once again, this conclusion is required by binding Eleventh Circuit case law. The Eleventh
Circuit has instructed that in order for any provision in a plea agreement to be enforceable, "there
must have been a valid, binding agreement in the first instance " San Pedro V. United States,
79 F.3d 1065, 1068 (11th Cir. 1996). In this case, with respect to the NPA's immunity provisions,
there never was a "valid, binding" agreement because the USAO-SDFL was not lawfully able to
offer such an agreement. Under the CVRA, it had to first confer with the victims.
On the other hand, with regard to the NPA's financial provisions, there was a "valid,
binding" agreement that obligated Epstein to make payments to those victims who want the
payment provisions enforced. The USAO-SDFL and Epstein were free to agree on those particular
terms. And, to the extent contract law is relevant, there would clearly be consideration supporting
those terms, since under the partial rescission that Jane Doe 1 and 2 propose, Epstein would still
continue to have the right to immunity from prosecution in the Southern District of Florida for any
victim who declined to ask for a rescission remedy. 16 As a result, "consideration" for the contract
(e.g., the NPA) would still exist, because something of value would exist for both sides. See
RESTATEMENT (SECOND) OF CONTRACTS $ 79.¹⁷
16 This argument assumes only that at least one of the dozens and dozens of Epstein Florida
victims would not seek rescission of the immunity provision connected with her case. In the
unlikely event that all of Epstein's victims unanimously demand rescission, then a different
circumstance might arise. The Court could address those circumstances if they ever occurred.
17 It may also be the case that Epstein retains some "consideration" for his NPA, because
the statute of limitations may have now expired on some of the crimes covered by his NPA. The
Court need not reach that issue, however, because other consideration exists. And Epstein's most
serious crimes covered by the NPA - specifically, the sex trafficking charges - are not time barred,
due to congressional extensions of the statutes of limitations. See 18 U.S.C. § 3299
("Notwithstanding any other law, an indictment may be found at any time without limitation
for any
felony under chapter 109A, 110 (except for section[s] 2257 and 2257A), or 117, or
section 1591")).
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Epstein also suggests that, if a partial rescission remedy is awarded, then he would be free
to raise a "collateral attack" on his state court guilty plea. Epstein Remedies Br. at 46. Of course,
whether he would be successful in doing so is dubious. Florida state courts take a dim view of
belated challenges to guilty pleas. See, e.g., Guzman-Aviles V. State, 226 So. 3d 339, 346 (Fla. 5th
DCA 2017) ("Every inroad on the concept of finality undermines confidence in the integrity of
our procedure
The impact is greatest when new grounds for setting aside guilty pleas are
approved because the vast majority of criminal convictions result from such pleas. Moreover, the
concern that unfair procedures may have resulted in the conviction of an innocent defendant is
only rarely raised by a petition to set aside a guilty plea."). But any collateral attack would
ultimately be an issue for the Florida state courts - not this Court. The only issue for this Court is
whether to enforce the CVRA - and Congress has commanded that it must. 18 U.S.C. §
3771(b)(1). And after rescission, given that prosecuting sex trafficking is a high priority of the
Justice Department, we assume that the USAO-SDFL would quickly prosecute Epstein in this
District on serious federal sex trafficking charges - charges that the victims could help explain to
the prosecutors. DE 464 at 33-34.
Epstein also argues that "the NPA is not a divisible agreement." Epstein Remedies Br. at
46. But the NPA provision he cites does not say that. Instead, it simply provides that each of the
NPA's provisions is "material" to the agreement and is supported "by independent consideration."
NPA at p. 6. If Epstein had wanted an "indivisible" NPA (whatever that may mean), he was free
to bargain for one. But nothing in the NPA's language provides that it is "indivisible."
In any event, Jane Doe 1 and 2 are not arguing that the NPA is some sort of "divisible"
agreement. Rather, their position is that the NPA's immunity provisions are unenforceable and
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must be rescinded. Epstein argues that the immunity provisions must be specifically enforced.
But Florida law recognizes that "[s]pecific performance [of a contract] will be denied when the
rights of innocent third parties have intervened so that enforcement of the contract would be harsh,
oppressive, or unjust to them." Seaboard Oil Co. V. Donovan, 99 Fla. 1296, 1306, 128 So. 821,
825 (1930) (citing 6 POMEROY EQUITY JURISPRUDENCE, § 794). Obviously, it is unjust to Jane
Doe 1 and 2 to enforce immunity provisions in the NPA depriving them of congressionally
guaranteed rights.
Finally, Epstein never specifically asks this Court to rule that the NPA is "indivisible" and
therefore must be declared void in its entirely. As noted above, the reason that Epstein has chosen
not to ask for the NPA to be declared totally invalid is obvious - he apparently intends to try to
use the NPA's immunity provisions in the Southern District of New York. 18 But the key point
remains that Epstein has waived any opportunity to ask for total rescission. The Court accordingly
must choose between no rescission and partial rescission. The CVRA commands a choice in favor
of the victims.
B.
The Civil Releases Signed by Jane Doe 1 and 2 Did Not - and Could Not -
Waive their CVRA Claims Against the Government.
Intervenor Epstein next contends that Jane Doe 1 and 2 have somehow signed releases in
a civil case that bar a rescission remedy in this criminal case. Epstein Remedies Br. at 37-38. His
argument is specious.
18 Equally obvious are the reasons why Epstein has declined to have the financial
compensation provisions declared invalid. Doing so would expose him to compensatory and
punitive damages claims that, for each victim, would be worth tens of millions of dollars. See DE
464 at 34.
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Epstein points to civil releases signed by Jane Doe 1 and 2 that resolved their civil cases
against Epstein. The terms of those releases plainly do not cover this case against the Government,
seeking to enforce their rights in a criminal investigation. As Epstein's own exhibits makes clear,
the release covers only claims for "compensatory or punitive damages":
[Jane Doe] individually, and Jeffrey Epstein, individually (jointly referred
to as "Parties"), enter into this Settlement Agreement and General Release
("Settlement Agreement") in order to resolve the pending litigation against them as
follows:
2. General Release. [Jane Doe] and her agent(s), attorney(s),
predecessor(s), successor(s) heir(s), administrator(s), and/or assign(s) (hereinafter
"First Parties"), for and in consideration of the sum of [redacted] and other valuable
consideration, received from or on behalf of Jeffrey Epstein and his agent(s),
attorney(s), predecessor(s), successor(s), heir(s), administrator(s), assign(s) and/or
employee(s) (hereinafter, "Second Parties"), the receipt whereof is hereby
acknowledge,
HEREBY remise, release, acquit, satisfy, and forever discharge the said
Second Parties and any other person or entity would could have been included as a
potential defendant ("Other Potential Defendants") from all, and all manner of,
action and actions of [Jane Doe], including State or Federal, cause and causes of
action (common law or statutory), suits, debts, dues, sum of money, accounts,
reckoning, bonds, bills, specialties, covenants, contracts, controversies,
agreements, promises, variances, trespasses, damages, judgments, executions,
claims, and demands whatsoever in law or in equity for compensatory or punitive
damages that said First Parties ever had or now have, or that any personal
representative, successor, heir, or assign of said First Parties hereafter can, shall, or
may have, against Jeffrey Epstein, or Other Potential Defendants, for, upon, or by
reason of any matter, cause, or thing whatsoever (whether or known or unknown),
from the beginning of the world to the day of this release.
DE 463-4. While the release is lengthy, what is being released is clear: claims "for compensatory
or punitive damages" against Epstein. Of course, this CVRA action does not seek any civil
"damages" against Epstein (or anyone else, for that matter). Accordingly, the release's plain
language makes clear it is inapplicable to this case.
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It is troubling that, in discussing this release, Epstein chooses to use ellipses to conceal the
critical language about the release being limited to "compensatory or punitive damages." Thus, in
Epstein's recounting of the tale, the general releases encompassed all "claims, and demands
whatsoever in law or in equity for, upon, or by reasons of any matter, cause or thing whatsoever
(whether known or unknown), from the beginning of the world to the day of this release." Epstein
Remedies Br. at 47 (ellipses in original). Notice the ellipses - which remove the pivotal
"compensatory or punitive damages" language. The Court should not permit such misleading
briefing to carry the day. Cf. Loeffel Steel Prod., Inc. V. Delta Brands, Inc., 387 F. Supp. 2d 794,
823 (N.D. III. 2005) ("ellipses are not a cure for misquotation and indeed are often the vehicle for
misleading. See Posner, OVERCOMING LAW, 277 (1995) ("Beware a [lawyer] bearing ellipses.")).
This CVRA rights enforcement action does not involve any claim for damages - much less,
a claim for damages against Epstein.¹⁹ As Jane Doe 1 and 2 made clear in their initial remedies
submission, they "are aware, of course, that the CVRA provides that it does not "authorize a cause
of action for damages.' 18 U.S.C. § 3771(d)(6). Accordingly, Jane Doe 1 and 2 are not seeking
'damages' under the CVRA DE 458 at 30 (emphasis added).
Even if the this case is somehow interpreted to involve "damages," Florida courts have
made clear that exculpatory clauses are only "enforceable where the intention to be relieved from
liability was made clear and unequivocal and the wording was so clear and understandable that an
ordinary and knowledgeable person will know what he or she is contracting away." Sanislo V.
19 The release also extends to "Other Potential Defendants," defined as any "other person
or entity would could have been included as a potential defendant" in the Jane Does lawsuit
alleging sex abuse. Obviously, the United States was a not sex abuser and could not have been
included in the lawsuit against Epstein.
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Give Kids the World, Inc., 157 So.3d 256, 260-61 (Fla. 2015); see also Fresnedo V. Porky's Gym
III, Inc., 271 So. 3d 1185, 1186 (Fla. 3d DCA 2019) (releases "that purport to deny an injured
party the right to recover damages from another who negligently causes injury are strictly
construed against the party seeking to be relieved of liability"); Diodato V. Islamorada Asset
Mgmt., Inc., 138 So.3d 513, 517 (Fla. 3d DCA 2014) (reiterating the "well-settled principle that
[exculpatory] clauses are disfavored and are narrowly construed").
As the beginning of the settlement agreement makes clear, "[Jane Doe] individually, and
Jeffrey Epstein, individually (jointly referred to as "Parties"), enter into this Settlement Agreement
and General Release ("Settlement Agreement") in order to resolve the pending litigation against
them
Of course, this CVRA case is not litigation between Jane Doe 1 and 2 and Epstein, but
rather was (and is) styled as Jane Doe 1 and 2 V. United States. Thus, in the summer of 2010,
Epstein was not a party to the CVRA case. He was not even an intervenor at that time. The general
release that Jane Doe 1 and 2 entered into with Epstein did not apply - much less "clearly and
unambiguously" apply - to this CVRA case against the United States.
Confirming this understanding is the fact that, shortly after the civil cases settled, Jane Doe
1 and 2 filed a statement with this Court explaining that the settlements of civil cases with Epstein
in no way affected this CVRA action against the United States:
The fact that Jane Doe #1 and Jane Doe #2 have settled their civil cases against sex
offender Jeffrey Epstein in no way affects their determination to move forward with
the above-captioned CVRA action against a different entity - the U.S. Attorney's
Office for the Southern District of Florida. For reasons explained in their earlier
pleadings, that Office grossly violated their rights under the Act. The fact that
Epstein has settled with Jane Doe #1 and #2 to resolve his civil liability in no way
exonerates the U.S. Attorney's Office for its failure to discharge its responsibilities
under the Act.
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DE 39 at 2. Epstein never argued that this statement was inaccurate, presumably because he knew
that was what the parties had agreed to. At the time of the settlements, Epstein was well aware of
the CVRA action against the United States. He chose not to attempt to include that case in the
release.
For all these reasons, it is unambiguously clear that the civil release of their "damages"
claims against Epstein does not bar Jane Doe 1 and 2 from proceeding with their CVRA claim
against the United States, seeking to vindicate their CVRA rights. Indeed, even if the release had
dismissed CVRA claims, such a provision would have been void as against public policy. Any
such CVRA release would let a wealthy defendant (like Epstein²⁰) buy his way out of prison. The
CVRA applies only to criminal cases. Affluent criminal defendants should not be able to, first,
illegally conceal an NPA in violation of crime victims' rights and then, second, simply payoff
victims to avoid having justice done.
Of course, that is not what happened in this case - as the releases to which Epstein refers
simply do not cover the CVRA case. But even if they did, they would be obviously contrary to
clearly announced public policy and unenforceable. As this Court has held, under "Florida law, a
contract that violates public policy is void and unenforceable." Neiman V. Provident Life &
Accident Ins. Co., 217 F.Supp.2d 1281, 1286 (S.D. Fla. 2002) (citing Harris V. Gonzalez, M.D.,
789 So.2d 405, 409 (Fla. 4th DCA 2001)). Public policy in Florida (and elsewhere) favors the
20 According to financial information recently filed in the Southern District of New York,
Epstein "is extraordinarily wealthy, and he owns and maintains luxury properties and residences
around the world, including in Manhattan, New York; Palm Beach, Florida; Stanley, New Mexico;
and Paris, France." Letter from Gov't Regarding Bail, U.S. V. Epstein, No. 19-cr-490-RMB, DE
11 (S.D.N.Y. July 8, 2019).
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reporting of crimes - particularly crimes involving vulnerable child sex abuse victims. See, e.g.,
Valladares V. Bank of Am. Corp., 197 So.3d 1, 10 (Fla. 2016) ("Private citizens should be
encouraged to become interested and involved in bringing the perpetrators of crime to justice
."). And, of course, Congress can articulate public policy. The articulated public policy in the
CVRA is that this Court "shall ensure" that crime victims receive their rights. 18 U.S.C. §
3771(b)(1). Construing the civil releases the way that Epstein would, obviously violates that
announced policy of protecting crime victims and promoting prosecution of dangerous criminals.
IV.
THE DOCTRINES OF EQUITABLE AND JUDICIAL ESTOPPEL ARE
INAPPLICABLE.
Next, convicted sex offender Epstein asks that Court rule against his sex abuse victims
under the "doctrine" of equitable and judicial estoppel. Epstein Remedies Br. at 39-43. Epstein
claims that Jane Doe 1 and 2 sought to enforce the terms of the NPA against him and, accordingly,
"[p]rinciples of equitable and judicial estoppel" now somehow preclude them from enforcing the
CVRA rights. Id. at 40. Epstein's estoppel arguments are meritless. 21
A. Jane Doe 1 and 2 Have Not Violated Any CVRA Requirement in Handling Their
Petition.
Intervenor Epstein's first argument is hinges on the fact that the CVRA requires a judicial
decision on a CVRA motion "forthwith." See id. at 40 (citing 18 U.S.C. $ 3771(d)(3)). Epstein
repeats his earlier argument, as discussed in Section II.B, supra, that Jane Doe 1 and 2 failed to
obtain a decision "forthwith." But as discussed above, the "forthwith" requirement was fully
satisfied in this case. The victims initially sought "emergency" relief and then this Court took
21 It bears emphasizing that the USAO-SDFL has not raised any estoppel arguments. See
DE 464 at 67-68.
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expeditious action in less than four days on the victims' motion. The CVRA contains no further
time requirements, so the notion that victims somehow deviated from CVRA requirements is
untrue. And, in any event, even assuming some sort of violation of the "forthwith" provision,
Epstein is precluded from taking advantage of it. The CVRA itself provides that "[a] person
accused of the crime may not obtain any form of relief under this chapter." 18 U.S.C. $ 3771(d)(1)
(emphasis added).
Moreover, Epstein seems to suggest that the victims somehow, as he puts it, "stymied the
operation of the CVRA." Epstein Remedies Br. at 40. But it was, of course, Epstein and the
USAO-SDFL who, in the first instance, "stymied" the CVRA by illegally concealing their NPA.
Since then, it has been a long and hard road for the victims - and the Court - to fully expose what
happened. But that Epstein succeeded in keeping the truth concealed for so long provides no basis
for withholding relief, particularly on alleged grounds of "equity."
B. Congress Has Not Added Doctrines of Estoppel to the CVRA.
Intervenor Epstein next resorts to what he describes as "doctrines" of "equitable" and
"judicial" estoppel. These doctrines will be of some interest to courts sitting in equity. But this
CVRA enforcement action is not an occasion where the Court is free to craft its own equitable
rules restricting the CVRA.
In the CVRA, Congress specifically directed that, when crime victims' issues come before
a court, "the court shall ensure that the crime victim is afforded the rights described in [the
CVRA]." 18 U.S.C. $ 3771(b) (emphasis added). That mandatory language gives no room for the
Court to ignore violations of crime victims' rights based on ill-defined notions of "estoppel." As
the CVRA's legislative history makes clear, "It is not the intent of this bill that its significance be
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whittled down or marginalized by the courts " 150 Cong. Rec. S4260-01 (Apr. 22, 2004)
(statement of CVRA co-sponsor, Sen. Feinstein). Allowing a CVRA violation to go unremedied
merely because a criminal can point to other competing estoppel considerations could not merely
"whittle down" the CVRA but completely destroy its effectiveness in some cases.
Controlling case law makes clear then when construing a remedial scheme for enforcement
of congressionally created rights, the courts must give "appropriate judicial deference toward the
will of Congress Hardison V. Cohen, 375 F.3d 1262, 1264 (11th Cir. 2004) (internal quotation
omitted). Congress is "in a better position to decide whether or not the public interest would be
served" by expansive or narrow remedies. Id. at 1264. Indeed, where Congress has created a
substantive right, the generally rule is that such a right "is not subject to equitable tolling or
equitable estoppel." Fulghum V. Embarq Corp., 785 F.3d 395, 416 (10th Cir.), cert. denied,
136 S. Ct. 537 (2015). If notions of, for example, equitable estoppel are to become part of the
CVRA, that choice is for Congress - not the courts.
Moreover, if the Court is going to read into the CVRA doctrines of estoppel, it must also
read in related defenses - such as the doctrine of "unclean hands." It is well-established that "[o]ne
defense to the equitable claim of estoppel is the doctrine of "unclean hands.' Bird V. Centennial
Ins. Co., 11 F.3d 228, 234 (1st Cir. 1993) (citing Peabody Gas & Oil Co. V. Standard Oil Co., 284
Mass. 87, 187 N.E. 112, 113 (1933) ("[O]ne must come into a court of equity with clean hands in
order to secure relief....")). Thus, "equity requires that those seeking its protection shall have acted
fairly and without fraud or deceit as to the controversy in issue." Ellenburg V. Brockway, Inc., 763
F.2d 1091, 1097 (9th Cir. 1985) (citing Johnson V. Yellow Cab Transit Co., 321 U.S. 383, 387
(1944)). Here, Epstein - a sex offender who worked with the USAO-SDFL to illegally conceal an
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NPA from minor sex abuse victims - has unclean hands for multiple and obvious reasons - and
thus is barred from raising estoppel arguments.
C.
Epstein Has Failed to Satisfy the Elements of the Equitable Estoppel
Doctrine.
In any event, even if some sort of equitable estoppel "doctrine" applied here, Epstein's
equitable estoppel argument is meritless. Equitable estoppel precludes challenging a document
only where that party "rel[ies] on the terms of the written agreement in asserting [her] claims." MS
Dealer Service Corp. V. Franklin, 177 F.3d 942, 947 (11th Cir. 1999). Here, of course, Jane Doe
1 and 2 did not "rely" on the NPA's terms to establish a CVRA violation - in fact, they were
challenging the terms. Thus, the basic elements of equitable estoppel are simply not in play.
Moreover, because equitable estoppel requires close assessment of all relevant
circumstances, it is important to understand the very limited reference the victims made to
Epstein's NPA in their civil lawsuits. Jane Doe 1 and 2 filed their civil lawsuits in about September
2008, only after their CVRA petition had been filed - and had succeeded in forcing the USAO-
SDFL to disclose the previously secret NPA. The victims' civil lawsuits briefly alleged that
Epstein had agreed that he had sexually abused the various victims and was therefore estopped
from denying the abuse. See DE 401-2 at 24 (quoting complaint). Of course, in September 2008,
the CVRA petition had already been filed - but had not yet been finally decided, much less decided
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in their favor. Accordingly, the victims (acting through legal counsel) could only speculate as to
the ultimate outcome of this CVRA case and had to preserve all possible arguments in their civil
suit. But simply preserving a claim is not the same thing as actually prevailing on a claim - a
necessary predicate for equitable estoppel. Ultimately, the civil suits that Epstein refers to were
settled before trial and Epstein does not argue that any dispositive rulings were made against him
based on the NPA.
Any other conclusion would convert the equitable estoppel doctrine from one having
limited scope to one having sweeping implications. Frequently litigants in the early stages of
litigation must, to preserve their rights, assert multiple arguments that might ultimately prove to
be inconsistent with positions either taken in the same case or in other litigation. It is only when a
party actually receives a court ruling based on a particular predicate that estoppel issues even begin
to come in to play. If the victims had obtained money from Epstein based on a court ruling that he
was estopped from contesting liability to them by the NPA, then conceivably some of the
prerequisites for equitable estoppel would have been in place. But until the victims moved for -
and received - such a ruling, they did nothing more than preserve their rights by simply listing all
possible arguments in their complaint.
Preserving arguments is commonplace in modern litigation - not some basis for precluding
later arguments. A plaintiff, for example, may allege in a complaint that she was harmed by either
Defendant A or Defendant B - to be sorted out after further discovery. Or a defendant may allege
that he did not harm the plaintiff but, if he did, the damages were only minimal. These are not
occasions for equitable estoppel to apply, but simply the routine assertion of potentially diverging
legal positions that protect the rights of a party. It would hardly be equitable to preclude parties,
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who in early stages of court proceedings raises all possible arguments, to somehow later become
"estopped" from selecting among them.
D.
Epstein Has Failed to Satisfy the Elements of the Judicial Estoppel Doctrine.
Intervenor Epstein also contends that the doctrine of "judicial estoppel" applies, blocking
the victims from challenging the NPA. Epstein Remedies Br. at 41-42. Once again, his argument
is meritless.
For starters, for all the reasons just explained that Epstein's reliance on equitable estoppel
doctrine fails, his judicial estoppel argument likewise fails. For example, the decision of whether
to allow a doctrine of judicial estoppel to provide a basis for declining to enforce CVRA's rights
is for Congress, not the courts. In addition, Epstein has "unclean hands" and cannot raise an
argument sounding in equity.
Remarkably, Epstein seeks to rely on this doctrine even though, under Eleventh Circuit
caselaw, one of the foundational elements for applying the doctrine is proof of "a party's success
in convincing a court of the earlier position, so that judicial acceptance of the inconsistent later
position would create the perception that either the earlier or later court was misled." Tampa Bay
Water V. HDR Engineering, Inc., 731 F.3d 1171, 1182 1th Cir. 2013)). In this case, even treating
the filing of a civil court complaint as an earlier "proceeding," Epstein does not even attempt to
argue that Jane Doe 1 and 2 had "success" in convincing the courts that Epstein was estopped from
contesting liability. The reason for this is that the victims never reached the point in the civil
proceedings of making that argument against Epstein - much less, having success by winning the
argument. Indeed, Epstein vigorously defended liability in those cases. The reason Epstein was
able to fully contest liability is that the NPA created such a limited remedy for Epstein's victims
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that it was, for all practical purposes, meaningless. Jane Doe 1 and 2 never sought summary
judgment based on the NPA and instead looked forward to fully trying their cases.
The relevant provision in the NPA is paragraph 9, which provided that if a victim elected
to sue Epstein exclusively under 18 U.S.C. $ 2255, Epstein agreed not to contest liability - "so
long as the [victim] agrees to waive any other claim for damages, whether pursuant to state, federal,
or common law." The practical effect of this provision was to cap the victims' claims against
Epstein to no more than $150,000 (or, Epstein argued, no more than $50,000), the statutory
maximum under $ 2255. Given the horrific abuse that Epstein inflicted on his child sex abuse
victims, this cap meant that the NPA was essentially meaningless for many of the victims -
including Jane Doe 1 and Jane Doe 2, who were unwilling to waive all other claims for damages
and thus had to proceed entirely apart from the NPA to obtain appropriate damages. The victims
thus never had "success" relying on the NPA's provisions - but could only have success by
escaping from the limits on liability that the Government had agreed to with the sex offender they
were pursuing.
The Supreme Court has clearly held "[a]bsent success in a prior proceeding, a party's later
inconsistent position introduces no risk of inconsistent court determinations and thus poses little
threat to judicial integrity." New Hampshire V. Maine, 532 U.S. 742, 750-51 (2001). The victims
never had "success" in arguing that Epstein was estopped from denying that he has abused the
victims. Indeed, to the contrary, the victims pressed an argument that they were not limited to
seeking damages under the NPA. Judicial estoppel is not applicable to this course of events.
Citing a bankruptcy case, Epstein concedes the principles of judicial estoppel are very
limited. Indeed, Epstein admits that, in bankruptcy proceedings, the Eleventh Circuit "employs a
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two-part test to guide district courts in applying judicial estoppel: whether (1) the party took an
inconsistent position under oath in a separate proceeding, and (2) these inconsistent positions were
calculated to make a mockery of the judicial system." Slater V. United States Steel Corp. 871 F.3d
1174, 1181 (11th Cir. 2017) (internal quotation omitted).
It should be remembered that Jane Doe 1 and 2 were confronting unprecedented secrecy
and violation of a congressional statute in trying to determine how to proceed. But Epstein gamely
argues that Jane Doe 1 and 2 made "a mockery of the judicial system [by] trying to convince one
court to rule in their favor based on the binding validity of the NPA and then trying to convince
this Court that the NPA was an "illegal agreement." Epstein Remedies Br. at 52. Epstein never
cites that specific document or argument in which Jane Doe 1 or 2 tried to somehow "convince
one court to rule in their favor" based on the NPA - and, indeed, this Court in fact had an essentially
identical case in front of it during the entire time where no such actions took place. See Doe V.
Epstein, 9:08-cv-80893-KAM (S.D. Fla. 2009-10). The reason that Epstein is unable to cite any
such example is that no such reliance on the NPA ever happened. For example, Jane Doe 1 and 2
never moved for summary judgment on liability in their civil cases - they were looking forward
to ultimately trying their case to a jury. And when they tried their cases to a jury, the victims
intended to call witnesses and fully prove that Epstein had sexually abused them - and then to seek
compensatory and punitive damages far in excess of what the NPA provided. No reliance on the
NPA ever existed, much less the kind of improper behavior that would make a "mockery" of the
system. Cf. Slater, 871 F.3d at 1178 (discussing deliberate concealment of claims from a
bankruptcy court).
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Moreover, all of the actions in the CVRA case and the civil cases took place in public
judicial proceedings in which Epstein was represented by a battery of lawyers. It "is difficult to
impute an intent 'to make a mockery of the judicial system' where the complaining party was
aware of the inconsistency in sufficient time and in a position to properly raise an objection in the
original proceeding." Ajaka V. Brooksamerica Mortg. Corp., 453 F.3d 1339, 1345 (11th Cir.
2006). Here, Epstein and the Government was well aware of both this CVRA action and the related
civil suits. There is no concealment or unfairness that are the hallmarks for applying judicial
estoppel. Cf. Burnes V. Pemco Aeroplex, Inc., 291 F.3d 1282 (11th Cir. 2002) (applying doctrine
in circumstances showing deliberate concealment of assets).
Instead of presenting evidence (such as a court ruling) that Jane Doe 1 and 2 had "success"
in relying on the NPA's provisions, Epstein appeals vaguely to the notion that Jane Doe 1 and 2
"reaped for themselves the financial benefits of the NPA
" Epstein's Remedies Br. at 42.
What benefits? Jane Doe 1 and 2 settled their civil cases - and obtained benefits entirely apart
from the NPA. The circumstances in which judicial estoppel would even potentially be in play
did not occur.
V.
ALLEGED PRINCIPLES OF "SUBSTANTIVE DUE PROCESS" DO NOT
PRECLUDE RESCISSION REMEDIES.
As his fifth argument against giving Jane Doe 1 and 2 their rights, Intervenor Epstein
contends it would violate "principles of substantive due process" to rescind the NPA's immunity
provisions. Epstein Remedies Br. at 43-45. In making his argument, Epstein cites run of the mill
cases in which the issue is interpretation of a plea agreement. Of course, the Government must
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generally abide by promises that it makes in such agreements. See, e.g., United States V. Hill, 643
F.3d 807, 874 (11th Cir. 2011) (analyzing scope of government promises in a plea agreement).
But as the Eleventh Circuit (and other courts) have made clear, this general rule that the
Government is bound by plea provisions is subject to qualifications. The key case on this point is
the Eleventh Circuit's decision in San Pedro V. United States, 79 F.3d 1065 (11th Cir. 1996), cited
previously by Jane Doe 1 and 2 but not discussed by Epstein. San Pedro explains that: "[T]he
general rule requiring governmental adherence to promises made during plea negotiations is
subject to two conditions. First, the agent making the promise must be authorized to do so, and
second, the defendant must detrimentally rely on the promise. If either condition is lacking, then
the agreement is unenforceable
San Pedro V. United States, 79 F.3d 1065, 1068 (11th Cir.
1996); see also United States V. Kachkar, No. 16-20595-CR, 2018 WL 6974948 at *2 (S.D. Fla.
2018), report and recommendation adopted, No. 16-20595-CR, 2019 WL 116864 (S.D. Fla. 2019)
(following San Pedro).
Here, of course, in adopting the CVRA Congress directed that prosecutors must reasonably
"confer" with the victim in a criminal case before making a binding resolution. 18 U.S.C. §
3771(a)(5). Prosecutors lack authority to deviate from this congressional command - and thus (at
least on the facts of this case) lacked "actual authority to make" a promise of immunity without
conferring with victims. San Pedro, 795 F.3d at 1068. The word "authority" means "[t]he official
right or permission to act, esp. to act legally on another's behalf " BLACK'S LAW DICTIONARY
158 (10th ed. 2014) (emphasis added). Here, as the Court has previously found (without challenge
from Epstein) "once the Government failed to advise the victims about its intention to enter into
the NPA, a violation of the CVRA occurred." 359 F.Supp.3d at 1221. In other words, the
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Government was no longer acting legally - and simply did not have authority to extend immunity
to Epstein.
The facts of San Pedro offer clear parallels to this case. There, the prosecutor offered a
promise of non-deportation to criminal defendant San Pedro. The Eleventh Circuit concluded that
this agreement was unenforceable, because by statute the power to enforce immigration laws rested
with the Immigration and Naturalization Service. Id. (citing 8 U.S.C. $ 1103(a)).
Here, Congress has also placed statutory limitations on the power of prosecutors,
specifically the USAO-SDFL - requiring it to follow the law. The statute establishing the duties
of the Office of U.S. Attorney provides that "[e]xcept as otherwise provided by law, each United
States attorney, within his district, shall
prosecute for all offenses against the United States
28 U.S. § 547 (emphasis added). Thus, here the USAO-SDFL had authority to make prosecutorial
decisions about this District but had to proceed as "provided by law." See 28 U.S. § 547. One law -
the CVRA - required the USAO-SDFL to confer with victims before extending Epstein's immunity
offer. Because that was not done - a fact that Epstein well knew, and indeed had sought - the USAO-
SDFL was without authority to extend the secret immunity offer.
The fact that Epstein was represented by a multitude of high-powered lawyers is also relevant.
"This case does not involve any government overreaching by taking advantage of an unsophisticated
defendant." United States V. Friedland, 83 F.3d 1531, 1539 (3d Cir. 1996). Instead, Epstein and the
USAO-SDFL sought to maneuver around the statutory commands of the CVRA. Now that their
maneuver has failed, Epstein is not entitled to take advantage of his illegal agreement.
This conclusion follows even if the Court were to proceed on the assumption (contrary to the
facts of this case) that Epstein's legal team had no knowledge whatsoever that the Government was
violating its CVRA obligations. A helpful case is United States V. Walker, 98 F.3d 944 (7th Cir. 1996).
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There, the Seventh Circuit refused to enforce a provision in a plea agreement where "the parties'
bargain was founded on a mutual misunderstanding of the legal consequences of the bargain.
Alternatively and equivalently, it is a case in which the bargain is vitiated by illegality - an attempt to
attach an unauthorized consequence to an inappropriate order." Id. at 946. Even assuming arguendo
that this case simply involves Epstein and the USAO-SDFL reaching an agreement based on a "mutual
misunderstanding," the fact remains that the NPA continues to be "vitiated by illegality" and this Court
cannot attach any effect to the improper agreement.
In response to Walker, Epstein calls the Seventh Circuit's ruling an "entirely confused"
decision. Epstein Remedies Br. at 25. But the Seventh Circuit simply followed standard principles
that a court must follow the law when interpreting plea agreements. Indeed, numerous cases hold that
such agreements are unenforceable when they deviate from legal requirements. See, e.g., Craig V.
People, 986 P.2d 951, 959-60 (Colo. 1999) (court cannot enforce a plea agreement that waives the
mandatory parole period); State V. Garcia, 582 N.W.2d 879, 881-82 (Minn. 1998) (plea agreement
promised a sentence that did not contain the statutorily-required 10-year conditional release term);
State V. Wall, 348 N.C. 671, 675-76 (1998) (holding that court cannot enforce a plea agreement for
concurrent sentence where law mandated consecutive one); Ex parte Rich, 194 S.W.3d 508, 515 (Tex.
Crim. App. 2006) (court cannot enforce an illegal sentence below the statutory range); State V.
Mazzone, 212 W.Va. 368, 374 (2002) (court would not enforce plea agreement that called for court to
unlawfully sentence the defendant by treating two misdemeanor offenses as felony offenses).
Epstein acknowledges this long line of cases but claims that they are all distinguishable because
they stand for the proposition that "a court cannot enforce facially invalid plea agreements that contain
illegal terms or omit the required components of a sentence." Epstein Remedies Br. at 26. Epstein's
concession effectively gives away the game. Epstein never explains why the principles expressed in
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these cases should be limited to "facially" invalid agreement. Here this Court has held that the NPA
was reached in violation of congressional command, which equally renders it plainly illegal - and thus
unenforceable.
Craig V. People, 986 P.2d 951 (Colo. 1999), for example, explains that when "the parties
attempt to fashion a sentence that is itself contrary to law, the resulting illegality is not subject to
specific enforcement." Id. at 959. Here, Epstein and the USAO-SDFL attempted to "fashion" an NPA
that was "contrary to law" - because it was reached without the congressionally required conferral with
Epstein's victims.
Similarly, State V. Wall, 348 N.C. 671 1998), holds that the defendant was not entitled to
specific performance of a plea agreement to receive a concurrent sentence, because "such action would
violate the laws of this state." Id. at 676. So too here. To allow Epstein to obtain specific performance
of the secret NPA would "violate the laws of this" country - i.e., the Crime Victims' Rights Act.
Directly contrary to Epstein's theory that "facial invalidity" only applies to the specific terms
of an agreement is Ex parte Rich, 194 S.W.3d 508 (Tex. Crim. App. 2006). There, the Court refused
specific performance of an illegal arrangement, explaining that "[a]lthough the plea bargain seemed
fair on its face when executed, it has become unenforceable due to circumstances beyond the control
of the Applicant or the State, namely the fact that one of the enhancement paragraphs was
mischaracterized in the indictment, resulting in an illegal sentence far outside the statutory range of
punishment." Id. at 515. Here, even if it could be argued that the NPA was "fair on its face," the fact
is that it is now unenforceable due to the fact that the victims were never given their CVRA right to
confer. Indeed, in Ex parte Rich, the court refused to enforce the plea agreement "due to circumstances
beyond the control" of the defendant and the State. Id. Here, of course, the resulting "circumstances"
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(i.e., non-conferral with the victims) were entirely within the control Epstein and USAO-SDFL - and,
in fact, were something that they conspired together to achieve.
Epstein further argues that he should not be held accountable for what he describes as "[t]he
government's failure to comply with its obligations to third parties." Epstein Remedies Br. at 45.
The Court would be faced with a more difficult question if Epstein had actually understood that
the Government was fully complying with its conferral obligations but had simply dropped the
ball. The situation here is entirely different. It was both the Government and Epstein who worked
together assiduously to hide the ball from the victims. Against that backdrop, no "inequities" (id.)
would result from rescinding the NPA's immunity provisions. Epstein chose to arrange for an
illegal deal - he is not entitled to reap the benefits of that illegality.
Finally, Epstein also refers to his alleged "full performance" of his obligations under the
NPA. Id. But that fact has recently been called into doubt by the ruling denying Epstein bail in
the criminal case proceeding before the U.S. District Court for the Southern District of New York.
See Decision and Order Remanding Defendant, DE 32 at 19-20, U.S. V. Epstein, No. 1:19-cr-490-
RMB (S.D.N.Y. July 18, 2019) (finding that "Mr. Epstein has not always been compliant with his
legal obligations as a registered sex offender"). As the Court noted there, Epstein's counsel
claimed that Epstein has been "scrupulously fulfill[ing] his obligations in every jurisdiction in
which he was required to register [as a sex offender]" since his 2008 Florida convictions." Id. at
19. But it appears that Epstein has not been compliant, for example, in New York. See id. at 20
(noting that, notwithstanding a New York judge's order imposing a sex offender reporting
requirement, according to an investigative report Epstein "has never reported as a sex offender to
New York law enforcement"); see also id. at 21 (noting lack of information from Epstein's counsel
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demonstrating proper sex offender registration in New Mexico, Florida, and the Virgin Islands).
These facts further undercut any claim by Epstein to being able to rely on the NPA.
VI.
SEPARATION OF POWERS DOES NOT PREVENT THE COURT FROM
EXERCISING ITS STATUTORY POWER TO ENFORCE THE CVRA.
Intervenor Epstein next argues that the rescission remedy would somehow interfere with
separation of powers. Epstein Remedies Br. at 46-49. But Epstein lacks standing to assert
interference with Executive prerogatives. The USAO-SDFL has been actively engaged in this
litigation and has filed dozens of pleadings. Any issues regarding interference with the Executive
branch have, no doubt, been properly advanced by that Office - and Epstein is simply an interloper
who is not free to kibitz on constitutional issues regarding separation of powers. The federal courts
are "not empowered to seek out and strike down any governmental act that they deem to be
repugnant to the Constitution. Rather, federal courts sit 'solely, to decide on the rights of
individuals." Hein V. Freedom from Religion Found., Inc., 551 U.S. 587, 598 (2007) (Alito, J.)
(citing Marbury V. Madison, 1 Cranch 137, 170, 2 L.Ed. 60 (1803)). Epstein does not have a
"right" to separation of powers.
Second, as discussed above in connection with the statutory authority of the U.S.
Attorney's Offices, Congress is entitled to pass laws establishing rights for crime victims. To our
knowledge, no litigant - and certainly not Epstein - has ever argued that the CVRA's extension of
rights to victims unconstitutionally intrudes on executive power. Indeed, this Court has already
explained why the CVRA does not interfere with prosecutorial discretion: "The Government
correctly notes that the CVRA provides that '[n]othing in this chapter shall be construed to impair
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the prosecutorial discretion of the Attorney General or any officer under his direction.' 18 U.S.C.A.
§ 3771(d)(6). The Court is not ruling that the decision not to prosecute was improper. The Court
is simply ruling that, under the facts of this case, there was a violation of the victims' rights under
the CVRA." 359 F.Supp.3d at 1222. The Court would say exactly the same thing in providing
the victims a rescission remedy. The Court would not be ruling that the immunity provisions were
"improper." The Court would simply say that, under the facts of this case, the provisions have to
be rescinded because they were adopted in violation of the victims' CVRA rights.
This Court's ruling to that effect would not "thrust the Court into the role of prosecutor and
negotiator Epstein Remedies Br. at 47. Instead, the Court would simply be performing the
task that Congress assigned to it by directing that district courts "shall ensure" that victims receive
their CVRA rights. 18 U.S.C. § 3771(b)(1). Once the immunity provisions have been rescinded,
the victims would confer with the USAO-SDFL and then the prosecutors would be free to proceed
as they saw fit. Ensuring that victims receive their procedural CVRA rights in no way intrudes
on substantive decisions by prosecutors.
To be sure, judicial authority is limited "when reviewing the Executive's exercise of
discretion over charging determinations." United States V. Fokker Servs. B.V., 818 F.3d 733, 741
(D.C. Cir. 2016). But Jane Doe 1 and 2 are not asking this Court to review any prosecutor's
ultimate charging determination; all the victims seek is that they have their promised opportunity
to "confer" with the prosecutors about what that determination should be. Thus, in enforcing the
victims' rights, the Court would not be "rejecting the deal agreed to by the parties." Epstein
Remedies' Br. at 49. It would simply be enforcing the victims' right to be involved in shaping that
deal. As this Court has held, "the CVRA was designed to give the victims the same opportunity
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to attempt to affect prosecutorial decisions before they became final" as defendants have. 359
F.Supp.3d at 1221. Enforcing that congressional decision is well within judicial authority.
VII. THE VICTIMS' REQUEST FOR DECLARATORY RELIEF (REMEDY #2)
IMMEDIATELY BECOMES RIPE UPON THE GRANTING OF A RESCISSION
(REMEDY #1).
Intervenor Epstein next argues that, even if the Court grants rescission (remedy #1), it
would be premature for this Court to rule on whether the Constitution would permit his prosecution
(remedy #2). Epstein Remedies Br. at 49. Epstein claims that such a ruling is precluded by the
"ripeness" doctrine, which on closer examination turns out to involve a claim that no "case or
controversy" would exist for such a determination. Id. at 50.
If the Court grants rescission (remedy #1), the issue of declaratory relief (remedy #2)
immediately becomes ripe. Specifically, unless this Court declares that it is permissible for the
USAO-SDFL to prosecute Epstein, it will not be giving Epstein's victims "the same opportunity
[as Epstein had] to attempt to affect prosecutorial decisions before they became final." 359
F.Supp.3d at 1221. See generally Victims' Resp. to Government Remedies Submission at 35-37.
Without such a declaration, the Jane Does would not be put back in the same position as they
would have been had the Government complied with the CVRA.
But, in any event, given the way that briefing has proceeded in this case, this request
(remedy #2) is now largely subsumed by the way in which Epstein has advanced his arguments
against rescission. If the Court reviews and rejects all of Epstein's arguments (as we believe it
should), then the victims would largely receive the declaratory relief that they need. Epstein
obviously believes that he is entitled to obtain a ruling on all of his constitutional arguments
advanced here. And Epstein has presented a wide array of constitutional and separation of powers
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arguments against the rescission remedy. See, e.g., Epstein Remedies Br. at 14-27 (arguing that
"procedural due process" precludes rescission); id. at 43-46 (arguing that "substantive due
process" precludes rescission); id. at 46-49 (arguing that separation of powers precludes
rescission). A Court ruling that, in spite of these constitutional arguments, rescission is nonetheless
appropriate would appear to sweep away most of the constitutional barriers that the victims have
been concerned about.
Accordingly, for remedy #2, the victims simply ask the Court to reach - and reject - all of
Epstein's constitutional claims. Following a court decision to that effect, the victims could then
approach the Court if any constitutional issues remained at that time that were improperly
impeding their ability to confer.
VIII. THE COURT IS AUTHORIZED TO HOLD A PUBLIC HEARING WITH THE
VICTIMS IN THIS CASE.
Jane Doe 1 and 2 have requested that the Court hold a hearing in this case, at which time
they could address the Court - and Epstein and prosecutors - about this case. DE 464 at 46-49.
The Government responded by agreeing that a court hearing was appropriate but suggesting a
slightly different format than the victims. DE 462 at 7. Jane Doe 1 and 2 have replied to the
Government, continuing to agree with the Government that a hearing is appropriate but reaffirming
their request (for example) that Epstein and former-U.S. Attorney Acosta attend the hearing. DE
464 at 46-49.²²
22 Since the filing of that brief by the victims, Secretary Acosta has decided to resign his
position as Labor Secretary. But during his press conference on July 10 on the topic of the NPA,
Acosta stated that he might be willing, at some point, to "circle back" with the victims to discuss
his handling of the case so as to be "more transparent." On July 15, counsel for Jane Doe 1 and 2
sent a letter to Acosta, advising him of the hearing that the victims and his prior Office was
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Now Epstein has weighed in, claiming that the Court has "no authority" under the CVRA
to preside over such a hearing. But, to the contrary, the CVRA provides enforcement powers to
district courts to enforce the CVRA. 18 U.S.C. § 3771(b)(1). And contrary to Epstein's
suggestion, there is clearly a "case or controversy" as to how to best provide the victims their
CVRA rights. In the unusual circumstances that exist in this case, where even the Government
concedes no remedy (rescission or otherwise) can fully put the victims back in the position that
they would have been had the Government properly conferred in 2007, this Court clearly has power
to act. As Senator Kyl explained, "it is the clear intent and expectation of Congress that the district
courts will establish procedures that will allow for a prompt adjudication of any issues
regarding the assertion of a victim's right, while giving meaning to the rights we establish." 150
Cong. Rec. 22953 (Oct. 9, 2004) (statement of Sen. Kyl) (emphases added). A hearing of the kind
that the victims - and the Government -propose is an appropriate way to give at least some
meaning to important CVRA rights.
IX.
ADOPTION OF EARLIER PLEADINGS BY REFERENCE
Jane Doe 1 and 2 have also advanced numerous arguments in other filings that defeat
Epstein's claims. To avoid duplicative briefing, Jane Doe 1 adopt by reference, in response to
Epstein, all of the arguments they have advanced in DE 458 and DE 464.
X.
THE COURT SHOULD EXPEDITE ITS RULING ON REMEDIES AND ON THE
VICTIMS' RIGHTS TO BE TREATED WITH FAIRNESS AND TO NOTICE.
At this time, all of the briefing that the Court requested in its scheduling order (DE 454)
has been completed. Accordingly, all the matters discussed in this submission are ripe for decision.
proposing and asking whether he would voluntarily attend the hearing. Jane Doe 1 and 2 have yet
to receive any response to the letter.
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Jane Doe 1 and 2 continue to request a rapid ruling on remedies by this Court. 23 Any delay
in ruling could further compound the damage that has already been done to Epstein's Florida
victims by denying them an opportunity to meaningfully confer about federal charges being filed
in this District - particularly given recent and on-going developments in New York that, while
independent of this case, may make it more difficult for Jane Doe 1 and 2 to seek prosecution here.
Jane Doe 1 and 2 also have pending before the Court two additional arguments as why the
CVRA has been violated - specifically, that their rights to be treated with fairness and to notice
have been violated. See DE 458 at 33. As previously explained, the Government has not
challenged that the Court should hold that these two rights have been violated. DE 464 at 15. And,
likewise, Epstein has not made any argument to the contrary. (He does not even cite the right to
fairness in his brief.) Accordingly, the Court should summarily find that these rights have also
been violated. After such a ruling, Jane Doe 1 and 2 would respectfully respect the opportunity to
provide additional briefing on what additional remedies would then become available to them.
Their existing briefing on remedies, of course, has been confined to explaining what remedies the
Court should award based on its existing findings. The Court would have more expansive remedial
powers based on more expansive findings of CVRA violations.
23 To be clear, having previously discussed the issue with the Court and seen the Court's
approach to resolving the pending issues, Jane Doe 1 and 2 are not seeking a jury trial on any
aspect of this case. With regard to crafting remedies for the violation of their right to confer, the
Court should exercise its remedial power. And with regard to the victims' still-pending claims that
there has been a violation of their rights to be treated with fairness and to notice, the Court can
make the necessary factual determinations to decide the matters.
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But none of these other possibilities should prevent the Court from moving forward rapidly
with the issues that are fully briefed and squarely before it now. The victims request that the
Court rule as rapidly as possible.
XI.
REQUEST FOR A HEARING (IF NECESSARY).
If the Court requires any further factual predicate from Jane Doe 1 and 2 in response to
Epstein's arguments, they request a hearing and opportunity to provide that predicate to the Court.
CONCLUSION
Intervenor Epstein set in motion a plan whereby he joined with the USAO-SDFL to reach
a secret non-prosecution agreement - and then to have it put it in place without the victims having
any opportunity to object. That plan to keep the victims in the dark was patently illegal under the
CVRA. And the plan was in service of keeping a deal secret that could never have survived public
or judicial scrutiny.
This Court has now held that the Government's illegal actions, undertaken at Epstein's
specific request, violated Jane Doe 1 and 2's rights under the Crime Victims' Rights Act. And the
Court now possesses ample power to respond to this deliberate attempt to keep innocent victims
uncertain about why multiple federal sex crimes against them were to go unpunished. The Court
should accordingly grant Jane Doe 1 and Jane Doe 2 all the remedies they have requested,
including rescission of the NPA's "immunity" provisions precluding prosecution of Epstein and
his co-conspirators for federal sex crimes committed in the Southern District of Florida.
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DATED: July 23, 2019
Respectfully Submitted,
/s/ Bradley I. Edwards
Bradley J. Edwards
Edwards Pottinger LP
Paul G. Cassell
Pro Hac Vice
Attorneys for Jane Does 1 and 2
* This daytime business address is provided for identification and correspondence purposes
only and is not intended to imply institutional endorsement by the University of Utah.
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CERTIFICATE OF SERVICE
I certify that the foregoing document was served on July 23, 2019, on counsel of record using
the Court's CM/ECF system:
U.S. Attorneys' Office for the Northern District of Georgia
Attorneys for the Government
Roy Eric Black
Jacqueline Perczek
Black Srebnick Kornspan & Stumpf
Attorneys for Jeffrey Epstein
67
EFTA00022615


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From:
To:
Subject: Final Voucher 11062816(1) prepared by a travel arranger is pending your review
Date: Mon, 24 Feb 2020 19:41:02 +0000
Importance: Normal
Dear
Final voucher 11062816(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 11062816
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13401 - Epstein Investigation - Witness interview
Destination: Pensacola, FL, United States
Dates: 2020-02-19 - 2020-02-20
Current status: Pending Voucher Approval
Voucher total expenses: 1027.98
Estimated trip cost: 1368.26
E2 Single Sign On Login (within DOJ Network Only):
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any further use of such e-mail or attachments is strictly prohibited.
EFTA00023306


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From:
To:
Cc:
Subject:
2nd interview
Date: Tue, 08 Oct 2019 18:25:06 +0000
Attachments:
See attached.
EFTA00021325


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From:
To:
Cc:
Subject: RE: Jeffrey Epstein Victim; Ms
,
17 years old
Date: Fri, 22 Nov 2019 18:38:04 +0000
Got it, thanks.
From:
Sent: Friday, November 22, 2019 13:37
To:
Cc:
Subject: RE: Jeffrey Epstein Victim; Ms
17 years old
called on our 800 line from New Mexico
she believes that her daughter
is a victim of
sex trafficking that the AG in New Mexico gave her our 800 line.
I don't know if this is Epstein.
From:
Sent: Friday, November 22, 2019 1:24 PM
To:
Cc:
is
Subject: RE: Jeffrey Epstein Victim; Ms
17 years old
Will do, thank you!
From:
Sent: Friday, November 22, 2019 13:17
To:
>;
>;
Subject: FW: Jeffrey Epstein Victim; Ms
17 years old
Can you send to FBI.
From:
Sent: Thursday, November 21, 2019 8:12 PM
To:
is
Subject: Jeffrey Epstein Victim; Ms
17 years old
I am a very close friend of Ms.
and her guardian, Ms.
of Calderitas, Mexico. Ms.
was abused by
Jeffrey Epstein on numerous occasions at his townhome in New
York and his caribbean island home in the Virgin Islands. They
EFTA00020917

=== Page 2 ===
both have expressed their interest in asking me to register her claim
as a victim in any case involving Mr. Epstein's estate, which she
believes she may have a claim.
She does not have legal representation yet, but is in negotiations to
retain and attorney soon.
Regards,
EFTA00020918


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21-58-cr (L), 21-770-cr
United States V. Maxwell
United States Court of Appeals
FOR THE
SECOND CIRCUIT
At a stated term of the United States Court of Appeals for the Second Circuit, held at the
Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the
27th day of April, two thousand twenty-one.
PRESENT: PIERRE N. LEVAL,
RAYMOND J. LOHIER, JR.,
RICHARD J. SULLIVAN,
Circuit Judges.
United States of America,
Appellee,
V.
21-58-cr (L)
21-770-cr
Ghislaine Maxwell, AKA Sealed Defendant 1,
Defendant-Appellant.
Defendant-Appellant Ghislaine Maxwell appeals from orders of the District Court entered
December 28, 2020 and March 22, 2021, which denied her renewed requests for bail pending trial.
See Dkts. 1, 20. Upon due consideration, it is hereby ORDERED that the District Court's orders
are AFFIRMED and that Appellant's motion for bail, or in the alternative, temporary pretrial
release pursuant to 18 U.S.C. $ 3142(i), Dkt. 39, is DENIED. During oral argument, counsel for
Appellant expressed concern that Appellant was improperly being deprived of sleep while
incarcerated. To the extent Appellant seeks relief specific to her sleeping conditions, such request
should be addressed to the District Court.
FOR THE COURT:
Catherine O'Hagan Wolfe, Clerk of Court
UNITED STATES
SECOND
Catherine
CIRCUIT
Hapaulwolfe
OF
EFTA00023011


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From:
)"
To:
(USANYS)"
Cc:
)"
)"
Subject:
evidence collection
Date: Wed, 07 Jul 2021 02:56:44 +0000
Attachments: 2007-08-
10_INVESTIGATIVE_CASE_MANAGEMENT_COLLECTED_ITEMS_FOR_A_CASE_0
8_10_2007.pdf; 2006-09-
06_DESCRIPTION_OF_PROPERTY_LOG_REGARDING_EPSTEIN,_JEFFREY
.pdf
Hi
As discussed, attached is paperwork from the FBI Florida file reflecting
seizure of the PBPD evidence on August
28, 2006.
Thanks,
EFTA00021118


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From: "Martin G. Weinberg"
Subject: RE: Call today
Date: Wed, 24 Jul 2019 16:03:31 +0000
speak at 3
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.
From:
Sent: Wednesday, July 24, 2019 11:58 AM
To: Martin G. Weinberg
Cc:
Subject: RE: Call today
Happy to, but I'm not sure I have Mike's number. Would you please send it to me?
Thanks,
Assistant United States Attorney
Southern District of New York
From: Martin G. Weinberg
Sent: Wednesday, July 24, 2019 11:56 AM
To:
Subject: RE: Call today
Yes, please
Would you also be able to call Mike Miller at his Steptoe Office and conference us? If not I will ask Mike to arrange a call
in.
EFTA00021386

=== Page 2 ===
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.
From:
Sent: Wednesday, July 24, 2019 11:50 AM
To: Martin G. Weinber
Cc: 'Marc Fernich'
; 'Weingarten, Reid
Subject: RE: Call today
3pm works for us. Should we call your cell?
Assistant United States Attorney
Southern District of New York
From:
Sent: Wednesday, July 24, 2019 11:44 AM
To:
Cc:
Subject: RE: Call today
I
am available by cell at 2. If you were available at or shortly after 3, Mike Miller could join us. 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.
From:
Sent: Wednesday, July 24, 2019 11:38 AM
To:
Cc:
EFTA00021387

=== Page 3 ===
Subject: RE: Call today
Thanks Marty. Can we plan for a 2pm call? We should be able to discuss your comments about the protective order at
that time as well.
Please let us know what number to call.
Best,
Assistant United States Attorney
Southern District of New York
From: Martin Weinberg
Sent: Wednesday, July 24, 2019 10:42 AM
To:
Cc: Marc Fernich
Weingarten, Reid
Subject: Re: Call today
I am available at or after 1
Marty
Sent from my iPhone
On Jul 24, 2019, at 10:36 AM,
wrote:
All,
Would one or some combination of you be available for a call today? We understand there was an incident involving Mr.
Epstein at the MCC, and we'd like to touch base with you about it.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00021388


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From:
To:
Subject: Read: JEFFREY EPSTEIN
Date: Tue, 23 Jul 2019 22:25:30 +0000
EFTA00022534


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=== Page 1 ===
From:
)"
To:
)"
Subject: FW: Subpoena to Interlochen Center for the Arts
Date: Mon, 26 Apr 2021 14:33:05 +0000
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Monday, April 26, 2021 10:32 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
I'm working on it and hope to have it complete and ready in the next couple of days.
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: Monday, April 26, 2021 at 9:28 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Could you please let us know when you expect to produce these materials?
Thanks very much,
EFTA00022997

=== Page 2 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, March 26, 2021 5:33 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Just confirming receipt. Also, I'm hopeful that we can have everything gathered by April 12th. However, I'll be out of the
office for the next week so it might be delayed. Will that be a problem?
In addition, and just for confirmation's sake, you are ok that we will make reasonable efforts to notify the
parents/students of the subpoena prior to compliance with the subpoena correct?
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, March 26, 2021 at 3:37 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
Thanks again for taking the time to speak with me this morning. As we discussed, I'm attaching a subpoena for additional
student records.
Thank you,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:41 PM
To:
Cc:
)
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Sounds good. Yes, that is the best number.
EFTA00022998

=== Page 3 ===
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 4:40 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Thanks so much-let's plan to talk at 9:30 tomorrow morning, if that works for you. Is this the best number to reach you
then: 231-947-0400
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:32 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm available between 9am and 10am, and then again after 11am.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
EFTA00022999

=== Page 4 ===
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:
>;
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
231-947-0400
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
III
)"
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
EFTA00023000

=== Page 5 ===
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?
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Sure. Does Wednesday or Thursday morning work?
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
i
(USANYS)"
EFTA00023001

=== Page 6 ===
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
H
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
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
EFTA00023002

=== Page 7 ===
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
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
EFTA00023003

=== Page 8 ===
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
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
EFTA00023004

=== Page 9 ===
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still
be grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
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
EFTA00023005

=== Page 10 ===
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com>, "Donnini, George B." <donnini@butzel.com>
Cc:
)"
i
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would
you please confirm that your production included all records of any tuition payments that Epstein (or his entities)
made for any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow
and will have limited availability this week, but my colleagues
and
(both cc'd) should be
able to coordinate with you as needed.
Best,
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.
EFTA00023006

=== Page 11 ===
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
)"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey
Epstein and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request
confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00023007


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
USANYS)"
Subject: RE: Epstein FOIA - OCME Report of Autopsy
Date: Thu, 01 Jul 2021 14:58:20 +0000
Sounds good and thanks.
Just confirming we are all set in your view to release the production tomorrow, right? As in, we're clear in terms of the
UMR and with
and
Please let us know if there is anything we need to discuss or follow up on at this stage.
Thank you!
From:
USANYS)
Sent: Wednesday, June 30, 2021 12:34 PM
To:
USANYS
Cc:
USANYS)
(USANYS)
(USANYS)
Subject: RE: Epstein FOIA - OCME Report of Autopsy
OCME asked whether we could send them a copy of the redacted autopsy report. Could you please send me a copy of it
on Friday so I can forward to them? Thank you!
From
(USANYS)
Sent: Tuesday, June 29, 2021 6:46 PM
To:
USANYS)
Cc:
USANYS)
(USANYS)
(USANYS)
Subject: RE: Epstein FOIA - OCME Report of Autopsy
Thanks,
Yes, we will ask BOP to redact that photo as well.
From:
(USANYS)
Sent: Tuesday, June 29, 2021 3:45 PM
To:
(USANYS)
C
(USANYS)
(USANYS)
(USANYS)
Subject: RE: Epstein FOIA - OCME Report of Autopsy
and
I spoke with the GC of OCME, who appreciated the head's up. One note for you all: the photo of the hyoid bone on page
12 is in fact Epstein's hyoid bone. To the extent we're redacting the closeup photos from page 13, shouldn't we also
redact the entire photo on page 12?
Thanks,
EFTA00023402

=== Page 2 ===
From:
(USANYS)
Sent: Monday, June 28, 2021 5:02 PM
To
(USANYS)
Cc:
(USANYS)
(USANYS)
(USANYS)
Subject: Epstein FOIA - OCME Report of Autopsy
Please find attached the OCME Report of Autopsy. The boxes show where there will be redactions.
Thanks,
Assistant United States Attorney
White Plains, NY 10601
EFTA00023403


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=== Page 1 ===
OFFICIAL RECORD
Intake (Rev. 5-23-17)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Intake
Date: 10/27/2020
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Drafted By:
Date/Time Received: 10/27/2020 03:20 PM EDT
Details:
On 10/27/2020, at 3:20 p.m. Eastern Time,
,
date of birth
,
cellular telephone number
,
called the FBI
National Threat Operations Center (NTOC) Unit, to report potential
information related to Jeffrey Epstein and Ghislaine Maxwell.
provided the following information:
reported around 1997, he made contact with
,
date of
birth
whom he had known from 6 or 7 years prior as they
had a son together.
and
ended up dating, as
explained
she was having money issues and problems with her daughters.
noted
they were friends from before. During the contact in 1997,
asked
how to spell "Ghislaine" numerous times, as
noted she had
taken her daughters up to see one of the "supposed father's" who lived in
Niagara Falls, NY recently.
reported she had met a lady who invited her daughters
,
date of birth
, and
date of birth
/
/
to a fancy hotel and met Donald Trump and some of his friends in 1997.
continued asking
how to spell "Ghislaine" implying
Ghislaine had given her money and would give her additional money if
needed.
On Christmas Eve of 1999, or the day prior,
was over visiting his
son, who he had with
years prior.
began talking to
/ as
she seemed to be acting strange and asked
if he needed a ride home.
UNCLASSIFIED
EFTA00020517

=== Page 2 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 10/27/2020
asked
about his time driving a limousine for two years in the
Dallas/Ft. Worth area. During
time as a driver, he had met Donald
Trump.
noted he picked the President up in 1995 and took him to the
DFW Airport.
reported some of things President Trump had spoken about
during the ride while on his cell phone were very concerning.
reported he was "a few seconds from pulling the limousine over on the
median and within a few seconds of pulling him out of the car and hurting
him due to some of things he was saying" as caller choose not to.
noted Trump continuously stated the name "Jeffrey" while on the phone,
and made references to "abusing some girl."
was unsure who he was
talking to nor who he was referencing. As
talked about his time
meeting Donald Trump,
immediately
demeanor went "stone
cold" as
stated "he raped me."
said "what" as
replied
"Donald J. Trump had raped her along with Jeffrey Epstein.' "
noted
some girl with a funny name "took me into a fancy hotel or building,
that's how it happened."
advised
to call the police regarding the incident as
stated "I can't they will kill me. " On Christmas Day,
contacted
stated she had in fact called the police about what they had talked
about.
told
she had "done good.
did not hear from
or
until 01/10/2000.
reached out to
stating
was dead and noted she was found
with her head "blown off" in Kiefer, OK. Officers on the scene and
stated there was no way it was a suicide. Corner stated it was a suicide.
later stated
committed suicide because
had gotten
cocaine from a Mexican drug cartel.
feels the murder is a cover for
Ghislaine.
The last contact with
was after
posted this information on
Facebook a couple of weeks prior.
called
yelling that he had
put the family in danger.
explained
had a third daughter named
date of birth
-
Note: During
report he mentioned John Doe No.2 was actually John
UNCLASSIFIED
2
EFTA00020518

=== Page 3 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 10/27/2020
W Nichols, date of birth
,
who tried to
originally set
up for the bombing in Oklahoma City. Nichols worked
security for Bill and Hillary Clinton as
ate at a place where Nichols
worked security at the door. Hillary walked up to
drunk and begin
yelling as they asked
to leave and fired Nichols, which led Nichols
to attempt to set up
for the bombing.
UNCLASSIFIED
3
EFTA00020519


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=== Page 1 ===
From:
To:
Subject: Re: any of you have vouchers for Epstein victims.
Date: Fri, 15 Nov 2019 03:48:55 +0000
Hi
I don't have any.
Sent from my iPhone
On Nov 14, 2019, at 9:50 AM,
wrote:
Victim Witness Coordinator
United States Attorney's Office
Southern District of New York
1 St. Andrews Plaza
New York, New York 10007
Tel.
EFTA00020965


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10808018 has received final approval
Date: Fri, 08 Nov 2019 22:41:11 +0000
Importance: Normal
Dear
Travel authorization 10808018 has received final approval.
Trip ID: 10808018
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R20NYS13180 - U.S. V. Epstein (2018R01618) - Witness Interviews
Destination:
Dates: 2019-11-13 - 2019-11-15
Current status: Authorization Approved
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
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Reference ID# T0006
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00021357


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
(USANYS)"
Subject: Fwd: [EXTERNAL] US V Maxwell
Date: Tue, 30 Nov 2021 01:11:31 +0000
Attachments: XLBTVMAXF_4PP.PDF; LBTVMAXF_4PP.PDF; LBTVMAXF.PDF; XLBTVMAXF.PDF
Trial transcripts from today
Sent from my iPhone
Begin forwarded message:
From:
Date: November 29, 2021 at 6:54:33 PM EST
To:
(USANYS) [Contractor]"
)"
X
(USANYS)"
)"
"
,
)"
Subject: [EXTERNAL] US V Maxwell
EFTA00022184


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=== Page 1 ===
From:
Subject: 2021.02.15 - NOTES Call with Jason Foy & Eric Sarraga re
Date: Tue, 16 Feb 2021 15:40:43 +0000
2021.02.15 - NOTES Call with Jason Foy & Eric Sarraga re
JL, NR, JF, ES
NR: checking in re June trial date
JF: would expect that court is going to adjourn this
JL: understanding is that some trials will start up beginning in February, but limited number
JF: suspect that this case will not take priority and will be adjourned; if the Court doesn't want to adjourn, will
move forward in June
JF: may find out more information at the March conference
NR: had previously mentioned wanting to put in a DP application; has not been a standard DP/misdemeanor
application process; if you are interested in making application, should make it sooner rather than later
JF: got sense that likelihood of them changing their minds was remote-is that still the case?
NR: pre-charge, you had mentioned misdemeanor (1018); have been some changes in leadership, there's a
currently a pandemic, could supply additional information about what your client has been doing, collateral
consequences of felony conviction, life plans, even in last year
JL: no predictions about the outcome, but here are some things to consider including:
life plans, how she
spent the past year, her familial responsibilities, etc.; less need to address litigation risk, because we are aware of
those issues, but can include; in terms of selective prosecution argument, can make it, but in a more informational
tone, rather than an accusatory tone
JF: not her formal position; goal was to put her in a position to cooperate and discuss disfunction at NYC BOP; no
criminal intent on her part; now that reviewed discovery, do not believe that she should take a misdemeanor;
believe that she was "not up to no good"; would recommend to her DP or trial; expect her to follow my lead, but
she may compromise and accept misdemeanor; have found instances of similar conduct that haven't been
prosecuted; understand that someone died, which makes it different; in case in Texas, COs weren't truthful to
Inspector General; not the case here; no one tried to trick or do anything to frustrate anything; did not try to avoid
what happened; said that they messed up in the moment; will not succeed if we (JL & NR) don't support it; have
seen from discovery, that when it comes to Epstein, things are always different; did not really emphasize Epstein-
related argument at last conversation; she can be held accountable without having a criminal record-people don't
usually get fired for this, so being fired would be a way of holding her accountable
JL: not previewing our position, but Nick and I have an open mind and will consider what you submit
JF: my duty to submit something; think it's a defensible case, but if I can get her the right result without all the
drama, should do that; will do my best to stay away from fighting the case; emphasize fairness and change of
circumstance; how long is process?
JL: explanation of DP process, including appeals
JF: same people who were at last meeting?
NR: some change in leadership
JL: not sure if the standard process will be followed or if brass will be involved earlier given that brass previously
considered DP in this case
JF: this would be first formal DP application; prior meeting was about potential cooperation pre-charge
JL: may want to drop a FN that this is first formal application and a different posture than last time
JF: should discuss with Montell as well
JL: we have had a similar conversation with Montell
JF: Ds can be viewed as differently situated
JL: at least at this point, Ds will each be analyzed separately
EFTA00022623

=== Page 2 ===
JF: can see how Ds' interests diverge, given seniority and reality of who was doing and not doing what on day in
question; include this?
JL: should include anything that mitigates her conduct
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00022624


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Cc:
(USANYS)"
Subject: FW: Discovery Requests
Date: Sat, 16 Jan 2021 02:02:26 +0000
Attachments: 2020.11.18_Maxwell_Discovery_Letter.pdf;_2006.12.06_FBI_Reportpdf; PROD011-
Gaps.xlsx
Inline-Images: image005.jpg; image006.jpg
Hi
Would you please take a look at request number 6 below and figure out how to address it? I believe you may need to
work with
for some of these issues.
Thanks,
From: Christian Everdell
Sent: Thursday, January 7, 2021 4:13 PM
To:
is
>;
(USANYS)
Cc: Mark S. Cohen
>; Bobbi Sternheim
>; Jeff Pagliuca
<jpagliuca@hmflaw.com>; 'Laura Menninger'
Subject: Discovery Requests
We write to raise a number of discovery issues. Please let us know your position on these issues at your earliest
convenience.
1. In our email correspondence on 11/18/2020, you agreed to create a new hard drive containing the entire discovery
production. We provided you with a 4TB hard drive for that purpose on 11/20/2020. It is very important for Ms.
Maxwell to have this drive as soon as possible to prepare her defense. Do you have an update on when the drive
will be ready?
2. We also informed you that the CD produced on November 18, 2020 did not work on the prison computer at the
MDC (as you know, the laptop provided to Ms. Maxwell does not have a CD drive). Accordingly, we asked you to
include the material on the CD in the new 4TB hard drive. We followed-up with you about this issue on December
30, 2020. Given that the new hard drive is still not ready, we ask that you download the material on the CD onto
a separate thumb drive or hard drive and provide it as quickly as possible to Ms. Maxwell at the MDC so that she
can review the materials this weekend. Alternatively, you can provide an external CD drive to Ms. Maxwell at
the MDC so that she can read the files on the MDC computer. We will provide whatever media device you
require to facilitate this production.
3. Unlike the November 9, 2020 discovery cover letter, the November 18, 2020 discovery cover letter (attached) does
not correlate the Bates numbers to the particular "Subject Device" from which the documents were recovered.
Instead, the cover letter indicates that the documents came from "SDNY_PROD015" or "SDNY_PROD016." We do
not know what those terms refer to. We request that the government produce a list that correlates the Bates
EFTA00021736

=== Page 2 ===
numbers for all of the documents in SDNY_PROD015 and SDNY_PROD016 to the particular devices from which the
documents were recovered.
4. We request that the government provide an unredacted version of the FBI report, dated December 6, 2006,
bearing Bates number SDNY_GM_02050812-14 (attached). We also request that the government produce a log
identifying all of the redacted documents in the discovery and the bases for each of the redactions.
5. There are a few documents that seem to be missing from the discovery. For example, the AT&T documents
(SDNY_GM_00001015-3637) do not seem to include subscriber information for the various phone numbers. Also,
the flight logs produced by
begin at Bates number
000028," suggesting that
000001-000027 were not produced to us. Please produce these documents to us or provide an
explanation why you are not producing them to us. Please confirm whether there are other documents that were
removed from the grand jury subpoena productions that we have not yet identified and the basis for their removal.
6. There are a few Bates number/metadata issues with some of the documents:
a. There is an overlap between the fourth and fifth document productions. The fourth production ends at
SDNY_GM_00328863, the fifth production begins at SDNY_GM_00328070. We propose renumbering the
range from the fifth production (i.e., renumber SDNY_GM_00328070-328863).
b. The metadata load files (*.DAT) for PROD011 had a number of gaps which are detailed in the attached Excel
file. We propose that you send us a new DAT file covering only the missing documents.
C. The metadata load files (*.DAT) for PROD015 had a gap from SDNY_GM_00723971 to SDNY_GM_00723981.
We propose that you send us a new DAT file covering only the missing documents.
7. To the extent that the government has created an index of the documents produced on November 9 and
November 18 that is more detailed than the production cover letters, we request that you provide a copy to the
defense.
8. We request that the government provide copies of the grand jury subpoenas for documents issued by the
government in this case. Also, please identify the date range of documents you requested in each subpoena.
There is one other issue we'd like to raise. An article in the Daily Beast on Monday referenced the search warrant affidavit
for the cell-site simulator used to track Ms. Maxwell's cellphone before her arrest (https://www.thedailybeast.com/how-
the-fbi-tracked-down-ghislaine-maxwell-alleged-madam-of-jeffrey-epstein). The article stated that the affidavit appeared
in a "newly unsealed court filing." I don't recall this affidavit being unsealed or referenced in anything that was filed on
the court docket. Please confirm whether or not the government unsealed this affidavit or any other materials from the
criminal discovery, and whether any discovery materials were released pursuant to FOIA requests.
Regards,
Chris
Christian R Everdell
COHEN & GRESSER LLP
EFTA00021737

=== Page 3 ===
view bio
www.cohengresser.com
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Paris
Washington DC
London
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=== Page 1 ===
Signature Page
By signing below and depositing cash or securities in my accounts, I acknowledge that I have read, understand and agree with the enclosed UBS Client
Relationship Agreement, as well as the terms, conditions and disclosures in the enclosed Agreements and Disclosures booklet.
Margin Agreement
Electronic Delivery Consent
I acknowledge that when I use margin privileges, UBS will hold the
As you requested, we have sent your agreements and disclosure booklet
SIGN AND RETURN TO UBS
securities in my Account as collateral against the amounts I borrow. I
and other account-related documents electronically to
agree to keep sufficient positions and margin in my Account to meet any
gmax1@ellmax.com, which we consider to be the e-mail address of
margin calls UBS may be required to issue. By signing below, I agree that
record for all owners of these accounts. The information is also available
the Margin Agreement in my Client Relationship Agreement applies to
at www.ubs.com/accountdisclosures or by request to your Financial
all of my accounts, including any accounts that I may open in the future.
Advisor, Scott Stackman I Lyle Casriel at 1-212-821-7000.
Note: UBS does not extend margin for certain types of accounts (e.g.,
IRA and ERISA Plan accounts, Coverdell Education Savings Accounts,
403(b)(7) Accounts, UGMA/UTMA, Estate or 529 Plan Accounts).
Likewise, I acknowledge and agree that certain securities in my account,
including any account I may open in the future, may be loaned to UBS or
to other persons or entities as described in the Margin Agreement.
W-9 Form Certification
Under penalties of perjury li certify that the number this form(isimy) taxpayer dentification number or am waiting for a number to
be issu to me); and 2) not subjectito backup withhold ause (a) am exempt-from ba withh or (b) have not been notified by the
Internal Revenue Service (IRS) that am subject to bac withholdi ureitogreport- interest and Midends, or (c) the IRS has notified
me that am no longer. subjectito back ip.withholding and a citizen nithe instructions)
Certification Instruction: Youtmust cross out item (2) above you notified by the RS that you currently subject to backup withholding
because you.have failed to report-all interest and dividends on you
tax-retum
The Internal Revenue Service does not require your consent to
The Client Relationship Agreement contains a pre-dispute arbitration clause
any provision of this document other than the certifications
located in the final section under the title "Arbitration."
required to avoid backup withholding
Ghislaine-Maxwell,
For Accounts:
Enter your Tax ID Number:
Y1 23568 RMA Domestic - Sole Owner
ENTER SSN HERE
Y1 23567 RMA Domestic - Sole Owner
Y1 23576 RMA Domestic - Sole Owner
Check here if you have been notified by the IRS that you are subject to
Y1 23575 RMA Domestic - Sole Owner
backup withholding, and therefore have crossed out item (2) above.
Y1 23574 RMA Domestic - Sole Owner
Y1 23573 RMA Domestic - Sole Owner
Y1 23572 RMA Domestic - Sole Owner
Y1 23571 RMA Domestic - Sole Owner
Y1 23570 RMA Domestic - Sole Owner
Y1 23569 RMA Domestic - Sole Owner
X
Ghisleine S Maxwell
X
2/18/14
SIGN AND
DATE HERE
Date
Address: of Record
116 E 65th Street
New York, NY 10065-7007
Email Address of Record
gmax1@ellmax.com 2014/02/19
0093830959
Page 1 of 1
21
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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: FW: Epstein IML violation
Date: Thu, 20 Feb 2020 15:22:49 +0000
Inline-Images: image001.jpg
FWIW.
From:
(USANYS)
Sent: Thursday, February 20, 2020 10:22 AM
To: 'Thomas Volscho'
Cc:
(USANYS) [Contractor]
Subject: RE: Epstein IML violation
Apologies for not returning your original email, we spoke on an incredibly hectic day.
Thank you for your inquiry, we'll decline to comment.
Public Affairs
United States Department of Justice
U.S. Attorney's Office Southern District of New York
I
Mobile:
I
Press Office:
From: Thomas Volscho
Sent: Thursday, February 20, 2020 10:14 AM
To:
(USANYS)
Subject: Re: Epstein IML violation
Hi
,
I am following up on my previous email. Is there a time frame for responding?
Thanks,
Tom Volscho
On Thu, Feb 13, 2020 at 4:13 PM Thomas Volscho
wrote:
Hi
I am a journalist that works with ABC News and simultaneously a sociology professor (CUNY / College of
Staten Island) doing research on the Epstein case for an academic study in criminology.
Thank you for your email address. Below is a screenshot of a page from the USMS investigation report from
1/8/19 I mentioned on the phone.
EFTA00023281

=== Page 2 ===
It appears the USAO of the SDNY suspected that Mr. Epstein was not disclosing all his international travel. I
would like to ask about that.
-What made the SDNY believe that Epstein may have been violating IML?
-Were there prior reports that he may have violated IML?
-Were there other investigations of Epstein's compliance with his obligations as a sex offender of concern to
the SDNY or DOJ over the years?
-In my review of Jeffrey Epstein's flight logs obtained from the FAA, the two flights, one to Vienna, Austria
and the second to Monaco, were not logged in FAA records.
-Was there any indication that Epstein took steps to conceal certain flights from being tracked by U.S.
authorities? (the Vienna and Monaco flights were picked up from "crowd-sourcing").
-Does the SDNY believe Epstein had advanced knowledge he would be arrested?
-Would the SDNY provide any reports detailing how the FBI and NYPD took him into custody. details about
the arrest itself? (e.g., Before or after he went through customs?)
Thank you kindly for your help,
Tom Volscho
(b) (6), (b) (7)(C). (b) (7)(F)
U.S. Department of Justice
United States Marshals Service
REPORT OF INVESTIGATION
Page of 1
1. FID: 10127184
2 DATE OF REPORT: 01/08/2019
3. REPORTED
CASE: 0C-1900-0108-2923-G
BY
AT: W00
4. SUBJECT NAME: EPSTEIN,JEFFREY EDWARD
5. MERGED FIDs:
6. TYPE OF REPORT:
REPORT OF ELECTRONIC INTERCEPTION
ARREST/CLOSE
COLLATERAL LEAD
INTELLIGENCE UPDATE
WITNESS INTERVIEW
MEMORANDUM TO FILE
ADMINISTRATIVE SUBPOENA
DUE DILIGENCE
CS REQUEST
[x] OTHER: (APPROVAL FOR INVESTIGATION)
7. HOURS WORKED:
Jeffrey EPSTEIN was referred to the USMS IML Unit by the US Attorney's Office for the Southern District of
New York as a convicted Sex Offender from the state of Florida who travels frequently Internationally and may
have not reported all his International travel as required by International Megan's Law.
EPSTEIN was convicted in 2008 in the state of Florida of procuring a person under the age of 18 for
prostitution, sentenced to 13 months incarceration and is required for life as a sex offender in the state of
Florida.
EPSTEIN is currently registered as a sex offender in the US Virgin Islands as his primary address and he has
secondary addresses in Florida, NY, New Mexico, and Paris France. In NY state, EPSTEIN is classified as a
Level 3 sex offender (highest-risk) with a lifetime registrant requirement.
Investigation reveals EPSTEIN travels Internationally quite frequently using private planes and may have
failed to report all his International travel. Based upon this information, a MS04 investigation has been
initiated to determine if EPSTEIN is in Violation of Title 18 Section 2250(b) regarding his failure to report
International travel.
End of Report
Dr. Thomas Volscho
ABC News Investigative Unit
40 Overlook Ave
West Orange, NJ 07052
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From:
To:
Cc:
Berman, Geoffrey (USANYS)"
(USANYS)"
(USANYS)"
)"
)"
Subject: Re: updates
Date: Sat, 06 Jul 2019 21:58:14 +0000
Importance: Normal
Great. Thanks very much for the update.
Sent from my iPhone
On Jul 6, 2019, at 5:56 PM, Strauss, Audrey (USANYS)
wrote:
Great work by all.
Sent from my iPhone
On Jul 6, 2019, at 5:55 PM, Birger, Laura (USANYS)
wrote:
Great. Thanks.
Sent from my iPhone
On Jul 6, 2019, at 5:54 PM, Berman, Geoffrey (USANYS)
wrote:
Epstein is in custody. Search warrants being executed now. Geoff
On Jul 6, 2019, at 12:44 PM, Berman, Geoffrey (USANYS)
wrote:
tells me that he is confirmed on board. Wheels up. Geoff
On Jul 6, 2019, at 11:10 AM,
)
wrote:
Good morning all-
asked me to pass along two quick updates. First, Judge Moses signed the search warrant this morning.
Second, our case agent told us that FBI received a flight manifest from CBP last night. The passengers listed are
Epstein and two pilots. Of course, that is subject to change, and I'm told that FBI will try to get confirmation of
the passengers after the flight takes off.
EFTA00021273

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Subject: SDNY DAILY PRESS CLIPS - AUGUST 14, 2020
Date: Fri, 14 Aug 2020 16:31:29 +0000
DONNELL RUSSELL
ABC: https://wgntv.com/news/chicago-news/prosecutors-charge-3-with-threatening-women-in-r-kelly-case/
MAXWELL:
Vanity Fair: https://www.vanityfair.com/style/2020/08/ghislaine-maxwell-denied-prison-move
MATTERS OF INTEREST
EFTA00021164

=== Page 2 ===
POLITICO: https://www.politico.com/news/magazine/2020/08/14/want-to-cure-nra-coruption-let-a-gun-loving-
democrat-run-it-395005
GOTHAMIST: https://gothamist.com/news/misconduct-complaints-pile-de-blasio-orders-deeper-cuts-nypd-
oversight-board
NY POST: https://nypost.com/2020/08/13/nypd-uses-misleading-footage-to-explain-inaction-during-teen-
beatdown/
FOX: https://www.foxnews.com/politics/barr-durham-report-development-friday-election-timing
DAILY MAIL: https://www.dailymail.co.uk/news/article-8625217/Trump-hints-FIRING-FBI-director-Chris-
Wray-claims-covering-Russia-probe.html
WAPO: https://www.washingtonpost.com/business/2020/08/14/top-dhs-officials-wolf-cuccinelli-are-not-legally-
eligible-serve-their-current-roles-congressional-watchdog-agency-finds/
ProPublica: https://www.propublica.org/article/electionland-2020-usps-chaos-election-cybersecurity-august-
voting-and-more
https://www.propublica.org/article/local-officials-say-a-nursing-home-dumped-residents-to-die-at-hospitals
The Blast: https://theblast.com/c/tekashi-6ix9ine-69-snoop-dogg-los-angeles-dangerous-gangs-video-photos-
nobu-malibu-bloods
https://www.cshub.com/attacks/articles/incident-of-the-week-garmin-pays-10-million-to-ransomware-hackers-
who-rendered-systems-useless
NYT: https://www.nytimes.com/2020/08/14/nyregion/donald-trump-taxes-cyrus-vance.html
Sent from my iPad
EFTA00021165


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=== Page 1 ===
From:
To: Nathan NYSD Chambers
Cc:
Jeff
Pagliuca
N
Laura Menninger
Subject: US V. Maxwell - Letter re Minor Victim-3
Date: Sun, 07 Nov 2021 16:55:12 +0000
Attachments: Gov't_Letter_re_MV-3_and_Victim_[Final].pdf
Chambers,
Attached please find a letter in response to the Court's order yesterday regarding Minor Victim-3. The Government is not
seeking redactions but is filing this letter temporarily under seal to permit the defense an opportunity to seek redactions,
and pending the Court's resolution of the Government's other redaction requests.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Subject: Accepted: Maxwell - Discuss Images from Epstein Devices
Date: Fri, 16 Oct 2020 02:00:28 +0000
Importance: Normal
Attachments: unnamed
EFTA00023250


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 19-2221 United States of America V. Epstein "Defective Document FILED"
Date: Mon, 05 Aug 2019 19:01:07 +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 08/05/2019
Case Name:
United States of America V. Epstein
Case Number: 19-2221
Document(s): Document(s)
Docket Text:
DEFECTIVE DOCUMENT, notice of additional counsel, [11], on behalf of Appellant Jeffrey Epstein, FILED.
[2624335] [19-2221]
Notice will be electronically mailed to:
Ms.
-:
, Assistant U.S. Attorney:
Martin G. Weinberg, -:
Reid Weingarten, -:
,
,
The following document(s) are associated with this transaction:
Document Description: Defective_Document_Notice
Original Filename:
/opt/ACECF/live/forms/DonnelBolden_192221_2624335_Defective_Document_Notice_142.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=08/05/2019] [FileNumber=2624335-0]
[4dbd012777752d2dd78a4b05be1da3886a8eefdd41ae09ba8fb89dcd558ec5e80d078587a77166d4cb2828494277
cc3fe1ac169fe526f23db66184f7fd75812d]]
Recipients:
Ms.
Assistant U.S. Attorney
Martin G. Weinberg, -
Reid Weingarten, -
EFTA00020919


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=== Page 1 ===
From: Adam Johnson
>
To: Stephanie Scannell <$
>,
)"
<
Cc:
)"
)"
>,
>
Subject: Re: CORRECTED: Subpoena and Request for Emails
Date: Fri, 12 Jul 2019 11:55:24 +0000
Hi Maurene,
I checked and confirmed we have no calls or emails for Epstein at this time.
Thank you,
Adam
Adam M. Johnson
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
p:
f:
>>>
)" 7/11/2019 9:53 PM >>>
Apologies, my prior email was missing some of the contact information for Epstein's attorneys. Please disregard the prior
subpoena and request.
Attached please find a revised subpoena with a corrected list of attorney phone numbers to exclude.
In addition, please accept our written request for the e-mail correspondence of inmate Jeffrey Epstein (76318-054) from
July 6, 2019 through July 11, 2019 - excluding any correspondence between Epstein and the following attorneys: Marc
Fernich
Weinberg
, and Reid Weingarten
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Thursday, July 11, 2019 9:43 PM
To: Adam Johnson ; Stephanie Scannell
Cc:
);
)
; Blachman, Eric (USANYS)
Subject: Subpoena and Request for Emails
Importance: High
Adam and Steph,
Attached please find a subpoena for recordings of Jeffrey Epstein's phone calls, excluding any attorney calls.
In addition to the materials requested in the enclosed subpoena, please accept our written request for the e-mail
correspondence of inmate Jeffrey Epstein (76318-054) from July 6, 2019 through July 11, 2019 - excluding any
EFTA00022361

=== Page 2 ===
correspondence between Epstein and the following attorneys: Marc Fernich
Martin Weinberg
and Reid Weingarten
(
).
As you can see on the subpoena, we have set the return date for tomorrow (July 12, 2019). We would be very grateful if we
could receive the requested materials as soon as possible. As always, please feel free to call
or me with any
questions or concerns.
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
February 6, 2020
Interlochen Center for the Arts
4000 Highway M-137
Interlochen, MI 49643
Attn: Jeffrey Jocks, Esq.
jjocks@sondeeracine.com
Re:
Grand Jury Subpoena
Please be advised that the accompanying grand jury subpoena has been issued in
connection with an official criminal investigation of a suspected felony being conducted by a
federal grand jury. The Government hereby requests that you voluntarily refrain from disclosing
the existence of the subpoena to any third party. While you are under no obligation to comply
with our request, we are requesting you not to make any disclosure in order to preserve the
confidentiality of the investigation and because disclosure of the existence of this investigation
might interfere with and impede the investigation.
Thank you for your cooperation in this matter.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
By:
Manlue
Assistant United States Attorney
Southern District of New York
(212) 637-2324
EFTA00020846

=== Page 2 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Interlochen Center for the Arts
4000 Highway M-137
Interlochen, MI 49643
Attn: Jeffrey Jocks, Esq.
jjocks@sondeeracine.com
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the GRAND JURY of the people of the United States for the Southern District of New York, at
the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New
York, New York, in the Southern District of New York, at the following date, time and place:
Appearance Date:
February 21, 2020
Appearance Time: 10 a.m.
to testify and give evidence in regard to alleged violations of federal criminal law, including:
18 U.S.C. $ 2423(a)
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
SEE ATTACHED RIDER. Personal appearance is not required if the requested records are (1)
produced by on or before the return date to Special Agent
Federal Bureau of
Investigation, 26 Federal Plaza, New York, NY 10278, telephone (212) 384-1000,
;
and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records.
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
February 6, 2020
Gilby
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
UNITED COURT
FOR
Assistant United States Attorney
THE
YORK
One St. Andrew's Plaza
New York, New York 10007
Telephone: 212-637-2324
EFTA00020847

=== Page 3 ===
RIDER
(Grand Jury Subpoena to Interlochen Center for the Arts
dated February 6, 2020)
Please provide any and all records reflecting any and all donation(s), tuition payment(s), and/or
any other financial contribution(s) or payment(s) made to Interlochen Center for the Arts,
including to Interlochen Arts Camp and/or to Interlochen Arts Academy, by the following
individuals, (including any entities associated with the below individuals):
Jeffrey Epstein
Ghislaine Maxwell
Please also provide any and all records reflecting dates when Jeffrey Epstein and/or Ghislaine
Maxwell visited the campus of Interlochen Arts Camp and/or Interlochen Arts Academy.
N.B.: Personal appearance is not required if the requested records are (1) produced by on or before
the return date to Special Agent
Federal Bureau of Investigation, 26 Federal
Plaza, New York, NY 10278, telephone (212) 384-1000,
; and (2) accompanied
by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE
IN ELECTRONIC FORMAT IF POSSIBLE.
IMPORTANT: REQUEST FOR NON-DISCLOSURE
Due to the ongoing nature of the investigation, it is requested that you do not
disclose any information relating to this Grand Jury subpoena request to any third party.
3
EFTA00020848

=== Page 4 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. $ 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of
records of the business named below, or I am otherwise qualified as a result of my position with
the business named below to make this declaration.
I am in receipt of a Grand Jury Subpoena, dated February 6, 2020, and signed by Assistant
United States Attorney
,
requesting specified records of the business named
below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify
that the records provided herewith and in response to the Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records,
by, or from information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
.
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data
compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business"
as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution,
association, profession, occupation, and calling of every kind, whether or not conducted for profit.
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=== Page 1 ===
Case 1:20-cv-02365-LJL Document 1 Filed 03/17/20 Page 1 of 8
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
JANE DOE,
Plaintiff,
-against-
COMPLAINT
DARREN K. INDYKE and RICHARD D. KAHN, in their
capacities as executors of the ESTATE OF JEFFREY E.
EPSTEIN;
Defendants.
X
Plaintiff, Jane Doe, by her attorneys, Kaiser Saurborn & Mair, P.C., as and for her
complaint against the defendants, alleges as follows:
I.
BACKGROUND
1.
Jane Doe seeks justice for the sexual crimes perpetrated against her by Jeffrey
Epstein over the course of many years and for the abuse, manipulation and exploitation she
suffered at his hands. Epstein identified Jane Doe as an extremely emotionally vulnerable young
woman who, at the time she met him, had been entirely abandoned by her community, friends,
and family which enabled him to seduce her into his world of horrific abuse. Every aspect of her
life was controlled by Epstein. He dominated her psychologically. Jane Doe was constantly
emotionally bullied and coerced by Epstein, including being required to submit to his constant
sexual abuse. This lawsuit is about Jane Doe claiming her power, becoming a survivor, not a
victim, and getting restitution for the sexual crimes perpetuated against her. She has real
damages that are lasting: 1) She has permanent emotional injuries; 2) Her capacity to pursue a
professional career has been severely compromised; 3) Her name and reputation has been ruined;
1
EFTA00023140

=== Page 2 ===
Case 1:20-cv-02365-LJL Document 1 Filed 03/17/20 Page 2 of 8
and 4) she is virtually bankrupt, having been forced to spend most of her resources defending
herself against false accusations, all of which stem from Epstein's crimes.
2.
The Estate of Jeffrey E. Epstein, who perpetrated crimes of sexual abuse, sexual
assault and rape against Jane Doe, must be held responsible for ruining her life. It has been
nearly 19 years since Jane Doe was recruited by Jeffrey Epstein and Ghislaine Maxwell and
plunged into a world in which she was psychologically, physically and sexually exploited and
controlled for years.
3.
Jane Doe was a naïve and uniquely vulnerable 22-year old when Epstein and
Maxwell first preyed upon her.
II.
JURISDICTION
4.
This Court has jurisdiction over this action pursuant to 28 U.S.C. $ 1331 because
the claims asserted herein arise under 18 U.S.C. $ 1591-1595.
5.
Venue is properly laid in this District pursuant to 28 U.S.C. § 1391 because it is a
District in which much of the alleged wrongdoing occurred.
III.
THE PARTIES
6.
Plaintiff is a sex trafficking victim of Epstein.
7.
At all times relevant herein, Jeffrey Edward Epstein ("Jeffrey Epstein" or
"Epstein") maintained a residence and businesses at 9 East 71st Street, New York, NY 10021
("Epstein's NY Residence") which was the location where Epstein committed repeated sexual
assaults of young women, like Plaintiff, and engaged in sex trafficking.
8.
At all times relevant herein, Epstein was an adult male over the age of 48, born on
2
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=== Page 3 ===
Case 1:20-cv-02365-LJL Document 1 Filed 03/17/20 Page 3 of 8
January 20, 1953, and who died on August 10, 2019. He continued to maintain a residence and
businesses at 9 East 71st Street, New York, NY 10021, and occupy it until his death.
9.
At all times relevant herein, Defendant, Darren K. Indyke, is named in his
personal capacity as an appointed executor of the Estate of Jeffrey E. Epstein (the "Estate of
Jeffrey E. Epstein"), which was opened and domiciled in the United States Virgin Islands, St.
Thomas Division, and is the legal entity responsible for intentional, criminal, and tortious
conduct committed by Jeffrey Epstein as described in this Complaint. The Estate of Jeffrey E.
Epstein includes Epstein's NY Residence, which was occupied by Jeffrey Epstein and his
businesses until his death and was one of the locations where repeated acts of sexual abuse and
sex trafficking against various women, including plaintiff, occurred.
10.
At all times relevant herein, Defendant, Richard D. Kahn, is named in his
personal capacity as an appointed executor of the Estate of Jeffrey E. Epstein (the "Estate of
Jeffrey E. Epstein").
11.
At all times relevant herein, Defendant, Darren K. Indyke, is named in his
personal capacity as an appointed executor of the Estate of Jeffrey E. Epstein (the "Estate of
Jeffrey E. Epstein").
12.
At all times relevant herein, Jeffrey Epstein (legally represented now through
Darren K. Indyke and Richard D. Kahn as Executors of the Estate of Jeffrey E. Epstein (and
referred to herein as the "Estate of Jeffrey E. Epstein"), owed a duty to Plaintiff to treat her in a
non-negligent manner and not to commit, or conspire to commit, or cause to be committed,
intentional, criminal, fraudulent, or tortious acts against Plaintiff, including any acts that would
cause Plaintiff to be harmed through conduct committed against her in violation of the TVPRA.
3
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=== Page 4 ===
Case 1:20-cv-02365-LJL Document 1 Filed 03/17/20 Page 4 of 8
IV.
EPSTEIN'S SEX TRAFFICKING CRIMINAL ENTERPRISE
13.
At all times relevant herein, Jeffrey Epstein ["Epstein"] was an extremely wealthy
financier, who used his wealth, power, resources, and connections to commit illegal sexual
crimes in violation of the TVPRA, and to employ and conspire with other corporate entities,
private foundations and trusts, to assist him in committing those sexual crimes or torts or to
facilitate or enable those acts to occur.
14.
Epstein displayed his enormous wealth, power, and influence to his employees; to
the employees of the corporate entities, private foundations, and trusts, who worked at his
direction; to the victims procured for sexual purposes; and to the public, in order to advance and
carry out and conceal his crimes and torts.
15.
At all times relevant herein, Epstein had access to numerous mansions, a fleet of
airplanes, motor vehicles, boats and several helicopters.
16.
At all times relevant herein, Jeffrey Epstein travelled between and frequently
inhabited and travelled between numerous properties and homes, including a Manhattan
townhome located at 9 East 71st Street, New York, NY 10021 valued conservatively by Jeffrey
Epstein's own admission at $55,931,000.00; a ranch located at 49 Zorro Ranch Road, Stanley,
New Mexico 87056 valued conservatively by Jeffrey Epstein's own admission at
$17,246,208.00; a home located at 358 El Brillo Way, Palm Beach, Florida 33480 valued
conservatively by Jeffrey Epstein's own admission at $12,380,209.00; an apartment located at 22
Avenue Foch, Paris, France 75116 valued conservatively by Jeffrey Epstein's own admission at
$8,672,820.00; and an Island Little St. James Island No. 6B USVI 00802 (A, B, C).
17.
As has been publicly reported, Epstein had a compulsive sexual preference for
4
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=== Page 5 ===
Case 1:20-cv-02365-LJL Document 1 Filed 03/17/20 Page 5 of 8
young females and took pleasure in corrupting vulnerable young females into engaging in sexual
acts with him. The allegations herein primarily concern Jeffrey Epstein's conduct while at his
NY, Virgin Islands, Florida, New Mexico, and Paris residences and other locations.
18.
Epstein fulfilled his compulsive need for sexual contact with and control over
young females by preying on their personal, psychological, financial, and related vulnerabilities.
Epstein's tactics included promising the victims shelter, transportation, gifts, money and
employment, admission into educational institutions, educational tuition, protection, illusion of
family and other things of value in exchange for sex.
19.
Jeffrey Epstein specifically targeted underprivileged, emotionally vulnerable
and/or economically disadvantaged young females exactly like Plaintiff to sexually molest and
abuse.
20.
Epstein's continuous psychological and physical control over Jane Doe facilitated
his sexual abuse of her on a relatively consistent basis for many years.
21.
The sexual abuse took many forms including Epstein's rape of Plaintiff.
22.
He would also enter plaintiff's room and get into her bed while she was sleeping
and then fondle or penetrate her with his fingers. This occurred often and repeatedly.
23.
He often directed her to undress and pose in certain ways and/or touch him and
herself while he masturbated. This occurred often and repeatedly.
24.
Epstein frequently directed Jane Doe to turn her head back during their sexual
encounters, telling her that he did not want to see her face.
25.
Epstein also repeatedly required Jane Doe to bathe with him and perform oral sex
on him.
26.
This occurred in New York, Palm Beach, New Mexico, London, Paris, on
5
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=== Page 6 ===
Case 1:20-cv-02365-LJL Document 1 Filed 03/17/20 Page 6 of 8
Epstein's private island, on Epstein's airplanes and other locations.
27.
Jane Doe was paid in part to be sexually available to Epstein.
28.
In or about January or February 2012, Epstein grabbed Plaintiff by the hand while
at his New York City Residence and took her to a small room on the third floor. It was a room
with two chairs in it. He sat her down, pulled her pants down, covered her eyes, and used a
vibrator on her. Epstein laughed afterwards.
CAUSE OF ACTION I AGAINST EPSTEIN
29.
Defendant, within the special maritime and territorial jurisdiction of the United
States, in interstate and foreign commerce, and/or affecting interstate and foreign commerce,
knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
solicited, threatened, forced, or coerced Plaintiff to engage in commercial sex acts.
30.
Such actions were undertaken knowing that Defendant Epstein's use of force,
threats of force, fraud, coercion, and/or combinations of such means would be used, and were in
fact used, in order to cause Plaintiff to engage in commercial sex acts. In doing so, Defendant
violated 18 U.S.C. $ 1591.
31.
Furthermore, Defendant attempted to violate 18 U.S.C. $ 1591. In doing so,
violated U.S.C. $ 1594(a).
32.
Defendant conspired with each member of the enterprise, and with other persons
known and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated U.S.C. $
1594(a).
33.
By virtue of Defendant's violations of 18 U.S.C. §§ 1591, 1593A, and 1594,
Defendant Darren K. Indyke and Richard D. Khan as Joint Personal Representatives of the Estate
of Jeffrey E. Epstein is subject to civil causes of action under 18 U.S.C. $ 1595 by Plaintiff, who
6
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=== Page 7 ===
Case 1:20-cv-02365-LJL Document 1 Filed 03/17/20 Page 7 of 8
is a victim of the violations.
34.
Certain property of Defendant was essential to the commission of the federal
crimes and torts described herein, including the use of multiple private aircraft including a
Boeing aircraft (of make and model B-727-31H with a tail number N908JE) and a Gulfstream
aircraft (of make and model G-1159B with a tail number N909JE). Such aircraft, along with
other of Defendants' property, were used as means and instruments of Defendants' tortious and
criminal offenses and, as such, are subject to forfeiture.
35.
Additionally, Defendant's mansion, located at 9 East 71st Street, New York, New
York, in the Southern District of New York, his Palm Beach residence and his private island
located in the United States Virgin Islands, and his ranch in New Mexico were among those used
as means and instruments of Defendants' tortious and criminal offenses, and, as such, are subject
to forfeiture.
36.
As direct and proximate result of Defendant's commission of the aforementioned
criminal offenses enumerated in 18 U.S.C. $ 1591, 1593A, and 1594, and the associated civil
remedies provide in $ 1595, Plaintiff has in the past suffered and will continue to suffer injury
and pain; emotional distress; psychological and psychiatric trauma; mental anguish; humiliation;
confusion; embarrassment; loss of self-esteem; loss of dignity; loss of enjoyment of life; invasion
of privacy; and other damages associated with actions. Plaintiff will incur further legal, medical
and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to
suffer from them in the future. In addition to these losses, Plaintiff has incurred attorneys' fees
and will be required do so in the future.
37.
WHEREFORE, Plaintiff demands judgment against Defendants for compensatory
and general damages, attorneys' fees, punitive damages and such other and further relief as this
7
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=== Page 8 ===
Case 1:20-cv-02365-LJL Document 1 Filed 03/17/20 Page 8 of 8
Court deems just proper. Plaintiff hereby demands trial by jury on all issues triable as of right by
a jury.
WHEREFORE, Plaintiff demands judgment against defendants as follows:
(i)
Assessing compensatory damages and punitive damages in an amount to be
determined at trial;
(ii) Attorney's fees and interest, and disbursements; and
(iii) For such other relief as the Court deems just and proper.
Dated: New York, New York
March 17, 2020
KAISER SAURBORN & MAIR, P.C.
V-IL
By:
Daniel J. Kaiser, Esq.
William H. Kaiser, Esq.
Attorneys for Plaintiff
30 Broad Street, 37th Floor
New York, New York 10004
(212) 338-9100
8
EFTA00023147


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=== Page 1 ===
From:
To:
Cc:
Subject: Modification to close-out 15JA5421F00000068
Date: Thu, 15 Jul 2021 14:30:55 +0000
Attachments: P00001.pdf
Inline-Images: image001.jpg; image002.jpg
Hi
Attached is modification P00001 to close out the referenced task order for your files. Thanks.
DEPARTMENT OF
Contract Specialist (FAC-C/COR III)
U.S. Attorney's Office, Southern District of New York
86 Chambers St. /New York NY 10007
EFTA00021163


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=== Page 1 ===
From:
"
To:
)"
Subject: Re: EMail 1 of 2: EPSTEIN
signed application/affidavit
Date: Thu, 29 Oct 2020 18:00:22 +0000
Inline-Images: image003.jpg
I think the application had attachments right? We should include those on the version we save on the shared (you
are probably on top of this already)
On Oct 29, 2020, at 1:45 PM,
)
wrote:
Attached are the signed warrant materials.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From:
Sent: Thursday, October 29, 2020 11:51 AM
To:
)
Cc:
Subject: FW: EMail 1 of 2: EPSTEIN
signed application/affidavit
Good Morning
Your signed Warrants are attached.
Arraignment Unit Clerk
United States District Court
<image003.jpg>
Southern District of New York
New York. NY 10007
EFTA00020897

=== Page 2 ===
From
Sent: Wednesday, October 28, 2020 7:18 PM
To
Cc:
Subject: FW: EMail 1 of 2: EPSTEIN -
signed application/affidavit
From
Sent: Tuesday, October 27, 2020 7:18 PM
To:
Subject: EMail 1 of 2: EPSTEIN -
, signed application/affidavit
USDC-SDNY
Sent from my mobile device
<20 MAG 11668
odf>
<20 MAG 11668.1
pdf>
UNTED STATES DISTRICTION CECOURT
0
EFTA00020898


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=== Page 1 ===
From:
To:
"
Cc:
,
Bcc: "USAHUB-USAJournal111"
Subject: RE: Wednesday's WebEx
Date: Mon, 26 Oct 2020 22:18:34 +0000
Embedded: RE:_Wednesday's_WebEx.msg
Sender:
Subject: RE: Wednesday's WebEx
Message-Id:
V
To:
Cc:
EFTA00023257


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=== Page 1 ===
From:
To:
Cc:
(USANYS) [Contractor]"
Subject: RE: Discovery - Witness Checks (from
)
Date: Tue, 05 Oct 2021 15:49:41 +0000
Thanks,
!
These have all been added to their respective folders.
From:
Sent: Tuesday, October 5, 2021 10:59 AM
To:
>;
Subject: RE: Discovery - Witness Checks (from
)
The Accurint checks for
should be added to their witness and 3500 folders. Maxwell
and Epstein you can put in the next production. Thanks!
From:
Sent: Tuesday, October 5, 2021 10:55 AM
To:
is
Subject: Discovery - Witness Checks (from
Hi team - I just picked up a disc from
containing Accurint witness checks on
,
Ghislaine Maxwell, Jeffrey Epstein, and
Would you like this added to the next
pending production folder? Thanks!
Paralegal Specialist
U.S. Attorney's Office
I
SDNY
1 St.
Plaza
New York, NY 10007
EFTA00023479


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=== Page 1 ===
From:
To:
Subject: RE: Out of money
Date: Thu, 10 Sep 2020 19:51:20 +0000
No.
Original Message
From:
Sent: Thursday, September 10, 2020 3:50 PM
To:
Subject: RE: Out of money
Did
respond to your email on this earlier?
Original Message
From:
Sent: Thursday, September 10, 2020 3:50 PM
To:
Subject: RE: Out of money
It's about 10k.
Original Message
From:
Sent: Thursday, September 10, 2020 3:39 PM
To:
Cc:
Subject: RE: Out of money
says we are seriously out of money. That said, he also said he'll deal with the emergencies. And Maxwell is
on his radar. So depending on how much money we are talking about, there will be some play in the joints.
Original Message
From:
Sent: Thursday, September 10, 2020 3:38 PM
To:
Cc:
Subject: FW: Out of money
Do you know if there is any play in the joints on this? We were hoping to hire an SDFL vendor immediately to
start work on scanning the SDFL Epstein stuff and to help process the OPR Epstein stuff. Would prefer not to put
that off until October if possible.
Original Message
From:
(USANYS)
Sent: Thursday, September 10, 2020 2:48 PM
To:
Cc:
Subject: Out of money
EFTA00023018

=== Page 2 ===
We are out of money through the end of the fiscal. Everything new will have to wait.
Sent from my iPad
EFTA00023019


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: [EXTERNAL EMAIL] - FW: Epstein victim call
Date: Thu, 25 Feb 2021 18:40:15 +0000
Great, thank you.
From:
Sent: Thursday, February 25, 2021 1:34 PM
To:
is
Cc:
Subject: [EXTERNAL EMAIL] - FW: Epstein victim call
No problem
I believe
was in contact with her. I will follow up with her this week.
Special Agent
FBI New York Field Office
On Feb 25, 2021 12:56 PM,
wrote:
Hi
and
Please see below. Would someone at the FBI be able to contact this woman for initial screening, please? Per our usual
practice, if the screening suggests she may have useful information for our investigation, we can schedule an interview
with the team.
Thanks,
From:
Sent: Thursday, February 25, 2021 12:46 PM
To:
is
is
Cc:
Subject: Epstein victim call
Team, I just received a call on my desk line from a woman named
who identified herself as a former
client of
and said she was a former victim of Jeffrey Epstein. I asked if her attorney had been in touch with
either the prosecutors or the case agents, since we had previously contacted him, and she said she believed he had not
been. She said she had been in touch with an NYPD detective but had not heard back in some time. She said
represented her for purposes of the Victim Fund, but was not currently representing her. She provided her cell phone as
She did not provide any substantive information on the call, and I did not ask for any. I advised that
someone would follow up with her, hopefully in the next week or so. The call lasted less than three minutes.
For context, we were in touch with Mr.
several times in 2020 when he claimed to represent at least nine Epstein
victims, all of which he said were unwilling to speak with us. He subsequently said one victim might be willing to speak
with us, but then stopped responding to our requests for the complaints he had purportedly filed (but which we couldn't
find online). I believe the last communication we had with him was the attached.
EFTA00021381

=== Page 2 ===
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00021382


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=== Page 1 ===
From:
)"
To: Martin Weinberg
Cc: "Weingarten, Reid"
)"
Subject: RE: bail topics
Date: Mon, 15 Jul 2019 21:48:03 +0000
Importance: Normal
Thank you.
From: Martin Weinberg
Sent: Monday, July 15, 2019 17:41
To:
Cc: Weingarten, Reid
>;
>;
)
Subject: Re: bail topics
Yes, we assent
Sent from my iPhone
On Jul 15, 2019, at 5:36 PM,
wrote:
Separate from the below, at the conference today I neglected to ask the court to exclude speedy trial time until
Thursday, which I'm going to ask for in a letter this evening-could you please let us know if you consent?
thank you,
From:
Sent: Monday, July 15, 2019 14:38
To: 'Martin G. Weinberg'
>; 'Weingarten, Reid'
Cc:
is
Subject: RE: bail topics
Marty, Reid,
Briefly following up on this morning, if you could please let us know what if any information you're able to provide about
the passport we discussed, with the copies we provided to you, we can address any new info as appropriate for a
possible submission tomorrow.
Related, something I'm not sure we've specifically asked, and I'm not sure whether pretrial asked-can you please
advise whether Mr. Epstein currently is, or has been in the past, a citizen or legal permanent resident of a country other
than the United States?
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00021426

=== Page 2 ===
EFTA00021427


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=== Page 1 ===
From:
To:
Bcc:
Subject: Jeffrey Epstein
Date: Tue, 23 Jul 2019 18:22:13 +0000
Hi,
Our Jeffrey Epstein team here is working on gathering material that may be discoverable in our case
or pertinent to an anticipated motion by Epstein for dismissal based on the S.D.Fla. agreement. We assume you
had to pull together a lot of discovery for the CVRA litigation, and that you probably have a good sense of where
else, or with whom else, in the S.D.Fla., we might need to look for pertinent information. The attorneys in the
N.D.Ga. who are handling the CVRA litigation said we should check directly with you, and
cleared us to reach out to you directly on this. Would you have some time this week for us to give you a call
about this? Thanks much,
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
New York, NY 10007
EFTA00022533


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: gloria allred purchases prince andrew 'wanted' poster
Date: Fri, 21 Feb 2020 14:46:13 +0000
Inline-Images: image001.jpg
Chief Public Information Officer
U.S. Attorney's Office, SDNY
On Feb 21, 2020, at 9:04 AM,
wrote:
Sent from my iPhone
Begin forwarded message:
From: "Katersky, Aaron" <Aaron.Katersky@abc.com>
Date: February 21, 2020 at 9:00:21 AM EST
To:
Subject: FW: gloria allred purchases prince andrew 'wanted' poster
Attorney Gloria Allred said she placed an ad on a school bus that circled Buckingham Palace this morning, calling for
him to talk to the FBI about the Jeffrey Epstein case.
The bus carried a large picture of the prince accompanied by the message -- "If you see this man please ask him to call
the FBI to answer their questions."
Allred just discussed her stunt outside criminal court in Lower Manhattan, where she is attending the Harvey
Weinstein trial.
Allred who represents some of Epstein's victims.
Allred displayed a photo of the bus on her computer and a photo from the Press Association is below
EFTA00023405

=== Page 2 ===
<image001.jpg>
The message on the bus was from US lawyer Gloria Allred. Photograph: Stefan Rousseau/PA
If you see this nan please ask him to call
the FBV to answer their questions
+1 (202) 324-3000
gloriaalired. com
gloriaallred.com
EFTA00023406


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
)"
Subject: RE: Epstein Sharing Order Part II
Date: Wed, 29 Jan 2020 20:54:50 +0000
Please add it in the right place and send me the order. Remember, I'm not a T&E lawyer. But you are getting to
be
From:
Sent: Wednesday, January 29, 2020 3:22 PM
To:
(USANYS)
is
(USANYS)
Cc:
>;
)
Subject: RE: Epstein Sharing Order Part Il
Yes, I think this document accurately describes the materials we've received, with just a note that it doesn't appear to
include revocations, so to the extent those are intended to be shared, I think that word may need to be added.
thanks,
From:
(USANYS)
Sent: Wednesday, January 29, 2020 10:40
To:
(USANYS)
is
Subject: Epstein Sharing Order Part Il
- I've updated the sharing order application to be one to share the additional trust and will documents we have now
received. Would you take a look when you can?
- I've tried to describe the various materials we have gotten from the estate attorneys over the last two weeks.
Would you mind taking a look (or asking a paralegal to take a look) to make sure I've accurately described/characterized
the new stuff we're looking to share?
Thanks,
EFTA00022990


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=== Page 1 ===
From:
To:
Subject: Re: https://www.nytimes.com/2021/02/18/fashion/alexander-wang-accusations.html
Date: Thu, 18 Feb 2021 20:39:03 +0000
Great! For sure, will do.
Sent from my iPhone
On Feb 18, 2021, at 3:24 PM,
Thanks again for sending this! Not sure there's a federal nexus, but the lawyer representing the victims represents
several Epstein victims, so I might reach out to her to see if there could possibly be something to work with.
If you see anything else like this, I'd be happy to have it passed along to me. I'm hoping to bring more sex abuse cases in
VOC.
From:
Sent: Thursday, February 18, 2021 12:41 PM
To:
Subject: https://www.nytimes.com/2021/02/18/fashion/alexander-wang-accusations.html
This may be dumb and I don't know if there's a federal nexus, but thought this was interesting (and had no idea who
else to send it to).
Spokesman
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
EFTA00021350


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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Epstein Victim Impact Statements
Date: Wed, 30 Oct 2019 17:30:28 +0000
On the third question, I think there may have been one or two victims who expressed an interest in attending but didn't
make it (I recall that
missed a flight, and I'm not sure if anyone else had issues like that), but I don't believe
any of those people in particular told us that they wanted to make a statement.
From:
Sent: Wednesday, October 30, 2019 1:23 PM
To:
(USANYS)
is
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein Victim Impact Statements
For the first question, the AUSAs contacted the attorneys we were aware of who represented victims to tell them that
their clients were welcome to attend and to make a statement. I believe
also sent out notifications, and hopefully
she can tell us how many she sent.
For the second question, based on my review of the transcript (attached), a total of 17 victims were present at the hearing
and either spoke at the hearing or had someone read a statement for them. An additional 7 did not attend the hearing
but had someone else speak for them or read a statement from them. It is possible there were others present who were
not referenced on the record.
I don't think we can answer the third question. I don't recall anyone off the top of my head who wanted to attend but
was unable to, but it's possible there were some in that position.
From:
(USANYS)
Sent: Wednesday, October 30, 2019 1:06 PM
To:
>;
i
;
i
(USANYS)
Cc:
(USANYS)
Subject: FW: Epstein Victim Impact Statements
Importance: High
Are we able to answer these questions for ODAG quickly? I am sure we can answer the second, and maybe the first - not
sure about the third.
From:
(ODAG)
Sent: Wednesday, October 30, 2019 12:53 PM
To:
(USANYS)
Cc:
(ODAG)
Subject: Epstein Victim Impact Statements
Importance: High
EFTA00021290

=== Page 2 ===
,
The Petitioner in the Epstein CVRA case has filed an appeal to the 11th Circuit. One of their issues is the
District Court's refusal to hold a hearing allowing the Epstein victims to "have their day in court." The
Court's ruling is, in part, on the basis that a hearing held in SDNY satisfied this request. The Petitioner has
alleged that not all of the Epstein victims who wanted to speak were able to do so at the New York hearing
because they did not have sufficient notice and were unable to travel to NY.
Can your office provide us some details about the following: 1) how many victims were contacted about
making a victim impact statement; 2) how many victims were able to travel and make an in-person victim
impact statement; and 3) how many victims indicated they wanted to make a victim impact statement but
were unable to do so given the notice/timing of the hearing?
Please provide as much of this information as possible today. I'm very sorry for the quick turnaround but
the Department's response to the mandamus petition is due tomorrow.
I really appreciate your assistance.
National Coordinator for Child Exploitation Prevention & Interdiction
Office of the Deputy Attorney General
Direct:
EFTA00021291


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
i
Subject: Travel Authorization 11063042 approved by
, now awaiting further
approval
Date: Thu, 13 Feb 2020 22:24:32 +0000
Importance: Normal
Dear
Travel authorization 11063042 has been approved by
, now awaiting further approval.
Trip ID: 11063042
Traveler name:
Purpose: R20NYS13403 - Epstein Investigation - Witness interview
Destination: Pensacola, FL, United States
Dates: 2020-02-19 - 2020-02-20
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0007
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00023262


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=== Page 1 ===
From:
To:
Subject: Voucher for Trip 10777198 is late
Date: Tue, 12 Nov 2019 05:02:37 +0000
Importance: Normal
Dear
Your travel voucher for the trip below is now late based on your customer settings. Please submit your voucher
for this trip and mark it as Final if you have no additional expenses to claim.
Trip ID: 10777198
Traveler name:
Destination: West Palm Beach
Purpose: R20NYS13144 - Epstein investigation - Witness Interviews
Trip Dates: 2019-11-04 - 2019-11-05
Current status: Authorization Approved
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0013
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00021156


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=== Page 1 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
Person Encounter Detail
09/21/2021 11:31 EDT
Generated By:
Page 1 of 1
Encounter Person Detail
Last Name
First Name
Middle Initial
Gender
Date of Birth
MAXWELL
GHISLAINE
Document Number
Document Type
Document Country
Class of Admission
Admit Until Date
PASSPORT
FRANCE
Encounter Person Detail
Encounter Line Type
Encounter Date
Encounter Time (Eastern)
Terminal Lane
Site/Encounter Location
ADVANCED PASSENGER
07/20/1998
19:30
EF03
4701 - 4701
RECORD
Inbound/Outbound
Inspector
Processing Result
Primary Query Result
Referred To Agency
INBOUND
3
NOT REFERRED
Manifest Data
Manifest Indicator
Passenger Status
Updated Passenger Status
Flight/Vessel Number
Departure Location
C
113
LHR - LONDON / HEATHROW
INTL
Transmitted By
Carrier Code
Arrival Location
RTZ
BA
JFK JOHN F KENNEDY INTL
For Official Use Only / Law Enforcement Sensitive
EFTA00021187


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: signature card
Date: Wed, 23 Jun 2021 16:57:53 +0000
Attachments: Maxwell_Account_Documents.pdf
The following is derived the JPMC Jeffery Epstein production.
Beginning
Ending
Bates
Bates
Description
Number
Number
Comment
JPMC - Hyperion Air Account
1788
1813
Ghislaine Maxwell listed as Treasurer
Documents (account
and authorized account signer - bates
# 1793
Jeffery Epstein Account
2376
2396
Ghislaine Maxwell listed as authorized
Documents (account
account signer - bates # - 2380
Freedom Air International Inc. /
2399
2469
Ghislaine Maxwell listed as president
Ghislaine Air Inc. Account/
and authorized account signer
Hyperion Air Inc. Documents
(account
- bates # 2410 -
(accounts
2411
)
Ghislaine Maxwell listed as Treasurer
and authorized account signer
(account
) - bates # 2443,
2449, 2462
JEGE Inc. Account Documents
2470
2486
Ghislaine Maxwell listed as authorized
(account
account signer - bates #- - 2470, 2474,
2478
Ghislaine Maxwell Account
2545
2556
Ghislaine Maxwell signature card -
Document (account
bates # 2551
5)
The following is derived from the JPMC Ghislaine Maxwell production. (copy attached of referenced items)
Description
Comment
Ghislaine Maxwell (account
Ghislaine Maxwell listed on
signature card - bates # 6
116 East 65th Street LLC (account
Ghislaine Maxwell listed on
)
signature card - bates # 1
EFTA00021994

=== Page 2 ===
Terra Mar Project Inc (account
Ghislaine Maxwell listed on
)
signature card - bates # 15
Max Hotel Services Corp (account
Ghislaine Maxwell listed on
signature card - bates # 11
I will send you references to KYC documents in a separate email.
If you have any questions, please contact me.
Best
From:
Sent: Wednesday, June 23, 2021 11:03 AM
To:
Cc:
Subject: [EXTERNAL EMAIL] - RE: signature card
Thanks! If you're able to send any other account ownership/KYC documents, that would be helpful.
From:
Sent: Wednesday, June 23, 2021 10:42 AM
To:
Cc
Subject: RE: signature card
Attached is the FTC October 1999 account statement. The $18,300,000 transfer to Maxwell is shown on bates number
36868. On that same page, a deposit of $18,300,000 is made sourced from the sale of JP Morgan Institutional Prime
Money Market Fund.
If you have any questions, please contact me.
Best
From:
Sent: Wednesday, June 23, 2021 10:14 AM
To:
Cc:
Subject: [EXTERNAL EMAIL] - FW: signature card
EFTA00021995

=== Page 3 ===
Thanks for sending. For this account, could you please send us the account statements surrounding the 10/19/99 transfer
to Maxwell that we discussed? It would be helpful to understand what the source is of the funds for the transfer. In
addition, could you please let me know the bates range for the account documents for this account? I'm having difficulty
locating them in the production. If you're able to flag any other KYC documents in the file, that would be extremely
helpful.
Thanks,
From:
Sent: Wednesday, June 23, 2021 10:04 AM
To
Cc
Subject: RE: signature card
Attached are the account documents for the Financial Trust Company. In the production, I did not see a signature card for
these accounts. However, there is a J.P. Morgan Entity Resolution form which schedules authorized signers (bates # 1934).
If you have any questions, please contact me.
Best
From
Sent: Tuesday, June 22, 2021 3:14 PM
To:
Subject: [EXTERNAL EMAIL] - signature card
Hi
When you have a moment, could you please send me the signature card for the JP Morgan account ending in
It's
the Financial Trust Co. account. I wasn't able to easily locate it in the production, so wanted to check with you.
Thanks!
Assistant United States Attorney
Southern District of New York
EFTA00021996


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=== Page 1 ===
From:
To:
Cc:
Subject: Referral of MLAT Request from France
Date: Wed, 30 Dec 2020 10:57:39 +0000
Attachments: 2020002015-Depi_En.pdf; 2020002015-Depi_Fr.pdf;,
Referral_Letter_(SDNY)_(December_2020).pdf
Dear
:
I hope you are both doing well, and have been enjoying the end of year festivities.
I am referring for your attention an MLAT request from the French in relation to their investigation of
(who was recently arrested and placed under examination here in Paris). Since I have been in touch anyway with
and
about the Maxwell bail proceedings, I took the opportunity to mention that this might be
coming their way.
Thanks in advance, and happy new year!
DOJ Attaché/Magistrat de liaison américain
U.S. Embassy, Paris
Ofc.
Mob
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From:
(USANYS) [Contractor]"
To:
(USANYS)"
Subject: AT&T court subpoena question
Date: Wed, 03 Nov 2021 19:01:21 +0000
Attachments: 2021.07.28_Court_Subpoena_-_AT&T.pdf
Hey
I know you're traveling, but when you get a chance, could you please let me know if you ever received a subpoena return
for the attached AT&T subpoena? I'm working on
checking all GJ and court subpoena returns, and I've found a few
other returns for two other AT&T court subpoenas, though not this one. Please let me know when you can, thank you!
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 Saint Andrew's Plaza
New York, NY 10007
Office
Cell:
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=== Page 1 ===
From:
(NY) (FBI)"
To:
)"
(NY) (FBI)"
Cc:
)"
)"
Subject: New York search warrant materials
Date: Mon, 30 Sep 2019 19:22:53 +0000
So the short answer is that the load files are not completed yet. One machine alone had over 800,000 emails. The
limitation of the load files is that they can only be generated with 25,000 entries at a time. So I got out as quickly
as I could what fit that bill. Now along has come all the stuff from the Island that had an expiration date, so that
took priority. I can now go back and try to generate the stuff that has yet to be processed into load files, but the
process is slow and painful. Just as an FYI, all the content is available for taint review in FTK right now.
Senior Forensic Examiner
cell
desk
On Sep 30, 2019 3:13 PM,
(NY) (FBI)"
wrote:
Hey
,
I've copied
here who has handled all of the Epstein evidence that was sent to CART. He should
be able to answer your questions regarding what he's processed.
On Sep 30, 2019 1:57 PM,
)"
wrote:
The taint team here apparently received materials from the search of the New York house but it's way fewer
documents than we would have expected. Can you please let us know exactly how many electronic devices (phones,
computers, hard drives, thumb drives, and/or discs) were sent to CART for processing, and how many were in fact
processed and sent back to us? Or if it's easier to just put us in touch with the CART people directly, that's fine too.
My understanding was that they were processing the materials in the attached, which appears to list approximately
38 computers and/or electronic storage devices seized along with an additional approximately 55 CDs.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00021704


