# docs_fts_content

c1: EFTA00015277
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015277.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Date: Wed, 16 Jun 2021 19:54:46 +0000
Attachments: Ex._H_Sealed.pdf
Here it is - Ex H.
From:
(USANYS)
Sent: Wednesday, June 16, 2021 3:45 PM
To:
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
And can you send me MJ Netburn's decision? Exhibit I to the def motion, I think
From:
(USANYS)
Sent: Wednesday, June 16, 2021 11:58 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Pottinger was a lawyer at Boies Schiller who represented
,
the plaintiff in the civil action.
The two letters we submitted in connection with our All Writs Application are attached.
From:
(USANYS)
Sent: Wednesday, June 16, 2021 11:53 AM
To:
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Another Q: who's Stan Pottinger?
From:
(USANYS)
Sent: Wednesday, June 16, 2021 10:53 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
From:
(USANYS)
Sent: Wednesday, June 16, 2021 10:40 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Can I see our original application to Judge Sweet? And I assume there was no transcript before Judge S?
EFTA00015277

=== Page 2 ===
From:
(USANYS)
Sent: Tuesday, June 15, 2021 5:45 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
In the spirit of completeness, I'm also attaching their replies.
From:
(USANYS)
Sent: Tuesday, June 15, 2021 5:20 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Re: Question re AJN/Maxwell Suppression Hearing
Goodness!
Associate U.S. Attorney
Southern District of New York
On Jun 15, 2021, at 5:06 PM,
(USANYS)
wrote:
She filed 12 (II) separate MOLs as a way to evade the Court's page limits. Defense attorneys have started doing that
over the last few years.
From:
(USANYS)
Sent: Tuesday, June 15, 2021 4:25 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Dumb Q: why does Maxwell have two memos of law?
From:
(USANYS)
Sent: Tuesday, June 15, 2021 2:19 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Per our discussion, I am attaching: (1) Maxwell's two briefs raising the suppression argument; (2) the transcript of the
McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our
motion (Ex 4-7). Judge Nathan has said that she will resolve the suppression motions "at a later time" ahead of trial.
Thanks very much.
From:
(USANYS)
Sent: Tuesday, June 15, 2021 10:09 AM
To:
(USANYS)
EFTA00015278

=== Page 3 ===
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Question re AJN/Maxwell Suppression Hearing
Sure, set a time other than 2:00. I'm in the office. Or Webex
From:
(USANYS)
Sent: Tuesday, June 15, 2021 9:11 AM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Question re AJN/Maxwell Suppression Hearing
Hi
We had an issue come up related to the upcoming suppression hearing (no date set yet, although we expect one)
related to
that we'd like your thoughts on. Let us know a convenient time to stop by over the next
few days, thanks.
Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
EFTA00015279


c1: EFTA00015328
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015328.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: FW: Subject: Request for Assistance Bringing
into the U.S. To Assist with
Law Enforcement Investigation
Date: Mon, 21 Oct 2019 18:34:48 +0000
Inline-Images: image001.jpg
If it touches on that case, it needs to go through them.
On Oct 21, 2019 2:34 PM,
wrote:
I know - but talking to
it seems like these facts aren't consistent. But if you think
and
are the best fit,
that's fine.
From:
Sent: Monday, October 21, 2019 2:31 PM
To:
Cc:
Subject: RE: FW: Subject: Request for Assistance Bringing
into the U.S. To Assist with Law Enforcement
Investigation
It references epstein multiple times.
On Oct 21, 2019 2:30 PM,
wrote:
I don't think that it does - so we'd like different agents, if possible.
From:
Sent: Monday, October 21, 2019 2:29 PM
To:
Cc:
Subject: Re: FW: Subject: Request for Assistance Bringing
into the U.S. To Assist with Law Enforcement
Investigation
If it has any connection to Epstein, it should go to
and
on my squad.
-
On Oct 21, 2019 2:21 PM,
wrote:
is there someone from the squad who is available to look into this? I can explain more by phone. Thanks.
From:
Sent: Monday, October 21, 2019 1:56 PM
To:
Cc:
is
i
EFTA00015328

=== Page 2 ===
is
is
Subject: Re: Subject: Request for Assistance Bringing
into the U.S. To Assist with Law Enforcement
Investigation
Please send me a number where we can reach you. Or you can call me on my cell at
Best
Marsh Law Firm PLLC
Direct Dial
Skype for Business
Blog I Facebook I Twitter I LinkedIn
From
Sent: Monday, October 21, 2019 1:48 PM
To:
Cc:
i
i
is
is
Subject: Re: Subject: Request for Assistance Bringing
into the U.S. To Assist with Law Enforcement
Investigation
Hi Ms.
-
We will call you very shortly.
Thank you so much.
Best,
Marsh Law Firm PLLC
Direct Dial
Skype for Business
Blog I Facebook I Twitter I LinkedIn
EFTA00015329

=== Page 3 ===
From:
Sent: Monday, October 21, 2019 1:46 PM
To:
Cc:
V.
i
>;
i
Subject: RE: Subject: Request for Assistance Bringing
into the U.S. To Assist with Law Enforcement
Investigation
Ms.
Please let me know when you have time to discuss this case.
Thanks,
From:
Sent: Monday, October 21, 2019 1:37 PM
To:
in
>
Cc:
V.
>;
is
Subject: RE: Subject: Request for Assistance Bringing
into the U.S. To Assist with Law Enforcement
Investigation
Thank you for being in touch, and for your assistance to Ms.
and also thank you to
for assisting
and facilitating. I've spoken with the human trafficking coordinator in our office,
who is our point person
for these types of circumstances and I'm copying her so she can reach out to you directly. My general
understanding is that we are very limited in our ability to affect immigration processes in particular, and that
ordinarily it would go through law enforcement and/or the normal visa process, and it sounds like those are
perhaps in progress, but
will know much better than I whether there are applicable exceptions to the normal
prohibitions on our direct involvement.
Thank you again for contacting us, and I certainly hope for a positive outcome for Ms.
Respectfully,
From:
Sent: Saturday, October 19, 2019 15:06
To:
)
Cc:
i
i
is
EFTA00015330

=== Page 4 ===
Subject: Subject: Request for Assistance Bringing
into the U.S. To Assist with Law Enforcement
Investigation
Dear Mr.
-
We reach out to you at the suggestion of
who we understand has been in touch
with you about our client,
sex trafficking in
the
United States, and Canada, and who appears to have information relevant to the Epstein investigation
and other sex trafficking crimes in the U.S. and elsewhere.
We need immediate assistance obtaining entry into the U.S. for
, and
others. As part of this trafficking, there is pictorial and other evidence that
at
approximately age five in a NYC location that may have been 9 East 71st Street in Manhattan, Jeffrey
Epstein's mansion.
similar perpetrators, stories and wounds to a large group of very young children, some of
whom are American, studied by Dr.
for many years. They all appear to be part of a powerful,
violent child sex trafficking ring in
the U.S., Canada, and elsewhere.
For the last several months, Dr.
and attorneys with the Marsh Law Firm PLLC have sought
assistance from law enforcement without success. Dr.
repeatedly left tips on the FBI hotline, and
briefly spoke with NYPD Detective
from the Epstein SDNY Taskforce. Dr.
talked with
several FBI agents as well as agents from Homeland Security, making images available to them. She was
advised that they had enough information, did not want further information, and would be back to her.
U.S. law
enforcement.
One of the photos depicts the
a child in or about 1997,
in a room
with a blue couch and a window facing the street. While the image outside the window is blurry, it
appears to be consistent with the view from an upper floor room at the front of Epstein's mansion,
which overlooks the Frick Museum across 71st Street between Madison and Fifth Avenues.
provided other information evidencing that she was
Epstein's mansion she has said that the
house was "big", was owned by a "rich" man, was located at "9 71", had a large, arched front door
topped by a scary man's face and flanked on either side by women's faces, had a large, adult doll on a
chandelier inside the house, had photos of what looked like important people around the house, and
contained many bedrooms. The "bigger girls" were placed in other bedrooms.
hearing the
EFTA00015331

=== Page 5 ===
names "Jeffrey",
, and others during her time at the house. Presumably
law enforcement would be able to sharpen the image to determine whether the room overlooked the
Frick Museum, and compare the information she has provided with the information known about the
features and contents of Epstein's mansion and the perpetrators, to help determine whether she was
with law
enforcement, Dr.
has received substantial evidence, including the photograph described above,
written communications from
names of other traffickers at Epstein's mansion, photographs of
the names of perpetrators pictured in some of the
photographs, current phone numbers of perpetrators who communicated
and conversations
with perpetrators.
We beseech you to do whatever you can to help
in order to enable us to
deliver such information to law enforcement.
Sincerely,
Marsh Law Firm PLLC
Direct Dial
Skype for Business
Blog Facebook I Twitter I LinkedIn
CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is
confidential and may be subject to the attorney-client privilege, or otherwise protected from disclosure by
applicable law. Any disclosure, distribution, copying, or use of the information contained in this message
or any attachment by anyone other than the intended recipient, regardless of address or routing, is strictly
prohibited. If you are not the intended recipient, please telephone or email the sender and delete this
message and any attachment from your system.
IF YOU ARE NOT A CLIENT: This material is general information of an educational nature and is not
legal advice. This communication does not establish or constitute the retention of Marsh Law Firm PLLC
for the provision of legal services, unless explicitly so stated herein. Any attached items, including the
content of this e-mail, are offered "as is" with no guarantee as to their accuracy, timeliness, or
completeness.
CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is
confidential and may be subject to the attorney-client privilege, or otherwise protected from disclosure by
EFTA00015332

=== Page 6 ===
applicable law. Any disclosure, distribution, copying, or use of the information contained in this message
or any attachment by anyone other than the intended recipient, regardless of address or routing, is strictly
prohibited. If you are not the intended recipient, please telephone or email the sender and delete this
message and any attachment from your system.
IF YOU ARE NOT A CLIENT: This material is general information of an educational nature and is not
legal advice. This communication does not establish or constitute the retention of Marsh Law Firm PLLC
for the provision of legal services, unless explicitly so stated herein. Any attached items, including the
content of this e-mail, are offered "as is" with no guarantee as to their accuracy, timeliness, or
completeness.
EFTA00015333


c1: EFTA00016939
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016939.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
)"
Subject: FW: RE: Epstein search warrant documents
Date: Sat, 15 Feb 2020 21:49:55 +0000
Having said all this, below, I'm still going to drop off the hard drive in your office in case you're able to tell what we
previously got and what's new - for obvious reasons I do want the FBI to start identifying this stuff, but if we're able to
move forward on the most recent addition that would be great. If you could please take a look at the hard drive and let us
know either way? Thank you!!
From:
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
(NY) (FBI)
Co
(USANYS) [Contractor]
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
EFTA00016939

=== Page 2 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00016940


c1: EFTA00014346
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014346.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: USA-5 Mail Utility <usa5.sender@usa.doj.gov>
Subject: Automatic reply: USA-5 Reminder for 08/18/2019 - 08/24/2019
Date: Tue, 27 Aug 2019 07:13:20 +0000
I am currently on trial before the Honorable Ronnie Abrams. I will be checking email at the end of each trial day. If you need immediate
assistance in connection with United States V. Epstein, 19 Cr. 490 (RMB), please contact AUSA
5. For all other matters,
please contact
Thank you.
EFTA00014346


c1: EFTA00014893
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014893.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc: Christian Everdell
>, Laura Menninger
>, Jeff Pagliuca
Subject: [EXTERNAL] US V. Maxwell S2 20 Cr. 330 (AJN)
Date: Sun, 28 Nov 2021 03:02:36 +0000
Attachments: Letter_regarding_trial_document_procedure.pdf
Courtesy copy of tonights ECF filing-
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
EFTA00014893


c1: EFTA00016620
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016620.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Christian Everdell
"Laura
,
Menninger"
Cc:
)"
)"
,
(USANYS)"
Subject: Dietz/Loftus redactions
Date: Tue, 23 Nov 2021 20:08:07 +0000
Attachments: Ex._1_[proposed_redactions].pdf
Counsel,
The Court ordered us to docket and propose redactions to the Dietz/Loftus briefing and the Court's Order. We are only
proposing redactions to Exhibit 2 to your response, as attached.
Assuming you have no other redactions, we'll plan to file a cover letter and send our proposed redactions to the Court.
You can then docket the redacted version of your response at your convenience today.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00016620


c1: EFTA00014175
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014175.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Epstein issue with State Attorney's Office
Date: Tue, 04 Aug 2009 17:16:38 +0000
Importance: Normal
It is Tuesday, so there must be a new issue with Epstein. This one potentially involves the Palm Beach County
State Attorney's Office so I included poor
on the email chain.
Here are the two issues:
First, I have heard from several sources that Epstein is trying to convince (or perhaps has already convinced) the
SAO to give him "cooperation credit" to shorten the length of his home confinement based upon "cooperation"
that he is giving to the Feds in the Bernie Madoff case. As you probably remember, a couple of weeks ago some
newspapers reported that Epstein is cooperating with FBI in the Madoff prosecution and that was the real reason
for him receiving such a light sentence. After those newspaper reports came out, the AUSA prosecuting the
Madoff case called me asking who Epstein was and stating in no uncertain terms that Epstein is not cooperating.
Nonetheless, I can imagine our good friends (Goldberger, Lefkowitz, and others) telling the SAO that Epstein
actually is cooperating and that the USAO agrees that he should have his sentence reduced. Now, this could all
be rumor, but
and I have heard it from so many different places (Town of Palm Beach PD, plaintiffs'
attorneys, etc.), that it seems like someone should reach out to the SAO to make sure that they aren't being told
any lies. I, of course, am happy to do so, but I didn't know if you felt that the contact should be made by
or
I also just pulled the state docket sheet and found another motion to "correct" Epstein's sentence that we were
never told about. Docket entry 7 in the procurement of child prostitution case reads: "Agreed Order that the
Order of Community Control is Corrected to Delete Special Condition #26 and #27." Something tells me that
there was no "correction," this was a "change" that takes out things we considered important.
Can
you get this from the courthouse and fax it to me? Case number is 502008CF009381AXXXMB.
Second, if new allegations or new victims come to light, are we allowed to investigate their claims? If we
cannot, or if there is jurisdiction in another district, can we refer to allegations to another USAO to investigate?
There are two very specific items that I would like to investigate further that relate to the S.D.Fl.. Also, as you
recall, we never were able to advance our investigation regarding the New York victims, and none of them were
included in our list of identified victims. The prosecutors on the Madoff case have asked if they can use some of
our evidence - or at least speak with me and the FBI agents -- to prosecute Epstein regarding conduct in New
York.
Thank you.
Assistant U.S. Attorney
Southern District of Florida
500 East Broward Boulevard, 7th Floor
Ft. Lauderdale, FL 33394
EFTA00014175

=== Page 2 ===
EFTA00014176


c1: EFTA00014514
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014514.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
(USANYS)"
(USANYS)"
)"
Subject: FW: USAO SDNY Prisoner for Court Production Request
Date: Mon, 15 Jul 2019 20:39:31 +0000
Importance: Normal
Already on it!
From:
Sent: Monday, July 15, 2019 1:01 PM
To:
(USANYS)
;
(USANYS)
Cc:
(USANYS)
;
Subject: USAO SDNY Prisoner for Court Production Request
PRISONER PRODUCTION FOR COURT REQUEST
Use this e-mail only to order defendants for Court.
DATE
7/18/19
TIME
9:30
JUDGE
Berman
COURT
17B
am
ROOM
PRODUCTION TYPE (enter X in box to the right of
CASE#
19 Cr. 490 (RMB)
description)
Arraignment
Bond hearing
Bond signing
Change of plea
Detention hearing
X
Fatico hearing
Motion hearing
Other, describe below
Preliminary
Revocation hearing
Revocation &
Sentencing
hearing
sentencing
Status hearing
Suppression
Trial
Material witness
hearing
Defendant
USMS #
On writ status
USMS use only/report result to
(indicate Y only)
CrimSec
Sentence
Time served
Detainer
1
Jeffrey Epstein
76318-
054
2
3
4
5
6
7
8
9
EFTA00014514

=== Page 2 ===
10
REMARKS (security precautions, separations, violent crime charge, not standard release issues):
AUSA NAME
AUSA
PHONE
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00014515


c1: EFTA00014966
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014966.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
11/26/21, 6:53 PM
Mail
(NY) (FBI) Outlook
RE: Add to CART for JE evidence review
(NY) (FBI)
<
>
Mon 7/13/2020 1:19 PM
To:
(NY) (FBI)
>
Thank you!
From:
(NY) (FBI)
Sent: Monday, July 13, 2020 12:52 PM
To:
(NY) (FBI)
Cc:
(NY) (FBI)
Subject: RE: Add to CART for JE evidence review
You are all set for access to the Epstein stuff. Let me know if you have any problems.
NYO CART Coordinator
Senior Forensic Examiner
From:
(NY) (FBI)
Sent: Friday, July 10, 2020 4:36 PM
To:
(NY) (FBI)
Cc:
(NY) (FBI)
Subject: Add to CART for JE evidence review
Hi
I have yet to receive access to CAIR and need it on Monday. Please inquire.
Thanks,
On Jul 8, 2020 12:42 PM, "
(NY) (FBI)"
wrote:
Sure. I'll see what's up.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jul 8, 2020 12:41 PM, "
(NY) (FBI)"
wrote:
Hey
Could you add SOS
to CART to review JE evidence items. She has been working with us on this
case and I'd like her to have access to help review items.
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
1/2
EFTA00014966

=== Page 2 ===
11/26/21, 6:53 PM
Mail
(NY) (FBI) - Outlook
She had prior CAIR access for previous JOCs but she does not believe it's current. Could you help with this?
Thanks!
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
U
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
2/2
EFTA00014967


c1: EFTA00015850
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015850.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To
Subject: RE: PRESS CLIPS 7-24-2020
Date: Fri, 24 Jul 2020 17:02:06 +0000
Inline-Images: image001.png
Love the header!
From:
Sent: Friday, July 24, 2020 12:51 PM
To:
Subject: PRESS CLIPS 7-24-2020
OF
SDNY PRESS CLIPPINGS
DEPARTMENT
JUSTITIA
JULY 24, 2020
GLOBAL ENTRY
Yahoo: https://news.yahoo.com/yorkers-allowed-apply-global-entry-110000287.html
The Hill: https://thehill.com/homenews/state-watch/508811-trump-administration-lifts-ban-on-new-orkers-enroling-in-federal
MICHAEL COHEN
https://www.yahoo.com/gma/michael-cohen-released-back-home-confinement-161039423-abc-news-topstories.html
WIRECARD
Reuters: https://www.reuters.com/article/us-wirecard-accounts/germanys-scholz-backs-tougher-oversight-ahead-of-wirecard-hearing-idUSKCN24P216
MAXWELL
ABC: https://abcnews.go.com/USjudge-rule-unsealing-records-defamation-case-ghislaine-maxwell/story2id-71934696
The Hill: https://www.msn.com/en-us/news/politics/lincoln-project-releases-new-video-targeting-trump-comments-on-ghislaine-naxwel/ar-BB179aqphp
MATTERS OF INTEREST
LAW.COM: https://www.law.com/litigationdaily/2020/07/23/how-steptoe-turned-the-tables-on-sdny-prosecutors-in-iran-sanctions-as/?slreturn-20200624124629
EFTA00015850


c1: EFTA00016537
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016537.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Exhibit E
EFTA00016537

=== Page 2 ===
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
November 23rd 2020
Your Honor
This statement is in support of Ghislaine Maxwell's request for bail and her
character.
My name is
I write this letter in support of
Ghislaine Maxwell.
We remain close and have been in communication by phone and videolink most weeks up
until her arrest on July 2nd 2020; I have historically regularly visited her in the United States
at least a couple of times a year and she has always caught up with me when she has visited
the UK or Europe. I have historically and continue to act as one her closest confidants and
advisors,
Ghislaine has always faced up to every challenge she has met in her life whether it involved
or decisions involving
either her business interests or philanthropic interests. I consider her to be absolutely straight,
clear and honest in all her dealings with third parties - this attitude applies to her filing her tax
returns as it does to every other aspect of her life: organised, clear and straight.
Until these charges,
has never been involved in any allegation of breaking the law
in any jurisdiction.
Speaking for myself,
I
can confirm that I stand absolutely behind her in her fight to clear her name.
she has been a constant visitor to my family homes, has
had my children to stay with her in her homes
and I would not hesitate to leave any of my kids or grandkids in her care. I have
never witnessed, nor heard from my children or grandchildren any reports of any
inappropriate behaviour
Ghislaine has stayed at all times in the jurisdiction of the Unites States since the new charges
against the late Jeffrey Epstein and has from the outset confirmed to me personally on
EFTA00016538

=== Page 3 ===
numerous occasions that she wanted to be available to deal with any civil or criminal
allegations, to confront these and to deal with them in situ. She provided evidence under oath
in deposition in civil litigation rather than stay silent which is a good illustration of her
candour.
From my own experience, I can confirm that Ghislaine is kind, thoughtful and generous
whether it is helping friends who have fallen on difficult times such as a friend who was
recently widowed and to whom Ghislaine provided her own home in London immediately; or
inviting my children and their friends when on their gap year to stay with her and to sort out
transport, housing and friends to support them on their travels; or whether devoting
considerable resources and time to her philanthropic activity primarily in oceans
conservation.
I have offered to co-sign a bond in the amount of US$3,500,000 where the amount of the
bond would be secured by properties owned by
as this
represents the entirety of realisable family wealth; I do this in support of
judgement in relation to Ghislaine's integrity and commitment to attend court and to
underline that the family would be left without resources in the event that the bond was
called.
Yours sincerely
EFTA00016539


c1: EFTA00017716
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017716.pdf
c6: pdf
c7: images
c0:
=== 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 17:26:05 +0000
Inline-Images: image001.png
Congrats on this,
Great job!
Hope you and your family are doing well!
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
OF JUSTICE QUI PRO ENITED MILLINGS
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,
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
EFTA00017716

=== Page 2 ===
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 [1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
EFTA00017717

=== Page 3 ===
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.
EFTA00017718


c1: EFTA00016156
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016156.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
"
(USANYS)"
(USANYS)"
Cc:
"
)"
N
)"
N
,
)"
(USANYS) [Contractor]"
Subject: Final Visual
Date: Tue, 30 Jun 2020 16:12:58 +0000
Attachments: Ghislaine_Maxwell_Visual_DRAFT_v5.pdf
Formatted for printing. Attached.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I
Mobile:
I
Press Office:
EFTA00016156


c1: EFTA00015908
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015908.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: FW: Ghislaine Maxwell 02879-509
Date: Tue, 29 Dec 2020 16:38:05 +0000
Happy to join if that's useful.
Original Message
From:
Sent: Tuesday, December 29, 2020 11:37 AM
To:
Cc:
Subject: Re: FW: Ghislaine Maxwell 02879-509
Are you available right now?
Best,
Sophia
>>>
12/29/2020
11:
Hi
I hope you are enjoying the holiday season. When you have a moment, could we please get on a call to discuss the below email from
Maxwell's counsel? Understanding that we are still in the middle of the holidays, maybe we can find a time early next week for a call.
Thanks,
Assistant United States Attorney
Southern District of New York
From: BOBBI C STERNHEIM
Sent: Monday, December 28, 2020 8:42 PM
To:
Cc: Christian Everdell
Mark S. Cohen
Subject: Ghislaine Maxwell 02879-509
Good evening,
We hope you and your family had a joyful holiday.
In response to your 12/14 email, we are requesting that Ms. Maxwell be permitted to use the laptop, in lieu of the MDC computer,,
during the typical length of time other inmates are permitted out of their cells (our understanding is 6 am - 9:30 pm daily, extended to
10:30 pm on
weekends.)
The voluminous discovery is easier to access and review on the laptop.
EFTA00015908

=== Page 2 ===
The MDC computer turns off every two hours and is not capable of opening all documents, and volume of discovery may be too taxing
for the operating system.
We also want to bring to your attention some of the ongoing issues concerning Ms. Maxwell's conditions and restrictions.
The constant rotation of security staff results in inconsistency of rules and restrictions, the current shift being unnecessarily restrictive,
punitive, and threatening.
Ms. Maxwell is ordered to remain in specific locations within her isolation cell to accommodate capture on the handheld camera,
restricting her use of an already small confinement area.
Her use of the laptop has been restricted.
She is invasively surveilled while showering.
Her cell is cold and precipitation accumulates on the concrete block walls.
Over the holiday weekend, a third blanket, used by Ms. Maxwell to keep herself warm, was removed leaving her cold; and she now has
the onset of a cold.
The blanket was returned the next day, after complaint was made by counsel.
The open-mouth, wanding, pat-down, and in-and-behind ear searches continue, with more frequently than other inmates are searched.
Her cell and legal papers are searched multiple times a day, a disruption to the organization of her legal work and an invasion into her
privileged work product.
She has not received daily newspapers for almost 3 weeks, and has not received certified mail (return receipts indicating delivery to
MDC on
12/17) and non-certified mail for more than a week.
We will keep you apprised of our concerns.
Your assistance is appreciated.
Best-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential
and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message.
Thank you.
EFTA00015909


c1: EFTA00016319
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016319.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
"
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - ex parte sealed letter
Date: Tue, 15 Sep 2020 00:00:16 +0000
Attachments:2020-09-14_Government_ex_parte_discovery_letter_20_Cr_330_(AJN).pdf
Good evening,
Attached for Judge Nathan's consideration please find a letter pursuant to Federal Rule of Criminal Procedure 16(d)(1),
which the Government respectfully requests be filed ex parte and under seal.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
EFTA00016319


c1: EFTA00016594
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016594.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
(
Cc:
Subject: Epstein search
Date: Tue, 06 Aug 2019 14:16:48 +0000
FYI - we are moving forward with a search of his island, potentially as early as this weekend.
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
EFTA00016594


c1: EFTA00015326
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015326.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: "Berman, Geoffrey (USANYS)"
Subject: RE:
Date: Wed, 15 Apr 2020 14:38:16 +0000
From the daily that parts starts at 16:57
Original Message
From: Berman, Geoffrey (USANYS)
Sent: Wednesday, April 15, 2020 10:29 AM
To:
Subject: Re:
in a recording talked about Maxwell massaging her breasts. Can you find that
> On Apr 15, 2020, at 10:24 AM,
wrote:
V
> In the article version accompanying the daily it is written like this:
)
>
V
also recalled Ms. Maxwell repeatedly asking whether she wanted a massage. Eventually relenting,
followed directions by taking off her clothes and bra and getting under a sheet on a massage table.
Ms. Maxwell performed the massage, at one point having
lie on her back as Ms. Maxwell pulled
down the sheet to massage her chest.
>
> "I don't think there was any reason for her to be touching me that way,"
said.
>
>
Original Message
> From:
> Sent: Wednesday, April 15, 2020 10:23 AM
> To: Berman, Geoffrey (USANYS)
> Subject: RE:
V
> From the daily:
)
Mike Baker
V V V V V V V V V V V
then remembers Ghislaine repeatedly asked whether -
Have you ever gotten a massage?
> Mike Baker
-
wanted a massage.
I'm very skilled in massage, right, and so I want to make sure you get a massage.
EFTA00015326

=== Page 2 ===
V
> Mike Baker
> She said that she was very -
V
V
>
She was skilled in massage. Yeah.
V
> Mike Baker
> And she eventually relents.
>
>
> But I had never had a professional massage before. So I didn't know what really was involved in that. And so
she said that I would take off my clothes and lay under the sheet.
>
> Mike Baker
>
Ghislaine performs the massage.
V
>
> She had me, you know, flip over to my back. And then she pulled the sheet down so that my breasts were
exposed.
>
> Mike Baker
> And she remembers how Ghislaine then went on to massage her chest.
>
>
>
Like it just - this feels weird. This feels uncomfortable. I don't think this is probably right, but I don't know.
>
> Mike Baker
> And all this time, she's struggling to figure out what's going on. Jeffery Epstein, she says, wasn't participating
in the massage. But she has this sense that he's in the area, that the doors are open, it's kind of an open area where
she's getting the massage.
V
>
>
I could feel his presence, like, oh, I'm sure he can see me from where he is.
V
>
>
V
Original Message
> From: Berman, Geoffrey (USANYS)
> Sent: Wednesday, April 15, 2020 10:08 AM
> To:
> Subject:
V
> Can you resend me the
quote from NYT about Maxwell massaging her breasts.
EFTA00015327


c1: EFTA00016937
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016937.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
USANYS)"
Cc:
(USANYS)"
Subject: PC Updates
Date: Thu, 06 Jun 2019 19:02:16 +0000
Importance: Normal
Attachments:PC_Unit_Short_Form_Update.6.6.19.docx
I
here are the PC updates.
EFTA00016937


c1: EFTA00014671
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014671.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Haddon, Morgan and Foreman, P.C
Jeffrey Pagliuca
HADDON
MORGAN
FOREMAN
Denver, Colorado 80203
PH
May 12, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: Response to Government Letters dated May 4, and May 6, 2021 Regarding F.R. Crim. P.
17(c) Subpoena, United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
On March 15, 2021, Ms. Maxwell asked the Court to issue a F.R.Crim.P. 17(c)(3)
subpoena for production of evidence controlled by Boies, Schiller, and Flexner ("BSF") lawyers
working with the government on behalf of alleged (now-adult) witnesses. In her ex-parte
application, Ms. Maxwell provided reasons for requesting certain items of evidence, including
that the government either failed to secure the evidence or refused to produce it to Ms. Maxwell;
she also disclosed theories related to her defense, strategy, and work product.
After considering the application and BSF's response, the Court invited comment from
the government regarding subpoenaed items 9 (a journal), 10 (boots), and 11 (photographs).
Specifically, the Court directed the government "to notify the Court of its views as to Requests 9
through 11." Dkt. 252.
The government's position is consistent with its general approach to evidence in this case
which is to blindly accept information it considers unfavorable to Ms. Maxwell, begrudgingly
EFTA00014671

=== Page 2 ===
The Honorable Alison J. Nathan
May 12, 2021
Page 2
produce Brady material with various disclaimers such as "although the government is not
obligated to do so" (Dkt. 269 pp. 8, 9), and obfuscate the importance of legitimate defense
requests for discovery. The government repeatedly demonstrates that it views this process not as
a search for the truth, but for a conviction at any cost, including the truth.
Request 9, The Journal
Accuser-2 has been represented by BSF since approximately 2016. She sued Ms.
Maxwell and participated in the Epstein Victim Compensation Fund. She claims to have kept a
journal for a period in 1996 in which she described various events, including her interactions
with Jeffrey Epstein. Seven (7) photocopied pages of this journal, two of which are the front and
back covers, were selectively produced by BSF in discovery during civil litigation to counsel for
Ms. Maxwell, apparently as support for her claims against Epstein. The civil litigation was
stayed and ultimately dismissed prior to resolution of questions related to the failure to produce
the entire journal. Accuser-2 relied on select portions of the journal in public discussions with
various representatives of the media and claims to have looked at the journal to "refresh [her]
memory about this time." See, e.g., Michael Baker, "The First Women to Report Jeffrey
Epstein," The Daily Podcast, NY Times (Aug. 26, 2019), Tr. at 2 ("When I was looking, trying
to refresh my memory about this time, I came across this journal entry. [Host] [Accuser-2] has
this journal from that time period. It's a spiral journal with a picture of two sisters on the
front.").¹
When it suits its purpose, such as arguing against bail, the government touts the journal
as powerful evidence, to wit, "Contemporaneous journal entries corroborate details of another
1 Podcast audio and transcript located at https://www.nytimes.com/2019/08/26/podcasts/the-
daily/epstein-maxwell-
?showTranscript=1.
EFTA00014672

=== Page 3 ===
The Honorable Alison J. Nathan
May 12, 2021
Page 3
victim's account, including the details of when, where, and how that victim came to meet
Epstein." Dkt. 100 p. 11. And, the government has signaled its intent to introduce these pages at
trial, arguing that there is no "basis for doubting the authenticity of the documents which the
Government expects that [Accuser-2] will be able to properly authenticate at trial." Dkt. 268, p.
5.
What did, or did not, happen "about this time" and what Accuser-2 recorded, and did not
record "about this time" is relevant, exculpatory, evidence. The government admits it does not
have the remaining pages of the journal and admits that it has made no effort to read the
remaining pages of the journal. This does not stop the government, however, from expressing
baseless opinions about the journal's content, relevance, or admissibility because, in the blind
search for a conviction regardless of the truth, ignorance is indeed bliss. The government
implies that the journal, here, has "been evaluated for Brady material" (Dkt. 269 p. 4) which is
not true. Free from any actual knowledge, the government liberally makes unfounded and
misleading claims like:
"The remainder of the diary consists of [Accuser-2's] unrelated personal diary
entries;" (Id., p.3)
"[T]he diary contains no relevant material;" (Id., p. 4)
The diary is "full of [Accuser-2's] personal and unrelated information;" (Id., p. 4
n.1)
The diary is "likely to sweep in a significant period of [Accuser-2's] life before
[she] met Epstein...." (Id., p. 6)
The government makes additional questionable, contradictory, statements regarding the
journal. The government offers that it "understands" that the item requested is Accuser-2's
"entire diary from her teenage years." (Id., p.2) The "understanding" has no factual attribution
EFTA00014673

=== Page 4 ===
The Honorable Alison J. Nathan
May 12, 2021
Page 4
and is belied by an "understanding" months earlier where the government represented that
Accuser-2 "stopped writing in her journal about a month after" her meeting with Epstein, Dkt.
100, p.11 n.2.
Incredibly, the government has never examined or taken possession of the journal and is
relying on the representations of lawyers adverse to Ms. Maxwell in multiple civil litigations, the
same lawyers who have taken an active role in providing the government with selective pieces of
evidence and who regularly bash Ms. Maxwell in the media, hardly a reliable source.²
It is fundamentally wrong to use a part of a writing to, for example, deny bail, or refresh
recollection, or as a past-recollection recorded, or as a prior-consistent statement, and at the same
time ignore the remainder of the writing. The government should know what is in the remainder
of the journal; it simply chooses selective ignorance and relies on lawyers adverse to Ms. Maxwell
for cover. This type of selective disclosure of information is routinely rejected by courts, including
the Second Circuit Court of Appeals. Known as the "fairness doctrine," when one party makes
assertions about parts of a communication or writing the entire communication loses protected
status and requires disclosure to the opposing party. The aim of the doctrine is to protect the adverse
"party, the factfinder, and the judicial process from selectively disclosed and potentially misleading
evidence." In re von Bulow, 828 F.2d 94, 102 (2d Cir. 1987); see also United States V.
Bilzerian, 926 F.2d 1285, 1292 (2d Cir. 1991); Joy V. North, 692 F.2d 880, 893-94 (2d Cir. 1982);
Teachers Ins. & Annuity Ass'n of America V. Shamrock Broadcasting Co., 521 F.Supp. 638
(S.D.N.Y. 1981).
2 As Ms. Maxwell previously pointed out, another of BSF's clients confessed to creating a fake
"diary" to sell to a tabloid news journalist, fifteen years after the fact, and while represented by
BSF. See Dkt. 244 at 10 n.4.
EFTA00014674

=== Page 5 ===
The Honorable Alison J. Nathan
May 12, 2021
Page 5
Given that Accuser-2, the putative witness, has publicly claimed to rely on the journal to
"refresh" her memory and the government's apparent intention to introduce the pages at trial other
evidentiary principles related to fairness come into play. F.R.E. 106, the Rule of Completeness,
allows that "[i]f a party introduces all or part of a writing or recorded statement, an adverse party
may require the introduction, at that time, of any other part--or any other writing or recorded
statement--that in fairness ought to be considered at the same time."
Federal Rule of Evidence 612 is also applicable here and states:
(a) Scope. This rule gives an adverse party certain options when a witness
uses a writing to refresh memory:
(1) while testifying; or
(2) before testifying, if the court decides that justice requires the party to
have those options.
(b) Adverse Party's Options; Deleting Unrelated Matter. Unless 18 U.S.C.
§ 3500 provides otherwise in a criminal case, an adverse party is entitled to
have the writing produced at the hearing, to inspect it, to cross-examine the
witness about it, and to introduce in evidence any portion that relates to the
witness's testimony. If the producing party claims that the writing includes
unrelated matter, the court must examine the writing in camera, delete any
unrelated portion, and order that the rest be delivered to the adverse party.
Any portion deleted over objection must be preserved for the record.
(c) Failure to Produce or Deliver the Writing. If a writing is not produced or
is not delivered as ordered, the court may issue any appropriate order. But if
the prosecution does not comply in a criminal case, the court must strike the
witness's testimony or--if justice so requires--declare a mistrial.
The witness has admitted using the journal to refresh her memory. Title 18 of U.S. Code
§ 3500 is inapplicable here by its very terms because the remainder of the journal is, admittedly,
not in the possession of the government. See 18 U.S.C. $ 3500(a) (applies exclusively to
statements "in the possession of the United States"); see also United States V. Bin Laden, 397 F.
Supp. 2d 465, 491 (S.D.N.Y. 2005) ("The statute thus establishes three essential elements
EFTA00014675

=== Page 6 ===
The Honorable Alison J. Nathan
May 12, 2021
Page 6
of 3500 Material: (1) a statement by the witness, (2) in the possession of the United States, (3)
that relates to the subject matter of the witness's testimony.").
This case now involves a ten-year time period beginning 27 years ago. The indictment
and the accusers are vague regarding when things happened, what things happened and who may
have been present when anything is alleged to have happened. Accuser-2's journal contains
dated entries that place events in context with other alleged events. Accuser-2's journal from
1996 purports to document encounters with Epstein in New York. The S2 indictment, paragraph
9(b), claims that "Maxwell interacted with [Accuser-2] on at least one occasion in or about 1996
at Epstein's residence in New Mexico...." The journal references other dates, places, and events
in 1996. The absence of any mention of Ms. Maxwell in context with other recorded events is
both relevant and exculpatory.
As a piece of physical evidence, the journal is subject to inspection and testing. See F. R.
Crim. P. 17(c)(1). Moreover, were the journal in the possession of the government it would be
subject to inspection under F. R. Crim. P. 16 (a) (1) (E) which provides, in relevant part:
Upon a defendant's request, the government must permit the defendant to
inspect and to copy or photograph books, papers, documents, data,
photographs, tangible objects, buildings or places, or copies or portions of
any of these items, if the item is within the government's possession,
custody, or control and:
(i) the item is material to preparing the defense;
(ii) the government intends to use the item in its case-in-chief at trial[.]
To avoid any disclosure obligations, the government has simply accepted partisan
photocopies of five substantive pages without questioning the provenance of an exhibit it intends
to introduce at trial. Comparison of one of the five pages demonstrates the problem. Attached as
exhibit A is a photocopy of a journal entry first produced during the civil litigation. A photocopy
EFTA00014676

=== Page 7 ===
The Honorable Alison J. Nathan
May 12, 2021
Page 7
of the same entry, produced in the criminal discovery and attached as exhibit B, is obviously, and
noticeably, different. The remaining six pages are identical except for the identifying bate ranges.
Examination of the original document would answer legitimate questions about whether the
document has been manipulated, altered, or fabricated. Disclosure of the document in advance of
trial would prevent the unnecessary delay of having a qualified forensic document examiner take
possession of the document, run tests, and offer an opinion during the middle of trial.
Request 10, the Boots
The Court directed the government "to notify the Court of its views" regarding item 10.
Instead of notifying the Court of its "views" the government, however, has taken steps to
circumvent the pending defense subpoena request; it is "working to moot request 10" by having
the FBI secure the boots, Dkt. 269, p.2. This is an interference with Ms. Maxwell's ability to
investigate her defense without interference from the government. Ms. Maxwell's original
request was ex parte, now the government is taking possession of the very things subject to Ms.
Maxwell's subpoena. The government's actions demonstrate a willingness to take control of
evidence when it is tactically advantageous to do so but resist disclosure when it is not. Ms.
Maxwell requests that the court order production of the boots to her lawyers pursuant to the
subpoena, not to the government.
Request 11, the Photographs
Regarding item 11, the photographs, the government offers inconsistent and illogical
positions. In its letter of May 4, 2021, the government first advised the Court that it obtained
"copies of the complete set of requested photographs" which it then produced to the defense.
Two days later it admitted that "some of the original photographs are currently in the Prosecution
Team's possession" and that it would "make them available to the defendant upon request."
EFTA00014677

=== Page 8 ===
The Honorable Alison J. Nathan
May 12, 2021
Page 8
(Dkt. 271, p.1) Tripping over its own largess, the "Prosecution Team" neglected to mention that
Ms. Maxwell and her lawyers traveled to New York to review all of the physical evidence,
including original photographs, in person, at considerable expense from April 12 to April 16,
2021. The government does not explain which original photographs it has in its possession nor
does it offer any reason why these photographs were not made available "upon request."
Attempts to confer with the government to explain these discrepancies have gone unanswered for
days.
Photocopies, in most cases, (and most certainly in this case) are not adequate substitutes
for originals, particularly when the photocopies are produced by lawyers adverse to Ms.
Maxwell, were not collected by law enforcement directly from the source, and are subject to
manipulation. Any original photographs will have markings that identify when the film was
developed and other indicia indicating whether they are genuine or not. Again, like the journal,
the government has outsourced the fact and truth finding function regarding the photographs to
partisan advocates. If the government possessed the originals Ms. Maxwell would have the Rule
16 right to inspect them, just like the many photographs she inspected between April 12 and
April 16, 2021.
Finally, the government devotes much of its submission attempting to bait Ms. Maxwell
into revealing defense strategy and work product. Ms. Maxwell is happy to address any questions
regarding relevance and admissibility ex-parte should the Court need any additional information.
Respectfully Submitted,
Jeffrey S. Pagliuca
CC: Counsel of Record (via ECF)
EFTA00014678


c1: EFTA00015031
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015031.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: AF & ADG
Date: Wed, 06 Oct 2021 19:53:24 +0000
Attachments: DiscoveryExport_-_AF_&_ADG.zip
Can you see if this will open for you? If not, can you send me a link to upload to USAfx?
Thanks,
From:
(USANYS)
Sent: Wednesday, October 6, 2021 3:41 PM
To:
(NY) (FBI)
>;
)
Cc:
(NYPD)
is
(USANYS) [Contractor]
Subject: [EXTERNAL EMAIL] - RE: AF & ADG
Thanks,
Unfortunately the zip seems to be empty? I'm copying
Can you try resending to her? Or she can
set you up with USAfx? Thanks!
From:
Sent: Wednesday, October 6, 2021 2:50 PM
To:
(USANYS)
is
)
Cc:
Subject: AF & ADG
1As you requested are attached.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
EFTA00015031


c1: EFTA00016124
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016124.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "Berman, Geoffrey (USANYS)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
Subject: My bad - no fewer than 4 articles today. Still relatively slow
Date: Mon, 29 Jul 2019 21:47:23 +0000
Epstein
Judge signs protective order over materials feds to turn over to jailed financier Jeffrey Epstein
ABC News
By James Hill and Chris Francescani
7/26/19
Judge signs protective order over materials feds to turn over to jailed financier Jeffrey Epstein originally appeared on
abcnews.go.com
Federal prosecutors in New York overseeing the case against millionaire Jeffrey Epstein are preparing to hand over highly-
sensitive investigative material to the financier's defense attorneys after a federal judge on Friday granted the
government's request to place a protective order on the documents.
Prosecutors sought the order because, they said in court filings, they intends to produce documents and materials that
could "affect the privacy and confidentiality of individuals [and that] would impede, if prematurely disclosed, the
Government's ongoing investigation of uncharged individuals."
When Epstein secured a non-prosecution agreement with federal prosecutors in southern Florida in 2008 over a previous
investigation, the much-criticized deal also immunized any and all potential co-conspirators, known or unknown, and also
included the names of four women who had been suspected by authorities of having facilitated or participated in alleged
crimes against children.
The deal, which is currently under review by the Justice Department's Office of Professional Responsibility, allowed
Epstein to plead guilty to two state counts and avoid federal charges for an allegedly broad pattern of similar conduct.
Throughout the negotiations -- and for nearly a year after the agreement was signed -- the victims were kept in the dark,
their attorneys said, claiming they were strung along as government lawyers promised victims they were still investigating
even long after they had cut the deal with Epstein.
One of Epstein's accusers in that investigation,
identified in court documents as "Jane Doe 1," sued the
Department of Justice in 2008, alleging that the non-prosecution agreement reached with Epstein by federal prosecutors
in South Florida was hatched in violation of the Crime Victims' Rights Act, which enumerates the rights afforded to victims
in federal criminal cases, including the right "to reasonable, accurate, and timely notice of any public court proceeding, or
any parole proceeding, involving the crime or of any release or escape of the accused."
In February of this year, U.S. District Court Judge Kenneth Marra ruled in favor of
and other Epstein accusers, finding
that the federal government failed to confer with the victims in advance of the deal. Marra is now considering the
possible remedies for the violation, which could potentially include tearing up the non-prosecutions agreement.
Epstein, 66 -- who at one time socialized with former President Bill Clinton, Great Britain's Prince Andrew and President
Donald Trump -- was arrested on July 6 for alleged sex trafficking of minor girls in Florida and New York. Some of the
charges date back to the early 2000s.
EFTA00016124

=== Page 2 ===
He was indicted on a child sex trafficking and conspiracy charges in which prosecutors charge that he "sexually exploited
and abused dozens of minor girls at his homes in Manhattan, New York, and Palm Beach, Florida, among other locations,"
using cash payments to recruit a "vast network of underage victims," some of whom were as young as 14 years old.
Epstein has pleaded not guilty to the latest charges and his defense attorneys have argued in court that the new
indictment is tantamount to "double jeopardy," the constitutional right that prevents a person from being tried on the
same (or similar) charges twice, based on the same facts, following a valid acquittal or conviction.
"It is our belief that this is basically a re-do," Epstein defense attorney Reid Weingarten told the judge at a bail hearing
earlier this month. "This is basically the feds today, not happy with what happened in the decision that led to the NPA,
redoing the same conduct that was investigated 10 years ago and calling it, instead of prostitution, calling it sex trafficking.
We think that is the heart of everything, and that will be the centerpiece of our defense."
At the same hearing, prosecutors claimed Epstein tried to buy off potential witnesses and charged that he had
demonstrated a "willingness to use intimidation and aggressive tactics in connection with a criminal investigation."
Prosecutors allege that late last year Epstein wired $100,000 from a trust account to a person who had been named in the
2008 case as a possible co-conspirator of Epstein's and then three days later wired $250,000 to another suspected co-
conspirator.
Weingarten did not respond at the time to an ABC News request for comment on prosecutors' claims of potential witness
tampering.
What Jail Is Like for Jeffrey Epstein
Wall Street Journal
By Ben Chapman
7/27/19
Now sleeping in the bottom bunk of a windowless 8-by-8-foot cell, the financier earlier was denied house arrest at his
sprawling Manhattan townhouse
Since his arrest on sex-trafficking charges, financier Jeffrey Epstein has spent much of his time in the bottom bunk of a
windowless 8-by-8-foot cell, according to the lawyer of his former cellmate.
The cell is in a wing of a federal jail in downtown Manhattan that is known as "the box" and has been the subject of
inmate complaints about mice and insect infestations, as well as standing water on the floor, according to lawyers of
inmates.
Mr. Epstein's roommate until Tuesday was Nicholas Tartaglione, a retired police officer accused of killing four people,
according to Mr. Tartaglione's lawyer, Bruce Barket.
"It is dark and it's disgusting," Mr. Barket said of the jail cell Messrs. Epstein and Tartaglione shared.
Mr. Epstein, 66 years old, was arrested July 6 and was later denied bail when a judge rejected his lawyers' request that he
be placed on house arrest in his sprawling Manhattan townhouse, which is valued at $77 million.
Mr. Epstein had built a fortune of more than half a billion dollars by cultivating his ties to rich and powerful individuals.
Prosecutors this month said they found a "piles of cash" and dozens of diamonds in a locked safe at his New York
mansion.
The financier has pleaded not guilty to sex-trafficking charges stemming from what prosecutors allege was a yearslong
scheme from 2002 to 2005 to recruit and sexually abuse dozens of girls.
EFTA00016125

=== Page 3 ===
Following his arrest, he has mostly been at the Manhattan jail, which is known as the Metropolitan Correctional Center.
He was moved to a suicide-watch unit after being found unconscious in his cell Tuesday morning, according to people
familiar with the matter.
A lawyer for Mr. Epstein declined to comment. Mr. Tartaglione was interviewed in connection with Mr. Epstein's injuries
but had no part in them, Mr. Barket said.
The jail houses 774 inmates, most of them awaiting trial. It has been home to such high-profile inmates as Mexican drug
lord Joaquín "El Chapo" Guzmán, who was sentenced earlier this month to life in prison.
Federal records show that the current occupants include Cesar Sayoc, who pleaded guilty to sending bombs to prominent
Democrats and is awaiting sentencing, and Sayfullo Saipov, accused of killing eight people by driving a truck on to a
Manhattan bike path. Mr. Saipov has pleaded not guilty.
Mr. Epstein and other inmates are allowed to leave their cells for an hour of recreation each day, as well as meetings with
lawyers, according to a correction officer.
Mr. Barket said that Messrs. Tartaglione and Epstein were friendly and frequently spoke while they were bunkmates. Mr.
Tartaglione was arrested in 2016 for killing four people in Chester, N.Y. He has pleaded not guilty.
Mr. Tartaglione's lawyer has been a vocal critic of the conditions in the jail, filing complaints to correction officials about
rodents and bugs.
Lawyers for Mr. Guzmán blamed frigid temperatures, lack of clean blankets and contaminated water at the jail as reasons
for their client's failing health.
Serene Gregg, a case worker at the Metropolitan Correctional Center and president of the correction workers' union
chapter, said there are mice and broken toilets and sinks.
Representatives for the Federal Bureau of Prisons, which manages the Metropolitan Correctional Center, didn't respond to
questions about the conditions there.
"There is no worse place you can find yourself," Mr. Barket said.
Lawmaker says she was warned to back off Jeffrey Epstein case: 'Little girl, you don't know what you're getting into'
Tampa Bay Times
By Miami Herald
7/26/19
Florida Sen. Lauren Book has reached out to Capitol police after receiving an anonymous warning connected to her
demand for a state inquiry into Palm Beach Sheriff Ric Bradshaw's handling of accused sex trafficker Jeffrey Epstein's
lenient work release program, the Miami Herald has learned.
Book, a vocal advocate for child sexual assault survivors, said she also received more than a dozen calls from Bradshaw's
political supporters asking her to back off on her call for an investigation by the Florida Department of Law Enforcement
into Bradshaw.
On Monday, Book, a Democrat, wrote a letter to Republican Gov. Ron DeSantis asking him to authorize a probe into how
Epstein, accused of molesting dozens of underage girls and a registered sex offender, was permitted to leave the Palm
Beach County Jail and spend much of his 2008-2009 incarceration in an office in West Palm Beach.
EFTA00016126

=== Page 4 ===
DeSantis said Thursday after a Cabinet meeting that he would "certainly consider" an investigation but that he has yet to
decide how the state should respond.
"I saw someone sent me a letter. I looked at it," he said. "I've got to figure out what the proper role of FDLE [is]. I know
they are investigating it down in Palm Beach. Clearly when you look at how that happened, if even like 10 percent of
the things about him are true, then that whole agreement was obviously suspect and willfully below what he should have
faced."
While the governor was still weighing the merits of the senator's request, the Palm Beach Sheriff's Office issued a new
statement that its previously announced internal affairs investigation of the deputies who guarded and supervised Epstein
during his work release had become a criminal investigation as well. No further elaboration was provided.
Meanwhile, Book, in an interview with the Herald, said she had asked the Capitol police, who handle security for state
lawmakers, to look into claims made on a Russian website alleging that Bradshaw was behind an effort to access her
phone and emails by using the pretext of "imminent danger" to obtain her personal information.
"I've received countless phone calls saying 'Little girl you don't know what you're getting into,' and telling me that I should
just stop," said Book, a child sexual abuse survivor herself who has worked to pass strict sex offender laws in Florida.
In a statement, the Palm Beach Sheriff's Office said it had no knowledge of anyone trying to threaten or pressure Book.
"Nor has (the Palm Beach Sheriff's Office) made any effort to access her phone or emails as alleged on a salacious website
run by a disgruntled former employee," the statement said.
Pbsotalk.org, the website in question, is a blog tied to a former Palm Beach sheriff's deputy who moved to Russia after
starting the site, which claims it is dedicated to exposing corruption in the Palm Beach Sheriff's Office. The former deputy,
John Dougan, fled to Moscow in 2016 following an FBI raid on his Palm Beach home that he claims was politically
motivated.
The pressure against Book came on the same day that Epstein, 66, was found injured in his cell at the Metropolitan
Correctional Center in New York, where he is awaiting trial on sex trafficking charges brought earlier this month by the
U.S. Attorney for the Southern District of New York. His arrest stemmed from alleged behavior with underage girls dating
back more than a decade in New York and Florida. Epstein was taken into custody July 6 after arriving at New Jersey's
Teterboro Airport from Paris on his private jet.
Epstein was found unconscious in his cell Wednesday evening amid speculation that he may have tried to commit suicide
or been attacked by another inmate. Jail officials said he was in the lockup Thursday.
Last Friday, Bradshaw announced the internal affairs investigation after reports emerged that Epstein - while on work
release in Palm Beach - was allowed female visitors to his office, including at least one visit that led to a sexual
encounter. The terms of Epstein's incarceration were detailed by the Herald as part of a series published last year about
Epstein's case, Perversion of Justice.
who represents several of Epstein's victims, said it is ludicrous to think that Bradshaw is able to investigate
his own department.
"The allegations are against the sheriff and there's no way a credible investigation can be conducted by the sheriff's office
when the allegations extend to the very top of the organization,"
said.
Book, whose father, Ron Book, is perhaps the most powerful lobbyist in Florida, said she intends to pressure the governor
for a full and thorough investigation.
"The privileges that Epstein received in Palm Beach County were outside the scope of what anyone else would receive.
We need an independent body to identify whether this was an issue of individual failures or systemic failures. And if it was
EFTA00016127

=== Page 5 ===
an individual failure, we need to hold those individuals accountable," she said.
Bradshaw, who is running for his fifth term, wields tremendous power in Palm Beach, where the agency has also been the
lead law enforcement detail assisting the Secret Service during President Donald Trump's visits to Mar-a-Lago. The Palm
Beach Sheriff's Office spent $5.6 million for Trump's 2017-2018 trips, the Palm Beach Post reported in April. The
department is reimbursed for the work.
Epstein was found on the floor of his jail cell with injuries to his neck, according to a report from NBC New York late
Wednesday.
The television station said another inmate had been questioned and that Epstein is on suicide watch. A source told CBS
News the injuries were not life threatening. The New York Post reported that Epstein was taken to a nearby hospital and
may have intentionally hurt himself in order to win a transfer out of the federal facility.
Quoting unnamed law enforcement officials, The New York Times said prison officials were treating the incident, which
left Epstein with "bruising around the neck," as a possible suicide attempt.
The jet-setting financier was denied bail last week after a federal judge said he posed a danger to young women. His
lawyers have filed their intent to appeal, saying he should be released to his palatial Upper East Side Manhattan
townhouse.
Epstein, who has pleaded not guilty, roamed the halls of power before dozens of underage girls accused him of sexual
assaults. After preparing a 50-plus-page indictment on sex trafficking charges, the U.S. Attorney's Office for the Southern
District of Florida shelved the charges and allowed Epstein to plead guilty to minor charges in state court. That's how
Epstein ended up in the Palm Beach County Jail - and then on work release approved by Sheriff Bradshaw.
A fixture on the high-society social circuit, he was known to associate with figures such as Bill Clinton, Donald Trump and
Prince Andrew of Britain. He owns homes around the world, including a mansion in Palm Beach. His lawyers pegged his
wealth at $559 million in court documents.
In an email, the Bureau of Prisons said Epstein was currently at the federal jail Thursday morning, not a hospital, but did
not address his condition or whether an incident had occurred.
"As with all inmates, for privacy and security reasons, we do not share information on an inmate's medical status or their
conditions of confinement," the Bureau of Prisons said.
The federal detention center where Epstein is locked up has been described by The New York Times as "less hospitable
than Guantánamo Bay." It has also held Joaquín Guzmán Loera, the Mexican drug lord known as El Chapo, Ponzi schemer
Bernie Madoff and Ramzi Ahmed Yousef, who plotted the 1993 World Trade Center bombing, according to the Times.
This story was written by Miami Herald staff writers Julie K. Brown and Nicholas Nehamas. Times/Herald Tallahassee
Bureau staff writer Elizabeth Koh contributed to this report.
One of the earliest known accusations against Jeffrey Epstein was reported to Santa Monica police in 1997
Insider
By Kat Tenbarge
7/26/19
In a police report obtained by The New York Times and published Thursday, a then-27-year-old model named
accused the wealthy financier Jeffrey Epstein of a now all-too-familiar sequence of events resulting in what Santa Monica,
California, officers classified as sexual battery.
EFTA00016128

=== Page 6 ===
Epstein, who registered as a sex offender after a 2008 case, is being held without bail in the Southern District of New York
on charges of sex trafficking of minors and conspiracy involving dozens of underage girls from at least 2002 to 2005.
Epstein has pleaded not guilty.
The newly unearthed police report is one of the earliest known accusations against the financier-
filed her
accusation with the Santa Monica Police Department in May 1997.
In that accusation,
said Epstein identified himself as a talent scout for Victoria's Secret before inviting her to a hotel
room in Santa Monica for an interview that
was told could have landed her a spot in the lingerie company's catalog.
told the police she "started having reservations" before her appointment with Epstein, because "generally,
interviews are not conducted in hotel rooms."
Read more: How Jeffrey Epstein, the mysterious hedge-fund manager arrested on sex-trafficking charges, made his
fortune
When
met Epstein in the hotel room for her interview, she told the police, she was "unsure of whether she was
safe" because he "was attempting to get her to act in an unprofessional manner for a model." She said that included
Epstein asking her to undress, twice, and on the second time pulling her blouse and skirt up and groping her buttocks
while saying, "Let me manhandle you for a second."
told The Times she fled in tears and went to the police the next day. She put her report on the record a week later,
worried that Epstein, whose hands she called "weopons," would use his Victoria's Secret connection to assault other
women.
Accusations from other women include descriptions of similar tactics. A former Italian model named
aid
Epstein also used his Victoria's Secret connection to attempt to coerce her into sex acts in 2004.
What's more, The Times reported that two senior executives at L Brands, the company owned by Epstein's only known
financial-services client and then friend
knew Epstein was posing as a Victoria's Secret talent scout. L Brands
was, and still is, the parent company of Victoria's Secret.
The Times cited the two unnamed former executives as saying they had learned in the mid-1990s that Epstein, then
serving as
financial adviser, was pitching himself to women as a recruiter for the Victoria's Secret catalog. The
two executives signed nondisclosure agreements while working for
but told The Times he was made aware that
Epstein was posing as a Victoria's Secret talent scout.
promised to take care of the situation at the time, the executives said, but the
remained
extraordinarily close with Epstein until 18 months after Epstein was charged with an array of sexual misconduct in Palm
Beach, Florida. After pleading guilty to state prostitution charges in that case, Epstein is now facing new charges accusing
him of trafficking girls as young as 14.
In a letter to L Brands employees this month about the new charges,
said he was "NEVER aware of the illegal
activity charged in the indictment" and "would never have guessed that a person I employed more than a decade ago
could have caused such pain to so many people."
That being said, the relationship between
and Epstein was extensive, with The Times reporting that
transferred Epstein's Manhattan mansion, private 727 Boeing jet, and Ohio estate to him from his and L Brands' previous
assets and that he gave Epstein full control over all his finances from 1991 to 2007.
EFTA00016129


c1: EFTA00017764
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017764.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Brass Meeting re Epstein
Start Date: 2019-08-15 16:00:00 +0000
End Date: 2019-08-15 18:00:00 +0000
Location: 8th Floor
Class: X-PERSONAL
Comment:
Date Created: 2019-08-14 17:53:50 +0000
Date Modified: 2019-08-14 17:53:50 +0000
Priority: 5
DTSTAMP: 2019-08-14 16:30:15 +0000
Attendee:
EFTA00017764


c1: EFTA00014348
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014348.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Re: Epstein update
Date: Sat, 10 Aug 2019 15:32:45 +0000
Can you loop me in?
Sent from my iPhone
On Aug 10, 2019, at 11:32 AM,
wrote:
Give me a call on my cell.
Sent from my iPhone
On Aug 10, 2019, at 11:31 AM,
wrote:
Just FYI. Will let you know if we get any additional information. I'll be in the subway for the next half hour
or so but then at my desk today.
Sent from my iPhone
Begin forwarded message:
From:
Date: August 10, 2019 at 11:30:02 EDT
To:
Cc:
Subject: Re: Epstein update
,
It is frankly unbelievable to me that BOP is issuing public press releases on this before telling us basic
information so that we can relay it to his attorneys who can relay it to his family. When can we expect to get
either some sort of statement we can pass along to counsel as accurate and reliable or have a call with
someone?
I understand from the Marshals that they have been unsuccessful in reaching anyone with authority at BOP,
and given the BOP press release that was just put out I assume we need to speak with someone there. Please
advise.
Thank you.
On Aug 10, 2019, at 10:43,
wrote:
EFTA00014348

=== Page 2 ===
As you might imagine, we are getting increasingly frantic calls from defense counsel who continue to be
seeing information in the press that we-the U.S. Attorney's Office-haven't yet received. We need to
know as soon as possible the very basic facts, such as time and cause of death at the absolute minimum. It
has now been hours since this was reported publicly. Please advise when we can expect to receive either a
written report on those basic facts or when we can have a call to get that information to relay to his
counsel. It is extraordinarily frustrating to have to tell them that we have less information than the press.
Please advise.
Thank you,
On Aug 10, 2019, at 08:46,
(USMS)
wrote:
,
Passed away. We are completing a significant incident report for HQ for Death of a Federal Inmatehowever, I do
not have any specifics from the BOP yet.
From:
Sent: Saturday, August 10, 2019 8:44 AM
To:
(USMS)
Cc:
>;
Subject: Re: Automatic reply: Epstein update
Thank you for telling us. What do you mean by "passed"?
Thanks,
Sent from my iPhone
On Aug 10, 2019, at 8:18 AM,
(USMS)
wrote:
BOP just provided another update- Epstein has passed. I have no additional info. I will push out updates as we
receive.
From:
(USMS)
Sent: Saturday, August 10, 2019 7:52 AM
To:
Subject: Re: Automatic reply: Epstein update
FYI:
The BOP just informed us that Epstein is being taken by ambulance to the hospital from another apparent
suicide attempt- no other information was provided.
They will update us as more info becomes available.
On Aug 10, 2019, at 7:26 AM,
)
wrote:
EFTA00014349

=== Page 3 ===
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my
responses may be delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
at 2
or
EFTA00014350


c1: EFTA00014968
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014968.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
11/26/21, 7:14 PM
Mail
(NY) (FBI) - Outlook
RE: DCAP Review
(NY) (FBI)
<
>
Fri 7/23/2021 3:27 PM
To:
(NY) (FBI)
is
(NY) (FBI)
>;
(NYPD)
A
Hello-
Just finished the review and all 3,662 with motion have now been completed.
Let me know if you need anything else!
Thanks for helping
From:
(NY) (FBI)
Sent: Friday, July 23, 2021 1:57 PM
To:
(NY) (FBI)
is
(NYPD)
in
(NY) (FBI)
Subject: RE: DCAP Review
Hey-
I was able to review approx. 1420 videos working from the opposite end (Media type: video; Relationship: Has
Motion; Order: Descending). We shouldn't have too many videos left to tag- I know
has been working
on it this week as well. My DCAP portal keeps crashing, so I will continue my efforts on Monday morning! As long
as the app works Monday we should be all complete then with tagging individuals as "file of interest" and others
as "reviewed."
See you later!
Operational Support Technician
C20 & C11, NYO
Federal Bureau of Investigation
From:
(NY) (FBI)
Sent: Thursday, July 15, 2021 6:12 PM
To:
(NY) (FBI)
is
(NYPD)
<
V.
(NY) (FBI)
Subject: DCAP Review
Hey all-
I've been able to review a decent amount of the video footage in DCAP and wanted to send an email where I left
off (I'll be out of the office Friday-Tues). I filtered the case specific to media type (video) and relationship (has
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
1/2
EFTA00014968

=== Page 2 ===
11/26/21, 7:14 PM
Mail
(NY) (FBI) - Outlook
motions). I tagged any video with an individual as "file of interest" and others of non-significance as "reviewed".
Once filtered there are 3,662 videos, so far I've been able to review 1,300.
See you next week!
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
2/2
EFTA00014969


c1: EFTA00015574
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015574.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein PR Final review
Date: Mon, 08 Jul 2019 14:21:44 +0000
Importance: Normal
Thanks!
From:
(USANYS)
Sent: Monday, July 8, 2019 10:20 AM
To:
(USANYS)
Subject: RE: Epstein PR Final review
Fine by me. Thanks.
From:
(USANYS)
Sent: Monday, July 8, 2019 10:17 AM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS)
in
is
>;
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: RE: Epstein PR Final review
Any other edits? Or are we good to finalize the release?
From:
(USANYS)
Sent: Monday, July 8, 2019 9:55 AM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS)
in
is
is
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: RE: Epstein PR Final review
Also in
quote: Are we trying to say no matter where the incident took place?
FBI Assistant Director
said: "We are asking anyone who may have been victimized
by Jeffery Epstein, or anyone who may have information about his alleged criminal behavior, to please call us.
The number is 1-800-CALL-FBI. We want to hear from you, regardless of the age you are now, or whatever age
you were then, no matter the incident that took place. The bravery it takes to call us might empower others to
speak out about the crimes committed against them. It is important to remember there was never, nor will
there ever be an excuse for this type of behavior. In the eyes of the FBI, the victims will always come first."
EFTA00015574

=== Page 2 ===
From:
(USANYS)
Sent: Monday, July 8, 2019 9:39 AM
To:
(USANYS)
>;
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
is
is
Cc:
(USANYS) [Contractor]
>;
(USANYS)
Subject: Epstein PR Final review
Importance: High
Attached is the final PR for review. Please note that
quote includes the number to call, so we need to
finalize that as soon as possible. Thanks.
Public Affairs
U.S. Attorney's Office for the Southern District of New York
Website: www.justice.gov/usao-sdny.
Facebook: https://www.facebook.com/usaosdny
Follow us on Twitter: @SDNYnews
EFTA00015575


c1: EFTA00014493
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014493.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:19-cr-00490-RMB Document 23 Filed 07/16/19 Page 1 of 3
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
July 16, 2019
VIA ECF
REQUEST TO FILE PARTIALLY
UNDER SEAL
The Honorable Richard M. Berman
United States District Judge
Southern District of New York
United States Courthouse
500 Pearl Street
New York, New York 10007
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Berman:
The Government respectfully submits this letter to provide the Court with additional
information in response to the Court's questions at the detention hearing held on July 15, 2019
(the "Detention Hearing").
I. Payments to Potential Witnesses
In a July 12, 2019 letter, the Government informed the Court that the Government had
recently obtained records from a financial institution ("Institution-1") that appeared to show the
defendant had made suspicious payments shortly after the Miami Herald began publishing, on
approximately November 28, 2018, a series of articles relating to the defendant, his alleged sexual
misconduct, and the circumstances under which he entered into a non-prosecution agreement
("NPA") with the U.S. Attorney's Office for the Southern District of Florida in 2007. The same
series highlighted the involvement of several of Epstein's former employees and associates in the
alleged sexual abuse. At the Detention Hearing, the Court asked the Government to provide
additional information about the individuals to whom these payments appear to have been made.
First, records from Institution-1 show that on or about November 30, 2018, or two days
after the series in the Miami Herald began, the defendant wired $100,000 from a trust account he
controlled to
, an individual named as
a potential co-conspirator-and for whom Epstein obtained protection in-the NPA. This
individual was also named and featured prominently in the Herald series.
Second, the same records show that just three days later, on or about December 3, 2018,
the defendant wired $250,000 from the same trust account to
, who was
1
For the reasons set forth at the Detention Hearing, and with the consent of the Court, the
Government is redacting the identities of these individuals in the publicly filed version of this
letter.
EFTA00014493

=== Page 2 ===
Case 1:19-cr-00490-RMB Document 23 Filed 07/16/19 Page 2 of 3
Hon. Richard M. Berman
United States District Judge
July 16, 2019
Page 2
also named as a potential co-conspirator-and for whom Epstein also obtained protection in-the
NPA. This individual is also one of the employees identified in the Indictment, which alleges that
she and two other identified employees facilitated the defendant's trafficking of minors by, among
other things, contacting victims and scheduling their sexual encounters with the defendant at his
residences in Manhattan and Palm Beach, Florida. This individual was also named and featured
prominently in the Herald series.
II. Police Report
During the Detention Hearing, the parties referenced a redacted copy of a Palm Beach
police report, which was annexed to the Government's July 12, 2019 detention memorandum. At
the Court's request, the Government has provided a supplemental copy of the police report
previously filed, with information referred to in open court unredacted. The updated copy of the
police report is attached as Exhibit A.
III. Foreign Passport
During the Detention Hearing, the Government informed the Court that it had recently
learned that law enforcement agents had seized what appears to be an expired foreign passport (the
"Foreign Passport") from a safe in the defendant's Manhattan residence during the execution of a
search warrant on or about July 6, 2019. The Foreign Passport has a photograph that appears to
depict the defendant, but lists a different name. Photographs of that passport are annexed hereto
as Exhibit B. In the same safe, agents discovered what appears to be an expired United States
passport issued to the defendant, in his true name, within three years of the date on the Foreign
Passport. A photograph of that United States passport is annexed hereto as Exhibit C, so that the
Court may compare the passports, both of which appear to depict the defendant. Because Exhibits
B and C contain personally identifiable information and sensitive information relevant to the
ongoing investigation, the Government respectfully requests that Exhibits B and C be filed under
seal.
The Government is attempting to obtain additional information about the Foreign Passport,
including how it was obtained and whether the passport is genuine or fabricated. But the
defendant's possession of what purports to be a foreign passport issued under an alias gives rise to
the inference the defendant knows how to obtain false travel documents and/or assume other,
foreign identities. This adds to the serious risk of flight posed by the defendant.
2 The Government has asked defense counsel to advise whether the defendant is currently, or has
been in the past, a citizen or legal permanent resident of a country other than the United States. To
date, defense counsel has declined to respond. Certainly if the defendant is, or has been, a citizen
or permanent resident of another country, that would add significantly to the overwhelming
evidence of risk of flight.
EFTA00014494

=== Page 3 ===
Case 1:19-cr-00490-RMB Document 23 Filed 07/16/19 Page 3 of 3
Hon. Richard M. Berman
United States District Judge
July 16, 2019
Page 3
IV. Cash and Diamonds
At the Detention Hearing, the Government informed the Court that diamonds and cash
were seized from a safe in the defendant's Manhattan residence. The Court inquired as to the value
of these items. After conferring with law enforcement agents who have reviewed the materials
from the safe, the Government has learned that the safe contained more than $70,000 in cash. In
addition, the safe contained 48 loose diamond stones, ranging in size from approximately 1 carat
to 2.38 carats, as well as a large diamond ring. The Government is currently unaware of whether
the defendant maintains similar stashes of cash and/or jewels at his multiple properties, or in other
locations. Such ready cash and loose diamonds are consistent with the capability to leave the
jurisdiction at a moment's notice.
V. Conclusion
For the reasons set forth herein, in the Government's July 8, 2019 and July 12, 2019
detention memoranda, and on the record at the Detention Hearing, the Court should order that the
defendant be detained pending trial. The defendant cannot meet his burden of overcoming the
presumption that there is no combination of conditions that would reasonably assure his continued
appearance in this case or protect the safety of the community were he to be released.
Respectfully submitted,
GEOFFREY S. BERMAN
United States Attorney
By:
/s
/
/
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2225 / 2415 / 2324
Cc:
Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant
EFTA00014495


c1: EFTA00014334
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014334.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before
the GRAND JURY of the people of the United States for the Southern District of New York, at the United States
Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the
Southern District of New York, at the following date, time and place:
Appearance Date:
July 31, 2019
Appearance Time: 10:00 a.m.
to testify and give evidence in regard to an alleged violation of :
18 U.S.C. §§ 1591, 2421, 2422, 2423, 371
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
See attached Advice of Rights
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
GEOFFREY Gilby S. BERMAN
July SBan/Me 15, 2019
United States Attorney for the
Southern District of New York
STATE UNITED COURT
/
/
Assistant United States Attorneys
FOR THE S RICT THE YORK
rev. 02.01.12
EFTA00014334

=== Page 2 ===
Advice of Rights
1. You may refuse to answer any question if a truthful answer to the question would tend to
incriminate you.
2. Anything that you do say may be used against you by the grand jury or in a subsequent legal
proceeding.
3. If you have a lawyer, the grand jury will permit you a reasonable opportunity to step outside the
grand jury room to consult with your lawyer if you so desire.
4. If you would like a lawyer but do not have funds to retain one, you may make an application to
the United States Magistrate Judge who will decide whether to appoint a lawyer to represent you.
EFTA00014335

=== Page 3 ===
BUT
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
July 15, 2019
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.
Moreover, if you intend to disclose the existence of this subpoena to a third party, please let me
know before making any such disclosure.
Thank you for your cooperation in this matter.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
By:
/
Assistant United States Attorneys
EFTA00014336


c1: EFTA00016461
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016461.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To: Nathan NYSD Chambers
Cc:
)"
(USANYS)"
"
,
i
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Letter from MDC Legal Counsel
Date: Fri, 04 Dec 2020 22:35:56 +0000
Attachments: Ltr_to_Hon_Nathan_12.04.20.pdf
Good evening,
Attached for Judge Nathan's review please find a letter from MDC legal counsel regarding the above-referenced case.
Because the MDC is not a party to this case, this letter has not been filed on ECF, but the Government has no objection to
the public docketing of this letter.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00016461


c1: EFTA00016813
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016813.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
]"
Subject: RE: Epstein Trust Analysis
Date: Wed, 29 Jan 2020 23:31:24 +0000
thanks
From:
Sent: Wednesday, January 29, 2020 5:51 PM
To:
Subject: Epstein Trust Analysis
Hi everyone,
I've attached a summary/analysis of the Epstein trust documents we received. This document incorporates the analysis of
the trusts from 2019 I did previously.
On the bottom, you'll see each trust has a tab and then further amendments to the trust (if any) go chronologically to the
right. There's also key and summary tabs at the beginning of the document.
Please let me know if you have any questions, or if you'd like me to walk you through how to use the document, in case it
isn't clear.
Thanks,
p.s. I wouldn't recommend printing the document, just due to the size of the excel tables.
EFTA00016813


c1: EFTA00015115
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015115.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
III Information
The following information is provided in response to your request for a III search from the State of Florida based on:
ADDITIONAL SENTENCING INFORMATION MAY BE AVAILABLE FROM ORIGINATING AGENCY
CRIMINAL HISTORY RECORD
Introduction
This rap sheet was produced in response to the following request:
The information in this rap sheet is subject to the following caveats:
This record contains
information only. When explanation of a
charge or disposition is needed, communicate directly with the agency
that contributed the record information. (; 2021-10-06)
This record may only be used for the purpose requested as defined by
the Code of Federal Regulations and/or
(; 2021-10-06)
** Expunged pursuant to
(; 2021-10-06)
** Sealed pursuant to
(; 2021-10-06)
This is a single-source offender record. (; 2021-10-06)
IDENTIFICATION
1/10
EFTA00015115

=== Page 2 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
(No Fingerprint Image Transmitted
Comment:)
DNA Data
(No DNA Detail Transmitted )
CRIMINAL HISTORY
2/10
EFTA00015116

=== Page 3 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
10
EFTA00015117

=== Page 4 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
0
EFTA00015118

=== Page 5 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
EFTA00015119

=== Page 6 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
6/10
EFTA00015120

=== Page 7 ===
7/10
EFTA00015121

=== Page 8 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
8/10
EFTA00015122

=== Page 9 ===
10/6/21, 12:42 PM
III/FBI/State Delayed Response
9/10
EFTA00015123

=== Page 10 ===
*** END OF RECORD ***
10/10
EETA00015124


c1: EFTA00016000
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016000.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "Biase, Nicholas (USANYS)"
To:
USANYS)"
Cc:
)"
)"
)"
Subject: RE: Prince Andrew as Epstein witness? - HuffPost
Date: Thu, 21 Nov 2019 19:52:03 +0000
l'll respond. Thanks.
From:
Sent: Thursday, November 21, 2019 2:51 PM
To:
Cc:
Subject: FW: Prince Andrew as Epstein witness? - HuffPost
From: Sara Boboltz
Sent: Thursday, November 21, 2019 2:49 PM
To:
Subject: Prince Andrew as Epstein witness? - HuffPost
Hello,
Writing to ask whether Britain's Prince Andrew will submit to questioning by U.S. investigators looking into
Jeffrey Epstein's potential co-conspirators. The Telegraph reported this morning that the prince is preparing to do
so.
Please let me know one way or the other if you can confirm. Thank you.
Sara Boboltz
Reporter, HuffPost
New York, NY 10003
(t) sara_bee
EFTA00016000


c1: EFTA00016299
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016299.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Shared
Date: Tue, 04 Dec 2018 16:18:52 +0000
The FOIA documents are saved here:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\FBI-FOIA
Assistant United States Attorney
Southern District of New York
EFTA00016299


c1: EFTA00015859
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015859.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:20-cr-00330-AJN Document 298 Filed 06/04/21 Page 1 of 6
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 6/4/21
United States of America,
-V-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
On April 27, 2021, the Court denied Defendant Ghislaine Maxwell's request for
authorization to serve a subpoena to Boies Schiller Flexner LLP. Dkt. No. 252. The Court
requested the Government's views as to three of those requests: Request 9, which sought
production of Minor Victim-2's entire diary from her teenage years; Request 10, which targeted
a pair of boots that Minor Victim-2 allegedly received as a gift from Jeffrey Epstein and
Maxwell; and Request 11, which sought original versions of certain photographs. Id. The
Government submitted its views on May 4, 2021. Dkt. No. 269. It supplemented its letter on
May 6, 2021. Dkt. No. 271. The Defendant filed a response on May 12, 2021. Having
considered the parties' views, the Defendant's request is denied in full.
As noted, Request 9 seeks the original copy of a journal from an alleged victim from
when she was a teenager. Maxwell received copies of some of the pages in the journal from the
Government pursuant to Rule 16, but the Government represents that it does not have access to
the entire journal. In those pages, Minor Victim-2 describes a trip to New York in which she
spent time with Epstein and, among other things, visited his residence. Minor Victim-2 also
describes her impression of Epstein at the time. There is no indication that Maxwell is
mentioned there or anywhere else in the journal.
1
EFTA00015859

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 298 Filed 06/04/21 Page 2 of 6
Maxwell appears to proffer two theories of relevance as to the entire journal. While she
studiously avoids using the word, one such theory relates to impeachment. As this Court has
noted, the potential impeachment of a witness does not provide grounds for issuance or
enforcement of a Rule 17(c) subpoena because such materials would only become relevant after
a witness has testified. United States V. Skelos, No. 15-CR-317 (KMW), 2018 WL 2254538, at
*2 (S.D.N.Y. May 17, 2018), aff'd, 988 F.3d 645 (2d Cir. 2021) (collecting cases).
The other theory of relevance that Maxwell proffers is that if the rest of the journal does
not mention her, the journal as a whole may serve as exculpatory evidence. At best, the theory
amounts to little more than a "fishing expedition," which is not the proper use of Rule 17(c). See
United States V. Nixon, 418 U.S. 683, 698-70 (1974). In any event, the argument is too
speculative to meet the standard set forth in Nixon. To begin with, the request appears to be
overbroad; under Rule 17(c), the moving party must show that all of the requested material is
relevant. Cf. United States V. Pena, No. 15-CR-551 (AJN), 2016 WL 8735699, at *2 (S.D.N.Y.
Feb. 12, 2016). It appears from the briefing that the diary includes entries from before Minor
Victim-2's first time meeting Epstein or Maxwell. Maxwell does not explain why the absence of
references to her in those entries would be relevant, and she provides no other basis as to the
relevance of any portions of the diary that precede her meeting Epstein or Maxwell. And here,
too, the theory that the rest of the journal contradicts Minor Victim-2's anticipated testimony as
to specific incidents is, in its nature, targeted at impeaching the alleged victim's anticipated
testimony.
In addition, Maxwell does not plausibly establish the relevance of the rest of the diary
other than the pages she has already received. BSF has represented that the rest of the journal
does not discuss Maxwell or Jeffrey Epstein. Dkt. No. 191 at 5. The Government has similarly
2
EFTA00015860

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 298 Filed 06/04/21 Page 3 of 6
represented that it understands that Minor Victim-2 stopped writing in the diary shortly after
meeting Jeffrey Epstein and that the diary, as a result, has no entries relating to any later trips she
took with Epstein. Dkt. No. 204 at 187. Maxwell does not provide any nonconclusory basis to
doubt these representations. So while it is undisputed that Maxwell is not referenced in the
diary-BSF, the Government, and Maxwell all agree on this point-the absence of references
alone, without regard to whether the diary contains entries relevant to the incidents about which
Minor Victim-2 is expected to testify at trial, does not establish any relevance except as to
potential impeachment.
Nor do any of Maxwell's additional arguments establish the relevance of the rest of the
journal. She points to the fairness doctrine and Rules 106 and Rule 612 of the Federal Rules of
Evidence as providing additional bases for the propriety of the request under Rule 17(c). She
cites cases regarding the fairness doctrine in the context of attorney-client privilege that have no
application to the issue presently before the Court. Furthermore, to the extent she makes an
argument under Rule 106 or Rule 612, the argument is premature. Even assuming that Rule 106
and Rule 612 could provide grounds for admissibility and relevance at trial, that would only
ripen at trial if portions of the journal are introduced and admitted. Her Rule 612 argument is
further strained by the fact that, even if that rule applied, it would not entitle the Defendant to
production of the entire journal. The Rule provides that "[i]f the producing party claims that the
writing includes unrelated matter, the court must examine the writing in camera, delete any
unrelated portion, and order that the rest be delivered to the adverse party." Fed. R. Evid.
612(b). Here, both the Government and BSF, on behalf of Minor Victim-2, have asserted that
the rest of the journal is unrelated. In any event, none of these principles establish the relevance
of the journal beyond impeachment, and all of the arguments presented to the contrary are
3
EFTA00015861

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 298 Filed 06/04/21 Page 4 of 6
meritless. Lastly, Maxwell's theory that a forensic analysis could reveal the date that the journal
was written and whether it had been altered is for impeachment of anticipated authentication
testimony. Moreover, it is entirely speculative and unsubstantiated. Maxwell provides no actual
reason to doubt the journal's authenticity. In her May 12, 2021 letter, Maxwell claims that two
copies of one of the pages are "obviously, and noticeably, different." The difference, which is
not explained in the letter, is neither obvious nor noticeable to this Court. Indeed, the writing
and handwriting in the two exhibits certainly look identical. At most, one version appears to be a
photograph of the page in the journal (Exhibit A), while the other appears to be a photocopy of
the same page (Exhibit B). Maxwell fails to identify any actual differences. Separately, here
again Maxwell's arguments sound in impeachment of anticipated authentication testimony. For
all of the reasons stated above, the Court concludes that a Rule 17(c) subpoena is not the proper
vehicle for Request 9.
Request 10 seeks production of a pair of black boots that Maxwell and Jeffrey Epstein
allegedly gave to an alleged victim. The Government has indicated that it has requested that
BSF produce the boots to the FBI and that, when the boots are in the FBI's possession, the
Government will promptly make them available to the defense for examination and use at trial.
Maxwell contends that the Court should nonetheless order the boots' production to the defense.
The argument is meritless. Rule 17(c) is not the proper mechanism for discovery from third
parties where the sought-after item is "otherwise procurable reasonably in advance of trial."
Nixon, 418 U.S. at 698-700. That is the case here: The Government has represented that the
defense will be able to inspect the boots before trial. The Defendant's request is therefore denied
as moot. If the Government fails to make the boots available for inspection within a reasonable
4
EFTA00015862

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 298 Filed 06/04/21 Page 5 of 6
timeframe, the Defendant may make an application to the Court to compel the Government to
adhere to its representation.
Request 11 seeks production of the original versions of certain photographs of the alleged
victim. Maxwell seeks these materials to inspect them prior to trial in order to investigate their
authenticity. In its May 6 letter, the Government indicated that the original versions of a subset
of the photographs are in the FBI's possession, and the Government will make those photographs
available to the defense for inspection upon request. The Court agrees with the Government that
the request is moot as to those photographs. Again, to the extent that the Government fails to
comply with its representation that it will make those photographs available to the defense upon
request, the defense may make an application to the Court.
As to the remaining photographs, the request is denied on the basis that the defense has
failed to establish the relevance of the original versions of the photographs. The defense already
has photocopies or scanned versions of the photographs in question. But the defense proffers
that it seeks the original versions of these photographs in order to determine whether they are
genuine. The only discernible theory of relevance as to this request is impeachment. Maxwell
does not set forth any other nonconclusory basis for their relevance. And again, because
impeachment evidence falls outside the scope of Rule 17(c), the request fails to meet Nixon's
relevance requirement. But even assuming that impeachment could permissibly establish
relevance, the argument fails because Maxwell does not yet know the scope of the victim's
testimony or whether it will implicate the photographs.
I.
Conclusion
The Defendant's motion for an order authorizing the subpoena pursuant to Rule 17(c)(3)
is DENIED.
5
EFTA00015863

=== Page 6 ===
Case 1:20-cr-00330-AJN Document 298 Filed 06/04/21 Page 6 of 6
so ORDERED.
Alim D. Netto
Dated: June 4, 2021
New York, New York
ALISON J. NATHAN
United States District Judge
6
EFTA00015864


c1: EFTA00015573
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015573.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: Jeffrey Epstein
Date: Sun, 07 Jul 2019 17:23:43 +0000
Importance: Normal
Thank you!!
From:
(USANYS)
Sent: Sunday, July 07, 2019 13:15
To:
is
>;
Subject: FW: Jeffrey Epstein
Unbelievable work all!
From:
(USANYS)
Sent: Sunday, July 7, 2019 1:08 PM
To:
Cc:
>;
is
>;
(USANYS)
Subject: Jeffrey Epstein
Hey PCU - As you likely may have seen/heard at this point, last evening, we arrested Jeffrey Epstein on sex trafficking
charges. Epstein is in custody and will be presented and arraigned on an Indictment that will be unsealed tomorrow
morning.
The case is an incredibly important one - not only is the conduct extremely serious and deeply disturbing - but our
charges ensure that dozens if not more of Epstein's victims, girls who were as young as 14 at the time they were abused,
will finally have their day in court. It is an extraordinarily worthy prosecution and just the latest example of how this unit
will never shy away from bringing tough cases against powerful people who have committed grievous crimes.
Please join me and
in extending a very well-deserved congratulations to the team,
who
have worked tirelessly to make this case happen (and happen so quickly). They have done us all proud, and if you are
free, we hope you join us for the press conference formally announcing the charges, which should happen Monday
morning at 11.
&
EFTA00015573


c1: EFTA00016814
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016814.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
)"
Subject: Re: Epstein Sharing Order Part II
Date: Thu, 30 Jan 2020 17:16:48 +0000
I just need to add "revocations" throughout, which I can do this afternoon, by about 3:00, and then circulate. Will
do.
Sent from my iPhone
On Jan 30, 2020, at 12:05,
(USANYS)
wrote:
Just wanted to circle back on this -
are you signed off? Is this something we could get over to Part I today or
tomorrow? Thanks
From:
Sent: Wednesday, January 29, 2020 3:56 PM
To:
(USANYS)
in
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
is it the intent to share those? If so, l'll just add it to every mention of each document, but if not then it's
unnecessary. I don't think those are substantive docs but I defer.
From:
(USANYS)
Sent: Wednesday, January 29, 2020 15:55
To:
)
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
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:
is
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,
EFTA00016814

=== Page 2 ===
From:
(USANYS)
Sent: Wednesday, January 29, 2020 10:40
To:
(USANYS)
in
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,
EFTA00016815


c1: EFTA00016466
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016466.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
Subject: RE: Maxwell Briefing re Sasso
Date: Wed, 24 Nov 2021 14:28:29 +0000
Attachments: Motion to preclude Hall et al [unredacted].pdf;
2021.11.22_20cr330_Hall_Temp_Seal_Mem_Op_&_Order_11.22.21.pdf
Here you go. Also attaching Judge Nathan's opinion.
did a really nice job with this, we're so thankful he pitched in.
We've litigated I think nine experts at this point.
The process of redacting/sealing this stuff has been overcomplicated, so if you'd like to cite to any of this please check
with
copied here, who can help sort that out.
From:
(USANYS)
Sent: Wednesday, November 24, 2021 9:08 AM
To:
Cc:
(USANYS)
Subject: Maxwell Briefing re Sasso
Can you please send us the brief you filed regarding admissibility of mental health evidence / Sasso -
says your team
filed something about this (and maybe
worked on it)?
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York, New York 10007
Tel:
EFTA00016466


c1: EFTA00016310
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016310.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: GM appeal
Date: Sun, 13 Sep 2020 16:34:52 +0000
Attachments: Government_MTD_GM_Interlocutory_Appeal_v1.docx
Driving to go pick
Attached is as far as I got with the MTD. If you're able to
turn to this now, that would be great. I should be back online in a couple hours and can take it back from you then.
Thanks!
From:
Sent: Sunday, September 13, 2020 11:31 AM
To:
Subject: Re: GM appeal
Sounds good thanks
Sent from my iPhone
On Sep 13, 2020, at 11:28 AM,
wrote:
No problem-l've gone ahead and started on the MTD. Will work on it for the next hour or so, then send to you to pick
up.
From:
Sent: Sunday, September 13, 2020 11:26 AM
To:
Subject: Re: GM appeal
Hi! I ended up just blocking off today to do this
(
is gone for the day), so I haven't gotten anywhere yet (sorry about
that) but am hopeful to knock this out today. Do you want to split topics, as we discussed, and merge later? Happy to do
this any way that works.
Sent from my iPhone
On Sep 13, 2020, at 10:36 AM,
wrote:
Hey-have you started a draft of either document? I'm diving in now, so happy to pickup wherever you left off, or get
them started if you haven't had the chance.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00016310


c1: EFTA00016234
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016234.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: John Ray <john@raymitevlaw.com>
Cc:
)"
)"
Subject: RE: Epstein investigation
Date: Tue, 31 Mar 2020 17:51:19 +0000
John,
Understood, and thanks for following up, we appreciate it. We'll incorporate this information into the investigation and
certainly will follow up as appropriate. Thanks again, both for the initial information and for following up.
best,
From: John Ray <john@raymitevlaw.com>
Sent: Friday, March 27, 2020 19:37
To:
Subject: Re: Epstein investigation
Dear
, both I and my life partner are the sources of info. She isMadeleine Kristoffersson. Her tel # is
She lives in
with me. Most of what we know about her is from
personal knowledge. The rest is from social media. A great deal of social media was taken away right after she
became controversial. They scrubbed the internet Epstein was her "BBB" Man of the Year in 2002. He paid her
$150,000 through two shell entities for her girls. We do not know the ages of the various women. We did not
become familiar with the women. We ask for confidentiality for Madeleine. Madeleine , who is an opera singer,
once sang for a BBB function. Enough social media, however, remains, and seems useful. We do not know all
the sordid details, but we were never aware of any rules or age restrictions she imposed. I guess our point in
contacting you was because we assumed that she is a person of interest and we know that she slipped into the US
after hiding out in Stockholm. So we were trying to help before she went back out of reach to
Stockholm.Sincerely, John Ray ps, we are sending along various photos of BBB girls, always teamed up with
old men. , including Hazeltine. These photos we captured beforeBarbru cleansed them from the internet.
On Fri, Mar 27, 2020 at 4:38 PM
)
wrote:
John,
Wanted to get back to you regarding your letter of March 9, 2020, which we received via the Eastern District
U.S. Attorney's Office, and your follow-up call this week, both of which we appreciate. We did receive the
letter, and in the first instance it would be helpful to know the name and contact info of the person who's the
source of this information (assuming it is someone other than you) - we ordinarily pass this kind of
information to the FBI for initial response, but it's not clear from the letter whom they would be in touch with
to follow up. It would also be helpful to know, if you're aware, whether there is any allegation that the
relevant interns were underage.
thanks very much,
EFTA00016234

=== Page 2 ===
Assistant U.S. Attorney
Southern District of New York
Very truly yours,
John Ray
Ray, Mitev & Associates, LLP
New York Attorneys
"Killer Bees"
Manhattan:
5 E 22nd Street, 17th Floor
At Broadway
New York, NY 10010
Tel: 1-866-88 NYLAW
Long Island:
122 North Country Road
Miller Place, New York 11764
Tel: 631-473-1000
Fax: 631-928-5385
IRS Circular 230 Required Notice-IRS regulations require that we inform you that to the extent this
communication contains any statement regarding federal taxes, that statement was not written or
intended to be used, and it cannot be used, by any person (i) for the purpose of avoiding federal tax
penalties that may be imposed on that person, or (ii) to promote, market or recommend to another
party any transaction or matter addressed herein.
This communication is otherwise privileged and confidential as attorney-client communication and/or
attorney work product and may not be used, reproduced, reformatted or in any way referred to without
the prior written consent of Ray, Mitev & Associates, under penalty of law. If you have received this
message in error, or are not the intended recipient, please notify us immediately and destroy this
message, along with any and all copies of this message.
Service of legal papers/documents by e-mail is not authorized and will be treated as a nullity. To the
extent that this communication may contain attorney advertising, same is not intended to form any
attorney-client relationship or otherwise impart or convey any legal advice.
EFTA00016235


c1: EFTA00016593
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016593.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
(USANYS)"
)"
i
)"
Subject: Re: Ex Parte Submission: United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Date: Mon, 05 Aug 2019 13:51:20 +0000
Great, well done.
Sent from my iPhone
> On Aug 5, 2019, at 9:45 AM,
)
wrote:
>
> FYI, here's the order from Berman on our 16(d) letter.
>
V
Original Message
> From: Christine_Murray@nysd.uscourts.gov <Christine_Murray@nysd.uscourts.gov>
> Sent: Monday, August 5, 2019 9:44 AM
> To:
)
> Cc:
)
i
)
> Subject: Re: Ex Parte Submission: United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
V
> (See attached file: 19CR490 AUG 5 2019 MEMO END.pdf)
> <19CR490 AUG 5 2019 MEMO END.pdf>
EFTA00016593


c1: EFTA00015825
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015825.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: David Oscar Markus
To:
(USANYS)"
Cc:
)"
)"
Subject: Re: U.S. V. Ghislaine Maxwell
Date: Sat, 10 Apr 2021 01:23:56 +0000
If you are filing that one unredacted pleading, would you be willing to file the others as well? I think the court
should have them all. Let me know if you will include the others.
Thanks,
David
--David Oscar Markus
Markus/Moss
markuslaw.com
On Apr 9, 2021, at 6:25 PM, David Oscar Markus
wrote:
Hi
No objection.
Have a nice weekend.
David.
--David Oscar Markus
Markus/Moss
markuslaw.com
On Apr 9, 2021, at 6:21 PM,
(USANYS)
wrote:
David,
We intend to submit a motion to seek leave to file an unredacted copy of Exhibit F under seal and need to indicate
your position. Do you consent to this request?
Thanks
EFTA00015825

=== Page 2 ===
From: David Oscar Markus
Sent: Thursday, April 01, 2021 6:35 PM
To:
(USANYS)
Cc:
is
Subject: Re: U.S. V. Ghislaine Maxwell
Thanks. I won't ask to shorten the 10 days if the government doesn't plan on asking for an extension. dm
--David Oscar Markus
Markus/Moss
markuslaw.com
On Apr 1, 2021, at 6:07 PM,
(USANYS)
wrote:
We do not oppose the Court expediting consideration but do oppose any request to shorten the ten days by which
we have to respond.
From: David Oscar Markus
Sent: Thursday, April 01, 2021 5:59 PM
To:
(USANYS)
Cc:
is
Subject: Re: U.S. V. Ghislaine Maxwell
Both.
--David Oscar Markus
Markus/Moss
markuslaw.com
On Apr 1, 2021, at 5:33 PM,
(USANYS)
wrote:
David,
Are you asking to expedite the Court's consideration of the appeal or asking to shorten our timeline for
responding?
Thanks,
From: David Oscar Markus
Sent: Thursday, April 01, 2021 5:27 PM
To:
Cc:
is
(USANYS)
Subject: Re: U.S. V. Ghislaine Maxwell
Counsel:
EFTA00015826

=== Page 3 ===
What is the government's position on expediting the appeal?
Thank you.
David
--David Oscar Markus
Markus/Moss
markuslaw.com
On Mar 25, 2021, at 7:11 PM,
wrote:
David,
Thanks for letting us know that you'll be counsel on this appeal. As an initial matter, the majority of the docket
entries you've referenced do not appear to be redacted. In any event, you may obtain these materials from
defense counsel -- I've copied them here. This case is already governed by a protective order (ECF No. 36), which
is binding on all counsel.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
(212) 63
From: David Oscar Markus
Sent: Thursday, March 25, 2021 5:33 PM
To:
is
)
V.
(USANYS)
Subject: U.S. V. Ghislaine Maxwell
Good afternoon counsel:
I have been engaged to represent Ghislaine Maxwell in her appeal from the denial of her third application
for bail. In preparing this appeal, I will need access to certain unredacted documents, including docket
entries 4, 18, 22, 97, 100, 103, 106, 159, 160, 165, 171, 169. Do you have any objection to me having
access to these unredacted documents? (There may be additional documents that I need, but I have not
identified them as of yet.) I'm happy to enter into a protective order with the government if you believe
EFTA00015827

=== Page 4 ===
that is necessary. I plan on filing the appeal next week, so I would appreciate it if you could get back to
me as soon as possible.
Thank you,
David
--David Oscar Markus
markuslaw.com
EFTA00015828


c1: EFTA00016542
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016542.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Signature Page Summary
Ghislaine Maxwell
Account Number and Description
Signature Requirement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
RMA Domestic - Sole Owner
Client Relationship Agreement
de 0177 2386 4771 02/12/2014
Package ID: 0093830915
1
SDNY_GM_00274191
EFTA00016542

=== Page 2 ===
Intentionally Left Blank
de 0177 2386 4772 02/12/2014
SDNY_GM_00274192
EFTA00016543

=== Page 3 ===
Client Information
Client Information
Client Information
Ghislaine Maxwell
Personal Information
U.S. Federal law requires us
Name
Ghislaine Maxwell
to obtain, verify and record
information that identifies
Citizenship
United States
each person or entity
Gender
Female
that opens an Account with
us. When you open an
Date of Birth
Account, we will ask for
Marital Status
Single
your name, street address,
date of birth and a tax
identification number, such
as a Social Security number.
We may also ask to see a
driver's license or other
Contact Information
documents that will allow
Residential Address
us to identify you.
City, State, Zip Code
New York, NY 10065-7007
Please review and verify all
Home Phone
of the information that you
provided to us when you
E-mail Address
opened your Account If
you have changes,
corrections or additions,
notify your Financial Advisor
Employment Information
as soon as possible.
Employment Status
Employed
If you share assets with
Occupation
Other
another person, the net
Other
worth figure here shows
Occupation Industry
your portion only, based
Employer Name
The TerraMar Project
upon instructions you
provided.
Business Address
Investment Information:
City, State, Zip Code
New York, NY 10065 7007
This section reflects answers
you provided related to
Net Worth Information
your investment experience,
market knowledge and
Annual Income
Range from $200,000 $499,999
other assets and is used to
ensure our investment
Liquid Assets (cash and marketable securities)
Range from $10,000,000 AND ABOVE
recommendations are
Net Worth (excluding primary residence)
Range from $10,000,000 AND ABOVE
suitable for your situation.
You have indicated that you do not derive a substantial amount of your income / wealth (over 50%) from a
country outside of the United States.
Investment Information
Years you have held investment accounts
20
Equities
None
Bonds
None
Futures
None
Options-Buy
None
Options-Sell
None
Knowledge of investments
You have indicated you are an experienced investor
in financial markets and market investments.
Percentage of total investable assets held at UBS
Less than 20%
Other
Own Home or Rent?
Own
Affiliations
Affiliated with securities firms or broker/dealer?
No
You have indicated that you are not an employee of UBS AG, its subsidiary or affiliates.
You have indicated that you are not related to an employee of UBS AG, its subsidiary or affiliates.
3
3
SDNY_GM_00274193
EFTA00016544

=== Page 4 ===
Client Information
You have indicated that you are not a control person (Policy-maker, director or 10% shareholder) of a publicly
traded corporation.
Client Information
4
4
SDNY_GM_00274194
EFTA00016545

=== Page 5 ===
Account Information
Account Information
Account Information
RMA Domestic Sole Owner
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Ghislaine Maxwell
Advisor immediately if you
Account Address
have any changes or
corrections.
City, State zip
New York, NY 10065-7007
For more information, please
refer to the UBS Deposit
Cards and Checks for this account, if requested, will
Account Sweep Program
be mailed to this address:
New York, NY 10065-7007
Disclosure Statement
Primary Account Holder
Ghislaine Maxwell
Please note the account risk
profile and investment
UBS will not disclose your name, address and security
objective below are specific only
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
to this account: other accounts
Account.
may have different account risk
profiles and investment
Margin
Yes
objectives.
Your Account Risk Profile for
You have agreed that the Margin Agreement in the Completing Your Account Opening Process
this particular account is defined
package governs your use of margin in this account and all other accounts you have now or any
as:
accounts that you may open in the future. As described in the Margin Agreement, certain securities
Aggressive Willing to accept
in your Account may be loaned to UBS or to other persons or entities.
high risk to principal and high
volatility to seek high returns over
time.
Cost Basis Method
First In,First Out
Different accounts may have
different risk profiles
Features and Services
Your Investment Objective
Produce a Combination of
Checking
Premier- RMA / BSA
Income and Capital
Appreciation Investments
VISA Credit (W/Rewards points)
seeking both the generation of
income and growth of principal.
Account Objectives and Risk Profile
A senior political official is
defined as a President or Vice
Account Risk Profile
Aggressive/Speculative
President, Cabinet Member,
Your answers to our profiling questions:
Supreme Court Justice,
member of the Joint Chief's
Risk Tolerance
High Risk
Staff, Member of Congress or
a Parliament, Chairperson,
Investment Objective
Produce a combination of income and capital
Head or Senior Leader of a
appreciation
major religious organization,
or the like.
Risk/Return Objectives
Higher Fluctuations, Higher Returns
Investment Time Horizon
Longer than 10 years (through several market cycles)
Short-Term Liquidity Needs
No
Sweep Account Election
Primary Sweep Fund
UBS BANK USA DEPOSIT ACCOUNT
Sweep Cap Election
Yes
Cap Amount
$250000.00
Secondary Sweep Fund
UBS AG DEPOSIT ACCOUNT
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Other Income Source
transfer
5
5
SDNY_GM_00274195
EFTA00016546

=== Page 6 ===
Account Information
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Account Information
Conditions of this service.
E-mail Address
UBS Credit Card Profile (With Rewards points)
Applicant
GHISLAINE MAXWELL
UBS Card Program
UBS Visa Signature Credit Card
Card Security Contact Phone Number (Applicant)
6
6
SDNY_GM_00274196
EFTA00016547

=== Page 7 ===
Account Information
Account Information
RMA Domestic Sole Owner
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Ghislaine Maxwell
Advisor immediately if you
have any changes or
Account Address
corrections
City, State zip
New York, NY 10065-7007
For more information, please
refer to the UBS Deposit
Cards and Checks for this account, if requested, will
Account Sweep Program
be mailed to this address:
New York, NY 10065-7007
Disclosure Statement
Primary Account Holder
Ghislaine Maxwell
Please note: the account risk
profile and investment
UBS will not disclose your name, address and security
objective below are specific only
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
to this account other accounts
Account.
may have different account risk
profiles and investment
Margin
No
objectives.
Your Account Risk Profile for
If you did not choose Margin when you opened this account, you may ask to establish margin by
this particular account is defined
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
as.
Account Opening Process package will govern your use of margin in this account and all other
Moderate Willing to accept
accounts you have now or may open in the future.
some risk to principal and tolerate
some volatility to seek higher
returns.
Cost Basis Method
First n,First Out
Different accounts may have
different risk profiles
Features and Services
Your Investment Objective
Produce a Combination of
Premier- RMA / BSA
Income and Capital
Appreciation: Investments
seeking both the generation of
Account Objectives and Risk Profile
income and growth of principal.
in accounts with conservative
Account Risk Profile
Moderate
or moderate risk profiles,
Your answers to our profiling questions:
investment eligibility
considerations help us
Risk Tolerance
Moderately High Risk
identify whether you may be
Produce a combination of income and capital
eligible to invest in certain
Investment Objective
higher risk securities as a
appreciation
portion of your portfolio.
Risk/Return Objectives
Moderate Fluctuations, Moderate Returns
These investments offer
additional diversification.
Investment Time Horizon
7- 10 years
A senior political official is
Short-Term Liquidity Needs
Yes
defined as a President or Vice
President, Cabinet Member,
Sweep Account Election
Supreme Court Justice,
Primary Sweep Fund
UBS BANK USA DEPOSIT ACCOUNT
member of the Joint Chief's
Staff, Member of Congress or
Sweep Cap Election
Yes
a Parliament, Chairperson,
Head or Senior Leader of a
Cap Amount
$250000.00
major religious organization,
Secondary Sweep Fund
UBS AG DEPOSIT ACCOUNT
or the like.
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Other Income Source
transfer
7
7
SDNY_GM_00274197
EFTA00016548

=== Page 8 ===
Account Information
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Account Information
Conditions of this service.
E-mail Address
8
8
SDNY_GM_00274198
EFTA00016549

=== Page 9 ===
Account Information
Account Information
RMA Domestic Sole Owner
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Ghislaine Maxwell
Advisor immediately if you
have any changes or
Account Address
corrections
City, State zip
New York, NY 10065-7007
For more information, please
refer to the UBS Deposit
Cards and Checks for this account, if requested, will
Account Sweep Program
be mailed to this address:
New York, NY 10065-7007
Disclosure Statement
Primary Account Holder
Ghislaine Maxwell
Please note: the account risk
profile and investment
UBS will not disclose your name, address and security
objective below are specific only
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
to this account other accounts
Account.
may have different account risk
profiles and investment
Margin
No
objectives.
Your Account Risk Profile for
If you did not choose Margin when you opened this account, you may ask to establish margin by
this particular account is defined
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
as.
Account Opening Process package will govern your use of margin in this account and all other
Moderate Willing to accept
accounts you have now or may open in the future.
some risk to principal and tolerate
some volatility to seek higher
returns.
Cost Basis Method
First In,First Out
Different accounts may have
different risk profiles
Features and Services
Your Investment Objective
Produce a Combination of
Premier- RMA / BSA
Income and Capital
Appreciation: Investments
seeking both the generation of
Account Objectives and Risk Profile
income and growth of principal.
in accounts with conservative
Account Risk Profile
Moderate
or moderate risk profiles,
Your answers to our profiling questions:
investment eligibility
considerations help us
Risk Tolerance
Moderately High Risk
identify whether you may be
Produce a combination of income and capital
eligible to invest in certain
Investment Objective
higher risk securities as a
appreciation
portion of your portfolio.
Risk/Return Objectives
Higher Fluctuations, Higher Returns
These investments offer
additional diversification.
Investment Time Horizon
7- 10 years
A senior political official is
Short-Term Liquidity Needs
No
defined as a President or Vice
President, Cabinet Member,
Sweep Account Election
Supreme Court Justice,
Primary Sweep Fund
UBS BANK USA DEPOSIT ACCOUNT
member of the Joint Chief's
Staff, Member of Congress or
Sweep Cap Election
Yes
a Parliament, Chairperson,
Head or Senior Leader of a
Cap Amount
$250000.00
major religious organization,
Secondary Sweep Fund
UBS AG DEPOSIT ACCOUNT
or the like.
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Other Income Source
transfer
9
9
SDNY_GM_00274199
EFTA00016550

=== Page 10 ===
Account Information
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Account Information
Conditions of this service.
E-mail Address
10
10
SDNY_GM_00274200
EFTA00016551

=== Page 11 ===
Account Information
Account Information
RMA Domestic Sole Owner
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Ghislaine Maxwell
Advisor immediately if you
have any changes or
Account Address
corrections
City, State zip
New York, NY 10065-7007
For more information, please
refer to the UBS Deposit
Cards and Checks for this account, if requested, will
Account Sweep Program
be mailed to this address:
New York, NY 10065-7007
Disclosure Statement
Primary Account Holder
Ghislaine Maxwell
Please note the account risk
profile and investment
UBS will not disclose your name, address and security
objective below are specific only
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
to this account: other accounts
Account.
may have different account risk
profiles and investment
Margin
No
objectives.
Your Account Risk Profile for
If you did not choose Margin when you opened this account, you may ask to establish margin by
this particular account is defined
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
as:
Account Opening Process package will govern your use of margin in this account and all other
Moderate Willing to accept
accounts you have now or may open in the future.
some risk to principal and tolerate
some volatility to seek higher
returns.
Cost Basis Method
First n,First Out
Different accounts may have
different risk profiles
Features and Services
Your Investment Objective
Produce a Combination of
Premier- RMA / BSA
Income and Capital
Appreciation Investments
seeking both the generation of
Account Objectives and Risk Profile
income and growth of principal.
in accounts with conservative
Account Risk Profile
Moderate
or moderate risk profiles,
Your answers to our profiling questions:
investment eligibility
considerations help us
Risk Tolerance
Moderately High Risk
identify whether you may be
Produce a combination of income and capital
eligible to invest in certain
Investment Objective
higher risk securities as a
appreciation
portion of your portfolio.
Risk/Return Objectives
Moderate Fluctuations, Moderate Returns
These investments offer
additional diversification
Investment Time Horizon
7- 10 years
A senior political official is
Short-Term Liquidity Needs
No
defined as a President or Vice
President, Cabinet Member,
Sweep Account Election
Supreme Court Justice,
Primary Sweep Fund
UBS BANK USA DEPOSIT ACCOUNT
member of the Joint Chief's
Staff, Member of Congress or
Sweep Cap Election
Yes
a Parliament, Chairperson,
Head or Senior Leader of a
Cap Amount
$250000.00
major religious organization,
Secondary Sweep Fund
UBS AG DEPOSIT ACCOUNT
or the like.
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Other Income Source
transfer
11
11
SDNY_GM_00274201
EFTA00016552

=== Page 12 ===
Account Information
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Account Information
Conditions of this service.
E-mail Address
12
12
SDNY_GM_00274202
EFTA00016553

=== Page 13 ===
Account Information
Account Information
RMA Domestic Sole Owner
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Ghislaine Maxwell
Advisor immediately if you
have any changes or
Account Address
corrections.
City, State zip
New York, NY 10065-7007
For more information, please
refer to the UBS Deposit
Cards and Checks for this account, if requested, will
Account Sweep Program
be mailed to this address:
New York, NY 10065-7007
Disclosure Statement
Primary Account Holder
Ghislaine Maxwell
Please note the account risk
profile and investment
UBS will not disclose your name, address and security
objective below are specific only
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
to this account: other accounts
Account.
may have different account risk
profiles and investment
Margin
No
objectives.
Your Account Risk Profile for
If you did not choose Margin when you opened this account, you may ask to establish margin by
this particular account is defined
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
as:
Account Opening Process package will govern your use of margin in this account and all other
Moderate Willing to accept
accounts you have now or may open in the future.
some risk to principal and tolerate
some volatility to seek higher
returns.
Cost Basis Method
First First Out
Different accounts may have
different risk profiles
Features and Services
Your Investment Objective
Produce a Combination of
Premier- RMA / BSA
Income and Capital
Appreciation Investments
seeking both the generation of
Account Objectives and Risk Profile
income and growth of principal.
in accounts with conservative
Account Risk Profile
Moderate
or moderate risk profiles,
Your answers to our profiling questions:
investment eligibility
considerations help us
Risk Tolerance
Moderately High Risk
identify whether you may be
Produce a combination of income and capital
eligible to invest in certain
Investment Objective
higher risk securities as a
appreciation
portion of your portfolio.
Risk/Return Objectives
Moderate Fluctuations, Moderate Returns
These investments offer
additional diversification.
Investment Time Horizon
7- 10 years
A senior political official is
Short-Term Liquidity Needs
No
defined as a President or Vice
President, Cabinet Member,
Sweep Account Election
Supreme Court Justice,
Primary Sweep Fund
UBS BANK USA DEPOSIT ACCOUNT
member of the Joint Chief's
Staff, Member of Congress or
Sweep Cap Election
Yes
a Parliament, Chairperson,
Head or Senior Leader of a
Cap Amount
$250000.00
major religious organization,
Secondary Sweep Fund
UBS AG DEPOSIT ACCOUNT
or the like.
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Other Income Source
transfer
13
13
SDNY_GM_00274203
EFTA00016554

=== Page 14 ===
Account Information
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Account Information
Conditions of this service.
E-mail Address
14
14
SDNY_GM_00274204
EFTA00016555

=== Page 15 ===
Account Information
Account Information
RMA Domestic Sole Owner
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Ghislaine Maxwell
Advisor immediately if you
have any changes or
Account Address
corrections.
City, State zip
New York, NY 10065-7007
For more information, please
refer to the UBS Deposit
Cards and Checks for this account, if requested, will
Account Sweep Program
be mailed to this address:
New York, NY 10065-7007
Disclosure Statement
Primary Account Holder
Ghislaine Maxwell
Please note the account risk
profile and investment
UBS will not disclose your name, address and security
objective below are specific only
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
to this account: other accounts
Account.
may have different account risk
profiles and investment
Margin
No
objectives.
Your Account Risk Profile for
If you did not choose Margin when you opened this account, you may ask to establish margin by
this particular account is defined
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
as:
Account Opening Process package will govern your use of margin in this account and all other
Moderate Willing to accept
accounts you have now or may open in the future.
some risk to principal and tolerate
some volatility to seek higher
returns.
Cost Basis Method
First n,First Out
Different accounts may have
different risk profiles
Features and Services
Your Investment Objective
Produce a Combination of
Premier- RMA / BSA
Income and Capital
Appreciation Investments
seeking both the generation of
Account Objectives and Risk Profile
income and growth of principal.
in accounts with conservative
Account Risk Profile
Moderate
or moderate risk profiles,
Your answers to our profiling questions:
investment eligibility
considerations help us
Risk Tolerance
Moderately High Risk
identify whether you may be
Produce a combination of income and capital
eligible to invest in certain
Investment Objective
higher risk securities as a
appreciation
portion of your portfolio.
Risk/Return Objectives
Higher Fluctuations, Higher Returns
These investments offer
additional diversification
Investment Time Horizon
7- 10 years
A senior political official is
Short-Term Liquidity Needs
No
defined as a President or Vice
President, Cabinet Member,
Sweep Account Election
Supreme Court Justice,
Primary Sweep Fund
UBS BANK USA DEPOSIT ACCOUNT
member of the Joint Chief's
Staff, Member of Congress or
Sweep Cap Election
Yes
a Parliament, Chairperson,
Head or Senior Leader of a
Cap Amount
$250000.00
major religious organization,
Secondary Sweep Fund
UBS AG DEPOSIT ACCOUNT
or the like.
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Other Income Source
transfer
15
15
SDNY_GM_00274205
EFTA00016556

=== Page 16 ===
Account Information
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Account Information
Conditions of this service.
E-mail Address
16
16
SDNY_GM_00274206
EFTA00016557

=== Page 17 ===
Account Information
Account Information
RMA Domestic Sole Owner
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Ghislaine Maxwell
Advisor immediately if you
have any changes or
Account Address
corrections.
City, State zip
New York, NY 10065-7007
For more information, please
refer to the UBS Deposit
Cards and Checks for this account, if requested, will
Account Sweep Program
be mailed to this address:
New York, NY 10065-7007
Disclosure Statement
Primary Account Holder
Ghislaine Maxwell
Please note the account risk
profile and investment
UBS will not disclose your name, address and security
objective below are specific only
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
to this account: other accounts
Account.
may have different account risk
profiles and investment
Margin
No
objectives.
Your Account Risk Profile for
If you did not choose Margin when you opened this account, you may ask to establish margin by
this particular account is defined
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
as:
Account Opening Process package will govern your use of margin in this account and all other
Moderate Willing to accept
accounts you have now or may open in the future.
some risk to principal and tolerate
some volatility to seek higher
returns.
Cost Basis Method
First In,First Out
Different accounts may have
different risk profiles
Features and Services
Your Investment Objective
Produce a Combination of
Premier- RMA / BSA
Income and Capital
Appreciation Investments
seeking both the generation of
Account Objectives and Risk Profile
income and growth of principal.
in accounts with conservative
Account Risk Profile
Moderate
or moderate risk profiles,
Your answers to our profiling questions:
investment eligibility
considerations help us
Risk Tolerance
Moderately High Risk
identify whether you may be
Produce a combination of income and capital
eligible to invest in certain
Investment Objective
higher risk securities as a
appreciation
portion of your portfolio.
Risk/Return Objectives
Moderate Fluctuations, Moderate Returns
These investments offer
additional diversification
Investment Time Horizon
7- 10 years
A senior political official is
Short-Term Liquidity Needs
No
defined as a President or Vice
President, Cabinet Member,
Sweep Account Election
Supreme Court Justice,
Primary Sweep Fund
UBS BANK USA DEPOSIT ACCOUNT
member of the Joint Chief's
Staff, Member of Congress or
Sweep Cap Election
Yes
a Parliament, Chairperson,
Head or Senior Leader of a
Cap Amount
$250000.00
major religious organization,
Secondary Sweep Fund
UBS AG DEPOSIT ACCOUNT
or the like.
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Other Income Source
transfer
17
17
SDNY_GM_00274207
EFTA00016558

=== Page 18 ===
Account Information
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Account Information
Conditions of this service.
E-mail Address
18
18
SDNY_GM_00274208
EFTA00016559

=== Page 19 ===
Account Information
Account Information
RMA Domestic Sole Owner
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Ghislaine Maxwell
Advisor immediately if you
have any changes or
Account Address
corrections.
City, State zip
New York, NY 10065-7007
For more information, please
refer to the UBS Deposit
Cards and Checks for this account, if requested, will
Account Sweep Program
be mailed to this address:
New York, NY 10065-7007
Disclosure Statement
Primary Account Holder
Ghislaine Maxwell
Please note the account risk
profile and investment
UBS will not disclose your name, address and security
objective below are specific only
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
to this account: other accounts
Account.
may have different account risk
profiles and investment
Margin
No
objectives.
Your Account Risk Profile for
If you did not choose Margin when you opened this account, you may ask to establish margin by
this particular account is defined
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
as:
Account Opening Process package will govern your use of margin in this account and all other
Moderate Willing to accept
accounts you have now or may open in the future.
some risk to principal and tolerate
some volatility to seek higher
returns.
Cost Basis Method
First First Out
Different accounts may have
different risk profiles
Features and Services
Your Investment Objective
Produce a Combination of
Premier- RMA / BSA
Income and Capital
Appreciation Investments
seeking both the generation of
Account Objectives and Risk Profile
income and growth of principal.
in accounts with conservative
Account Risk Profile
Moderate
or moderate risk profiles,
Your answers to our profiling questions:
investment eligibility
considerations help us
Risk Tolerance
Moderately High Risk
identify whether you may be
Produce a combination of income and capital
eligible to invest in certain
Investment Objective
higher risk securities as a
appreciation
portion of your portfolio.
Risk/Return Objectives
Moderate Fluctuations, Moderate Returns
These investments offer
additional diversification
Investment Time Horizon
7- 10 years
A senior political official is
Short-Term Liquidity Needs
No
defined as a President or Vice
President, Cabinet Member,
Sweep Account Election
Supreme Court Justice,
Primary Sweep Fund
UBS BANK USA DEPOSIT ACCOUNT
member of the Joint Chief's
Staff, Member of Congress or
Sweep Cap Election
Yes
a Parliament, Chairperson,
Head or Senior Leader of a
Cap Amount
$250000.00
major religious organization,
Secondary Sweep Fund
UBS AG DEPOSIT ACCOUNT
or the like.
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Other Income Source
transfer
19
19
SDNY_GM_00274209
EFTA00016560

=== Page 20 ===
Account Information
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Account Information
Conditions of this service.
E-mail Address
20
20
SDNY_GM_00274210
EFTA00016561

=== Page 21 ===
Account Information
Account Information
RMA Domestic Sole Owner
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Ghislaine Maxwell
Advisor immediately if you
have any changes or
Account Address
corrections.
City, State zip
New York, NY 10065-7007
For more information, please
refer to the UBS Deposit
Cards and Checks for this account, if requested, will
Account Sweep Program
be mailed to this address:
New York, NY 10065-7007
Disclosure Statement
Primary Account Holder
Ghislaine Maxwell
Please note the account risk
profile and investment
UBS will not disclose your name, address and security
objective below are specific only
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
to this account: other accounts
Account.
may have different account risk
profiles and investment
Margin
No
objectives.
Your Account Risk Profile for
If you did not choose Margin when you opened this account, you may ask to establish margin by
this particular account is defined
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
as:
Account Opening Process package will govern your use of margin in this account and all other
Moderate Willing to accept
accounts you have now or may open in the future.
some risk to principal and tolerate
some volatility to seek higher
returns.
Cost Basis Method
First In,First Out
Different accounts may have
different risk profiles
Features and Services
Your Investment Objective
Produce a Combination of
Premier- RMA / BSA
Income and Capital
Appreciation Investments
seeking both the generation of
Account Objectives and Risk Profile
income and growth of principal.
in accounts with conservative
Account Risk Profile
Moderate
or moderate risk profiles,
Your answers to our profiling questions:
investment eligibility
considerations help us
Risk Tolerance
Moderately High Risk
identify whether you may be
Produce a combination of income and capital
eligible to invest in certain
Investment Objective
higher risk securities as a
appreciation
portion of your portfolio.
Risk/Return Objectives
Higher Fluctuations, Higher Returns
These investments offer
additional diversification
Investment Time Horizon
7- 10 years
A senior political official is
Short-Term Liquidity Needs
No
defined as a President or Vice
President, Cabinet Member,
Sweep Account Election
Supreme Court Justice,
Primary Sweep Fund
UBS BANK USA DEPOSIT ACCOUNT
member of the Joint Chief's
Staff, Member of Congress or
Sweep Cap Election
Yes
a Parliament, Chairperson,
Head or Senior Leader of a
Cap Amount
$250000.00
major religious organization,
Secondary Sweep Fund
UBS AG DEPOSIT ACCOUNT
or the like.
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Other Income Source
transfer
21
21
SDNY_GM_00274211
EFTA00016562

=== Page 22 ===
Account Information
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Account Information
Conditions of this service.
E-mail Address
22
22
SDNY_GM_00274212
EFTA00016563

=== Page 23 ===
Account Information
Account Information
RMA Domestic Sole Owner
Your Account
Please review the information
Account Number
about each of your accounts
and notify your Financial
Account Title
Ghislaine Maxwell
Advisor immediately if you
have any changes or
Account Address
corrections.
City, State zip
New York, NY 10065-7007
For more information, please
refer to the UBS Deposit
Cards and Checks for this account, if requested, will
Account Sweep Program
be mailed to this address:
New York, NY 10065-7007
Disclosure Statement
Primary Account Holder
Ghislaine Maxwell
Please note the account risk
profile and investment
UBS will not disclose your name, address and security
objective below are specific only
Disclosure of Beneficial Ownership
position to issuers of any securities held in your
to this account: other accounts
Account.
may have different account risk
profiles and investment
Margin
No
objectives.
Your Account Risk Profile for
If you did not choose Margin when you opened this account, you may ask to establish margin by
this particular account is defined
contacting your Financial Advisor. You agree that the Margin Agreement in the Completing Your
as:
Account Opening Process package will govern your use of margin in this account and all other
Moderate Willing to accept
accounts you have now or may open in the future.
some risk to principal and tolerate
some volatility to seek higher
returns.
Cost Basis Method
First In,First Out
Different accounts may have
different risk profiles
Features and Services
Your Investment Objective
Produce a Combination of
Premier- RMA / BSA
Income and Capital
Appreciation Investments
seeking both the generation of
Account Objectives and Risk Profile
income and growth of principal.
in accounts with conservative
Account Risk Profile
Moderate
or moderate risk profiles,
Your answers to our profiling questions:
investment eligibility
considerations help us
Risk Tolerance
Moderately High Risk
identify whether you may be
Produce a combination of income and capital
eligible to invest in certain
Investment Objective
higher risk securities as a
appreciation
portion of your portfolio.
Risk/Return Objectives
Moderate Fluctuations, Moderate Returns
These investments offer
additional diversification
Investment Time Horizon
7- 10 years
A senior political official is
Short-Term Liquidity Needs
No
defined as a President or Vice
President, Cabinet Member,
Sweep Account Election
Supreme Court Justice,
Primary Sweep Fund
UBS BANK USA DEPOSIT ACCOUNT
member of the Joint Chief's
Staff, Member of Congress or
Sweep Cap Election
Yes
a Parliament, Chairperson,
Head or Senior Leader of a
Cap Amount
$250000.00
major religious organization,
Secondary Sweep Fund
UBS AG DEPOSIT ACCOUNT
or the like.
U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory, beneficial
owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of their
immediate family members or close associates is a Current U.S. Political Official.
Non-U.S. Senior Political Affiliation: You have indicated that no account holder, an authorized signatory,
beneficial owner, trustee, power of attorney, or other individual with authority to effect transactions, or any of
their immediate family members or close associates is a Current or Former non-U.S. Political official or non-U.S.
Religious Group/Organization or Senior/Influential representative of a non-U.S. Religious Group/Organization.
Source of Funds in the Account
You have indicated the following as the source of
funds for this account:
Other Income Source
transfer
23
23
SDNY_GM_00274213
EFTA00016564

=== Page 24 ===
Account Information
Electronic Delivery Features
Electronic Delivery of Shareholder Communications: You have elected to receive shareholder communications
via electronic format in this UBS account. Please refer to Client Relationship Agreement for Terms and
Account Information
Conditions of this service.
E-mail Address
24
24
SDNY_GM_00274214
EFTA00016565

=== Page 25 ===
UBS Client Relationship Agreement
Introduction
UBS Client Relationship Agreement
At UBS, we understand that we succeed only when our clients succeed. With that in mind,
"Accounts" refers to all securities
we provide a customized approach to wealth management, built on your personal
accounts, brokerage accounts,
relationship with your Financial Advisor and shaped by an understanding of your needs
margin accounts, deposit accounts or
and aspirations.
other accounts you open with us
now or in the future.
Known as the Client Relationship Agreement, this document outlines the terms and
conditions of your relationship with us. By maintaining your Accounts at UBS, you agree to
We refer to the Client Relationship
these terms and conditions and the other agreements and disclosures we refer to here. If
Agreement together with all other
signatures are required, please return the signed signature page in the enclosed envelope.
agreements and disclosures that we
make available to you, and any
To confirm that our records are complete, we will send you a record of the information you
give us after you open a new Account. Please review the Client Information and Account
amendments, as our "Agreement"
Information pages of the Completing Your Account Opening Process package and notify
with you.
us promptly if there are any updates or corrections.
We also refer to the "Completing
Please note: this Client Relationship Agreement applies to all of your accounts at UBS,
Your Account Opening Process"
including any Accounts you may already have with us and Accounts you may open in the
package, which includes Signature
future. You will not receive another copy of the Client Relationship Agreement or the
Pages, optional forms and other
Agreements and Disclosures unless there are updates and amendments, or if we require
required documents.
your signature on this Agreement when you open Accounts in another capacity. Some of
the information in this document and the other agreements and disclosures we send you
If a Signature Page is included, please
may not apply to you now. Please retain these documents for future reference because
have all named account holders sign
they contain important information if you decide to add services or open new Accounts.
the Signature Page and return it to
us in the enclosed envelope.
The terms and conditions in this Client Relationship Agreement apply to all Accounts you
This column contains important
open with UBS Financial Services Inc. or UBS Financial Services Incorporated of Puerto Rico
definitions applicable to our
or any other introducing broker-dealer that has a clearing agreement with UBS Financial
Agreement with you.
Services Inc. In addition, we will send you other agreements and disclosures for the UBS
accounts and services you choose when you open your account, as well as features you
may add in the future. We refer to all these documents, including any amendments, as the
Agreements and Disclosures booklet.
Your acceptance of your initial Client Relationship Agreement will serve as your agreement
"You," "your" and "yours" refer to
to the terms and conditions governing any new Accounts, features or services. Deposits of
you as a client of UBS.
cash or securities and your continued use of your UBS Accounts constitute your agreement
to all of the terms and conditions applicable to your Accounts. If you do not agree to the
"UBS," "we," "us," "our" and "ours"
terms and conditions, you may cancel a feature or service or close your account.
refer to UBS Financial Services Inc.
and unless we indicate otherwise, its
As a UBS client, you may decide to open additional Accounts or take advantage of services
successor firms, subsidiaries,
and account features in the future. With some exceptions, you will be able to do so
correspondents and Affiliates,
without signing additional documents or agreements. Upon approval of your accounts and
including its parent company, UBS
services, we will confirm your requests in writing and provide any relevant agreements and
AG.
disclosures you have not already received. Any authorization of features and services you
give us will remain in effect until a reasonable time after you notify us to terminate the
"Affiliates" refers to UBS Financial
feature or service.
Services Incorporated of Puerto Rico
(which clears through UBS Financial
It is important to note that when we act as your broker-dealer, we do not enter into a
Services Inc.), UBS Bank USA, UBS
fiduciary relationship with you, regardless of the fee structure you select. Except in special
circumstances, we are not held to the same legal standards that apply when we have a
Credit Corp., UBS Trust Company,
fiduciary relationship with you, as we do when providing investment advisory services. We
N.A. and their insurance agency
will effect transactions for your brokerage Accounts only as instructed by you, and neither
affiliates and subsidiaries and all
de 0177 2398 4795 02/12/2014
UBS Financial Services Inc. nor your Financial Advisor will have any discretion over your
other subsidiaries and affiliates.
Accounts.
25
SDNY_GM_00274215
EFTA00016566

=== Page 26 ===
UBS Client Relationship Agreement
Representations
By signing a Client Relationship Agreement, you make the following representations:
Please review and verify the
information about you and your
00 You are at least 18 years old or have reached the age of majority according to the laws
Accounts in the "Completing Your
of the state in which you reside and the laws of the State of New York.
Account Opening Process" package.
If you have questions, changes or
00 You have notified us if you, your spouse or any beneficial owner of the Account(s) are
corrections, call your Financial
or become employed by any of the following: a member firm of FINRA or other
Advisor.
exchange (including broker/dealer subsidiary of a bank, insurance company or other
financial institution), or securities or commodities exchange or self-regulatory
organization or any of their affiliated organizations or UBS's independent auditor. You
agree to notify us promptly of any changes.
00 No one other than you, and the individuals identified to UBS in connection with the
opening of the Account, has or will have an interest in your Account unless you notify
us in writing and UBS Financial Services Inc. agrees to continue to carry the Account.
00 All of the personal and financial information you have supplied to UBS is true and
accurate, and you will notify UBS promptly of any material changes, particularly the
information regarding your residence, financial situation, investment objectives or tax
status.
00 You understand that UBS provides financial and investment services only and does not
provide legal or tax advice.
00 You represent that you have fulfilled and will continue to fulfill all tax related and
reporting obligations associated with any assets in your UBS accounts.
00 If you are acting as executor, trustee, conservator, guardian or custodian:
- You understand that you are a fiduciary on behalf of the beneficial owners
of the Account and that you have a duty to use the services and features
provided through the Account for the benefit of the beneficial owners of
the Account and not for your own benefit.
- You acknowledge that you will make an independent determination that
any activity in the Account is suitable and appropriate for the beneficial
owners and that the compensation we receive is reasonable.
- You understand and agree that this determination is solely your
responsibility and not ours.
Fees and Charges
As a client of UBS, you agree to pay all fees and charges relating to your accounts for any
Please refer to the Fees and Charges
transactions or services you receive from us, such as annual service fees, brokerage fees for
section of the Agreements and
securities transactions, fees for specific services you request and fees or charges by a third
Disclosures booklet or more
party that we incur in the course of providing services to you.
information about fees and charges.
If you have questions, please contact
All fees and charges are subject to change at any time. Fees and charges will be charged to
your Financial Advisor.
your accounts and may be satisfied, along with any other amounts you owe us, from free
credit balances, margin and other assets in any of your accounts. We may sell assets in
de 0177 2398 4796 02/12/2014
your Account to satisfy debit balances for any amounts due, including those resulting from
unpaid fees and charges.
26
SDNY_GM_00274216
EFTA00016567

=== Page 27 ===
Individual Retirement Accounts
The Agreements and Disclosures booklet contains the UBS IRA Custodial Agreements and
The features and fees of your IRA are
the IRA Disclosure Statements that apply to any Traditional, Roth, SEP or SIMPLE Individual
fully described in the Agreements
Retirement Accounts (IRAs) you open with us now or in the future. If we make changes to
and Disclosures booklet.
the UBS IRA Custodial Agreement and the IRA Disclosure Statement we will send you
UBS Client Relationship Agreement
updated documents, and you agree to be subject to those updated terms and conditions.
Please note: UBS does not extend
margin for Individual Retirement
According to the UBS IRA Custodial Agreements, UBS Financial Services Inc. is named as
Accounts.
the custodian of your IRA when we accept the Account. At your death, the beneficiary or
beneficiaries whose name(s) are shown on the Account Information pages of the
Employers with a SEP IRA or SIMPLE
Completing Your New Account Process package will become entitled to your IRA.
IRA plan for their businesses must
Beneficiaries must be named in writing. Your written designation may apply to future
sign a separate plan document. We
accounts, and in that case, we will confirm your designation in the Completing Your
accept any approved plan
Account Opening Process package. If you do not designate beneficiaries, or your
documents, known as prototypes,
beneficiary designation does not effectively dispose of the assets, your beneficiary with
whether they were produced by UBS,
respect to the IRA or any part of the IRA not effectively disposed of, will be your surviving
an IRS model or a document from
spouse, or your estate if you do not have a surviving spouse. You may be charged a
another provider. If you would like to
Custodial Account fee in connection with this IRA.
use a UBS prototype, please ask for a
copy of the SEP IRA Plan or SIMPLE
If this IRA account is funded via transfer from a non-UBS account, you represent that all
IRA Plan prototype document from
transfers to this account originate from a same name inherited IRA of the same type
your UBS Financial Advisor.
indicated on this IRA Account Application (e.g., Traditional IRA, Roth IRA) and/or a direct
rollover from a qualified plan which named you as beneficiary.
Accounts with Cash Management Features
The Agreements and Disclosures booklet contains the terms and conditions that apply to
UBS offers a variety of accounts with
the cash management features you may select. All requests to enroll in cash management
cash management features, including
features are subject to approval. We consider your continued use of your Account as your
the Resource Management
acceptance of the applicable terms and conditions.
Account® (RMA), Business Services
Account BSA® (BSA) and
There are important differences in the cash management features and other services that
International Resource Management
are available to U.S. residents through UBS accounts and those that are available to clients
Account® (IRMA®).
who reside outside the U.S. For example, we have different sweep programs for uninvested
cash and different Card programs for these accounts. This agreement and the Agreements
and Disclosures booklet describe which programs apply to which types of accounts.
Verbal Authorization to Upgrade or Add Cash Management Features to an Account
For any account you have with us now or may open in the future, we may accept verbal
Cash management features available
requests to upgrade or add cash management features to your Account. Generally, we
for eligible accounts include:
permit any authorized person to provide verbal instructions to upgrade or add services to
8
Check writing
your Account unless you instruct us otherwise. In some circumstances, we may ask you or
8
Debit cards
another person who is named on the account to sign additional documents or provide
00 Credit cards
additional information for those additional features. We will provide you updated terms
00
Rewards programs
and conditions for the services you request if we have not already sent them to you or
DO Bill Payment
another owner of the Account. We consider your use of the Account as your acceptance of
DO Electronic Funds Transfer
the applicable terms and conditions.
8
Margin loans
Our Sweep Options and Your Sweep Election
Sweep Options* refers to the options
made available by UBS for the
As a service to you, we offer options for the automatic investment or deposit of available
automatic investment or deposit
cash balances ("sweep") in your Accounts. Current Sweep Options include the UBS Bank
("sweep") of available cash balances
Sweep Programs and the Sweep Funds. The available Sweep Options and their features,
in your Account. Sweep Options
and the eligibility of an Account for a specific Sweep Option varies by the type of Account
include the UBS Bank Sweep
you open, the services you select, the type of entity you are and your country of residence.
Programs, the Sweep Funds, the
de 0177 2399 4797 02/12/2014
We may change or discontinue our sweep service at any time, including adding or
Puerto Rico Short Term Investment
discontinuing specific Sweep Options. We may establish criteria for Sweep Options offered
Fund, the International Deposit
to different clients, including, but not limited to, establishing minimum asset requirements
Account Sweep Program and any
for clients to qualify for specific Sweep Options.
other sweep investments we may
make available from time to time for
You authorize and direct us to deposit or invest your available cash balances on each
eligible Accounts.
business day in your Sweep Option and to withdraw your funds from, or liquidate your
27
SDNY_GM_00274217
EFTA00016568

=== Page 28 ===
UBS Client Relationship Agreement
shares in your Sweep Option, as described in this section and in the General Terms and
"Sweep Funds" refers to one or more
Conditions in the Agreements and Disclosures booklet, and any amendments.
of the UBS money market funds
made available as a Sweep Option.
Please refer to the UBS Bank Sweep Programs Disclosure Statement for a description of the
Sweep Funds are described in the
eligibility requirements for the UBS Bank Sweep Programs. If your Account is not eligible
respective prospectuses for the UBS
for the UBS Bank Sweep Programs, you may select an available Sweep Fund as the Sweep
RMA Funds, UBS Cashfund, UBS
Option for your Account.
Retirement Money Market Funds,
UBS Liquid Assets Fund, UBS Cash
For Accounts eligible for one of the UBS Bank Sweep Programs, unless you are eligible for
Reserves Fund and the UBS Select
and select an available tax-advantaged Sweep Fund, your Sweep Option will be one of the
Capital Money Market Funds.
UBS Bank Sweep Programs.
In general, most clients with a Resource Management Account® (RMA®), Individual
Retirement Account (IRA), Basic Investment Account, Business Services Account® (BSA®),
Coverdell Education Savings Account and certain Investment Advisory Accounts will be
eligible for one of the UBS Bank Sweep Programs. Eligibility is based primarily upon the
type of client. Most non-business clients and employee benefit plans qualified under
Section 401(a) or Section 403(b)(7) of the Internal Revenue Code of 1986, as amended, or
under any other employee retirement or welfare plan subject to the Employee Retirement
Income Security Act of 1974, as amended (ERISA) (Plans) are eligible for the Deposit
Program. In cases where a participant in a Plan has established a Securities Account for
purposes of participation in the Plan (each a Plan Participant), the Plan Participant will be
eligible for the Deposit Program. Most business clients are eligible for the Business
Program.
The *UBS Bank Sweep Programs"
The UBS Bank Sweep Programs
collectively refers to the UBS Deposit
Account Sweep Program (the
Through each of the UBS Bank Sweep Programs, available cash balances in each eligible
"Deposit Program") and the UBS
Account are automatically deposited into deposit accounts at Bank USA up to the Bank
Business Account Sweep Program
USA Sweep Cap. Available cash balances in excess of the Bank USA Sweep Cap will be
(the "Business Program") as more
automatically swept without limit to your Secondary Sweep Option.
fully described in the UBS Bank
Sweep Programs Disclosure
Unless you select an available Sweep Fund, the Secondary Sweep Option for eligible
Statement.
Accounts other than Investment Advisory Accounts is deposit accounts at AG Stamford
Branch. Investment Advisory Accounts will not sweep to the AG Stamford Branch; instead
UBS Bank USA (Member FDIC) (*Bank
the Secondary Sweep Option for Investment Advisory Accounts will be an available Sweep
Fund.
USA"),is an FDIC-member bank
affiliate of UBS.
Funds in deposit accounts at AG Stamford Branch are not eligible for FDIC
insurance or protection by SIPC. Sweep Funds are not FDIC-insured, not guaranteed by
UBS AG, Stamford Branch ("AG
Stamford Branch") is a US branch of
a bank, are sold by prospectus only and may lose value.
UBS AG, a Swiss Bank that is the
Deposits held at Bank USA through the Business Program are subject to monthly
parent of UBS Financial Services Inc.
withdrawal limits, as described in the UBS Bank Sweep Programs Disclosure Statement. If
and UBS Financial Services
your withdrawals in a month reach the limit, all funds on deposit through the Business
Incorporated of Puerto Rico.
Program will be withdrawn from Bank USA and transferred into your Secondary Sweep
Option and available cash balances will sweep to your Secondary Sweep Option for the
For clients other than Plans and Plan
remainder of the month. These funds, up to the Bank USA Sweep Cap, will be transferred
participants, the "Bank USA Sweep
back to Bank USA on the first business day of the following month.
Cap" is $250,000 per Securities
Account owner. For Plans and Plan
FDIC Insurance Coverage and Limitations: If you have more than one Account that
participants, the Bank USA Sweep
sweeps to Bank USA, the amount deposited at Bank USA may exceed the amount covered
Cap is $250,000 per Securities
by FDIC insurance (currently $250,000 per insurable capacity). You are responsible for
Account.
de 0177 2399 4798 02/12/2014
monitoring the total amount of deposits that you have with Bank USA to
determine the extent of FDIC deposit insurance coverage available to you. Please
Please refer to the UBS Bank Sweep
refer to the UBS Bank Sweep Programs Disclosure Statement for more detailed information
Programs Disclosure Statement for
regarding the UBS Bank Sweep Programs and FDIC insurance.
important information about how
the UBS Bank Sweep Programs work,
Alternatives to the UBS Bank Sweep Programs
how the Bank Sweep Cap is
determined, eligibility, interest rates,
With the exception of tax-advantaged Accounts and Basic Investment Accounts, if you are
withdrawal limits, FDIC insurance and
eligible to participate in one of the UBS Bank Sweep Programs, but do not wish to have
your relationship with UBS, Bank USA
your available cash balances deposited with Bank USA, you may elect at any time to have
and AG Stamford Branch. You
should review the Disclosure
carefully.
28
SDNY_GM_00274218
EFTA00016569

=== Page 29 ===
your available cash balances swept without limit to a tax-advantaged Sweep Fund or, for
"Secondary Sweep Option" refers to
Puerto Rico residents only, the Puerto Rico Short Term Investment Fund, Inc.
deposit accounts at AG Stamford
Branch or one of the available Sweep
The following tax-advantaged Sweep Funds currently are available:
Funds.
00 UBS RMA Tax-Free Fund Inc.
"Investment Advisory Account" refers
8
UBS RMA California Municipal Money Fund
UBS Client Relationship Agreement
to an Account enrolled in any of the
8
UBS RMA New York Municipal Money Fund
following investment advisory
8
The Puerto Rico Short Term Investment Fund, Inc.
programs: Managed Accounts
8
UBS Select Tax-Free Capital Fund (subject to minimum asset requirements)
Consulting Program, Portfolio
State-specific municipal funds are intended for residents of those states only. The Puerto
Management Program, ACCESS,
Rico Short Term Investment Fund, Inc. is offered exclusively to Puerto Rico residents as
Managed Portfolio Program, UBS
defined in the fund's prospectus. The Puerto Rico Short Term Investment Fund is not a
Strategic Wealth Portfolio, UBS
money market fund registered under the U.S. Investment Company Act of 1940, does not
Strategic Advisor, and Private Wealth
comply with rules applicable to U.S. registered funds, presents a higher degree of risk than
Solutions and such other programs as
those funds, and is for Puerto Rico residents holding accounts with UBS Financial Services
UBS may add from time to time.
Incorporated of Puerto Rico only. The Puerto Rico Short Term Investment Fund and the
Sweep Funds are sold by prospectus only, and are not FDIC-insured, not guaranteed by
Please refer to the section
a bank, and may lose value.
"International Accounts" for
information about the sweep option
If your Account is tax-advantaged, or is a Basic Investment Account, whether
for the International RMA.
tax-advantaged or not, you are not eligible to select a tax-advantaged Sweep Fund as a
Sweep Option. Tax-advantaged Accounts include, but are not limited to, Accounts of
Plans, Plan Participants and IRAs. If your tax-advantaged Account or Basic Investment
Account is not an Investment Advisory Account, and you choose not to participate in a
Bank Sweep Program, available cash balances will remain in your Account and will not
earn interest. If your tax-advantaged Account or Basic Investment Account is an
Investment Advisory Account, available cash balances must be swept through a Bank
Sweep Program.
Changing Your Sweep Option
You may change your sweep election to an available alternative Sweep Option at any time.
By instructing us to change your sweep election, you are authorizing and directing us to
redeem your Sweep Fund shares, or withdraw funds from one of the UBS Bank Sweep
Programs, and transfer the funds to your new Sweep Option. You may change your sweep
"Institutional Sweep Funds" refers to
election by contacting your Financial Advisor.
one or more of the UBS money
For additional information regarding program availability and Account eligibility, please
market funds made available by UBS
to clients who meet certain minimum
refer to the UBS Bank Sweep Programs Disclosure Statement and the UBS International
asset thresholds.
Deposit Account Sweep Program Disclosure in the Agreements and Disclosures booklet,
and to the prospectuses for the Sweep Funds and the Puerto Rico Short Term Investment
Fund.
Institutional Sweep Funds and Automatic Exchanges
We may offer Institutional Sweep Funds as Sweep Options or Secondary Sweep Options
for clients (except for Plans and IRAs in investment advisory programs) who meet certain
minimum asset thresholds. Current eligibility criteria may be obtained from your Financial
Advisor. UBS may change the eligibility criteria at any time in its discretion without notice
to you. Institutional Sweep Funds will generally offer a higher yield than other Sweep
Funds, though there is no guarantee that the yield will be, or will remain, higher.
Clients other than Plans and Plan Participants
Your eligibility for the Institutional Sweep Funds will be determined at the end of each
"QP Relationship assets" is defined in
month, based on the value of your Marketing Relationship assets as determined in the sole
the UBS Bank Sweep Programs
de 0177 2400 4799 02/12/2014
discretion of UBS. If the value of your Marketing Relationship assets reaches the minimum
Disclosure Statement.
asset threshold at any time other than the end of the month, you will not be eligible for an
Institutional Sweep Fund.
Plans and Plan Participants
A Plan's eligibility for the Institutional Sweep Funds will be determined at the end of each
month, based on the value of the Plan's QP Relationship assets, as determined in the sole
29
SDNY_GM_00274219
EFTA00016570

=== Page 30 ===
UBS Client Relationship Agreement
discretion of UBS. A Plan Participant's eligibility for the Institutional Sweep Funds will be
determined at the end of each month, based on the greater of the value of the Plan's QP
Relationship assets and the Plan Participant's Marketing Relationship assets, both as
determined in the sole discretion of UBS. If the value of a Plan's QP Relationship assets or
a Plan Participant's Marketing Relationship assets reaches the minimum asset threshold at
any time other than the end of the month, the Plan or Plan Participant will not be eligible
for an Institutional Sweep Fund.
If you are eligible for an Institutional Sweep Fund as either your Sweep Fund or your
Secondary Sweep Option for one of the Bank Sweep Programs, we will liquidate your
shares in your current Sweep Fund or your Secondary Sweep Option, as applicable, and
purchase shares in the Institutional Sweep Fund with the same investment objectives
without direction from you. Thereafter, your Sweep Fund or Secondary Sweep Option, as
applicable, will be the Institutional Sweep Fund. Once an Account's Sweep Option or
Secondary Sweep Option, as applicable, is an Institutional Sweep Fund and a first purchase
has been made into the Fund, that Institutional Sweep Fund will remain the Account's
Sweep Option or Secondary Sweep Option even if the Account's Marketing Relationship
assets cease to meet the minimum asset thresholds for that Institutional Sweep Fund. QP
Relationship assets as a means to determine eligibility will not be available until on or
about Dec 2, 2013.
Check Writing
Many UBS accounts incorporate a check writing feature. If you choose this feature for your
"Check Provider" is the provider and
account, you authorize us and our Check Provider to honor checks that bear your
processor we have appointed to
signature(s) and unsigned drafts that are presented on the basis of separate written
handle payment of your checks and
authorization from you to the payee. These checks may be used only in conjunction with
drafts. We reserve the right to
your accounts and only up to the account's "Withdrawal Limit" as defined in the General
change check providers from time to
Terms and Conditions in the Agreements and Disclosures booklet. We will deduct funds
time.
from your Accounts and reimburse the Check Provider in federal funds when checks or
drafts are presented to the Check Provider. We may delay or deny payment if there are
insufficient available assets in your Account to cover payment on the day you write the
check or authorize the draft through the day on which we deduct funds from your
accounts to pay the check or draft.
Bill Payment and Electronic Funds Transfer Services
Many UBS accounts incorporate the Bill Payment and Electronic Funds Transfer services. If
The Bill Payment and Electronic Funds
you enroll in these services, you authorize UBS and its processing bank to effect the types
Transfer Service Agreement is located
of transactions described in the Bill Payment and Electronic Funds Transfer Service
in the Agreements and Disclosures
Agreement. This service agreement also applies to other electronic transfers to or from
booklet.
your Accounts, including transfers made with UBS CashConnect feature and certain
payments made through the Automated Clearing House ("ACH") system, even if you do
Bill payments are only available to
not enroll in this service.
payees located in the U.S.
Transfers through the ACH system
are only available to and from
accounts at financial institutions and
banks within the U.S.
de 0177 2400 4800 02/12/2014
30
SDNY_GM_00274220
EFTA00016571

=== Page 31 ===
UBS Visa Debit Card for RMA or BSA
Brokerage accounts with cash management features include the UBS Visa Debit Card
"Card Issuer" means UBS Bank USA,
(Card). If you choose this feature either verbally or in writing, you will be issued one or
its successors and assigns, or the
more Card(s) by the Card Issuer. UBS or the Card Issuer will complete any transactions you
issuer of UBS Cards we appoint in
initiate using the Card(s). The Card Issuer will approve transactions up to your account's
our sole discretion.
UBS Client Relationship Agreement
"Withdrawal Limit," as described in the Agreements and Disclosures booklet.
Your UBS Visa Debit Card(s) will be
You agree to maintain sufficient available assets in your account to make payment in full,
mailed to you under separate cover
and transactions may be denied if there are insufficient assets in your account to make full
after your Account has been
payment for any Card transactions as they are processed. As your Card cash withdrawals
approved.
are processed, we will deduct funds from your Account to reimburse the Card Issuer. Once
each calendar month, we will deduct from your Account the amount of purchases made
with the Card that have been received by the Card Issuer but not yet deducted from your
Account. The Card Issuer may suspend or cancel Cards if there are insufficient assets to
cover transactions. Your use of the Card constitutes your agreement to the terms and
conditions in the UBS Visa Debit Card Cardholder Agreement, which is included in the
Agreements and Disclosures booklet.
UBS Credit Card for RMA or BSA
Your UBS Credit Card(s), if approved
You may apply for a UBS Visa Signature credit card or UBS Preferred Visa Signature credit
for issuance by the Card Issuer, will
card (Credit Card) either verbally or in writing. If your application is approved by the Card
be mailed to you under separate
Issuer, you will be issued one or more Credit Cards. We will bill transactions made with
your Credit Card separately from your eligible brokerage account. You may pay your
cover after your Account has been
Credit Card balance automatically each month from your eligible brokerage account, or
approved.
you may pay the bill from other sources or allow a balance to revolve. The Credit Card
terms and conditions describes rates, fees and other costs for the Credit Card. The Card
Express Delivery. If you are
Issuer will issue and manage your Credit Card according to Utah law and the UBS Credit
approved for an account and your
Card Cardholder agreement (Credit Card Agreement). The Card Issuer will include the
card was requested next day delivery,
Credit Card Agreement with your Credit Card.
your card will be sent the next day
after your account is opened if the
Your use of the Credit Card constitutes your agreement to the terms and conditions in the
request is made before 3:00 p.m.
Credit Card Agreement, which may change occasionally. The Credit Card is not subject to
Eastern time of that day. A signature
the General Terms and Conditions of this UBS Client Relationship Agreement. To fulfill
is required for Express Delivery.
your application for a Credit Card, we will share the personal information the Card Issuer
requires to open your Credit Card Account, and we share your personal information such
The information contained in these
as application data, approval status and transaction information on a regular basis to
disclosures is accurate as of
update your UBS monthly account statement and our records.
04/04/2012 and may change after
this date.
When you request a Credit Card, the Card Issuer will obtain a credit report as part of your
application and after it establishes your Credit Card account to administer your Credit Card
The UBS Credit Card is not available
account and report its credit experience with you to others. At your request, the Card
with the International RMA.
Issuer will provide the name and address of each consumer reporting agency from which it
obtained a report about you. After your Credit Card account is open, you will have the
The Credit Card terms and
opportunity to select how the Card Issuer can use or share information about you for
marketing or Credit Card account maintenance purposes.
conditions describe the fees for the
UBS Credit Card.
Any disputes you may have with the Card Issuer will be resolved by binding Arbitration. For
more information regarding Arbitration please consult the UBS Credit Card Agreement.
By requesting Credit Card, you agree with the following statements:
8
I (we) am at least 18 years old and a permanent resident of the United States.
00 I (we) have reviewed and agree to the Important Information about the UBS Credit
Card Account Terms and Conditions that was provided with this Client Relationship
Agreement.
de 0177 2401 4801 02/12/2014
8
All information provided to UBS and the Card Issuer was truthful and complete.
31
SDNY_GM_00274221
EFTA00016572

=== Page 32 ===
UBS Client Relationship Agreement
International Accounts
Please note: The International RMA and certain of its cash management features and other
The features and fees of your
services are not available in all countries and may be changed at any time.
International Resource Management
Account are more fully described in
In connection with your certification regarding purchases made in reliance on Regulation S,
the Agreements and Disclosures
including off-shore mutual fund purchases, the definition of a U.S. Person is 1) any resident
booklet.
of the United States; 2) any partnership or corporation organized in or under the laws of
the United States; 3) any estate or trust in which the executor, administrator or trustee is a
U.S. person and/or if the income from the estate or trust is subject to U.S. federal income
taxation (regardless of the source of the income); 4) any corporation, partnership, estate,
trust or other entity that is directly or indirectly controlled by one or more of the above
categories of U.S. Persons; 5) any agency or branch of a foreign entity that is located in the
U.S.; 6) any non-discretionary account (other than an estate or trust) held by a dealer or
other fiduciary for the benefit or account of a U.S. Person; 7) any discretionary account
(other than an estate or trust) held by a dealer or fiduciary that is a U.S. Person, not
including those held for the benefit of a non-U.S. Person; 8) certain partnerships or
corporations that are organized or incorporated under the laws of any non-U.S. jurisdiction
that have formed principally for the purpose of investing in securities not registered under
the U.S. Securities Act of 1933; and 9) any other person or entity considered a U.S. Person
for purposes of U.S. tax law and/or Regulations under the Securities Act of 1933.
International Deposit Account Sweep Program
The Sweep Option for International Accounts is generally the UBS International Deposit
Account Sweep Program (IDA). The IDA is an interest-bearing account maintained by UBS
AG at the Cayman Islands Branch where funds are invested into short-term deposits. If
you are eligible and choose to participate in the IDA sweep program, free cash balances in
your Accounts are automatically deposited into a demand deposit account at the New York
Branch of UBS AG, from which funds are then swept and re-deposited each business day
into an overnight deposit account at the Cayman Islands branch of UBS AG. As your
agent, UBS Financial Services Inc. will make the necessary withdrawals from the New York
deposit account to satisfy debits or charges in your Account in accordance with the
General Terms and Conditions. You may choose to withdraw from the IDA Program at any
time, however, your free cash balances in your Account at UBS Financial Services Inc. will
not earn interest or dividends. Funds on deposit in the accounts at the New York and the
Cayman Islands branches of UBS AG are not eligible for federal deposit insurance from the
Federal Deposit Insurance Corporation (FDIC).
A full description of the IDA Sweep Program is included in the Agreements and Disclosures
Booklet. At times, we may update or modify the terms of the IDA Sweep Program and/or
change the Sweep Options we make available.
UBS Visa Debit Card®
The International RMA includes the UBS Visa Debit Card (Card). If you are eligible for the
"Card Issuer" refers to UBS Bank
Card under applicable law and UBS policies and you request this feature either verbally or
USA, its successors or assigns, or
in writing, you will be issued one or more Card(s) by the Card Issuer. UBS or the Card
the issuer of the UBS Card we
Issuer will complete any transactions you initiate using the Card(s). Your use of the Card
appoint in our sole discretion.
constitutes your agreement to the terms and conditions in the UBS Visa Debit Card
Cardholder Agreement that is included in the Agreements and Disclosures booklet.
The UBS Credit Card and the UBS
The Card Issuer will approve transactions up to your account's "Withdrawal Limit," as
Rewards Program are not features
de 0177 2401 4802 02/12/2014
described in the Agreements and Disclosures booklet. You agree to maintain sufficient
of the International RMA.
available assets in your account to make payment in full and understand that transactions
may be denied if there are insufficient assets in your account to make full payment for any
Card transactions as they are processed.
As your Card cash withdrawals are processed, we will deduct funds from your Account to
reimburse the Card Issuer. Once each calendar month, we will deduct from your Account
the amount of purchases made with the Card that have been received by the Card Issuer
but not yet deducted from your Account. The Card Issuer may suspend or cancel Cards if
there are insufficient assets to cover transactions.
32
SDNY_GM_00274222
EFTA00016573

=== Page 33 ===
Insurance Accounts
As a service to clients, we also offer accounts to maintain or permit the purchase of
insurance products and services. By signing the Signature Page for your non-brokerage
insurance account, you accept the Client Relationship Agreement and the other documents
referred to here, and as a result, you may be able to open brokerage accounts with us in
UBS Client Relationship Agreement
the future without having to sign additional agreements.
Joint Accounts
For joint accounts, each person or entity named on the Account has full power and
authority over the Account, and the account holders are jointly and severally liable for all
obligations with respect to the Account. Please refer to the "Joint Accounts" section of the
General Terms and Conditions for more information about the terms and conditions that
apply to joint accounts.
When we open additional joint accounts for the same account holders, we establish them
with the same legal ownership as the most recently-opened joint account, unless we are
instructed otherwise. If you request a different form of ownership, we will request your
signature acknowledging that election. For example, if you open an account as joint
tenants with rights of survivorship, your next account with the same parties will also be
established as joint tenants with rights of survivorship, unless you tell us you want a
different type of ownership for that account.
Margin Agreement and Margin Requirements
All Accounts that you open now or in the future will be established with margin, if eligible,
If you do not want to establish
unless you instruct us that you do not want margin privileges for specific Accounts. By
margin for your current accounts or
signing the Signature Page for any Account except for an ERISA Plan or for an Estate, you
any accounts you open in the future,
agree that the Margin Agreement governs your use of margin in all of your current
please contact your Financial Advisor.
Accounts and any Accounts that you may open in the future.
Please note: UBS does not extend
Therefore, if you do not establish margin privileges when you open an Account and later
margin for the following accounts:
decide to use margin, you may be able to do so without signing additional forms. Likewise,
if you cancel your margin privileges on an Account, your margin agreement with us will
DO Individual Retirement Accounts
remain in effect and you may request to use margin again at any time. In either event, we
8
ERISA Plans
will confirm your request.
00 Coverdell Education Savings
Account
When you use your margin privileges, we hold your securities in your Account as collateral
8
against the amounts you borrow, and your securities may be loaned to UBS or to others as
403(b)(7) Accounts
DO UGMA
described in the Margin Agreement. In addition, margin-eligible Accounts are subject to
applicable statutes, rules, regulations, procedures or industry customs. We may deem it
00 UTMA
necessary or advisable to establish additional requirements for margin accounts. You agree
00 Estate
to maintain sufficient assets to satisfy all applicable statutes, rules or regulations, or as we
DO 529 Plan Accounts
deem necessary or advisable. You also agree to maintain sufficient assets in your Account
to satisfy any and all margin calls issued in connection with the Account.
Hypothecation is the pledging of
As long as your Account is a margin account, you authorize UBS in the usual course of
securities or other assets to secure a
business to lend, pledge as collateral, hypothecate, relend or repledge any Property we
loan such as debit balance in a
carry for you on margin, whether separately or together with Property of others, either to
margin account.
ourselves or to others. This authorization remains in effect until we receive payment for
such Property.
"Property" includes, but is not limited
When you use your margin privileges, as permitted by law, we may use certain securities in
to, securities, securities entitlements,
your account for, among other things, settling short sales and lending securities for short
investment property and financial
sales. We may receive and retain compensation in connection with such transactions. If
assets, including without limitation,
you are engaged in short selling a security, you may incur a charge due to certain
money, stocks, options, bonds,
borrowing costs for that particular security.
notes, futures contracts,
commodities, commercial paper,
de 0177 2402 4803 02/12/2014
Subject to applicable rules and regulations, we may amend, the requirements applicable to
certificates of deposit and other
your margin account at any time in our sole discretion, including changing the level of
obligations, contracts, all other
credit available to you and applicable maintenance requirements without notice to you. A
property usually and customarily
prior demand or call, or prior notice of the time and place of such sale or purchase shall
dealt in by brokerage firms and any
not be considered a waiver of our right to sell or buy without demand or notice as
other property that can be recorded
described here. For additional terms, please refer to the section "Liquidation of Collateral
in any of your Accounts, as well as
or Account" below.
the Accounts themselves.
33
SDNY_GM_00274223
EFTA00016574

=== Page 34 ===
UBS Client Relationship Agreement
We have the right to satisfy a margin call or to obtain full or partial payment of a margin
Please refer to the UBS Statement of
loan at any time without a demand for margin or additional margin or other notice. To
Credit Practices for additional
satisfy a margin call or to obtain full or partial payment of the margin loan, in addition to
information.
all rights provided by law, we have the right to:
1. require additional collateral,
2. sell any Property in any of your Accounts with us, whether carried individually or
jointly with others,
3. buy any Property which may be held short in your Account,
4. cancel any open orders and close any or all outstanding contracts, or
5. liquidate any of your Accounts with us.
We may also exercise these rights if in our discretion we consider it necessary for your or
our protection; if a bankruptcy petition, or petition for the appointment of a receiver, is
filed by or against you; if an attachment is levied against any Account; or in the event of
your death or dissolution.
You understand that there are substantial risks involved in trading securities on
margin, using leverage as a liquidity source or as part of your investment strategy,
or otherwise pledging your securities in order to obtain credit. Please review the
Loan Disclosure Statement included in the Agreements and Disclosures booklet
carefully for a detailed discussion of these risks.
Security Interest
As security for the payment of all liabilities or indebtedness presently outstanding or to be
"UBS," "we," "us," "our" and "ours"
incurred under this or any other agreement between you and any UBS Entity, including but
refer to UBS Financial Services Inc.
not limited to any loans or promissory notes, you hereby grant to each UBS Entity a security
and, unless we indicate otherwise, its
interest in and lien on any and all Property held or carried by any UBS Entity for you or on
successor firms, subsidiaries,
your behalf in or credited to any UBS Account(s) (other than qualified plan or IRA accounts
correspondents and Affiliates,
or other accounts where doing so would be a prohibited transaction or violation of
including without limitation, its
applicable law or regulation) and in any other Account with any UBS Entity in which you
parent company, UBS AG.
may have any legal, equitable or other interest.
"Affiliates" refers to UBS Financial
All such Property will be subject to such security interest as collateral for the discharge of
Services Incorporated of Puerto Rico
your obligations to any UBS Entity, wherever or however arising and without regard to
whether or not we made loans with respect to that Property. In enforcing our security
(which clears through UBS Financial
interest, we have the discretion to determine the amount, order and manner in which the
Services Inc.), UBS Bank USA, UBS
Property will be sold and have all the rights and remedies available to a secured party
Credit Corp., UBS Trust Company,
under the Uniform Commercial Code (UCC) in addition to all other rights provided in this
N.A. and their insurance agency
Agreement or by law.
affiliates and subsidiaries, and all
other subsidiaries and affiliates.
You will not cause or allow any of the Property held in any of your UBS Accounts, whether
owned now or acquired later, to be or become subject to any liens, security interests,
"UBS Entity" refers to UBS Financial
mortgages or encumbrances of any nature other than our security interest, without our
Services Inc. and each of these
prior written consent. Each UBS Entity shall act as agent for and on behalf of each UBS
Affiliates.
Entity for purposes of perfecting, maintaining and enforcing the security interests granted
hereunder or by operation of law. Each UBS Entity acting in the capacity of a deposit bank,
"Securities Intermediary" means: 1) a
securities intermediary or commodities intermediary, agrees to follow the instructions and
clearing corporation; or 2) a person,
entitlement orders of each other UBS Entity with respect to the Property as a secured party
including a bank or broker, that in
without further consent by you. You hereby authorize and direct each UBS Entity to follow
the ordinary course of business
the instructions and entitlement orders of each other UBS Entity.
maintains securities accounts for
others and is acting in that capacity,
as such terms are interpreted under
de 0177 2402 4804 02/12/2014
Section 8-102(a)(14) of the United
States Uniform Commercial Code.
34
SDNY_GM_00274224
EFTA00016575

=== Page 35 ===
Liquidation of Collateral or Account
We may satisfy any and all amounts you owe us in connection with any of your Accounts
or agreements with us, or any other agreement between you and any UBS Entity, including
but not limited to any loans or promissory notes, from Property we hold or carry in any of
your Accounts with us (other than qualified plan or IRA accounts or other accounts where
UBS Client Relationship Agreement
doing so would be a prohibited transaction or violation of applicable law or regulation).
Additionally, we may sell any or all Property held in any of your Accounts with us and
cancel any open orders for the purchase or sale of any Property without notice in the event
of your death or dissolution, or whenever in our discretion it is necessary for our
protection. In these instances, we may also borrow or buy-in all Property held in any of
your Accounts required to make delivery against any sale initiated for you. These sales or
purchases may be public or private and may be made without advertising or notice to you
and in the manner we determine in our sole discretion. You waive diligence, presentment,
protest, demand for payment and notice of nonpayment and further waive all other
notices and formalities to which you may be entitled under applicable law or otherwise, to
the extent the waiver of such notices and other formalities is permissible under applicable
law. Your waiver will not be invalidated by any demands, calls, tenders or notices that we
may make. At any sale, we may purchase the Property or any portion thereof free of any
right of redemption and you will remain liable for any deficiency in any of your Accounts,
plus any accrued interest on the deficiency at our then customary rate, if applicable, or at
the maximum rate allowable by law. We will not be liable to you in any way for any loses
or adverse tax consequences resulting from a liquidation of your Property.
USA Patriot Act
To help the government fight the funding of terrorism and money laundering activities,
Federal law requires all financial institutions to obtain, verify and record information and
documentation identifying each account holder. Therefore, when you open an Account,
we ask for your name, address, date of birth and other identifying information about you.
We may ask to see your driver's license or other identifying documents. We may also
screen your name against various databases to verify your identity. If we are unable to
verify your identity, we may take any of the actions described under "Termination of your
Account" in the General Terms and Conditions in the Agreements and Disclosures booklet.
Credit Report
When you open an account with us, we may obtain your credit report or other credit
references and verify or update the credit information you may have given to us previously.
We may make verbal and written inquiries concerning your credit history. Likewise, we
may request your credit report or other credit information and provide it to our Card
Issuers and Check Provider or to our affiliates, as necessary or advisable to service and
maintain your Accounts. We also use this information to offer you additional products that
may be of interest to you.
de 0177 2403 4805 02/12/2014
35
SDNY_GM_00274225
EFTA00016576

=== Page 36 ===
UBS Client Relationship Agreement
Your Privacy
At UBS, we are committed to safeguarding your personal information. Please refer to the
Please see the UBS Client Privacy
UBS Client Privacy Notice in the Agreements and Disclosures booklet, which describes the
Notice in the Agreements and
personal information we collect about you and how we handle and protect it.
Disclosures booklet for further
information, including how to
Disclosure of Beneficial Ownership
opt-out of certain information
sharing.
The issuers of securities held in your Accounts may request your name, address and
security position so that they may contact you directly for proxy voting and other
shareholder communications. You may instruct us not to supply this information, in which
case, you will receive information regarding those securities from UBS instead of the
issuers. Your current instructions are reflected on the Account Information pages of the
Completing Your Account Opening Process package. If you would like to change your
instructions, please call your Financial Advisor.
As described in the section "Foreign Securities" in the General Terms and Conditions, we
may share information about the beneficial ownership of foreign securities in your
Accounts with the issuers of those securities, foreign government authorities of their
agent, to obtain reduced tax withholding rates, to comply with local law or to respond to
other lawful requests.
Householding of Statements and Other Communications
As a convenience to you, we may consolidate periodic communications for certain
Please refer to the Client Privacy
accounts with the same address. This practice, called "householding," applies to account
Notice for more information about
statements, trade confirmations, personal and financial information required to be sent by
Statement Householding.
regulation, preliminary and final prospectuses and Summary of Accounts statements,
which provide consolidated information for all of the accounts in your household.
If you do not want your statements
Households are determined as follows:
to be bundled by household, please
contact your Financial Advisor and
8
Accounts that share the same name, address and Social Security or Tax ID
ask to receive individual account
Number are automatically placed in the same household.
statements mailed in separate
envelopes or delivered separately via
8
Accounts that share only the same address will be placed in the same household
electronic means.
only with the express consent of all the Account holders.
We mail househeld communications in a single envelope (if you receive paper delivery) or,
For more information regarding
if you receive electronic delivery, we make them available through UBS Online Services or
electronic delivery of periodic
other electronic delivery method. Any member of your household who is enrolled in UBS
communication for your Account,
Online Services can have access to view all Accounts in the household.
please refer to the Electronic Delivery
Agreement below.
The composition of a household will change as clients move away from the household
mailing address, and the addressee for househeld mailings may also change over time.
Where owners of joint accounts live at different addresses, househeld mailings will be sent
to at least one account owner's address and may be included with mailings for other
accounts at that address under the conditions described above.
Periodically we are required by industry regulators to send records of certain
personal and financial information to our clients. Because we deliver these records
with your account statements, other members of your household may have access to these
records unless you instruct us to send them to you separately.
de 0177 2403 4806 02/12/2014
If you do not want your statements and other periodic communications from us to be
bundled by household, please contact your Financial Advisor and ask to receive individual
mailings in separate envelopes or delivered separately via electronic means.
E-mail Communications
We discourage clients from transmitting personal or confidential information through
e-mail. If you choose to send personal and confidential information to us via e-mail, we
cannot be responsible for any loss or damages that occur as a result, such as losses or
damages arising from mistaken identity or unauthorized access and the use of the
information (for any purpose) by others who may intercept or otherwise access the
communications during and after transmission.
36
SDNY_GM_00274226
EFTA00016577

=== Page 37 ===
Entire Agreement and Changes to the Agreement
This Client Relationship Agreement and the related documents, including the General
Terms and Conditions and the rest of the Agreements and Disclosures booklet form the
entire "Agreement" between you and us with respect to your account(s). This Agreement
supersedes any prior representations or agreements.
UBS Client Relationship Agreement
The accounts and services we offer may change over time. We may change our Agreement
with you at any time by sending you a written notice of the change, and the changes will
be effective on the date of the notice unless we specify a later date. We also may cease to
offer services at any time without prior notice. Your continued use of your Accounts and
our products and services constitutes your acceptance of the new terms and conditions.
All changes by you to the Agreement will become effective only if offered in writing and
signed by us.
Applicable Law
This Agreement, including the Arbitration provisions in the next paragraph, and its
enforcement, are governed by the laws of the State of New York, without giving effect to
such State's choice of law or conflict of laws provisions. The Agreement is binding on all
parties provided that there is no inconsistency with the Federal securities laws or the
Federal or State banking laws. In connection with any Card issued, the respective
Cardholder Agreement shall be governed by Federal law and the law designated by the
Card Issuer in that Cardholder Agreement.
In the event that any of the Arbitration provisions below are found to be unenforceable,
you submit to the exclusive jurisdiction of the courts of the State of New York and the
Federal courts sitting in the Southern District of New York for the purpose of determining
all matters with regard to the Agreement. You also consent to service of process by
certified mail to your Account's address of record, and you waive any objection to the
venue and any claims that an action or proceeding has been brought in an inconvenient
forum. If any provision of the Agreement is held to be invalid, void, or unenforceable, the
remaining provisions will remain in full force and will be construed to the fullest extent
permitted by law, to give effect to the intent of any provision that has be called into
question.
Non-Primary Residence Address for Mailing Purposes
Unless you notify us otherwise in writing, you authorize us to use the Account Address you
provided in the Account Application to mail all notices, correspondence and for the
disbursement of Property, even if it is not your primary residence. Based upon this
authorization, we will not telephone you to confirm receipt of property or require a signed
written confirmation from you acknowledging transmittal of property. If you would like to
designate an alternative mailing address for the account, please contact your Financial
Advisor to provide the necessary authorization. Even when you have provided a mailing
address for the Account, some correspondence may be delivered to your legal residence
address only based upon operational considerations.
Electronic Records
Any agreements accepted by facsimile or electronic means (such as clicks or other online
means) are legally binding and are considered to have been "signed" by you with the
same effect as a manual signatures. Electronic records of an agreement that is made online
will also be considered to be "in writing." You agree not to dispute the validity or
enforceability of any agreements entered into electronically by you (or by anyone using
your authentication devices, such as a password or PIN).
Electronic Delivery Agreement
de 0177 2404 4807 02/12/2014
UBS offers certain communications through electronic delivery. Categories of
communications you may enroll in for e-Delivery include:
00 Statements for your UBS Accounts, which include your UBS Visa Signature credit
card statement from the Card Issuer; notices delivered on or with statements such as
our annual Client Privacy Notice; and messages about transactions and payments.
00 Trade confirmations and notices regarding account activity.
37
SDNY_GM_00274227
EFTA00016578

=== Page 38 ===
UBS Client Relationship Agreement
8 Shareholder communications, including annual and other shareholder reports,
preliminary and final prospectuses, proxy materials and information about other
corporate actions. Shareholder communications also includes all account documents
related to Investment Advisory accounts, including Form ADV disclosure brochures,
manager profiles, asset allocations, performance reports and other disclosures, reports
and notices related to advisory accounts.
8 Quarterly performance reports.
8 Corporate Employee Financial Services plan advices.
8 Tax reporting documents, including 1099s and other tax documents that are available
now or become available in the future.
8 Agreements and disclosures relating to the accounts, features and services we offer.
Any member of your household may enroll any other household account in electronic
delivery of these periodic communications, except for tax reporting documents. By
enrolling in e-Delivery of any communications described above, you agree that we may
also deliver similar firm documents electronically that may be available now or in the
future. When available, confirmations of your personal and account information may be
included with related documents that are delivered electronically through UBS Online
Services or any other secure method. Please note: These confirmations are sent
periodically and to confirm certain changes to your account information. These
confirmations may be viewable by other members of your household through UBS Online
Services or other secure methods. Contact your Financial Advisor if you prefer to receive
Please see the section Householding
private, paper versions of confirmations of personal and account information instead of
of Statements and Other
electronic versions.
Communications above for further
information regarding how a
household is established.
If you enroll in e-Delivery for any of the communications described above, the following
terms and conditions will apply to all of the UBS accounts (current and future) in your UBS
statement household.
8 A valid e-mail address is required for our e-Delivery services and you are responsible
for notifying UBS when your e-mail address changes; you may update your e-mail
address online through UBS Online Services or by calling your Financial Advisor.
8 Access to UBS Online Services is required for e-Delivery of documents that contain any
personal information; we may, however, deliver such documents by other secure
means in the future.
00 Enrollment in e-Delivery is effective immediately and may be cancelled at any time,
either by changing your elections online or by contacting your Financial Advisor; we
confirm cancellations and other changes to your delivery preferences by e-mail or
regular mail whether they were initiated by you or UBS.
8 Enrollment for any e-Delivery services for any of your accounts will automatically apply
to any accounts that you open in the future at UBS, subject to certain system
limitations.
8 You may request paper copies of any document we are required to deliver to you at
any time for no additional charge by contacting your Financial Advisor.
8 We notify you by e-mail when a new document is available; to protect your
information, the electronic message generally includes a link to a secure UBS website
where the document can be viewed and downloaded.
8 If your e-mail address fails, we will mail paper copies of documents or a paper notice
that a document is available with instructions on how to access it.
8 By enrolling in e-Delivery, you confirm that you have access to a printer or other device
to print or save documents you may wish to retain.
8 We do not charge for e-Delivery, but your Internet access provider may have separate
de 0177 2404 4808 02/12/2014
charges.
38
SDNY_GM_00274228
EFTA00016579

=== Page 39 ===
Representations and Agreement for Trustee Certification
Representation of a Trust Agreement in Effect
For trust accounts, each Trustee, certifies, represents and warrants that the trust to which
The "UBS Client Relationship
this certification applies is in full force and effect and that the information you have
Agreement" plus the additional
UBS Client Relationship Agreement
supplied to UBS is true and accurate, as we rely on that information to service your
information, terms and conditions,
accounts.
and disclosures pertaining to the
accounts and services you have
Unless we are updated subsequently by the trustees, UBS will rely on this certification,
requested UBS to establish for the
which includes the information you provide on the Signature Page, to service accounts you
Trust govern the overall relationship
may open in the future for the same trust. By signing a UBS Trustee Certification and
between the Trust and UBS.
Agreement, you agree that:
8 Each trustee (or a corporate officer if the account is a corporate trust) executed the
certification.
8 You have full power under the trust agreement and applicable law to submit valid
orders and other instructions relative to the trust Account(s).
8 The trust agreement authorizes you to make distributions and transfers from the
trust.
8 You have received and read the "UBS Client Relationship Agreement" and the
documents it references and agree to those terms and conditions for all accounts you
open on behalf of the trust.
8 As Trustee(s), you have broad investment powers under the Trust and applicable law.
You have noted any restrictions on your power as trustee(s) on the Signature Page for
the first trust account you open, and agree that the powers and restrictions listed
here and on the Signature Page are accurate and complete.
Trustee's Ability to Bind the Trust
Unless you indicate otherwise on the Signature Page, you agree that any individual trustee
may independently exercise any of the trust's powers. This means that UBS is authorized to
take instructions from and accept any document on behalf of the trust (including but not
limited to agreements to arbitrate all disputes involving the trust account) signed by any
one of the trustees. In some instances, however, we may require the joint action of all
trustees for certain activities.
By signing a UBS Trustee Certification and Agreement, you agree that:
8 Unless you have noted otherwise, you have the authority to pledge, mortgage, assign
or subject to a security interest or lien in favor of UBS, any property of the trust as
security for any liability of the trust.
00 You have the authority to execute any and all relevant documents and bind the trust
to any agreements entered into with respect to such activities.
8 You understand that, if you have requested margin privileges on behalf of
the trust, UBS holds securities in margin-eligible trust accounts as a lien
against the amounts borrowed by the trust, and you agree to maintain
sufficient collateral in the account to meet margin calls we might issue.
Trustee's Acknowledgement
de 0177 2405 4809 02/12/2014
By signing a UBS Trustee Certification and Agreement, you agree that:
8
UBS may assume without further inquiry and is not required to confirm your power
and authority as trustee(s) or to verify instructions for the delivery of any money or
property to you as trustee(s).
8 UBS is not required to confirm that you are properly exercising your power and
authority unless UBS has actual knowledge to the contrary.
39
SDNY_GM_00274229
EFTA00016580

=== Page 40 ===
UBS Client Relationship Agreement
Liability and Indemnification
By signing a UBS Trustee Certification and Agreement, you agree that:
00 UBS is acting in reliance on this certification and is not liable for any breach of
fiduciary duty for account activities and transactions that are not specifically identified
in this certification as a limitation on your authority to invest or act on behalf of the
trust.
00 UBS is not required to inquire whether any transaction represents a proper exercise of
the trustees' power or authority, unless it is demonstrated that UBS had actual
knowledge that either the transaction's proceeds were being improperly used for the
trustees' benefit or that the transaction exceeded or was in breach of the trustees'
powers or authorities.
00 You fully indemnify UBS from all losses, liabilities, damages, claims, costs and
expenses, including attorney fees resulting from UBS acting in reliance on this
certification.
00 As trustees, you are each jointly liable for performing your obligations under this
certification and agreement
00 Your obligations and this indemnification remain in effect if the trust is terminated or
its accounts are transferred and shall bind all your successors and assigns.
Duty to Update
You agree to provide UBS an updated certification if there is any amendment to the trust,
any change in the composition of the trustees, or any other event that materially alters the
facts which you have certified and upon which we are relying to service the trust
account(s).
If we are uncertain of the authority conferred by this certification, its continuing
effectiveness, or any other certification of the trustees, we may refrain from taking any
action with respect to the account(s) until we are satisfied as to the authority of the
trustee(s). You agree to indemnify us from any claims, demands, expenses, losses or
damages if we refrain from acting for these reasons.
Authority To Appoint/Hire Investment Advisor or Other Third Party
By signing a UBS Trustee Certification and Agreement, you agree that:
00 Unless you have indicated otherwise on the Signature Page, you have the power
under the trust agreement and applicable law to appoint or hire an investment
advisor or other third party to manage and have discretion with respect to the trust's
assets and liabilities, including, the authority to execute a power of attorney or letter
of authorization for that purpose. In the event that you appoint or hire an investment
advisor or third party on behalf of the trust, you agree to provide additional
documentation to UBS as we request.
00 You have the authority to open the trust account(s), place assets in the trust
de 0177 2405 4810 02/12/2014
account(s), make each and every representation and warranty set forth in this
certification and agreement, engage in each of the actions on behalf of the trust set
forth in this certification and agreement, and execute this certification and
agreement.
00 All investment advisors or other third parties you appoint or hire to manage and/or
have discretion with respect to the trust's assets and liabilities are bound by your
acknowledgements, agreements, representations and warranties in this certification
and agreement, and the obligations you have undertaken.
40
SDNY_GM_00274230
EFTA00016581

=== Page 41 ===
Grantor Power to Amend and Revoke - Revocable Trusts Only
By signing a UBS Trustee Certification and Agreement, you agree that either:
You are the grantor of a revocable trust and you have full power and authority under the
trust agreement and applicable law to freely amend and revoke the trust, OR
UBS Client Relationship Agreement
As a non-grantor trustee, you represent that the grantor has full power and authority
under the trust agreement and applicable law to freely amend and revoke the trust.
Grantor Authorization for Credit Disclosure
By signing a UBS Trustee Certification and Agreement, each grantor agrees that:
You authorize UBS to obtain a credit report or other verbal or written credit references
about your credit history or to verify or update credit information given to UBS.
Introduced Accounts
Accounts opened with UBS Financial Services Incorporated of Puerto Rico or any other
broker-dealer under a clearing agreement with UBS Financial Services Inc. are "introduced"
to UBS Financial Services Inc. and will be carried by UBS Financial Services Inc. in your
name. Please refer to the section titled "Introduced Accounts" in the General Terms and
Conditions for a description of the services provided by your introducing broker and by
UBS Financial Services Inc.
Puerto Rico Residency Representation
If Puerto Rico investments are purchased and/or held in a UBS Financial Services Incorporated
of Puerto Rico account, each account owner, or for an account of an entity, the authorized
person(s), certifies the following:
You may hold or purchase certain investments in your Account, including, but not limited to,
closed-end and open-end mutual funds, preferred stock and debt securities that are not
registered under the U.S. Securities Act of 1933 or the U.S. Investment Company Act of
1940 and are exempt from registration under the U.S. Securities Act of 1933 and/or the U.S.
Investment Company Act of 1940 ("Puerto Rico Investments*), based in part, on the
requirement that they be offered or sold only to individuals who have their principal
residence in Puerto Rico and to entities whose principal office and place of business are in
Puerto Rico ("Puerto Rico Residents"), as disclosed in the respective prospectuses or offering
materials. You are aware that certain Puerto Rico Investments may not be suitable to all
investors as they may be designed primarily for long-term investors.
Accordingly, you hereby represent that:
8
You have acquired or propose to acquire Puerto Rico Investments for your own
Account and will be the beneficial owner of those assets.
8
If you propose to acquire Puerto Rico Investments for the Account of a retirement plan
that is the beneficial owner of the assets, you acknowledge that UBS may limit, in part
or in total, the amount of any such purchase, whether or not the retirement plan is
subject to ERISA.
8
As of the date of this agreement, (i) you are an individual whose principal residence is
in Puerto Rico, or (ii) if organized as a non-business trust, the trust has its principal
office and principal place of business within Puerto Rico and the trustee and all
beneficiaries of the trust are Puerto Rico Residents, or (iii) if organized as a trust, the
trustee and all beneficiaries of the trust are Puerto Rico Residents, or (iv) if organized as
de 0177 2406 4811 02/12/2014
a corporation, partnership or other form of business organization, the entity has its
principal office and principal place of business within Puerto Rico and has not been
organized for the purpose of acquiring Puerto Rico Investments.
8
If you cease to be a Puerto Rico Resident, you will (i) notify us within 30 days of ceasing
to be a Puerto Rico Resident, (ii) liquidate your holdings in any Puerto Rico Investment
when such liquidation becomes economically feasible, and (iii) not acquire additional
Puerto Rico Investments.
41
SDNY_GM_00274231
EFTA00016582

=== Page 42 ===
UBS Client Relationship Agreement
8 You acknowledge that if at the time of your acquisition of Puerto Rico Investments you
are not a Puerto Rico Resident, UBS may declare such acquisition null and void.
Arbitration
This Agreement contains a predispute arbitration clause. By signing an arbitration
This Arbitration Agreement
agreement the parties agree as follows:
represents standard industry practice
00 All parties to this Agreement are giving up the right to sue each other in court,
and binds you and us to arbitrate any
including the right to a trial by jury, except as provided by the rules of the arbitration
disagreements that may arise
forum in which a claim is filed.
between us.
00 Arbitration awards are generally final and binding; a party's ability to have a court
reverse or modify an arbitration award is very limited.
00 The ability of the parties to obtain documents, witness statements and other
discovery is generally more limited in arbitration than in court proceedings.
00 The arbitrators do not have to explain the reason(s) for their award, unless, in an
eligible case, a joint request for an explained decision has been submitted by all
parties to the panel at least 20 days prior to the first scheduled hearing date.
00 The panel of arbitrators will typically include a minority of arbitrators who were or are
affiliated with the securities industry.
00 The rules of some arbitration forums may impose time limits for bringing a claim in
arbitration. In some cases, a claim that is ineligible for arbitration may be brought in
court.
00 The rules of the arbitration forum in which the claim is filed, and any amendments to
them, shall be incorporated into this Agreement.
By opening an account at UBS, and by UBS Financial Services Inc. or UBS Financial Services
Incorporated of Puerto Rico by accepting your application and carrying your account, you,
UBS Financial Services Inc. and UBS Financial Service Incorporated of Puerto Rico agree as
follows:
00 We agree to resolve any controversy, claim or issue in any controversy that may arise
by arbitration, whether it happen before or after, or at the time this Agreement was
executed, including but not limited to controversies, claims or issues in any
controversy concerning any account, transaction, dispute or the construction,
performance or breach of this Agreement or any other agreement
00 Any arbitration under this Agreement shall be governed by the Federal Arbitration Act
and shall be conducted before an arbitration panel convened by the Financial Industry
Regulatory Authority (FINRA) or any other national securities exchange's arbitration
forum, upon which UBS Financial Services Inc. is legally required to arbitrate the
controversy with you, including, where applicable, the Municipal Securities
Rulemaking Board.
00 Such arbitration shall be governed by the rules of the organization convening the
panel.
00 All parties to this Agreement agree that the arbitrators shall resolve any controversy in
accordance with applicable law.
00 The arbitrators will apply state and federal statutes of limitation the same as if the
claim were brought as a civil action in court.
00 The award of the arbitration panel is not subject to appeal and judgment upon the
award may be entered in any court of competent jurisdiction.
00 No person shall bring a putative or certified class action to arbitration nor seek to
enforce any pre-dispute arbitration Agreement against any person who has initiated
in court a putative class action; or who is a member of a putative class who has not
opted out of the class with respect to any claims encompassed by the putative class
de 0177 2406 4812 02/12/2014
action until:
- the class certification is denied; or
- the class is decertified; or
- the customer is excluded from the class by the court. Such forbearance to
enforce an agreement to arbitrate shall not constitute a waiver of any rights
under this agreement except to the extent stated herein.
00 You expressly agree that service of process in any action shall be sufficient if served
by certified mail, return receipt requested, at your last address known to UBS.
00 You expressly waive any defense to service of process as set forth above.
42
SDNY_GM_00274232
EFTA00016583

=== Page 43 ===
Signature Page
For Your Records
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.
FOR YOUR RECORDS
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
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
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 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, I certify that: (1) the number shown on this form is my correct taxpayer identification number (or I am waiting for a number to
be issued to me), and 2) I am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the
Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest and dividends, or (c) the IRS has notified
me that I am no longer subject to backup withholding, and (3) I am a U.S. citizen or other U.S. person (defined in the instructions).
Certification Instruction: You must cross out item (2) above if you have been notified by the IRS that you are currently subject to backup withholding
because you have failed to report all interest and dividends on your tax return.
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:
RMA Domestic - Sole Owner
XXX - X X - X X X X
ENTER SSN HERE
RMA Domestic - Sole Owner
RMA Domestic - Sole Owner
Check here if you have been notified by the IRS that you are subject to
RMA Domestic - Sole Owner
backup withholding, and therefore have crossed out item (2) above.
RMA Domestic - Sole Owner
RMA Domestic - Sole Owner
RMA Domestic - Sole Owner
RMA Domestic - Sole Owner
RMA Domestic - Sole Owner
RMA Domestic - Sole Owner
X
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
SIGN AND
DATE HERE
Ghislaine Maxwell
Date
Address of Record
New York, NY 10065-7007
Email Address of Record
de 0177 2407 4813 02/12/2014
43
SDNY_GM_00274233
EFTA00016584

=== Page 44 ===
Intentionally Left Blank
de 0177 2407 4814 02/12/2014
SDNY_GM_00274234
EFTA00016585

=== Page 45 ===
UBS
How can you simplify your life and have your
financial information when you need it?
It's easy with UBS Online Services and
Enroll now or update your e-Delivery
e-Delivery
preferences at ubs.com/fs
With UBS Online Services, you can monitor your
accounts, stay informed about the financial markets,
and explore potential investment planning strategies
and much more.
to
UBS
Add electronic delivery of statements, confirmations
and other shareholder communications and
managing your finances become even easier.
-
Online Services gives you:
Comprehensive Account Information-
Investment and loan accounts, asset allocation,
updates on your top holdings
Easy Access to Your Documents-Account
statements, confirmations and Form 1099s
Enroll Now
Convenient Cash Management-Pay bills, view
cash and checking account balances, track credit
Select Profile Settings, then Go Paperless!
card purchases and more
to add e-Delivery in one simple step.
8
Quotes, News and Research-Consolidated
UBS Online Services Enrollment
quotes and research, including market news and
*
UBS research for covered companies
Planning & Insights-Helpful tools and resources
to assist you and your Financial Advisor with
developing a wealth management plan that suits
your financial needs and objectives
And with e-Delivery, you can reduce your paper mail
by choosing which documents you want delivered
electronically. All documents are delivered securely
and you'll receive an e-mail when your documents
are available for viewing.
de 0177 2408 4815 02/12/2014
be
Take advantage of UBS Online Services and e-Delivery today.
45
SDNY_GM_00274235
EFTA00016586

=== Page 46 ===
Intentionally Left Blank
93830915_0177
de 0177 2408 4816 02/12/2014
93830915_DE00177_00177_S
SDNY_GM_00274236
EFTA00016587


c1: EFTA00016930
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016930.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Epstein (records for Relativity upload)
Date: Wed, 04 Sep 2019 23:11:27 +0000
Importance: Normal
Wanted to follow up on the latest round of document processing, referenced below from a few weeks ago, on the Epstein
case. Could you please let us know what we expect the ETA will be for that latest round of breaking out files (as
necessary) and indexing?
thanks,
From:
Sent: Sunday, August 11, 2019 17:58
To:
Cc:
>;
Subject: RE: Epstein (records for Relativity upload)
I've generally reviewed the PDF file creations and indices and overall I think they look good. A couple notes for the next
round of materials - most importantly, for any phone bills or invoices, in the index they create, please have them list the
phone number in the index along with the rest of the description of the file or document (so we can more easily search,
rather than having to rely on the OCR versions in Relativity). And then second, if in the index they can create a tab that
contains a column with just the document description (rather than the entire file extension, which it looks like they did for
these ones).
For this round, though, it looks good, and we'll have our paralegals make those changes for these docs. Accordingly, these
records can be uploaded into Relativity under the general folder "Florida investigation FOIA files". (Due to the events of
this weekend we no longer have active discovery obligations, but we will be reviewing the documents in connection with
the ongoing investigation.) Your door was locked so I put the envelope with the flash drive right outside your office.
The next round of materials is the set of discs we've been discussing over the past several days. Unfortunately for us,
there's likely to be a lot of overlap in this round of materials and the previous documents, because in theory they all come
from the same place, but we want to process all of them to make sure we're ultimately meeting any and all obligations. In
terms of the vendor, this newer set of docs should be easier because they should be already broken up into component
parts, but as discussed we'd like them to double-check that - and also to do the same type of index creation as in the last
round.
Please let us know if any other questions or issues, let me know if I'm forgetting anything, and thanks as always.
EFTA00016930

=== Page 2 ===
From:
Sent: Friday, August 09, 2019 11:08
To:
Subject: Epstein
Hello
The vendor has finished creating the new PDF files based on the 66 PDF files you gave to me in June. I have the data on a
flash drive and figured you would like to review the data before it is loaded to Relativity. Please let me know if you are in
your office and I will bring you the flash drive.
Thank you.
EFTA00016931


c1: EFTA00015036
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015036.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Date: Wed, Oct 3, 2012 at 12:42 PM
Subject: Jeffrey Epstein
To:
Hello
Jeffrey would like to speak with you could you please give him a call at
and I will connect you to him!
thanks,
Tel:
EFTA00015036


c1: EFTA00017763
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017763.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Accepted: Brass Meeting re Epstein
Date: Wed, 14 Aug 2019 16:30:17 +0000
Importance: Normal
Attachments: unnamed
EFTA00017763


c1: EFTA00016123
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016123.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(NY) (FBI)"
(NYPD)"
>,
(USANYS)"
(USANYS)"
Subject: FW: Ghislaine Maxwell Triggerfish
Date: Mon, 28 Dec 2020 15:58:02 +0000
Attachments:20-mj-127-01-AJ,_SDNY_Triggerfish_Court_Bundle_(final_signed).pdf
See below. I do not think we can justify seeking extended sealing at this point, but let me know if you all disagree. The
warrant materials are attached for reference.
From
USANH)
Sent: Wednesday, December 23, 2020 2:42 PM
To:
(USANYS)
Cc:
(USANH)
Subject: FW: Ghislaine Maxwell Triggerfish
do you need the seal on the DNH triggerfish warrant extended?
Merry Christmas to you and yours!
Mr.
From
(USANH)
Sent: Wednesday, December 23, 2020 10:20 AM
To:
Subject: Ghislaine Maxwell Triggerfish
1
The seal on this triggerfish is set to expire soon.
Am I correct in assuming we can go ahead and let this lapse?
EFTA00016123


c1: EFTA00031430
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031430.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
IN THE MATTER OF AN APPLICATION
TO BRING PERSONAL ELECTRONIC DEVICE(S) OR
GENERAL PURPOSE COMPUTING DEVICE(S) INTO
THE COURTHOUSES OF THE
SOUTHERN DISTRICT OF NEW YORK FOR
USE IN A PROCEEDING OR TRIAL
x
The following Order is subject to the definitions, obligations and restrictions imposed pursuant to
Standing Order M10-468, as Revised. Upon submission of written application to this Court, it is hereby
ORDERED that the following attorney(s) are authorized to bring the Personal Electronic Device(s) and/
or the General Purpose Computing Device(s) (collectively, "Devices") listed below into the Courthouse for use in
a proceeding or trial in the action captioned:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
ORDERED that for the device(s) checked below SDNY Courtroom WI-FI access shall be provided.
4/12/2021-9/1/2021
The date(s) for which such authorization is provided is (are)
Attorney
E-Mail
Device(s)
Courtroom
WIFI
Granted
Christian Everdell
2 iPhones, iPad, laptop
40 Faley (#306) or - ordered
Laura Menninger
iPhone, iPad, laptop
40 Faley (#306) or - ordered
Jeffrey Pagliuca
Phone, laptop
40 Faley (#306) or - ordered
(Attach Extra Sheet If Needed)
The attorney(s) identified in this Order must present a copy of this Order when entering the
Courthouse. Bringing any authorized Device(s) into the Courthouse or its Environs constitutes a certification by
the attorney that he or she will comply in all respects with the restrictions and obligations set forth in Standing
Order M10-468, as Revised.
so ORDERED:
Dated:
April 13, 2021
Alin
D.Netto
United States Judge
Revised: July 1, 2019.
EFTA00031430


c1: EFTA00031397
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031397.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
)"
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Epstein Victim Impact Statements
Date: Wed, 30 Oct 2019 17:37:40 +0000
and I were doing parallel work and she beat me to it, but in case it's helpful, in addition to the individuals who
spoke or were present for their letters being read (10 identified by name and 7 Jane Does), Brad Edwards stated that he
had 15 clients present (eight of whom spoke) and "at least 20 more who didn't make this hearing today for a multitude of
reasons." (Tr. at 29). And I similarly don't recall anyone who expressed directly to us that they wanted to attend but
couldn't, with the exception of
as
mentioned.
Also to the extent it's helpful, the Tuesday, August 27 hearing was ordered on Wednesday, August 21, and that day we
posted the following general notification to the case page on our Office's website:
August 21, 2019 update:
On August 21, 2019, a hearing was ordered by the Court in the case of United States v. Jeffrey Epstein, 19 Cr. 490
(RMB). The hearing is in connection with the nolle prosequi order proposed to the Court on August 19, 2019, by the
United States Attorney, following the death of defendant Jeffrey Epstein. At the hearing, counsel for the victims and
the victims will be heard, if they wish to be. The hearing is scheduled for Tuesday, August 27, 2019, at 10:30 a.m.
before the Honorable Richard M. Berman, United States District Judge for the Southern District of New York, Daniel
Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, New York, in Courtroom 17B.
https://www.justice.gov/usao-sdny/programs/victim-witness-services/united-states-v-jeffrey-epstein-19-cr-490.
rmb
And I believe the notification from
went out that afternoon as well.
From:
(USANYS)
Sent: Wednesday, October 30, 2019 13:24
To:
)
is
;
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein Victim Impact Statements
Thanks very much. I agree on the third question. If we could come up with a number on the first, with the caveat that it
is an approximation, that would be great.
From:
Sent: Wednesday, October 30, 2019 1:23 PM
To:
(USANYS)
is
is
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein Victim Impact Statements
EFTA00031397

=== Page 2 ===
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:
is
>;
is
(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
,
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:
EFTA00031398

=== Page 3 ===
EFTA00031399


c1: EFTA00030270
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030270.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
,
(USANYS)"
Subject: Re: Epstein - Forfeiture
Date: Mon, 08 Apr 2019 17:39:32 +0000
Importance: Normal
Go for it! Thanks.
Sent from my iPhone
On Apr 8, 2019, at 1:34 PM,
(USANYS)
wrote:
,
I can do this.
From:
(USANYS)
Sent: Monday, April 08, 2019 1:32 PM
To:
y
(USANYS)
>;
Subject: Epstein - Forfeiture
Following up on our Brass meeting just now, It's that time of year when we need to do forfeiture funding requests.
These are basically short write-ups of cases that may involve forfeiture and are also likely to incur significant
investigative costs (e.g., traveling to Florida a dozen times, hiring a vendor retaining an expert). Could you guys do a
super quick Epstein write up this afternoon and send it back to me (unfortunately need to get these done today - sorry
for the short notice)? I've attached a blank form and a go-by (you'll see just how short these can be).
Also, notwithstanding what the form says, please do NOT email it down to DC - please send it back to me.
Thanks,
EFTA00030270


c1: EFTA00030611
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030611.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(ODAG)'
Subject: Automatic reply: Epstein
Date: Tue, 11 Jun 2019 23:40:30 +0000
Importance: Normal
I am presently out of the office. I will be checking email during my absence, but for matters requring immediate
attention, please contact
EFTA00030611


c1: EFTA00029808
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029808.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein
Date: Mon, 29 Jun 2020 22:45:39 +0000
Attachments: 2020-02-03,_JE,_6e_disclosure,_signed_order.pdf
Sorry, I think I found it. Attached.
From:
Sent: Monday, June 29, 2020 5:44 PM
To:
YS)
Cc:
(USANYS)
Subject: Re: Epstein
Do you have a copy of the second 6(e) order from February that allowed Civil to review the additional trust agreements
beyond those referenced in the order attached to
email? I don't have a copy.
Thanks,
-
On Jun 29, 2020, at 2:13 PM, McEnany, John (USANYS)
wrote:
Yes. We need to apply for a new order with an application that would discuss why we need to disclose; privacy
concerns; potential protective orders; should we give notice to the people we got the trust agreements from (and
if not why not), etc.
From:
(USANYS)
Sent: Monday, June 29, 2020 2:05 PM
To: N
(S)
Cc: F
USANYS) <LFogelman@usa.doj.gov>
Subject: FW: Epstein
This is the original order, which does seem to suggest we need "further order of the court" to further disclose.
From:
(USANYS)
Sent: Wednesday, January 29, 2020 9:33 AM
To:
SANYS)
Subject: Epstein
Will come by in a second.
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00029808

=== Page 2 ===
Tel.
EFTA00029809


c1: EFTA00031080
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031080.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject:
Date: Mon, 18 Nov 2019 21:52:34 +0000
Attachments: Tova_Noel_et_al_PR_v3.docx
EFTA00031080


c1: EFTA00031727
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031727.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Call W. SDNY re. USVI Epstein Litigation
Start Date: 2020-12-08 18:30:00 +0000
End Date: 2020-12-08 19:00:00 +0000
Location: 1-800-501-8979,,4279915#
Class: X-PERSONAL
Comment:
Date Created: 2020-12-07 16:13:30 +0000
Date Modified: 2020-12-07 16:13:30 +0000
Priority: 5
DTSTAMP: 2020-12-07 13:25:03 +0000
Attendee:
EFTA00031727


c1: EFTA00030974
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030974.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Subject: Final brief as filed
Date: Sat, 27 Feb 2021 05:00:05 +0000
Attachments: 2021.02.26_Government_Omnibus_Opposition_to_Maxwell_Defense_Motions_FINAL_U
NREDACTED.pdf
Hey
In case you're interested, attached is the final version of our brief, as filed. Please note that this is filed under seal (the
public version will have a bunch of redactions), so please keep it on our system and do not share outside the office.
Thanks again for all your help on this - really appreciate it.
EFTA00030974


c1: EFTA00030506
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030506.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: ODAG Update Memos
Date: Wed, 19 Jun 2019 18:27:06 +0000
Importance: Normal
Yep, makes sense. Will have the team send to you both shortly.
From
Sent: Wednesday, June 19, 2019 2:25 PM
To:
Subject: RE: ODAG Update Memos
I think it is helpful for me to see them so that I am in the loop. But I don't want to slow you down in any way. (You could
CC me if that's easier).
From:
Sent: Wednesday, June 19, 2019 2:23 PM
To
Subject: ODAG Update Memos
Do you want to review those? Or should they go straight to Audrey? I confess, most of the ones we have done historically
have been MC related, so they went straight to Audrey, but this one is on Epstein, so if you'd like to see first, let me know.
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00030506


c1: EFTA00030798
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030798.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: FW: DOJ ongoing Investigation.
Date: Fri, 27 Mar 2020 18:26:20 +0000
Inline-Images: image001.jpg; image002.jpg
From:
(USANYS)
>
Sent: Friday, March 27, 2020 2:07 PM
To:
(USANYS)
is
(USANYS)
^
Cc:
(USANYS)
is
(USANYS)
Subject: RE: DOJ ongoing Investigation.
From:
(USANYS)
Sent: Saturday, March 07, 2020 19:33
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: DOJ ongoing Investigation.
EFTA00030798

=== Page 2 ===
From:
(USANYS)
Sent: Friday, February 14, 2020 12:17
To:
(USANYS)
>;
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: FW: DOJ ongoing Investigation.
FYI
From: Gary Bloxsome
Sent: Friday, February 14, 2020 12:00
To:
(USANYS)
is
(USANYS)
>;
; Jennifer Richardson
i
)
Subject: DOJ ongoing Investigation.
Dear
We and the Duke of York set out to assist your investigation when the DOJ asked for his help in January 2020.
However, we regret to say that we have reached the conclusion that the DOJ's dealings with the Duke of York
have not been designed to seek his assistance in investigating and prosecuting the targets of the investigation but
instead have been used only to gather publicity for Mr Geoffrey S. Berman, the United States Attorney for the
Southern District of New York.
EFTA00030799

=== Page 3 ===
It is essential, if justice is to be done for Epstein's victims, that a proper and thorough criminal investigation is
carried out. Although the public record indicates your office (SDNY) has been actively investigating Mr. Epstein
and other targets for more than 2 years, the first time you ever attempted to make contact and request The Duke
of York's help was on 2 January 2020.
The Duke instructed my firm to make contact with you pertaining to this request. When we made contact, you
confirmed that the Duke of York was not and is not a target of the US criminal investigation.
Due to the publicity surrounding the investigation, we asked you to confirm that our discussions and any
interview arrangements would remain confidential, in accordance with your rules. The Duke did not want to add
to the media circus that has now surrounded the investigation. On 10 January 2020 you confirmed
that any arrangements would indeed be kept confidential.
We indicated that we would refer back to you once we had dealt with the various issues and procedures, which
would need to be addressed to enable the Duke to cooperate to the fullest extent possible, including the need to
obtain all the information that you might need to consider. It was at that time that we informed you, by email
dated 20 January, that such preliminary issues would be dealt with within 14 days. It was also in that email that
we confirmed that The Duke has a strong desire to cooperate with the ongoing investigation by the DOJ.
Instead of waiting to hear from us (as you indicated on 22 January 2020), Mr Geoffrey S. Berman, the United
States Attorney for the Southern District of New York, chose to make a public statement about the Duke on 27
January 2020. This led to press reports that there had been "a wall of silence" and that there had been "zero co-
operation" by the Duke. These statements were not true. They should not have been made.
Quite apart from your promise of confidentiality, in England it would not be thought to be in the interests of
justice for any prosecutor or investigator to make public statements about witnesses who may be willing, in
confidence, to assist their investigation.
In England, prosecutors and investigators try to make sure that the investigation and trial of serious criminal
cases take place in court and not in press conferences or publicity battles.
When we complained about the way the Duke (and we) had been treated by the DOJ, you refused to
apologise and you have now also gone back on your promise that any arrangements for the interview will be
confidential.
We cannot advise the Duke to speak to prosecutors who cannot be trusted to deal with him fairly nor to treat
what he says or does confidentially. He has reluctantly accepted our advice that, in those circumstances, there is
no purpose to be served in continuing to try to assist further.
Finally we have no wish to engage in any further publicity battle about the DOJ's conduct and for that reason we
ask that you treat this email as private and confidential.
Regards
Gary
EFTA00030800

=== Page 4 ===
Gary Bloxsome I Partner
RANKED IN
Chambers
LEGAL
Blackfords LLP | 15 Old Bailey I London | EC4M 7EF
UK
500
UNITED KINGDOM
DX 161400 Old Bailey 5 | 020 3427 3343 I www.blackfords.com
2020
TOP TIER
Leading Firm
2020
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint
Walk, Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
EFTA00030801


c1: EFTA00029981
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029981.pdf
c6: pdf
c7: images
c0:
=== 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
November 9, 2020
BY FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the drive containing discovery materials pertinent to Ghislaine Maxwell
(02879-509) is
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
New ne
Assistant United States Attorneys
EFTA00029981


c1: EFTA00029635
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029635.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
<yashema.davis@usdoj.gov>,
Subject: Final Voucher 10810811(1) approved by
, now awaiting further approval
Date: Fri, 22 Nov 2019 14:12:13 +0000
Importance: Normal
Dear
Final voucher 10810811(1) has been approved by
, now awaiting further approval.
Trip ID: 10810811
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13176 - Epstein investigation (2018R01618) - Witness Interviews
Destination: Santa Monica (City), CA, United States
Dates: 2019-11-14 - 2019-11-15
Current status: Pending Voucher Approval
Voucher total expenses: 740.28
Estimated trip cost: 1067.95
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# V0010
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.
EFTA00029635


c1: EFTA00029950
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029950.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Subject: Boies Schiller-Jeffrey Epstein Supposedly Sealed Order
Date: Tue, 30 Mar 2021 14:20:31 +0000
Attachments: IN_RE_APPLICATION_TO_UNSEAL_CIVIL_DISCOVERY_MATERIALS_USAO_Refe
rence_No_2018R016.pdf
Do you know what this is about?
Original Message
From:
(USAGAN)
Sent: Tuesday, March 30, 2021 9:08 AM
To:
(USANYS)
Subject: FW: IN RE APPLICATION TO UNSEAL CIVIL DISCOVERY MATERIALS, USAO Reference No.
2018R01618.
This is weird to me. The order says it is sealed, but it's quite public, as you can see.
Original Message
From: Westlaw@westlaw.com <Westlaw@westlaw.com>
Sent: Tuesday, March 30, 2021 9:06 AM
To:
(USAGAN)
Subject: IN RE APPLICATION TO UNSEAL CIVIL DISCOVERY MATERIALS, USAO Reference No.
2018R01618.
sent you content from Westlaw Edge.
Please see the attached file.
Item: IN RE APPLICATION TO UNSEAL CIVIL DISCOVERY MATERIALS, USAO Reference No.
2018R01618.
Citation: Slip Copy
Sent On: Tuesday, March 30, 2021
Sent By:
Client ID: DOJ
Note:
Westlaw © 2021 Thomson Reuters. No claim to original U.S. Government Works.
EFTA00029950


c1: EFTA00031109
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031109.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
)"
(USANYS)"
)"
Subject: RE: Time sensitive review of pending productions
Date: Wed, 24 Nov 2021 20:57:28 +0000
Attachments:2021.1124_US_v_Maxwell_Non-Testifying_Witness_Material_Index_(Defense),pdf
2021.11.24_Maxwell_Discovery_Leter.pdf;
2021.11.24_U.S._v_Maxwell_3500_Index_(Defense).pdf;
2021.11.24_Maxwell_3500_Cover_Letter.pdf
Cover letters and indices for the 3500 and Rule 16 productions are attached. The hard drive and password have been sent
via FedEx with the following tracking numbers: 8166 1408 9156 (drive) and 8166 1408 9145 (pw).
The production is uploaded to USAfx and is ready to share with defense counsel when you email out.
Thanks,
From:
Sent: Wednesday, November 24, 2021 3:18 PM
To:
(USANYS) [Contractor]
is
)
is
(USANYS)
is
Subject: RE: Time sensitive review of pending productions
and I sorted out out. All set.
From:
Sent: Wednesday, November 24, 2021 3:10 PM
To:
(USANYS) [Contractor]
is
)
is
(USANYS)
is
Subject: RE: Time sensitive review of pending productions
Hi all,
I've reviewed all of the productions and the two cover letters. So everything is reviewed and ready to go except the index
- I just got a time sensitive call. Can someone else look at that?
From:
(USANYS) [Contractor]
Sent: Wednesday, November 24, 2021 2:59 PM
To:
is
is
(USANYS)
is
)
Subject: Time sensitive review of pending productions
Hi all,
If you want to get a production out today (sent on a drive via FedEx to GM), we will need to have it reviewed and ready for
me to load by 3:20pm latest (FedEx last pick up is 4pm today).
EFTA00031109

=== Page 2 ===
The TW 3500 production is here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\!Trial\3500\1.
Testifying\Production 11
NTW 3500 production is here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\!Trial\3500\2.Non-
Testifying\Production 11
Rule 16 production is here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Discovery\GM\41
Thirty-Second Production (2021-11-xx)
Cover letters for both and 3500 indices (excel version) are attached. Please let me know as soon as you can if there are
any changes you want to make.
Thanks,
Paralegal Specialist
U.S. Attorney's Office I
SDNY
1 Saint Andrew's Plaza
New York, NY 10007
Office:
Cell:
EFTA00031110


c1: EFTA00029874
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029874.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Pages from Times V BOP 20cv833 Draft Supplemental Declaration of
v011421.pdf
Date: Thu, 14 Jan 2021 22:41:52 +0000
Attachments:
v011421.pdf
EFTA00029874


c1: EFTA00029711
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029711.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
)"
Cc:
(NY) (FBI)"
)"
Subject: Re: Florida
Date: Fri, 09 Aug 2019 16:02:34 +0000
Ok call my cell phone in about 30 minutes we will be back in the car.
On Aug 9, 2019, at 10:35,
)
wrote:
Hi team,
Just following up on this. Please let us know when you can. Thanks.
From:
Sent: Thursday, August 8, 2019 10:46 AM
To:
(NY) (FBI)
is
Cc:
is
Subject: Florida
I know you're traveling this morning, but when we spoke last night we discussed finalizing by this morning your
availability for a proffer with
late next week. Can you please let us know your availability? We are
coordinating with her attorney, who has a busy schedule next week, and would like to get something on the calendar.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00029711


c1: EFTA00031603
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031603.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Epstein
Date: Mon, 22 Apr 2019 17:02:25 +0000
Importance: Normal
Attachments: 2019-04-16,_JE,_sealed_memorandum_and_order_re_unsealing,_17_Civ_0616.pdf
Yes, and sorry for the delay -- attached.
Original Message
From:
Sent: Sunday, April 21, 2019 18:36
To:
Subject: Epstein
Can you send me Judge Netburn's opinion?
Sent from my iPhone
EFTA00031603


c1: EFTA00029649
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029649.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
)"
Subject: Fwd: legal / coordination question
Date: Tue, 03 Dec 2019 13:51:39 +0000
Want to knock this out today? That window works for me.
Sent from my iPhone
Begin forwarded message:
From:
Date: December 3, 2019 at 3:51:53 AM EST
To:
)"
Cc:
)"
)"
Subject: RE: legal / coordination question
Glad you are reaching out. There has been quite a bit of news in the UK about FBI/DOJ interest in Prince
Andrew. Right now I have open afternoons today and tomorrow, but have events both nights. So if there is a
time that works between 1:30 and 5 pm GMT (8:30-noon EDT), let me know. I have some time late in my day
on Thursday. Friday is pretty much flat out.
Thanks,
US Department of Justice Attaché
United States Embassy
33 Nine Elms Lane
London SW11 7US
Desk:
Mobile:
(after hours)
From US
Email:
SBU -LAW ENFORCEMENT
From:
)
Sent: Tuesday, December 3, 2019 12:23 AM
To:
EFTA00029649

=== Page 2 ===
Cc:
is
Subject: RE: legal / coordination question
My colleagues
and I are the team of prosecutors working on the Jeffrey Epstein investigation, and
we wondered if we might be able to set up a call with you for sometime this week, to ask you some logistical questions
we're hoping you might either be able to answer or to point us in the right direction on. Would that be possible? If
there are a few times in the coming days that you're free, we can try to figure out a slot that works for everyone.
Thanks very much, and looking forward to being in touch.
Assistant U.S. Attorney
Southern District of New York
EFTA00029650


c1: EFTA00030385
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030385.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: WBTW/Epstein
Date: Mon, 13 Jul 2020 17:38:32 +0000
Thank you. I hope you are doing well and safe.
From:
Sent: Monday, July 13, 2020 1:34 PM
To:
Subject: WBTW/Epstein
Hi
Just wanted to say that I know you've done a ton of work on both of these cases, and I know everyone on both teams
really appreciates your hard work. Thanks so much, and hope you're doing well!
Best,
Assistant United States Attorney
Southern District of New York
EFTA00030385


c1: EFTA00031262
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031262.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: ISO BOP not part of prosecution team
Date: Mon, 29 Nov 2021 16:35:03 +0000
Attachments: 2020.04.24_Opposition_to_Thomas_Motion_to_Compel_-_final.docx
Here's the opposition and if you tell me your specific issue I have some additional cites from some guidance the Disclosure
Committee is working on.
From:
Sent: Monday, November 29, 2021 11:18 AM
To
Cc
Subject: Re: ISO BOP not part of prosecution team
I'm pretty sure Nick has briefed this for the MCC guard case.
On Nov 29, 2021, at 11:07 AM,
wrote:
If you have briefed this, or have law on this, we'd appreciate seeing your work product.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York. NY 10007
EFTA00031262


c1: EFTA00030092
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030092.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
March 12, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These discovery materials
are stamped with control numbers SDNY_GM_02742963 through SDNY_GM_02743100. Please
note that these are the materials that the Court directed the Government to disclose by today's date
in an Order dated November 18, 2020 (Dkt. No. 73).
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. I This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. An index of the materials contained in this production is below:
1
Files in PDF format designated as "confidential" under the protective order have been stamped
"confidential." However, certain files cannot be individually labeled as confidential on the
documents themselves due to their file format.
EFTA00030092

=== Page 2 ===
Page 2
Bates Start
Bates End
Summary Description
Confidential
Designation
Photographs and documents received
from victims not referenced in
SDNY GM 02742963
SDNY GM 02743100
Indictment No. S1 20 Cr. 330
Confidential
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
Assistant United States Attorneys
EFTA00030093


c1: EFTA00030735
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030735.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: "CottNYSDChambers@nysd.uscourts.gov" <CottNYSDChambers@nysd.uscourts.gov>
Cc:
)"
)"
Subject: Applications for Search Warrants
Date: Wed, 11 Sep 2019 23:25:06 +0000
Attachments: USVI Devices SW - Application & Affidavit.pdf; USVI Devices SW - Warrant.pdf;
SW for 6 binders - Application & Affidavit.pdf; SW for 6 binders - Warrant.pdf
Dear Judge Cott,
Attached for the Court's consideration, please find two applications for search warrants and the corresponding proposed
warrants. The agent will be available tomorrow to swear out both warrants, and I am available to answer any questions
that may arise. I can be reached at my desk
, on my cellphone
, or by email at this address.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York NY 10007
EFTA00030735


c1: EFTA00031839
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031839.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Monday Grand Jury
Date: Fri, 26 Jun 2020 17:48:40 +0000
See below. Adding
Monday 6/29
AUSA
Case/USAO
Time
Indictment
Seal/Arrest
(Y/N?)
warrant?
Ghislaine
10:00-11:30
Y
Maxwell,
Conf. Room A
2018R01618
11:30-12:00
Y
From
Sent: Friday, June 26, 2020 1:01 PM
To:
Cc:
Subject: RE: Monday Grand Jury
Hi All,
Fyi, please see below. Thanks
From:
(
Sent: Friday, June 26. 2020 11:03 AM
To:
Cc:
Subject: Monday Grand Jury
Welcome to White Plains. Here is the schedule for Monday. Please reply with the case name and USAO number for your
case. This schedule may change and cases will likely be added. Please do your best to stick to your allotted time. A couple
of pieces of information for the day in case you haven't been to White Plains:
Please arrive early and wear a mask as you enter the courthouse. Come to the 3rd floor. We will have fresh masks
available when you arrive.
Please have your agents park in the street or use the municipal lot near the Courthouse.
Dion will provide you with your room assignment for the day if you need a place to prep or do other work.
You'll have access to copiers and computers to you copy/print/email.
EFTA00031839

=== Page 2 ===
You must fill out a slip before you enter the grand jury which we'll provide.
The grand jury session will be held on the first floor in the jury assembly room.
There is an Elmo and laptop hookup in the GJ room.
After you vote your indictment bring it back to the third floor where it will be scanned and emailed to the duty
magistrate. The last person will have to do the returns at the end of the day. If you need arrest warrants and/or
sealing please don't forget to provide the warrants and the reasons for the sealing to them.
Monday 6/29
AUSA
Case/USAO
Time
Indictment
Seal/Arrest
(Y/N?)
warrant?
10:00-11:30
Y
Conf. Room A
EFTA00031840


c1: EFTA00029873
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029873.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: quick question re: MCC stuff
Date: Tue, 27 Jul 2021 14:13:08 +0000
Hey
- I have a quick question for you re: MCC stuff and Epstein guards case, as it relates to Tartaglione. Let me
know when you have a second to chat. Thanks.
Deputy Chief, White Plains Division
United States Attorney's Office
Southern District of New York
300 Quarropas Street
White Plains, New York 10601
EFTA00029873


c1: EFTA00029716
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029716.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: please print three color stapled copies and put on my desk
Date: Thu, 15 Aug 2019 13:28:44 +0000
Attachments: 2019.08.14_Brass_Presentation_PPT_v3.pptx
thanks
Assistant United States Attorney
Southern District of New York
EFTA00029716


c1: EFTA00031604
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031604.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "
To:
Subject: RE: Epstein
Date: Fri, 26 Apr 2019 20:24:21 +0000
Importance: Normal
thnx
From:
Sent: Friday, April 26, 2019 4:13 PM
To:
Cc:
Subject: Epstein
- Attached is a copy of the memo we sent down about five weeks ago along with the NPA from the Florida
prosecution which is discussed in that memo.
We'll send you later this afternoon a memo with updates in our investigation since March.
EFTA00031604


c1: EFTA00030353
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030353.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From
To
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:23:59 +0000
Inline-Images: image001.png
So proud to be your bud. Good luck with the presentment.
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 JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
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,
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.
EFTA00030353

=== Page 2 ===
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 [1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
EFTA00030354

=== Page 3 ===
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.
EFTA00030355


c1: EFTA00030886
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030886.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Subject: 1.20.21
interview rough draft
Date: Wed, 20 Jan 2021 22:41:48 +0000
Attachments:
.docx
Hey all,
Attached is a very rough draft from the interview today.
EFTA00030886


c1: EFTA00030095
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030095.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Subject: Read: Question re Epstein Relativity
Date: Mon, 15 Mar 2021 18:18:32 +0000
EFTA00030095


c1: EFTA00031437
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031437.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
April 14, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These discovery materials
are stamped with control number SDNY_GM_02753398.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
SDNY GM 02753398
SDNY GM 02753398
Photograph
Confidential
EFTA00031437

=== Page 2 ===
Page 2
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
Assistant United States Attorneys
EFTA00031438


c1: EFTA00031845
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031845.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
(NY) (FBI)"
Subject: FW: Application for Search Warrant
Date: Thu, 25 Jun 2020 20:59:35 +0000
Attachments:1)_Application_&_Affidavit_for_SW_for_all_JE_electronic_devices.pdf;2)_Warrant.pdf
Attached is the final version of the affidavit. I'll let you know when the Judge wants to swear it out.
From:
Sent: Thursday, June 25, 2020 4:58 PM
To:
Cc:
is
Subject: Application for Search Warrant
Good afternoon,
Attached for Judge Gorenstein's review please find an application for a search warrant, as well as a proposed warrant.
The agent is available to swear out this warrant tomorrow morning whenever would be convenient for the Court. I can be
reached on my cellphone at
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00031845


c1: EFTA00030616
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030616.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Subject: RE: US V Epstein
Date: Fri, 19 Jul 2019 20:45:08 +0000
Sounds good to me. Afternoon is much better for me if possible.
Original Message
From:
Sent: Friday, July 19, 2019 4:45 PM
To:
)
Subject: FW: US V Epstein
I would propose we just schedule a call for Tuesday, which will give us time to sort out a few things.
Original Message
From: Martin Weinberg
Sent: Friday, July 19, 2019 4:42 PM
To:
Cc: Martin Weinberg
Subject: US V Epstein
Should we talk about any case management issues? Protective Order? Discovery rollout?
Thanks
Marty
Sent from my iPhone
EFTA00030616


c1: EFTA00031720
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031720.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: transcript
Date: Thu, 29 Aug 2019 20:49:30 +0000
Attachments: 2019-08-27,_nolle_conference.pdf
The transcript is attached-hope this helps. Please let me know if you need anything else.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00031720


c1: EFTA00031087
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031087.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Automatic reply: RE: plaintiff counsel request for documents, Epstein case
Date: Mon, 30 Dec 2019 20:48:41 +0000
Out of the Office. Back Tuesday. Checking emails occasionally.
EFTA00031087


c1: EFTA00030973
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030973.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: BOBBI C STERNHEIM
To:
)"
)"
(USANYS)"
Cc: Christian Everdell
>, Laura Menninger
>, Jeff Pagliuca
Subject: U.S. V. Maxwell 20 Cr. 330 (AJN)
Date: Tue, 23 Feb 2021 19:44:15 +0000
Attachments: MAXWELL_BAIL_APPLICATION_with_EXHIBIT_2-23-17pdf
Good afternoon-
Attached is a courtesy copy of today's ECF filing.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
EFTA00030973


c1: EFTA00031678
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031678.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(NY) (FBI)"
To:
(OIG)"
(USANYS)"
(USANYS)"
(OIG)"
Cc:
O. (NY) (OGA)"
Subject:
302
Date: Fri, 30 Aug 2019 16:55:06 +0000
Attachments:
pdf
Finalized 302 of
(
and
- I Know you guys already have this but not sure about
and
Special Agent
FBI New York Field Office
Violent Crimes Task Force
EFTA00031678


c1: EFTA00029632
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029632.pdf
c6: pdf
c7: images
c0:
=== 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 13, 2020
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of
Criminal Procedure ("Fed. R. Crim. P."). Based on your request for discovery in this case, today
we are producing copies of the materials listed in the below index, which materials are stamped
with control numbers SDNY_GM_00012842 through SDNY_GM_00165540. The materials are
available for pickup at the U.S. Attorney's Office in Manhattan. Additionally, to aid in the
preparation of the defense, the Government hereby provides notice of the month and year in which
the minor victims listed in the Indictment in the above-referenced case were born. Minor Victim-
1 was born in August of 1980. Minor Victim-2 was born in July of 1979. Minor Victim-3 was
born in March of 1977.
Please note that both this letter and enclosed materials are governed by the July 31, 2020
Protective Order in this case.¹ This letter is itself designated as "confidential," because it
includes witness-identifying information and information regarding records designated as
"confidential" under the Protective Order.
I
Files in PDF format designated as "confidential" under the protective order have been stamped
"confidential." However, certain files cannot be individually labeled as confidential on the
documents themselves due to their file format. Such files include in their electronic names the
word "Confidential."
06.20.2018
EFTA00029632

=== Page 2 ===
Page 2
An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
SDNY GM 00012842
SDNY GM 00020407
First Bank of Puerto Rico Records
Confidential
SDNY GM 00020408
SDNY GM 00028286
UBS Financial Records
Confidential
SDNY_GM_00028287
SDNY_GM_00029786
Wells Fargo Records
Confidential
Fifth Third Bank records
Confidential
SDNY GM_00065957
Deutsche Bank Records
Confidential
SDNY_GM_00065958
SDNY_GM_00078659
JPMorgan Chase Bank records
Confidential
0998/000 ND ANGS
SDNY GM 00165521
Boies Schiller records
Confidential
SDNY_GM_00165522
SDNY_GM_00165540
Experian records
Please do not hesitate to reach out if you have any difficulty accessing these materials.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
06.20.2018
EFTA00029633


c1: EFTA00031445
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031445.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
SPECIAL ACT AWARD
Presented to:
Michael A. Thomas
Correctional Officer
in recognition of your contributions and dedication to the goals of
Correctional Services.
METROPOLITAN CORRECTIONAL CENTER
New York, New York
FEDERAL BURE OF OF
Suzanne Sugardy R. Hastings, Warden
October 3, 2012


c1: EFTA00030205
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030205.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Invitation to view the folder "Epstein
(
)"
Date: Sat, 13 Jul 2019 17:57:09 +0000
Inline-Images: ATT00001.png
AMERICAN
AMEXDRIVE
EXPRESS
Invitation to view shared folder
used AmexDrive to share a folder with you. To view the
shared folder, click on the button below.
Epstein
Sharing expires on Jul 12, 2020
We will be happy to answer any questions you may have.
The AmexDrive Team
https://square.americanexpress.com/community/tools-programs/amexdrive
EFTA00030205

=== Page 2 ===
American Express made the following annotations
"This message and any attachments are solely for the intended recipient and may contain confidential or privileged
information. If you are not the intended recipient, any disclosure, copying, use, or distribution of the information
included in this message and any attachments is prohibited. If you have received this communication in error,
please notify us by reply e-mail and immediately and permanently delete this message and any attachments. Thank
you."
American Express a ajouté le commentaire suivant le
Ce courrier et toute pièce jointe qu'il contient sont réservés au seul destinataire indiqué et peuvent renfermer des
renseignements confidentiels et privilégiés. Si vous n'êtes pas le destinataire prévu, toute divulgation, duplication,
utilisation ou distribution du courrier ou de toute pièce jointe est interdite. Si vous avez reçu cette communication
par erreur, veuillez nous en aviser par courrier et détruire immédiatement le courrier et les pièces jointes. Merci.
EFTA00030206


c1: EFTA00030664
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030664.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: Prince Andrew 'maybe has something to hide': Epstein butler
Date: Mon, 01 Jun 2020 16:11:49 +0000
The British tabloids' willingness to (1) pay sources, (2) ask leading questions about Andrew and Maxwell in
particular, and then (3) twist and sensationalize the answers ("He was a nice guy. I never see him with girls. I
never see him with
I never saw him naked or actually having the massage" becomes the headline
"maybe has something to hide") is really not helpful.
Original Message
From:
)
Sent: Saturday, May 30, 2020 19:42
To:
)
;
)
Subject: Prince Andrew 'maybe has something to hide': Epstein butler
Not good.
https://nypost.com/2020/05/30/prince-andrew-maybe-has-something-to-hide-epstein-bitler/
Sent from my iPhone
EFTA00030664


c1: EFTA00029718
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029718.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Subject: RE: Subpoena request
Date: Mon, 19 Aug 2019 14:55:17 +0000
Thanks, I will reach out to
From:
Sent: Monday, August 19, 2019 10:27 AM
To:
Subject: RE: Subpoena request
Our grand jury subpoenas are to obtain evidence that would relate to a crime, and I'm not sure that this would be
reasonably related to evidence for the sex trafficking investigation, which is what we are working on. Are you not able to
simply request these materials from the relevant offices? If not, and if this is in connection with an investigation into his
death, I think you would need to have a subpoena issued in connection with the team that is working on that investigation
in our office, which is
and
Their emails are:
thanks,
From:
Sent: Monday, August 19, 2019 09:55
To:
Subject: Subpoena request
We need to obtain a copy of the death certificate and autopsy report to close out Jeffrey Epstein's case. Can I please get
subpoenas for both?
Death Certificate:
Office Of Vital Records
Bureau of Vital Statistics
New York City Department of Health and Mental Hygiene
Autopsy Report:
New York City Office of Chief Medical Examiner
EFTA00029718

=== Page 2 ===
You can use my info for the return:
Thank you
Supervisory Deputy U.S. Marshal
Southern District of New York
EFTA00029719


c1: EFTA00030901
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030901.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Voicemails from Civilian
in Australia, possibly about Epstein
Date: Mon, 10 Aug 2020 15:42:28 +0000
Received, thanks.
From:
Sent: Monday, August 10, 2020 10:01
To:
is
is
Subject: FW: Voicemails from Civilian
in Australia, possibly about Epstein
FYI, these voicemails came into
direct line. They are from someone named
in Australia. She knows to call
by name. She is talking about
crimes committed against her. She claims to be a prisoner. She references Lisa Marie
Presley, the British Royal Family, President Trump, and Jeffrey Epstein. We are passing
these along to you for review and follow up if appropriate or nothing if not. We will be
blocking the number from calling again and otherwise doing nothing further on our end
because the caller is from a foreign country and because of international comity, we
can't respond. Let me know if you have any questions.
From:
Sent: Sunday, August 9, 2020 7:44 PM
To:
>;
Subject: Voicemails
The attached are 3 voicemails that
received this morning at 9:22, 9:26, and 9:54 respectively.
They are from someone named
in Australia. She knows to call
by name. She is talking about crimes
committed against her. She claims to be a prisoner. She references Lisa Marie Presley, the British Royal Family, President
Trump, and Jeffrey Epstein.
Let me know what other actions I should take.
Thank you!
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
EFTA00030901


c1: EFTA00031494
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031494.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Maxwell
Date: Thu, 02 Jul 2020 14:49:02 +0000
Ha, thank you!!
From:
Sent: Thursday, July 02, 2020 10:48
To:
Subject: FW: Maxwell
Big congrats! Very impressive you were able to bring this home. You guys are by far the most productive members of the
unit during quarantine.
From:
Sent: Thursday, July 2, 2020 10:43 AM
To:
Subject: Maxwell
PCU - Please join me in congratulating
on the arrest this morning of Ghislaine Maxwell.
spoke a bit about the case on our call on Tuesday and the truly remarkable job the team has done in bringing it. I won't
repeat all of that, buy you should know, as you read press coverage today that already is making it seem like these charges
were inevitable, that they were anything but, and that they are instead the result of an extraordinary amount of work and
perseverance and creativity by
in building a case based on conduct that I'm pretty sure is older
than all of our paralegals.
will be holding a press conference at 12, and while it is sadly not possible for all of us to be there to join her given
current conditions, I hope we can all take a moment to remotely congratulate the team on a terrific accomplishment in
bringing an extremely important case against a woman very worthy of criminal prosecution.
EFTA00031494


c1: EFTA00029640
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029640.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: FW: Jeffrey Epstein Victim; Ms
,
17 years old
Date: Fri, 22 Nov 2019 18:37:57 +0000
Similarly also passing along the below per our usual policy.
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:
i
Subject: Jeffrey Epstein Victim; Ms
17 years old
EFTA00029640

=== Page 2 ===
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
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,
EFTA00029641


c1: EFTA00030888
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030888.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS) [Contractor]"
)"
Cc:
)"
(USANYS)"
Subject: RE: Discovery Requests
Date: Wed, 27 Jan 2021 17:13:56 +0000
Attachments: 2021.01.27_MDC_-_Maxwel_MAIN.pdf;2021.01.27_MDC_-_Maxwell_PASSWORD.pdf
Inline-Images: image001.jpg; image002.jpg
The two cover letters heading to MDC today with the disc are attached. Thanks, all!
From:
(USANYS) [Contractor]
Sent: Wednesday, January 27, 2021 9:56 AM
To:
(USANYS) [Contractor]
>;
Cc:
is
(USANYS)
Subject: RE: Discovery Requests
Hi all - I just checked PROD011 and it contains all the requisite ranges. l'll go ahead and burn a CD for MDC containing the
PROD011 and PROD015 .dat files and the re-bates stamped items, and I'll have that sent out today. Thanks!
From:
(USANYS) [Contractor]
Sent: Wednesday, January 27, 2021 9:37 AM
To:
>;
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: Discovery Requests
We have all of the materials just about prepared to go out.
is doing a last check of the PROD011 that
exported
to the shared and then everything will be all set.
From:
Sent: Thursday, January 21, 2021 9:40 PM
To:
(USANYS) [Contractor]
i
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: Discovery Requests
Thanks so much,
and my apologies for the delayed response. I've been traveling for work and fell behind on emails
as a result. I will email defense counsel to ask them to send a link where they'd like the materials uploaded.
From:
(USANYS) [Contractor]
Sent: Wednesday, January 20, 2021 10:29 AM
To:
is
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: Discovery Requests
I can upload these files for defense counsel today and will be able to load a disc for Maxwell when I'm back at the office
tomorrow. I recall that the last time we produced to defense in this manner they preferred to use their FTP site. Would
you mind asking them to send over a link to where they'd like the materials uploaded? Thanks!
EFTA00030888

=== Page 2 ===
From:
Sent: Tuesday, January 19, 2021 8:27 PM
To:
(USANYS) [Contractor]
i
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: Discovery Requests
Thanks so much! Once you have the renumbered files, would you please prepare them for production to the defense?
Ideally, they could go on a disc for Maxwell and USAfx for defense counsel, but let me know if
too large.
From:
(USANYS) [Contractor]
Sent: Tuesday, January 19, 2021 1:45 PM
To:
is
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: Discovery Requests
The materials from 6a have been re-stamped with the range: SDNY_GM_00327069.001 - SDNY_GM_00327069.794. They
are currently being loaded here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Discovery\GM\13
Re-Bates
Once we have 6b and 6c sorted out we will let you know.
From:
(USANYS) [Contractor]
Sent: Tuesday, January 19, 2021 10:21 AM
To:
>;
(USANYS) [Contractor]
Cc:
in
(USANYS)
Subject: RE: Discovery Requests
Hey
We will take care of 6a today.
6b and 6c will require us to check the drives that we have at the office. Neither
nor I will be at the office today or
tomorrow. I plan on going in on Thursday and will be able to check on those issues that defense points out. Not to jump to
conclusions but I believe that
.DAT files typically include only the beginning number in a range which would give the
appearance of gaps in the production. As such there is a decent chance that defense is incorrect about the gaps as they
list them although we will not know until we actually check the productions.
Thanks,
Will
From:
Sent: Friday, January 15, 2021 9:02 PM
To:
(USANYS) [Contractor]
i
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: FW: Discovery Requests
Hi
and
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.
EFTA00030889

=== Page 3 ===
Thanks,
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Thursday, January 7, 2021 4:13 PM
To:
)
is
is
(USANYS)
Cc: Mark
Cohen
>; Bobbi Sternheim
>; Jeff Pagliuca
>; 'Laura Menninger'
Subject: Discovery Requests
and
-
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
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 David Rodgers begin at Bates number "Rodgers000028," suggesting that
Rodgers000001-000027 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).
EFTA00030890

=== Page 4 ===
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.
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,
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7268
ceverdell@cohengresser.com | view bio
www.cohengresser.com
New York Paris Washington DC | London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00030891


c1: EFTA00029925
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029925.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 - 1B9
Evidence
31E-MM-108062 -- 1B9
Item:
Evidence
General
Type:
Description:
(U//FOUO) One red rope containing: 1) BOOK - AN INVITATION TO POETRY 2) VICTORIA'S SECRET WHITE
BRA AND PANTIES SET
Location:
E03707388 - ECR8
E616844 ECR8, VS33
E5448596 - ECR8, VS33 A
Barcode:
E6516732
Details
Collected On: 04/30/2007 8:00 AM
Receipt Item #: None
CATS ID #: None
CATS Abandonment #: None
FBI Seizure #: None
Abandonment #: None
Storage Location
Discovery
Location
Holding Office: NY - NEW YORK
Finalized By:
Area:
Unavailable in data migrated from
Last Inventory: 07/20/2021 12:00 AM
ACS
Seizing
Individual:
Specific:
Unavailable in data migrated from
ACS
Collected By:
Retention
Retention: Missing
Legal Caveats
None
Chain of Custody
Shipping Log
History
Acquisition Event
Acquisition Event: (U//FOUO) Items migrated on 2007-04-30
Collected From: (U//FOUO)
700 25TH STREET
WEST PALM BEACH, FL,
Receipt Given:
No
Holding Office: MM - MIAMI
Evidence Log:
Missing
Missing
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/1
SDNY_GM_02753582
EFTA00029925

=== Page 2 ===
FD-1004
FEDERAL BUREAU OF INVESTIGATION
Revised
9-25-2006
EVIDENCE CHAIN-OF-CUSTODY
Evidence Type:
-
General
Drug
Valuable
Firearms
CART
Special Handling Instructions
Initial Receipt
Date and
Time
Batteries
Biohazard
FGJ
Signature:
HAZMAT
Latents
Refrigerate
04/30/2007
Req. Charging
None
Printed Nan
Other
12:00 pm
Reason: Collected
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature
02/08/2008
Printed N
10:00am
Reason:
Date and
Time
Signature
Printed N
2/8/08
Reason:
330PM
Date and
Time
Signature
Printed N
04/10/2008
Reason:
11:01am
Date and
Time
Signature:
01-13-07
Printed Na
Reason:
314Pm
Date and
Time
Signature:
Signature:
Printed Name:
6/14/19
Printed Name:
Reason:
Reason:
Firearms Certification:
Printed Name:
Signature:
Date:
Case ID: 316-MM-108062
1B:
9
Barcode: 54222236
E6516732
SDNY_GM_02753583
EFTA00029926

=== Page 3 ===
EVIDENCE CHAIN OF CUSTODY
Relinquished Custody
Date and
Time
Signature
Printed 1
6/20/19
Reason:
3:00PM
Relinqui
Date and
Time
Signature
Printed N
6/24/19
Reason:
2:10p
Relinqui
Date and
Time
Signature
Printed N
7/26/19
Reason:
220p
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody.
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Case ID: 31E-MM-108062
1B: 9
Barcode:
E6516732
This form is incomplete without reference to the FD-1087.
SDNY_GM_02753584
EFTA00029927


c1: EFTA00031439
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031439.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Date: Wed, 14 Apr 2021 15:02:28 +0000
Attachments: 2021.04.14_Maxwell_Discovery_Letter.pdf; S SDNY_GM_02753398-
SDNY_GM_02753398.pdf
Counsel,
Today we are producing to you an additional photograph in discovery. Attached please find the bates stamped
photograph, as well as the accompanying cover letter. We will include both the photograph and the cover letter on the
drive that we are preparing for your client to use at the MDC.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00031439


c1: EFTA00030279
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030279.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Re: Thread by
"So, apologies in advance, but I want to do a quick little THREAD
to explain my theory of what the Epstein story really is. I promise this is [...]"
Date: Sat, 13 Jul 2019 17:27:26 +0000
Importance: Normal
It sure is.
> On Jul 13, 2019, at 1:26 PM,
wrote:
V
> It's a theory!
>
V
Original Message
> From:
> Sent: Saturday, July 13, 2019 03:19
> To:
> Subject: Thread by
: "So, apologies in advance, but I want to do a quick little THREAD to explain
my theory of what the Epstein story really is. I promise this is [...]"
>
> I assume you've seen this:
>
>
https://threadreaderapp.com/thread/1148303671857491968.html
EFTA00030279


c1: EFTA00029801
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029801.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: MCC Subpoena
Date: Fri, 31 Jan 2020 23:08:31 +0000
Attachments: 2019.08.20._MCC_Subpoena.pdf; 2019.08.21_MCC_Subpoena_(Outlaw_Calls).pdf
Hey - here are the two subpoenas that were served to MCC.
EFTA00029801


c1: EFTA00031089
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031089.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: RE: plaintiff counsel request for documents, Epstein case
Date: Tue, 31 Dec 2019 19:03:25 +0000
I am indeed. Want me to swing by?
From:
(USANYS)
Sent: Tuesday, December 31, 2019 12:42
To:
Subject: RE: RE: plaintiff counsel request for documents, Epstein case
You in today?
From:
Sent: Monday, December 30, 2019 3:49 PM
To:
(USANYS)
Cc:
is
is
(USANYS)
is
(USANYS)
Subject: RE: plaintiff counsel request for documents, Epstein case
Following up on our brief discussion of this issue earlier this month, I wanted to see if you had any additional thoughts on
how to handle requests from counsel for plaintiffs who are suing Epstein and his estate who ask us for information or
materials in connection with our investigation - I think you had said we should instruct them to submit Touhy Requests,
and that you would designate a Civil Division person to whom we could have them direct those requests. If that's right,
could you please let us know who that person will be? So far we've just gotten the request from one plaintiff's counsel,
Robbie Kaplan at Kaplan Hecker, and her request is very narrow but we want to set up the system in a way that will work if
we get additional and/or more expansive requests going forward. And we would like to let her know how she should
proceed relatively soon because that case has a status conference on January 10 and I think they'd like to make the
request before then.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00031089


c1: EFTA00029988
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029988.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(OPCL)"
To:
(ODAG)"
Cc:
(ODAG)"
(OPR)"
(OPR)"
(OLA)"
(USAGAN)"
(USANYS)"
Subject: RE: Victim Meeting Talking Points
Date: Mon, 09 Nov 2020 21:27:37 +0000
Attachments: x_Meeting_Agenda_and_Talking_Points_OPCL_Comments.docx
Thanks
Here are some redlines and comments from OPCL.
Acting Chief Privacy and Civil Liberties Officer
Office of the Deputy Attorney General
United States Department of Justice
From:
(ODAG)
Sent: Monday, November 09, 2020 12:17 AM
To:
(ODAG) ;
(OPR) ;
(OPR) ;
(OPCL) ;
(OLA) ;
(USAGAN) ;
(USANYS)
Subject: Victim Meeting Talking Points
Importance: High
Attached for your review and comment are draft talking points for Thursday's victim briefing. I would really
appreciate your input on topics I should avoid as well as topics I should expand more upon. Please send any and
all comments by COB November 10. I really appreciate your help in preparing for this meeting.
Associate Deputy Attorney General &
National Coordinator for Child Exploitation & Human Trafficking
U.S. Department of Justice
EFTA00029988


c1: EFTA00030791
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030791.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
,
(OPR)"
To:
)"
Subject: OPR Epstein investigation -- request for consultation
Date: Tue, 10 Mar 2020 12:52:12 +0000
-
If you're still working on the matter, could we speak briefly, this afternoon if possible? What time would work for you?
Thank you,
Office of Professional Responsibility
U.S. Department of Justice - Suite 3266
950 Pennsylvania Avenue NW
Washington DC 20530
EFTA00030791


c1: EFTA00030825
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030825.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Subject: RE: 9 E 71st Street New York NY DEED
Date: Thu, 27 Jun 2019 18:35:06 +0000
Importance: Normal
Attachments: export_report.pdf
That's the building owned by Mark Epstein (Jeffrey's brother). In the Clear report, attached, apartment 10F is specifically
associated with Jeffrey (as well as a few other female names).
From:
Sent: Thursday, June 27, 2019 14:30
To:
is
>;
is
Subject: RE: 9 E 71st Street New York NY DEED
Hi Mandy,
Thanks for sending. Do you recognize this address listed on the deed-301 - East 66th Street, Apt. 10F, NY NY? If you could
check who that is associated with, that would be useful to know, just for background.
Thanks!
From:
Sent: Thursday, June 27, 2019 2:22 PM
To:
is
>;
)
is
Subject: Fwd: 9 E 71st Street New York NY DEED
Sorry about that. Here's the attachments.
Forwarded message
From:
"
Date: Jun 27, 2019 1:44 PM
Subject: 9 E 71st Street New York NY DEED
To:
Cc:
Hi Mandy
This is from ACRIS. It's the Last Deed of Record, dated 12/23/2011.
Notice that the Grantor and Grantee lines are both signed by Jeffrey Epstein.
The Grantee is Maple Inc which is located in St Thomas, VI.
No mortgages from Maple Inc are indicated in the online records.
EFTA00030825

=== Page 2 ===
SFI)
EFTA00030826


c1: EFTA00030457
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030457.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
NCRBM 531.01 *
INMATE HISTORY
*
04-29-2020
PAGE 001 OF 001 *
QUARTERS
*
09:22:47
REG NO..: 76318-054 NAME....: EPSTEIN, JEFFREY EDWARD
CATEGORY: QTR
FUNCTION: PRT
FORMAT:
FCL ASSIGNMENT DESCRIPTION
START DATE/TIME STOP DATE/TIME
NYM
Z04-206LAD HOUSE Z/RANGE 04/BED 206L AD
08-10-2019 0734 08-10-2019 0736
NYM
Z04-206LAD
HOUSE
Z/RANGE
04/BED
206L
AD
07-29-2019
1221
08-10-2019
0747
NYM
H01-001L
HOUSE
H/RANGE
01/BED
001L
07-23-2019 0324 07-29-2019 1221
NYM
Z05-124LAD
HOUSE
Z/RANGE
05/BED
124L
AD
07-10-2019 1526 07-23-2019 0324
NYM
H01-001L
HOUSE H/RANGE 01/BED 001L
07-08-2019 1803 07-10-2019 1526
NYM
Z02-201LAD
HOUSE
Z/RANGE
02/BED
201L
AD
07-08-2019 1749 07-08-2019 1803
NYM
Z02-201LAD
HOUSE
Z/RANGE
02/BED
201L
AD
07-07-2019
1920
07-08-2019
0920
NYM
E06-547U
HOUSE
E/RANGE
06/BED
5470
07-06-2019 2136 07-07-2019 1920
NYM
R01-001L
HOUSE R/RANGE 01/BED 001L
07-06-2019 2124 07-06-2019 2136
G0000
TRANSACTION SUCCESSFULLY COMPLETED
EFTA00030457

=== Page 2 ===
PP10
NCRBM 535.07 *
CIM CLEARANCE AND SEPARATEE DATA
*
04-29-2020
PAGE 001 OF 001 *
*
09:20:18
REGISTER NO: 76318-054 NAME: EPSTEIN, JEFFREY EDWARD
REGISTER
FIRST
ARS ARS
ARS
ARS QTR
NUMBER LAST NAME
NAME
FCL ASSIGN
DATE
TIME ASSIGN
76318-054 EPSTEIN
JEFFREY NYM DEATH
08-10-2019 0736
*****
FOI EXEMPT
P0011
THIS INMATE HAS NO CMC ASSIGNMENTS
https://bop.tep.do.gov9049/SENTRY/I1PPG20.dol4/29/20209:21:09 AM]
EFTA00030458

=== Page 3 ===
NCRBM
*
INMATE DISCIPLINE DATA
*
04-29-2020
PAGE 001 OF 001 *
CHRONOLOGICAL DISCIPLINARY RECORD
*
09:21:56
REGISTER NO: 76318-054 NAME..: EPSTEIN, JEFFREY EDWARD
FUNCTION...: PRT
FORMAT: CHRONO
LIMIT TO
MOS PRIOR TO 04-29-2020
G5463
NO ENTRIES EXIST IN CHRONOLOGICAL LOG FOR TIME PERIOD REQUESTED
EFTA00030459

=== Page 4 ===
PPG0
NCRBM 600.00 *
SECURITY/DESIGNATION
*
04-29-2020
PAGE 001 OF 001 *
DATA
*
09:25:22
REGNO:
76318-054
NAME: EPSTEIN, JEFFREY EDWARD
ORG:
RC/SEX/AGE: W/M/66 FORM D/T:
RES: NEW YORK, NY 10021
OFFN/CHG..: SEX TRAFFICKING CONSP.
SEX TRAFFICKING OF MINORS
CUSTODY..:
BIL:
CITIZENSHP: UNITED STATES OF AMERICA
CIM CONS.:
USM:
JUDGE....:
RECFACL/PGM:
VOLSUR:
VS DT/LOC:
MOS REL:
SEVERITY:
CHP/CHS/S:
VIOLENCE:
ESCAPES.:
DETAINER.:
AGE:
EDUC LV:
HGC:
DRUG/ALC.:
TOTAL:
SEC LVL:
PUB SAFTY:
CAR MD/MH:
OMDT REF:
CCM RMKS.:
P5110
DESIGNATION RECORD DOES NOT EXIST FOR THIS INMATE
https://bop.tep.doj.gov:9049/SENTRY/J1PPG00.do[4/29/20209:25:36 AM]
EFTA00030460

=== Page 5 ===
PPG6
NCRBM 606.00 *
MALE CUSTODY CLASSIFICATION FORM
*
04-29-2020
PAGE 001 OF 001
09:25:54
(A) IDENTIFYING DATA
REG NO..: 76318-054
FORM DATE:
ORG:
NAME....: EPSTEIN, JEFFREY EDWARD
CR HX PT:
MGTV:
PUB SFTY:
MVED:
(B) BASE SCORING
DETAINER:
SEVERITY :
MOS REL.:
CRIM HIST SCORE:
ESCAPES.:
VIOLENCE :
VOL SURR:
AGE CATEGORY...:
EDUC LEV:
DRUG/ALC ABUSE.:
(C) CUSTODY SCORING
TIME SERVED..... :
PROG PARTICIPAT:
LIVING SKILLS...:
TYPE DISCIP RPT:
FREQ DISCIP RPT.:
FAMILY/COMMUN..:
--- LEVEL AND CUSTODY SUMMARY ---
BASE CUST VARIANCE SEC TOTAL SCORED LEV MGMT SEC LEVEL CUSTODY CONSIDER
P5154
CUSTODY CLASSIFICATION RECORD DOES NOT EXIST FOR THIS INMT
https://bop.tcp.doj.gov:9049/SENTRY/J1PPG60.dol4/29/20209:26:06 AM]
EFTA00030461

=== Page 6 ===
NCRBM 535.03 *
INMATE PROFILE
*
04-29-2020
PAGE 001 OF 001
09:23:16
76318-054
REG
REGNO: 76318-054
FUNCTION: PRT DOB/AGE.: 01-20-1953 / 66
NAME.: EPSTEIN, JEFFREY EDWARD
R/S/ETH.: W/M/O
WALSH: YES
RSP..: NYM-NEW YORK MCC
MILEAGE.: 5 MILES
PHONE: 646-836-6300
FAX: 646-836-7751
ARS ASSIGNMENT..: DEATH
FBI NO..:
ARS DATE/TIME...: 08-10-2019/0736
INS NO..:
PROJ REL METHOD: UNKNOWN
SSN.....: 090443348
PROJ REL DATE..: UNKNOWN
PSYCH: NO
DETAINER: NO
CMC..: NO
RELEASE DESTINATION
AGENCY
DST ASSIGNMENT
ADDRESS
:
150 PARK ROW
NEW YORK, NEW YORK 10007
OFFN/CHG RMKS: SEX TRAFFICKING CONSP.
OFFN/CHG RMKS: SEX TRAFFICKING OF MINORS
FACL CATEGORY
CURRENT ASSIGNMENT
EFF DATE
TIME
NYM
ADM-REL
DEATH
DEATH
08-10-2019 0736
NYM
CARE LEVEL
CARE1-MH
CARE1-MENTAL HEALTH
07-08-2019 0934
NYM CASE MGT
CFSA
CERT FOOD SINCERITY APPROVAL
07-19-2019 1209
NYM
EDUC
INFO
GED UNK
GED STATUS UNKNOWN
07-06-2019 2124
NYM
FIN RESP
UNASSG
FINANC RESP-UNASSIGNED
07-06-2019 2124
NYM
RELIGION
UNKNOWN
RELIGION UNKNOWN
07-06-2019 2124
G0000
TRANSACTION SUCCESSFULLY COMPLETED
EFTA00030462

=== Page 7 ===
Morning Watch
(b)(7)(A)
AM Watch
(b)(7)(B)
(b)(7)(F)
Day Watch
PM Watch
Evening Watch
**Back Page Categor
Day Off
Sick Leave
Annual Leave
LWOP
LWOP(M)
AWOL
SUSPENSION
OFFICIAL TIME
COP
IF TRAINING
TIME OFF AWARD
Total Correctional Svcs. Staff:
Non Correctional Svcs. Staff:
Overtime Occurrences:
Comptime Occurrences

=== Page 8 ===
(3)(/)(q) (8)(/)(q) (V)(/)(q)
Comptime Occurrence
Overtime Occurrences
Non Correctional Svcs. Staff
Total Correctional Svcs. Staff:
TIME OFF AWARD
IF TRAINING
COP
OFFICIAL TIME
SUSPENSION
AWOL
(W)dom7
LWOP
Comptime Used
Annual Leave
Day Off
Sick Leave
**Back Page Catego
Evening Watch
PM Watch
(b)(7)(F)
Day Watch
(9)(/)(q)
AM Watch
(b)(7)(A)
Morning Watch

=== Page 9 ===
(3)(/)(q) (8)(/)(q) (v)(2)(q)
OFFICIAL TIME
SUSPENSION
AWOL
LWOP(M)
LWOP
Annual Leave
Sick Leave
HO Day
**Back Page Categori
Evening Watch
Watch Wd
(3)(/)(q)
Day Watch
(8)(2)(q)
Watch MA
(b)(7)(A)
Morning Watch

=== Page 10 ===
Day watch
(4)(g)(g)
PM Watch
Evening Watch
**Back Page Categori
Day Off
Sick Leave
Annual Leave
LWOP
COP
Total Correctional Svcs. Staff:
Non Correctional Svcs. Staff:
Overtime Occurrences:
Comptime Occurrences
b)(6) (b)(7)(A) (b)(7)(B); (b)(7)(C): (b)(7)(F)

=== Page 11 ===
DEPARTMENT REAL OF of JUSTICE HOUSE
U.S. Department of Justice
Federal Bureau of Prisons
Metropolitan Correctional Center
New York, New York
For Immediate Release
Contact: Lee Plourde
August 10, 2019
Public Information Officer
(646) 836-6300
Inmate Death at the MCC New York
New York, NY: On Saturday, August 10, 2019, at approximately 6:30 a.m., inmate Jeffrey
Edward Epstein was found unresponsive in his cell in the Special Housing Unit from an apparent
suicide at the Metropolitan Correctional Center (MCC) in New York, New York. Life-saving
measures were initiated immediately by responding staff. Staff requested emergency medical
services (EMS) and life-saving efforts continued. Mr. Epstein was transported by EMS to a local
hospital for treatment of life-threatening injuries, and subsequently pronounced dead by hospital
staff. The FBI is investigating the incident.
Mr. Epstein was a 66-year-old male who arrived at MCC New York on July 6, 2019 under
pretrial status after being indicted for sex trafficking of minors and conspiracy.
MCC New York is an Administrative security facility that currently houses 763 male offenders
in New York, New York.
Additional information about the Federal Bureau of Prisons can be found at www.bop.gov.
###
EFTA00030467

=== Page 12 ===
Date: 05/11/2020
Location: DC
Time:
09:28 AM
Federal Bureau of Prisons
TRUVIEW
Inmate Center Report
Sensitive But Unclassified
Reg #:
76318054
Start Dt: 7/6/2019
End Dt: 8/10/2019
<
Money Received
Money Sent
<
Contact List
<
Addresses
Phone List
>
Calls
<
Email List
Messages
Visitor List
Visits
<
Timeline
Money Received
Transaction Date
Loc
Trans Type
Amount
Sender Nm
Address
City
St Zip
Phone
(b)(6) (b)(7)(C); (b)(7)(F)
8/7/2019 12:04:45 PM
NYM
Western Union
$200.00
7/31/2019 9:04:12 AM
NYM
Western Union
$300.00
7/8/2019 10:04:21 AM NYM Western Union
$200.00
Money Sent
Transaction Date
Loc Trans Type
Amount Recipient Nm
Address
City
St Zip
**No information was found for the given criteria.**
Contact List
Contact Nm
Relationship
Email Phone Mail
**No information was found for the given criteria.**
Addresses
Contact Nm
Relationship Address
City
State
Zip
**No information was found for the given criteria.**
Phone List
Contact
Contact
Creation Date
Last Change Date
Loc Status
Phone
First Nm
Last Nm
Alerted Block Description
**No information was found for the given criteria.**
Calls
User ID: TF34228
Page 1 of 2
EFTA00030468

=== Page 13 ===
Date: 05/11/2020
Location: DC
Time:
09:28 AM
Federal Bureau of Prisons
TRUVIEW
Inmate Center Report
Sensitive But Unclassified
Contact
Contact
Start Date
Loc Completed Duration Phone
First Nm
Last Nm
City
St Country
**No information was found for the given criteria.**
Email List
Creation Date
Loc Status
Email Address
Contact Nm
Relationship Reject Reason
**No information was found for the given criteria.**
Email Messages
Rev
Entered Date
Loc Type
Status
Req Email Address
Contact Nm
Relationship
**No information was found for the given criteria.**
Visitor List
Visitor Nm
Relationship Address
City
St Zip
Phone
Alpha Cd
**No information was found for the given criteria.**
Visits
Alpha
Visitor Nm
Relationship Address
City
St Zip Phone
Start Date
End Date
Cd
**No information was found for the given criteria.**
Timeline
Date
Type
Summary
8/7/2019 12:04:45 PM
Money Received
Inmate: 76318054 EPSTEIN, JEFFREY I Sende(b)(6) (b)(7)(C) (b)(7)(F)
bunt: 200.0000
7/31/2019 9:04:12 AM
Money Received
Inmate: 76318054 EPSTEIN, JEFFREY I Sende
Amount: 300.0000
7/8/2019 10:04:21 AM
Money Received
Inmate: 76318054 EPSTEIN, JEFFREY I Sende
ount: 200.0000
User ID: TF34228
Page 2 of 2
EFTA00030469

=== Page 14 ===
7.30.19 Epstein, Jeffry 76318.054
(b)(6) (b)(7)(C)
5:15pm
X
(b)(6) (b)(7)(C)
n
EFTA00030470

=== Page 15 ===
(b)(6) (b)(7)(C)
completed PROTO
(friend)

=== Page 16 ===
PP10
Page 1 of 1
NYMD4 535.07 *
CIM CLEARANCE AND SEPARATEE DATA
*
08-10-2019
PAGE 001 OF 001 *
*
07:17:28
REGISTER NO: 76318-054 NAME: EPSTEIN, JEFFREY EDWARD
REGISTER
FIRST
ARS ARS
ARS
ARS QTR
NUMBER
LAST NAME
NAME
FCL ASSIGN
DATE
TIME ASSIGN
76318-054 EPSTEIN
JEFFREY NYM A-PRE
07-08-2019 1749 Z04-206LAD
*****
FOI EXEMPT
P0011
THIS INMATE HAS NO CMC ASSIGNMENTS
https://bop.tcp.doj.gov:9049/SENTRY/J1PPG20.do
8/10/2019
EFTA00030472

=== Page 17 ===
PPG0
Page 1 of 1
NYMD4 600.00 *
SECURITY/DESIGNATION
*
08-10-2019
PAGE 001 OF 001 *
DATA
*
07:18:27
REGNO: 76318-054 NAME: EPSTEIN, JEFFREY EDWARD
ORG:
RC/SEX/AGE: W/M/66 FORM D/T:
RES: NEW YORK, NY 10021
OFFN/CHG..: SEX TRAFFICKING CONSP.
SEX TRAFFICKING OF MINORS
CUSTODY..: IN
BIL:
CITIZENSHP: UNITED STATES OF AMERICA
CIM CONS.:
USM:
JUDGE....:
RECFACL/PGM:
VOLSUR:
vs DT/LOC:
MOS REL:
SEVERITY:
CHP/CHS/S:
VIOLENCE:
ESCAPES.:
DETAINER.:
AGE:
EDUC LV:
HGC:
DRUG/ALC.:
TOTAL:
SEC LVL:
PUB SAFTY:
CAR MD/MH:
OMDT REF:
CCM RMKS.:
P5110
DESIGNATION RECORD DOES NOT EXIST FOR THIS INMATE
https://bop.tcp.doj.gov:9049/SENTRY/J1PPG00.do.
8/10/2019
EFTA00030473

=== Page 18 ===
PD15
Page 1 of 1
NYMD4
*
INMATE DISCIPLINE DATA
*
08-10-2019
PAGE 001 OF 001 *
CHRONOLOGICAL DISCIPLINARY RECORD
*
07:18:09
REGISTER NO: 76318-054 NAME..: EPSTEIN, JEFFREY EDWARD
FUNCTION. : DIS
FORMAT:
CHRONO
LIMIT TO
MOS PRIOR TO 08-10-2019
RSP OF: NYM-NEW YORK MCC
G5463
NO ENTRIES EXIST IN CHRONOLOGICAL LOG FOR TIME PERIOD REQUESTED
https://bop.tcp.doj.gov:9049/SENTRY/J1PPD50.do
8/10/2019
EFTA00030474

=== Page 19 ===
NYMD4 535.03 *
INMATE PROFILE
08-10-2019
PAGE 001 OF 001
07:15:51
76318-054
REG
REGNO: 76318-054
FUNCTION: PRT DOB/AGE. 01-20-1953 / 66
NAME.: EPSTEIN, JEFFREY EDWARD
R/S/ETH. W/M/O
WALSH: YES
RSP..: NYM-NEW YORK MCC
MILEAGE. 5 MILES
PHONE: 646-836-6300
FAX: 646-836-7751
PROJ REL METHOD: UNKNOWN
FBI NO..:
PROJ REL DATE..: UNKNOWN
INS NO..:
PAR ELIG DATE..:
SSN.....:
090443348
PAR HEAR DATE..:
PSYCH: NO
DETAINER: NO
CMC..: NO
OFFN/CHG RMKS: SEX TRAFFICKING CONSP.
OFFN/CHG RMKS: SEX TRAFFICKING OF MINORS
FACL CATEGORY
CURRENT ASSIGNMENT
EFF DATE
TIME
NYM
ADM-REL
A-PRE
PRE-SENT ADMIT, ADULT
07-08-2019 1749
NYM
CARE LEVEL CARE1-MH
CARE1-MENTAL HEALTH
07-08-2019 0934
NYM COR COUNSL UNT 5N
VACANT
07-22-2019 1805
NYM
CASE MGT
CFSA
CERT FOOD SINCERITY APPROVAL
07-19-2019 1209
NYM CASEWORKER UNT S
(b)(6),(b)(7)(C)
07-22-2019 1806
NYM
CUSTODY
IN
IN CUSTODY
07-06-2019 2124
NYM EDUC INFO GED UNK
GED STATUS UNKNOWN
07-06-2019 2124
NYM
FIN RESP
UNASSG
FINANC RESP-UNASSIGNED
07-06-2019 2124
NYM
LEVEL
UNASSG
UNASSIGNED
07-06-2019 2124
NYM
MED DY ST
NOT MED CL
NOT MEDICALLY CLEARED
07-06-2019 2124
NYM
PGM REVIEW
OCT
OCTOBER PROGRAM REVIEW
10-19-2019 1804
NYM
QUARTERS
Z04-206LAD
HOUSE Z/RANGE 04/BED 206L AD
07-29-2019 1221
NYM
RELIGION
UNKNOWN
RELIGION UNKNOWN
07-06-2019 2124
NYM SECOND RSP 54N
USM NYS 54N NEW YORK, NY
07-08-2019 1749
NYM
UNIT
5
UNT MGR.
07-22-2019 1806
NYM WRK DETAIL UNASSG
UNASSIGNED WORK DETAIL
07-08-2019 1749
Report# Amb. CARE Report
CAD - 97774214 OYD Sheild #
7046
G0000
TRANSACTION SUCCESSFULLY COMPLETED
EFTA00030475


c1: EFTA00031217
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031217.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Subject: RE: new materials for Maxwell upload to Relativity
Date: Tue, 04 Aug 2020 18:11:46 +0000
Yes please
From:
Sent: Tuesday, August 04, 2020 14:11
To:
Subject: Re: new materials for Maxwell upload to Relativity
Great! I'll grab it and mail it on Monday?
Sent from my iPhone
On Aug 4, 2020, at 2:09 PM,
wrote:
Hey, I stopped by your office but didn't catch you - could you please swing by and pick up this thumb drive whenever
you have a chance? And if I'm not in my office, I put it on top of the bookshelf right inside the door. Thanks very much.
From:
Sent: Tuesday, August 04, 2020 13:48
To:
Cc:
is
V.
Subject: RE: new materials for Maxwell upload to Relativity
I know you're on vacation this week, but wanted to very briefly follow up on the below - I'm going to ask
to
mail you the thumb drive referenced below, which has folders for five devices (NYC024332, NYC024369, NYC024369_1,
NYC024372, and NYC024384) on this coming Monday, so that you'll be around when it arrives (and in case you have to
sign for it). Per usual, if you could please take a look at it when you receive it, and then send on to PAE for processing
and upload to Relativity, that would be great. Thank you!!
From:
Sent: Tuesday, August 04, 2020 13:44
To:
Cc:
is
is
is
is
is
)
is
Subject: RE: [EXTERNAL EMAIL] - RE: Epstein Evidence status
EFTA00031217

=== Page 2 ===
Following up on the below, thanks for those responses, that's very useful. In terms of the one outstanding item, in the
thumb drive I received from
yesterday with CART materials, NYC027913 is not included, so we are still missing
that one.
But I do see that each of the items with the "Included next round" label from the most recent spreadsheet (attached,
with those items highlighted in red) are included, so that's helpful, thanks.
In terms of any of the folders that have been produced so far, I know that you've sent supplemental materials on a
handful of them (approximately seven total, I think) - do you currently expect to send any other supplemental materials
for any of the devices we've received so far? Or are we fully complete?
And then assuming those are all fully complete, or once they are, the only items pending will be the devices highlighted
in gray in the attached, which we understand are being processed for hardware recovery.
thanks,
From:
Sent: Monday, August 03, 2020 19:17
To:
Cc:
is
i
is
>;
is
>;
Subject: RE: [EXTERNAL EMAIL] - RE: Epstein Evidence status
Sorry I didn't get back sooner. It's been kinda crazy. I'll answer your questions in order, so match them up. I'm
going off what I can see on my phone.
The final items were given to
She should have them. Reach out to her for delivery.
The 3 folders you mention contain supplemental files, do not ignore them.
I am pretty sure NYC027913 is included with the items
has. If not, please let me know.
As far as the old questions, you should have everything now.
The zero byte files are just that. Sometimes the software will recover either file headers, or items off the
directory listings, but no actual content. It lists them as zero length files.
Need anything further, let me know.
On Aug 3, 2020 3:33 PM,
)"
wrote:
I know you may still be traveling, but I wanted to check in on a handful of outstanding issues. If you're not available,
perhaps
can assist?
1. On this past Sunday and Monday, you had said you had you had additional materials you planned to get to us
on Monday. I don't believe we ever received anything additional this past week. Are those still pending, and if
so, when can we get those materials?
EFTA00031218

=== Page 3 ===
2. There were three folders that were included in the first disc you provided to us, but then also provided again on
the most recent disc. Those folders are: NYC024328, NYC024366, and NYC024392. Can you please let us know
why those were provided twice? In particular, we need to know whether any supplemental information is in the
new folders with those NYC numbers, or whether we can ignore them on the recent disc because we already
received them.
3. One item is listed on your spreadsheet as having been provided on 7/23, but it was not on the most recent disc
you sent. That item is: NYC027913 (row 40 in your spreadsheet).
In case it's useful, I'm attaching a version of the spreadsheet you put on the disc, but with all the items we received
folders for on the most recent hard drive highlighted in yellow.
Separately, we're still waiting on answers to the questions from Thursday and Friday, July 23 and 24. To refresh, those
questions are:
4. Comparing your most recent spreadsheet to the prior one, and leaving aside the "Nothing for Southern"
designations as well as the NYC numbers that look like they're for the desktops that held the actual drives we're
looking at (such as NYC024385, 387, 389, 391, and 393, and NYC027909), I think there are just three additional
devices listed here that weren't on the spreadsheet you previously sent. I have those as: NYC024328 (row 10),
NYC024367 (row 62), and NYC027910 (row 96). Please confirm that these were added, and also that we're not
missing any? I believe those were all provided on the first disc.
5. As previously mentioned, the vendor has advised that in the initial seven devices provided, there were
approximately 71,000 documents that are zero bytes (i.e., empty files). They are listed in the second attached
spreadsheet. Is that accurate? Or does that reflect some issue with the extraction process?
thanks,
From:
Sent: Friday, July 24, 2020 15:09
To:
Cc:
is
is
is
is
is
Subject: [EXTERNAL EMAIL] - RE: Epstein Evidence status
I don't have the evidence in front of me, but it is probably accurate. It is not unusual for the software to find
such files. I will review Monday to make sure. As to your questions from last night, the sheet should be
comprehensive. I only recall 1 addition, but I am sure that what I have is reflected in the sheet. As for the items
in dark grey, there are 2 servers with multiple drives. Some of those drives have physically failed. We have to
get them to one of our HQ specialists for recovery. Since they are physically broken, data recovery may or may
not be possible. It can be a very long process. We will get that moving ASAP. Need anything else, let me
know.
EFTA00031219

=== Page 4 ===
On Jul 24, 2020 2:20 PM,
)"
wrote:
In addition to the pending questions below, we've been advised by the vendor that is reviewing the initial seven devices
(that were provided on a per-device extraction basis, as previously discussed) that those materials include
approximately 71,000 documents that are zero bytes (i.e., empty files). They are listed in the attached spreadsheet.
Is that accurate? Or does that reflect some issue with the extraction process?
thanks,
From:
)
Sent: Thursday, July 23, 2020 18:08
To:
Cc:
is
is
is
)
is
Subject: RE: Epstein Evidence status
This is very helpful, thank you. Comparing this to the prior spreadsheet, and leaving aside the "Nothing for Southern"
designations as well as the NYC numbers that look like they're for the desktops that held the actual drives we're looking
at (such as NYC024385, 387, 389, 391, and 393, and NYC027909), I think there are just three additional devices listed
here that weren't on the spreadsheet you previously sent. I have those as:
1. NYC024328 (row 10)
2. NYC024367 (row 62)
3. NYC027910 (row 96)
Could you please confirm that I have those additions correct, and that I'm not missing any? And it looks like all of those
were included in the drive you provided today.
I also see there are some drives that are still being processed, including NYC024376 through 380 and several drives in
NYC024395 - could you please let us know what that means?
Thanks very much, and we'll circle back if any issues with anything we received today, which should get to
in the
next day or two.
thanks again,
Original Message
From:
Sent: Thursday, July 23, 2020 14:44
To:
)
Cc:
is
Subject: Epstein Evidence status
EFTA00031220

=== Page 5 ===
Here is the up to date spreadsheet. I color coded things to hopefully make it easier. There are 5 items I have to
get you (as we discussed this morning) Those should take another day or 2, so looking at Monday/Tuesday for that. Any
questions, let me know.
EFTA00031221


c1: EFTA00031100
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031100.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Voucher for Trip 10416822 is late
Date: Tue, 23 Jul 2019 04:02:36 +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: 10416822
Traveler name
Destination: West Palm Beach
Purpose: R19NYS13654 - U.S. V. Epstein (2018R01618) - Victim Interviews
Trip Dates: 2019-07-11 - 2019-07-12
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.
EFTA00031100


c1: EFTA00030169
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030169.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
Subject: Re: counsel having difficulty meeting with client
Date: Sun, 07 Jul 2019 22:38:52 +0000
Importance: Normal
Thanks so much for the quick response (and solution). Mr. Weinberg should be able to get back to MCC in
about 30 minutes so should be all set, and I'll let you know if he reaches out to me with any issues.
thanks again,
On Jul 7, 2019, at 18:28,
wrote:
He's in with an attorney now (not sure which) but I cleared Mr. Weinberg to go in too.
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
)"
Date: 7/7/19 6:18 PM (GMT-05:00)
To:
Subject: RE: counsel having difficulty meeting with client
"
)" 07/07/2019 18:18 >>>
Massachusetts
From:
Sent: Sunday, July 07, 2019 18:18
To:
Subject: Re: counsel having difficulty meeting with client
Sorry
just seeing this now. Where is he barred?
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
"
)"
Date: 7/7/19 5:36 PM (GMT-05:00)
To:
EFTA00030169

=== Page 2 ===
Subject: RE: counsel having difficulty meeting with client
)" 07/07/2019 17:36
With apologies for the weekend email, we have a defendant, Jeffrey Epstein, who was arrested last night and is
currently being detained at MCC, and is expected to be presented on an indictment tomorrow. His attorney, Martin
Weinberg, has represented him in the past, and represents him in connection with our case and has been in touch with
us throughout the weekend. He went to MCC today to meet with him in advance of the presentment tomorrow, but
was just told he is not allowed in because he is from out-of-state.
We're concerned about the defendant not having access to his attorney in advance of the presentment (as we would be
for any defendant) and so I wanted to reach out to you-is it at all possible to address this issue so Mr. Weinberg can
meet with his client this evening? I'm available anytime at
to discuss, if that's helpful, or Mr. Weinberg
can also be reached directly at
if that's easier (though if you reach out directly to him if you could please
just let me know afterward I'd be grateful).
thanks very much,
EFTA00030170


c1: EFTA00031729
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031729.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Subject: Letter
Date: Tue, 30 Nov 2021 23:53:25 +0000
Attachments: 2021-11-XX_GM_letter_re_exhibits_v2.docx
Here's the letter due at 9. None of the team has reviewed, since everyone is in preps now.
I also have witness prep from 7 to 8:30, but I can end it whenever you've had a chance to look at this.
Thanks!
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00031729


c1: EFTA00030796
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030796.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
Subject: Epstein VNS
Date: Thu, 30 Jul 2020 16:20:16 +0000
Hi
When you are back from leave, would you please check to see what, if any, VNS notifications have been sent out to the
below individuals for the Epstein case?
Thanks very much,
EFTA00030796


c1: EFTA00031210
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031210.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
)"
Subject: draft
Date: Tue, 28 Jul 2020 16:47:41 +0000
Attachments: 2020-07-27,_GM,_letter_to_Judge_Nathan_re_protective_order.docx
Hey I'm really sorry, proofing and incorporating my own edits took much longer than expected. But I'm here for any and
all suggestions / changes / edits - thank you!!!
EFTA00031210


c1: EFTA00030822
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030822.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted
counsel call
Start Date: 2019-07-09 14:00:00 +0000
End Date: 2019-07-09 14:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-07-08 02:34:01 +0000
Date Modified: 2019-07-08 02:34:01 +0000
Priority: 5
DTSTAMP: 2019-07-08 02:20:23 +0000
Attendee:
EFTA00030822


c1: EFTA00031566
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031566.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
London
Thurber
London & Thurber, LLC
3340 Peachtree Rd., N.E. Suite 2570
Atlanta, GA 30326
Tel.: 770-919-5750
londonandthurber.com
PROPERTY SUMMARY REPORT
USMS CASE ID #:
USMS-D54-00000307
L&T ref.:
USMS-D54-00000307
EFFECTIVE DATE:
06/14/2019
REPORT DATE:
07/19/2019
STREET ADDRESS:
9 East 71st Street, New York NY 10021
COUNTY:
New York
TITLE IS VESTED IN:
Record Owner(s):
Maple, Inc., a U.S. Virginia Islands Corporation
Instrument type:
Deed
Grantor:
Nine East 71st Street Corporation, a New York Corporation
Date:
12/23/2011
Rec. date:
01/10/2012
Rec. Vol.:
2012000008342
Consideration:
$10.00
VOLUNTARY ENCUMBRANCES:
A. MORTGAGES/DEEDS OF TRUST/SECURITY AGREEMENTS: NONE
B. UCC FINANCING STATEMENTS/FIXTURE FILINGS/OTHER: NONE
INVOLUNTARY ENCUMBRANCES:
A. JUDGMENTS/LIENS: NONE
B. OTHER ENCUMBRANCES: NONE
EFTA00031566

=== Page 2 ===
C. LIS PENDENS:
1. Lis Pendens:
Lis Pendens
Lienor:
United States of America
Named party:
Jeffrey Epstein
Date:
07/11/2019
Rec. Date:
07/16/2019
Rec. Vol.:
003887343-01
Case No.:
19CR490
Court:
Supreme Court
PROPERTY TAXES:
Parcel ID/APN:
Block 1386 Lot 10
Current Tax Year:
2020
Current Tax Year (base):
Period One
$173,510.58
Period Three
$171,775.47
Tax Due Date:
Period One
07/01/2019
Period Three
01/01/2020
Base Year Amount Paid:
Period One
$173,510.58
Period Three
$171,775.47
Date Last Paid (if avail.)
07/18/2019
Due for Prior Years:
$0.00
Assessor's FMV (if avail.)
$1,658,880.00 (Estimated Market Value $75,016,000.00)
Total Amount Due:
$0.00
HOA/POA/CONDO:None reported.
ROUTINE TITLE MATTERS:
1. Satisfaction of Mortgage recorded on 09/28/1988 in Book 1471 at Page 1309.
2. Notice of Designation recorded on 07/02/1982 in Book 629 at Page 739.
NOTE(S) OF INTEREST: NONE
LEGAL DESCRIPTION:
ALL that certain plot, place or parcel of land, with the buildings and improvements thereon
erected, situate, lying and being in the Borough of Manhattan, City, County and State of New
York, bounded and described as follows:
EFTA00031567

=== Page 3 ===
BEGINNING at a point on the northerly side of 71st Street distant 225 feet easterly from the
corner formed by the intersection of the easterly side of 5th Avenue with the northerly side of
71st Street; running
thence Easterly along the northerly side of 71st Street 50 feet;
thence Northerly and parallel with 5th Avenue 102 feet 2 inches to the center line of the block
between 71st and 72nd Streets;
thence Westerly along the said center line and parallel with 71st Street 50 feet;
thence Southerly and parallel with 5th Avenue 102 feet 2 inches to the northerly side of 71st
Street at the point or place of beginning.
DESCRIPTION IS: SUFFICIENT
TITLE SEARCH PERIOD: 09/11/1989 TO 06/14/2019
DISCLAIMER: This report is prepared based upon information found in the public records of the
county/parish in which the property is situated that was furnished to our office by an independent third-
party title examiner. This Report does not contain or constitute a legal opinion regarding the status of the
title to the subject real property. If you require a legal opinion of title or an attorney title opinion, please
let us know and we will obtain a legal opinion of title or an attorney title opinion for you from an attorney
licensed to practice law in the state in which the property is located.
EFTA00031568


c1: EFTA00031107
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031107.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: bail memo
Date: Thu, 02 Jul 2020 04:51:02 +0000
Attachments: 2020-07-02,GM_detention_memorandum.docx
Hi
Here's the final version we plan to file in the morning. It's in brief format, at the District of New Hampshire's request. The
plan is to file it in SDNY and email a copy to the DNH magistrate judge, but let us know if you think we should proceed
otherwise (the AUSA in DNH didn't seem to have a view on how we should file). We didn't want to file it with New
Hampshire captions and signature blocks, as much as I would have gotten a kick out of signing as a SAUSA. But let us know
if you think we should be going about this a different way.
Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00031107


c1: EFTA00030747
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030747.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From
To
Subject: to fill in
Date: Tue, 12 Nov 2019 22:23:46 +0000
Assistant United States Attorney
Southern District of New York
Tel
EFTA00030747


c1: EFTA00030202
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030202.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Fwd: Jeffrey Epstein
Date: Fri, 12 Jul 2019 22:05:19 +0000
*** This email was sent via my iPhone using the dictation app.. Please understand there may be some
typographical or grammatical errors.
NOTICE: This E-mail (including attachments) is covered by the Electronic Communications Privacy
Act, 18 U.S.C. 2510-2521, is confidential and may be ATTORNEY PRIVILEGED and CONFIDENTIAL
It is intended only for the use of the individual or entity named as recipient. If the reader
of this message is not the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication or any of its contents, is strictly prohibited.
If you have received this communication in error, please notify sender immediately by re-sending
This communication to the sender and delete the original message and any copy of it from your
computer system.
Thank you for your cooperation.
Begin forwarded message:
From:
Date: July 12, 2019 at 11:22:04 AM EDT
To:
Cc:
Subject: Jeffrey Epstein
Mr.
was great touching base with you this morning. As I mentioned on the phone, the Office of the State Attorney is
interested in any information that could lead to criminal charges from that crimes occurred in Palm Beach County. If you
aware of any victims who would like to make a statement to local law enforcement please advise. Feel free to pass my
contact information on to anyone who might have information.
Regards-
Assistant State Attorney
EFTA00030202

=== Page 2 ===
Special Victim's Unit
Human Trafficking and ICAC
Office Of The State Attorney
15th Judical Circuit
Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records
available to the public and media upon request. Your e-mail communications may therefore be subject to public disclosure.
EFTA00030203


c1: EFTA00031830
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031830.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Accepted: Epstein Call
Date: Thu, 21 May 2020 14:03:00 +0000
Importance: Normal
Attachments: unnamed
EFTA00031830


c1: EFTA00031442
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031442.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Nathan NYSD Chambers
To: David Oscar Markus
Cc:
)"
)"
(USANYS)"
Subject: Re: permission to bring electronics into courthouse in U.S. V. Maxwell, 20-Cr-330 (AJN)
Date: Wed, 14 Apr 2021 15:56:05 +0000
Good morning,
Pursuant to the Judge's Individual Practices in Criminal Cases, all communications with the Court must be
docketed on ECF unless a request to seal is being made. Furthermore, please note that Judge Nathan does not
sign electronic device orders for any attorney who has not entered an appearance on ECF in the case for which
the order is sought. Finally, the form for the order authorizing electronic devices may be accessed through this
link: https://www.nysd.uscourts.gov/sites/default/files/practice_documents/PED%20Pilot%20Program%20-
%20Electronic%20Device%20and%20Wi-Fi%20Access%20for%20Attorneys.pdf
Respectfully,
Law Clerk to the Hon. Alison J. Nathan
From: David Oscar Markus
Sent: Wednesday, April 14, 2021 9:33 AM
To: Nathan NYSD Chambers
Cc:
is
is
(USANYS)
is
Subject: permission to bring electronics into courthouse in U.S. V. Maxwell, 20-Cr-330 (AJN)
CAUTION - EXTERNAL:
Dear Judge Nathan:
My name is David Oscar Markus, and I am a lawyer in Miami who is representing Ghislaine Maxwell in
the Second Circuit Court of Appeals regarding bail. I will be present at the arraignment on April 23 and
look forward to meeting you and your staff in person.
My understanding is that out of town lawyers need a court order to take their electronics into the
courthouse. I am writing to ask for permission to bring my cell phone and laptop computer. If the Court is
agreeable, I am happy to provide a proposed order.
Thank you for your consideration and understanding.
Sincerely,
David Oscar Markus
cc: Bobbi Sternheim
Gov't counsel
EFTA00031442

=== Page 2 ===
--David Oscar Markus
Markus/Moss
markuslaw.com
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
EFTA00031443


c1: EFTA00030663
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030663.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Subject: RE: Discovery review project
Date: Wed, 07 Oct 2020 16:01:55 +0000
Embedded: RE:_Discovery_review_project.msg
Sender:
Subject: RE: Discovery review project
Message-Id:
<DM3P110MB02828CA85C95598B82A213B8F00A0@DM3P110MB0282.NAMP110.PROD.OUTLOOK.CO
M>
To:
Cc:
EFTA00030663


c1: EFTA00030115
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030115.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Page 1 of 3
---START MESSAGE Subject: eFOIA Request Received Sent: 2018-12-06T12:21:29.820058+00:00 Status: pending Message:
Individual Information
Prefix
First Name
Live
Middle Name
Last Name
Attempt
Suffix
Email
Phone
Location
United States
Domestic Address
Address Line 1
NA
Address Line 2
City
NA
State
California
Postal
NA
Agreement to Pay
How you will pay
am requesting a fee waiver for my request and have reviewed the FOIA reference guide If my fee
waiver is denied, I am willing to pay additional fees and will enter that maximum amount in the box below
Allow up to $
1,000
Proof Of Affiliation for Fee Waiver
Waiver Explanation
This request is NOT for any commercial use. This request is being made
specifically because or the compelling public interest in the rB:'s
operations as they relate to convicted and prolific SEX offenders like
Jeffrey Epstein. Furthermore, open source reporting shows that Epstein had
close ties with former president Bill Clinton, current president Donald
Trump, Prince Andrew, and other politicians and heads-of-state. For that
additional reason, the public interest here outweighs any on-going right to
privacy that may be in play.
"Documents shall be furnished without any charge or at reduced rate If
disclosure of the information is in the public interest because it is likely
to contribute significantly to public understanding of the operations OF
activities of the government and is not primarily in the commercial interest
of the requester."
All 4 of the factors are net in this case. 1) The request is clearly related
to the operations of the federal government in general and the FBI in
particular. 2) The request 1# likely to contribute to the public's
understanding of the FBI's handling of Epstein. 3) The request is likely to
contribute to the public's understanding (T intend to publish all records
received), and 4) Considering Epstein's reported ties to former and current
presidents and royals, any information you can provide would absolutely be
significant.
Documentation Files
file://hqrd-sfile-fdps/FDPS_Repository/EFOIA/b83d/EMailCorrespondence.html
12/19/2018
EFTA00030115

=== Page 2 ===
Page 2 of 3
Non-Individual FOIA Request
Request Information
I am requesting records related to Jeffrey Epstein (DoB: 01/20/1953), and
the investigation that vas conducted between roughly 2006 and 2010.
Specifically, I - requesting the following:
1) Copies of any and all unredacted investigative reports that have not
already been published https://voulb.fbi.gov/jcffrey-spstsin.
2) Any and all video and photos taken by investigators as part of the
aforementioned investigation.
3) Any and all videos and photos that were collected as evidence from
Epstein's property houses, planes, etc.).
4) Names of any and all co-conspirators that were identified during the
course of the aforementioned investigation.
5) Confirmation as to whether any additional investigations have been
undertaken in to Epstein or any of the co-conspirators that were identified
subsequent to the aforementioned investigation.
6) Copies of any and all directives, policies, instructions, or agreements
relating to the FBI's investigations into Epstein and his co-conspirators,
especially any that may, in any way, limit, hinder, or prevent the FBI from
investigating or prosecuting Epstein and/or his co-conspirators.
7) Copies of any emails sent OF received by Robert Mueller (then head of the
FBI) that include the word "Epstein" or that otherwise relate to the
aforementioned investigation.
Expedite
Expedite Reason
I = requesting this request be expedited on the following basis:
1) The request is made by a person primarily engaged in disseminating
information to the public and the information is urgently needed to inform
the public concerning some actual or alleged federal government activity
I intend to publish (non-commercially) any and all responsive records that
you provide, specifically for the purpose of disseminating said information
** the public The information is urganaly - inform the public about
a matter that is currently making headlines (e.d.,
2) The subject of the request is of widespread and exceptional media
interest and the information sought involves possible questions about the
government's integrity which affect public confidence.
This subject is unquestionably of widespread and exceptional media interest
(sample of recent news stories below), and the information requested speaks
directly to the government's integrity in investigating and prosecuting
prolific child #** predators, which absolutely affects public confidence.
ttps://www.washingtonexaminer.com/policy/ecosomy/democratsrseet-justicerinvestigation-into-labor-secretary+a
ttps://www.thedailybeast.com/lavmakers-demand-proberof-laborrsecretary-acostiroverrsexrabuserjeffreyepsta1
Please be advised that efoia@subscriptions.fbi.gov is a no-reply email address. Questions regarding your FOIA request may be directed to foipaquestions@fbi.gov. If you
have received a FOIPA request number, please include this in all correspondence concerning your request. Please note eFOIPA requests are processed in the order that they
are received. If you have not received a FOIPA request number, your request is in the process of being opened at which time it will be assigned a FOIPA request number
and correspondence will be forthcoming.
Upon receipt of your FOIPA request number, you may check the status of your FOIPA request on the FBI&ETMs electronic FOIA Library (The Vault) on the FBIa€ᵀMs
public website, http://vault.fbi.gov by clicking on the &€"Check Status of Your FOI/PA Request toola€ᵀ link. Status updates are performed on a weekly basis. If you
receive a comment that your FOIPA request number was not located in the database, please check back at a later date.
file://hqrd-sfile-fdps/FDPS_Repository/EFOIA/b83d/EMalCorrespondence.html
12/19/2018
EFTA00030116

=== Page 3 ===
Page 3 of 3
END MESSAGE
----
file://hqrd-sfile-fdps/FDPS_Repository/EFOIA/b83d/EMailCorrespondence.html
12/19/2018
EFTA00030117


c1: EFTA00030906
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030906.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Date: Thu, 13 Aug 2020 21:26:20 +0000
That makes sense to me, thanks.
From:
Sent: Thursday, August 13, 2020 5:19 PM
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
That is okay with me! I agree it is better.
I will make sure to do that moving forward. So far it has been easy to upload/not too large.
From:
Sen
To:
Cc:
Subject: FW: delivery of hard drive to MDC for discovery production to inmate
Can I make a small suggestion on this? Unless and until it gets super inconvenient to do this in terms of upload time, I'd
suggest putting *all* the current discovery on whatever disk we send to the prison, like USAO_GM_000001 through
whatever is the latest production, and then having the facility send back whatever is the last disc we sent after the new
one arrives.
That way at any time there are only two disks out in the world with her discovery on them (the one she has at any given
time, and the one that's on its way to replace it), and only one in her possession at all times. Otherwise in two months
she's going to have a half dozen hard drives sitting in the MDC, with all different stuff on each one. But per usual anybody
should weigh in if anyone disagrees!
From:
Sent: Thursday, August 13, 2020 17:06
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
I just sent the next round of discovery via FedEx. The password for this drive is
We also sent a letter with
the password in a separate envelope.
Please let us know when it arrives.
EFTA00030906

=== Page 2 ===
Thank you,
From:
Sent: Monday, August 10, 2020 6:03 PM
Subject: Re: delivery of hard drive to MDC for discovery production to inmate
That should be enough to track it down, thank you! If I have any issues, I'll let you know.
Best,
>>>
8/10/2020 5:59 PM >>>
I sent this via FedEx. When I enter the tracking number it says:
Delivered
Friday 8/07/2020 at 7:16 am
Let us know if you have any other questions.
Thanks!
Sent from my iPhone
On Aug 10, 2020, at 5:48 PM,
wrote:
Good evening
Just confirming - did you use FedEx, USPS, or some other carrier to send the discovery here? I have not received it yet, but
it could just be that staff did not notify me a package arrived. Depending on the carrier, it could be in the warehouse or
mailroom, so I just want to verify so I can find it expeditiously.
Thanks!
8/5/2020 7:13 PM >>>
That's extremely helpful, thanks so much. We'll plan to put the drive in the mail tomorrow, and of course please let us
know if any issues arise.
thanks again,
From:
Sent: Wednesday, August 05, 2020 19:05
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
EFTA00030907

=== Page 3 ===
Hard drives should be mailed to the facility to the attention of the legal department. We need to etch the drive with a
number and provide an authorization memo so she can retain it. Then it will be provided to her. It can be password
protected so long as you include a cover letter that contains the password for her.
Hope this helps,
8/5/2020 4:34 PM >>>
We have a hard drive with loaded discovery that we need to deliver to Ghislaine Maxwell,
at MDC. Could
you please let us know what the current protocol is for that? Also, it's our understanding that hard drives with discovery
materials for inmates needs to be non-encrypted (and not have a password for access), is that also correct?
We're hoping to get these materials to her tomorrow if at all possible, so we greatly appreciate your help. And I'm
reachable any time at
if it would be helpful to discuss.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00030908


c1: EFTA00029647
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029647.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Accepted:
proffer (re abuse)
Date: Mon, 02 Dec 2019 23:48:32 +0000
Importance: Normal
Attachments: unnamed
EFTA00029647


c1: EFTA00029696
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029696.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
VTC wit
AUSAs
SA
, Det.
was only involved in search of JE PB residence on one day in October 2005. Had no
other involvement in the investigation of Epstein that
can recall.
Det.
drafted the only report documenting
's involvement in the search.
AUSA
emailed TM a copy of Det.
S report to refresh recollection of
search.
reviewed report and confirmed he recalled searching the rooms identified in
the report with Det
Otherwise,
really doesn't remember details of the search. Recalls being in the house
and the various rooms, but doesn't recall specific items that were seized. Is not confident
that his recollection would be further refreshed by reviewing photographs.
EFTA00029696


c1: EFTA00031879
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031879.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From
T
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:46:23 +0000
Inline-Images: image001.png
Thanks!
From:
Sent: Thursday, July 2, 2020 1:26 PM
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congrats, guys!!
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
OF JUSTICE QUI PRO UNITED DONINIST VILLING
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
OF
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
EFTA00031879

=== Page 2 ===
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated 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
EFTA00031880

=== Page 3 ===
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
*
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
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
EFTA00031881

=== Page 4 ===
unless and until proven guilty.
EFTA00031882


