# docs_fts_content

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c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031553.pdf
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=== Page 1 ===
From:
To:
Subject:
Date: Tue, 07 Jul 2020 12:43:00 +0000
Hey - what is the latest with the Epstein electronics from FBI?
Sent from my iPhone
EFTA00031553


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Maxwell
Date: Thu, 17 Sep 2020 15:54:49 +0000
© I'm making popcorn as we speak.
Much appreciated, sorry for the dumb Q.
From:
Sent: Thursday, September 17, 2020 11:53 AM
To:
is
Cc:
Subject: RE: Maxwell
Oh sure. I can screen them for you in the Library if you want. We have Clinton too.
From:
Sent: Thursday, September 17, 2020 11:51 AM
To:
is
Cc:
Subject: Maxwell
This will probably sound ridiculous, but I promised I'd ask (since it's from a credible publication): A reporter has heard
rumors that Maxwell claims she was in possession of video(s) Epstein captured of Dershowitz and other high-profile
individuals at the time of her arrest and may be using them to negotiate with you
EFTA00031582


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=== Page 1 ===
I.
MS. RICHARDSON'S COOPERATION AND ASSISTANCE
While incarcerated, Ms. Richardson, unsolicited, has provided important assistance to the
Government on various investigations and prosecutions. Although she herself cannot file a motion
for a sentencing reduction under Rule 35, all of the Assistant United States Attorneys with whom
Ms. Richardson has met or to whom she has offered information welcomed her assistance, even
where her testimony at trial was not ultimately required. Examples of Ms. Richardson's assistance
are described below.
C. Ms. Richardson Provided Information to the Government Regarding Jeffrey
Epstein's Death.
Given that Ms. Richardson has been a prisoner at the MCC since her arrest in 2016, she
has relationships with guards and inmates who often share invaluable information concerning
events at the MCC. When Jeffrey Epstein died in August 2019, Ms. Richardson heard helpful
information concerning the circumstances surrounding his death and requested that counsel
provide such details (such as the names of the guards on duty at his time of death, their actions in
response to his hanging, and which cameras to check for potentially helpful footage) to the
Government. The Government expressed appreciation for the information, followed up with Ms.
Richardson through counsel to confirm additional details and, although it did not request her
testimony or an in-person proffer, we note that many of the details Ms. Richardson provided were
reflected in various charging documents.
EFTA00030817


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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: PDF now fine
Date: Wed, 24 Jun 2020 15:51:40 +0000
Attachments: 1- - GEP_1-_Global_Energy_Producers_ - Talking Pointsv2.docx; 2 - Maxwell_1
Jeffrey_Epstein_Co-Conspirators_Talking Points,.v2.docx; 3-W1-
Wall_Talking_Points.v2.docx; 4 - TPC 1 - The Presidential Coalition -
Talking_Pointsv2.docx; 5 - NRA 1 - Talking_Points.docx; 6 - AOC 1
_Investigation_Talking_Points.docx; 7 - _NYPD_Talking_Points.docx
Here are the talking points documents, numbered to correspond to the sequence in which they appear in the
briefing book.
Original Message
From:
Sent: Wednesday, June 24, 2020 11:40 AM
To:
)
Subject: RE: PDF now fine
A lot, when you include all the memos. Happy to combine them for you, but it strikes me that what might be
most efficient is for me to forward you just the talking points documents (there are only 7), either in one word
document or as individual word files--since that's what you're likely to be editing.
Original Message
From:
)
Sent: Wednesday, June 24, 2020 11:38 AM
To:
Subject: RE: PDF now fine
How many word docs are there?
Original Message
From:
)
Sent: Wednesday, June 24, 2020 11:19 AM
To:
)
Subject: RE: PDF now fine
Of course. What's most helpful to you. Individual word documents for each part of the briefing book or
everything in one word document?
Original Message
From:
)
Sent: Wednesday, June 24, 2020 11:17 AM
To:
)
Subject: PDF now fine
But can I get a version I can edit ?
Sent from my iPhone
EFTA00030004


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=== Page 1 ===
From:
To:
)"
Subject: US V. Epstein
Date: Tue, 14 Jul 2020 17:41:11 +0000
Hello
I should be ready to send the hard drive to the vendor by tomorrow. Please let me know how you would like to proceed
with the data (sending the data out or holding off for now)?
Thank you.
EFTA00031301


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=== 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
May 3, 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_02753399 through SDNY_GM_02753431.
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 02753399
SDNY GM 02753431
Photographs
Confidential
EFTA00031016

=== 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
EFTA00031017


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=== Page 1 ===
From:
"
)"
To:
)"
Subject: latest
Date: Mon, 01 Jul 2019 17:06:43 +0000
Importance: Normal
Attachments: 2019-07-01,_JE,_first_indictment.docx
EFTA00030237


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=== Page 1 ===
From:
To:
Subject: Re: Photos
Date: Wed, 30 Mar 2011 22:56:57 +0000
Hi
My sincere appreciation for keeping to your word and getting my photos back quickly!! I hope you and
are taking care and continuing to make great progress on the case. Good Luck and Best Wishes!!
Many Thanks,
--- On Tue, 29/3/11,
wrote:
From:
Subject: Photos
To:
Received: Tuesday, 29 March, 2011, 3:29 AM
Your photos were copied and sent out via FedEx this afternoon (Monday in FL). In addition to the printed
photos we had them save the images to a CD so you could have them in digital format. Please let us know
when they arrive. Thanks.
EFTA00030590


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=== Page 1 ===
United States V. GHISLAINE MAXWELL, 20 Cr. 330 (AJN)
Paul Kane Q&A
Objectives GX 761
Rule 803(6)
- Record made at or near the time by --- or from information transmitted by ---
someone with knowledge
-
Kept in the course of a regularly conducted activity of a business
-
Making the record was the regular practice of that activity
BACKGROUND
Question
Answer
Rule
Mr. Kane, where do you work?
Professional Children's
School
What is Professional Children's School?
What is your title?
Director of Finance
How long have you worked there?
2019
What did you do before that?
Chief Admin Officer at
international preschools
from 2009 to 2019
Are those private schools?
Yes
What are your responsibilities?
All financial oversight,
archives, financial
aspects of enrollment
In that capacity, are you familiar with the normal business
Yes
practices of Professional Children's School?
Are you familiar with the business practices regarding
Yes
student files?
Are you familiar with how those practices worked in the
Through archives and
early 1990s? How?
conversations with other
employees who have
been there longer
What are student files?
PCS keeps a permanent
file on each student
Does PCS regularly maintain student files?
Yes
How are those records maintained?
Electronically
How did it work in the 1990s?
Paper
What happened to paper files?
Digitized in about
2011/12
What sort of information is contained in the student
Transcript, college recs,
record?
admissions info
Are those records regularly put in the student file at the
Yes
time they are created?
1
EFTA00031259

=== Page 2 ===
United States v. GHISLAINE MAXWELL, 20 Cr. 330 (AJN)
Were they in the 1990s?
Yes
How long are student records kept?
6 years
Are those records kept in the ordinary course of business?
Yes
What happens at the end of that time?
Destroyed
Are they always purged from the file at the completion of
No
that time?
I am handing you what has been marked for identification
Yes
as GX 761. Do you recognize this document?
Without saying any names, what is it?
Application
Did you review this prior to today?
Yes
How? [Did you compare it with the records from PCS's
This student's electronic
files database]
file is digitized
Is this a true and accurate copy of the document at PCS?
Yes
Government offers 761
These are business records
Admissions records:
Business records. Doesn't matter whether student or school actually put
the information on the school's form.
In any event, "made" by school when received and relied on in ordinary
course of business - adopted business records doctrine.
If must: offering for fact of application, and for the state-of-mind
statement that JE was going to pay for her tuition. Not offered for truth:
not saying he was actually going to do it.
EXTRA FOUNDATION [if necessary]
Question
Answer
Rule
Mr. Kane, a few more questions about this document
Where does the form come from?
PCS
Who filles out the application?
The student
When an application is received by PCS, what happens?
Is PCS in the regular practice of receiving and
maintaining applications for admission?
What efforts does PCS make to verify the information on
[confirm with Kane]
the application?
2
EFTA00031260

=== Page 3 ===
United States V. GHISLAINE MAXWELL, 20 Cr. 330 (AJN)
Does PCS regularly rely on this information to make
Yes
admissions decisions?
Does PCS make admissions decisions in the ordinary
course of business?
Yes
After PCS makes admissions decisions, do these
Yes
applications remain in their records?
Where are they kept?
In the student file -
there is no admissions
file
REVIEW
Question
Answer
Rule
Directing your attention to page 1, what grade is the
12
student applying for?
Where did the student attend high school previously?
WPB, Florida
Where is that located?
Why did the student leave?
Moved to New York
Turning to page 2, Section E, who is listed as the person
JE
Not
with financial responsibility for this applicant?
offered
for
truth
but for
state
of
mind
Does the applicant expect to apply for financial
No
assistance?
Turning to page 3, Section H, how did the student say she
Referred by the
became interested in PCS?
president of admissions
at Julliard
Finally, turning to section K, who signed this application?
3
EFTA00031261


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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: RE: Epstein search materials for upload and privilege review
Date: Fri, 21 Feb 2020 21:52:30 +0000
I think they are in the Subpoena Returns folder, which I thought was strange. I'm heading to
now but will log in
after that to find them.
From:
Sent: Friday, February 21, 2020 4:32 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
just tried calling but didn't catch you - I don't see where these are located in Relativity? I think they should be under
"Search Warrant Returns" but I don't see them there (or anywhere else under the Epstein overall folder). Let me know if
I've just missed them, which is entirely possible, or if they're not accessible to us yet? Thank you!
From:
Sent: Thursday, February 20, 2020 21:12
To:
is
Cc:
is
Subject: Re: Epstein search materials for upload and privilege review
The NP folder has been released.
On Feb 20, 2020, at 2:28 PM,
wrote:
Here's the STR and the data should be released soon, it's just taking a while because the load is so large.
From:
Sent: Thursday, February 20, 2020 11:42 AM
To:
is
Cc:
is
Subject: RE: Epstein search materials for upload and privilege review
EFTA00029672

=== Page 2 ===
New data is loaded and we've segregated the PP hits; you should have access to the new data today. Will keep you
posted.
Thanks,
From:
Sent: Wednesday, February 12, 2020 1:04 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
wanted to follow up on this - is the data fully uploaded, or did it get delayed? Thanks.
From:
Sent: Friday, February 07, 2020 11:25
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
Great, thank you!
From:
Sent: Friday, February 07, 2020 09:34
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
The data should be ready by Monday morning.
From:
)
Sent: Tuesday, February 4, 2020 6:58 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
Wanted to quickly check the status of the below - it's only been a couple weeks, so totally understand it may not be
complete, but hopefully we're getting close? If you could please check with the vendor and let us know, we'd be grateful
- and we'll plan to get it to
asap once we have access.
thanks,
From:
)
Sent: Tuesday, January 21, 2020 18:50
To:
Cc:
is
is
EFTA00029673

=== Page 3 ===
)
>
Subject: RE: Epstein search materials for upload and privilege review
We've received a hard drive from FBI CART, which they've processed from devices seized and searched in connection
with the Epstein case. Can we please get those materials uploaded to Relativity, for privilege review by
(copied
here)? I've left the hard drive with the materials on your chair. (And if we could please get that hard drive back once
the materials are uploaded, the FBI has another batch they want to transmit to us for the same process, so that will also
be coming shortly.)
And then
these will be subject to just the exact same privilege review you previously ran in connection with Epstein
search warrant returns.
Please let us know if any questions or issues at all? And thanks very much as always.
<STR_Epstein_Privilege Terms_02.14.2020.pdf>
EFTA00029674


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=== Page 1 ===
From:
To:
)"
Subject: Accepted: Call re: Epstein FOIA
Date: Thu, 11 Mar 2021 21:07:25 +0000
Importance: Normal
Attachments: unnamed
EFTA00030078


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=== Page 1 ===
CG
800 Third Avenue
COHEN & GRESSER LLP
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
Christian R. Everdell
December 28, 2020
BY EMAIL
United States Attorney's Office
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
On behalf of our client, Ghislaine Maxwell, we hereby request that the government file a
Bill of Particulars pursuant to Rule 7(f) of the Federal Rules of Criminal Procedure. Please let us
know by January 4, 2021 whether it will be necessary to raise any aspect of this request with the
Court.
We request clarification of the allegations specified below in order to permit Ms. Maxwell
to prepare her defense and avoid unfair surprise at trial. See United States V. Bortnovsky, 820 F.2d
572, 574 (2d Cir. 1987). The Superseding Indictment does not sufficiently inform Ms. Maxwell of
the specific conduct of which she is accused. Accordingly, we request the following particulars
regarding the indicated paragraphs of the Superseding Indictment:
1. Please provide the full names and full birthdays of the individuals identified in the
Superseding Indictment as Minor Victims-1-3 (11 7, 11, 13, 17, 19).
2. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or
interacted with Minor Victim-1 (1 7a).
3. Please identify the dates when, and locations where, Ms. Maxwell allegedly "groomed"
Minor Victim-1 "to engage in sexual acts with Epstein" (I 7a).
4. Please identify the dates when, and locations where, Jeffrey Epstein allegedly sexually
abused Minor Victim-1 (1 7a).
EFTA00030934

=== Page 2 ===
December 28, 2020
Page 2
5. Please identify the dates when, and locations where, Ms. Maxwell allegedly "was
present for and involved in" Epstein's sexual abuse of Minor Victim-1 (1 7a).
6. Please identify the dates when, and locations where, Minor Victim-1 participated in
"group sexualized massages" of Epstein (1 7a).
7. Please describe with particularity the conduct that the government contends is a "group
sexualized massage" and identify the criminal statute(s) the conduct allegedly violates
and the other participants in those massages (1 7a).
8. Please describe with particularity how Ms. Maxwell allegedly "involved" Minor
Victim-1 in these massages and how Ms. Maxwell allegedly participated in these
massages (1 7a).
9. Please identify the dates when Minor Victim-1 allegedly traveled "across state lines for
the purpose of sexual encounters with Epstein" (I 7a).
10. Please identify the dates when Ms. Maxwell allegedly enticed Minor Victim-1 "to
travel across state lines for the purpose of sexual encounters with Epstein" and describe
with particularity the actions that Ms. Maxwell allegedly took to entice Minor Victim-1
to travel (I 7a).
11. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or
interacted with Minor Victim-2 (1 7b).
12. Please identify the dates when Minor Victim-2 allegedly traveled across state lines to
and from New Mexico in 1996 (1 7b).
13. Please identify the dates when Ms. Maxwell allegedly "groomed" Minor Victim-2 to
engage in "acts of sexual abuse" with Epstein (I 7b).
14. Please describe with particularity what Ms. Maxwell allegedly did as part of the
"unsolicited massage" of Minor Victim-2 and identify the criminal statute(s) the
conduct allegedly violates (1 7b, 11c, 17c).
15. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or
interacted with Minor Victim-3 (1 7c).
16. Please identify the dates when, and locations where, Ms. Maxwell allegedly introduced
Minor Victim-3 to Epstein and the dates and locations of their subsequent "multiple
interactions" (1 7c).
EFTA00030935

=== Page 3 ===
December 28, 2020
Page 3
17. Please identify the dates when, and locations where, Ms. Maxwell allegedly "groomed"
Minor Victim-3 to engage in sex acts with Epstein (I 7c).
18. Please identify the dates when, and locations where, Jeffrey Epstein allegedly sexually
abused Minor Victim-3 (1 7c).
19. Please describe with particularity the "sex acts" that Minor Victim-3 allegedly engaged
in with Epstein during massages and identify the criminal statute(s) the conduct
allegedly violates and the other participants in those massages (I 7c).
20. Please identify the dates when Minor Victim-3 allegedly traveled in interstate or
foreign commerce to engage in illegal sexual activity with Epstein (I 7c).
21. Please specify when the conspiracies charged in Count One and Count Three began
and ended. (11 9, 15).
22. Please identify the "others" who allegedly participated in the conspiracies charged in
Count One and Count Three with Epstein and Ms. Maxwell. (II 9-10, 15-16).
23. Please identify any individuals who were enticed to travel, or were transported, in
interstate or foreign commerce to engage in illegal sexual activity with Epstein during
the time period of the charged conspiracies (1994-1997), apart from Minor Victims-1-3
(1 10, 16).
24. Please identify the dates when, and the locations where, Ms. Maxwell participated in
"group sexualized encounters" with Jeffrey Epstein and Minor Victim-1 (II 11a, 17a).
25. Please describe with particularity the conduct that the government believes constitutes
a "group sexualized encounter" and identify the criminal statute(s) the conduct violates
and the participants in those encounters (11 11a, 17a).
26. Please identify who allegedly enticed Minor Victim-1 to travel from Florida to New
York in 1996 (II 11b, 17b).
27. Please identify from whom Ms. Maxwell was allegedly trying to "conceal her crimes"
when she allegedly lied under oath in depositions in 2016 (1 2).
28. Please identify "the specific events and acts of abuse" about which Ms. Maxwell
allegedly "repeatedly provided false and perjurious statements" (8).
EFTA00030936

=== Page 4 ===
December 28, 2020
Page 4
29. As to each statement alleged to be perjurious in Counts Five and Six of the
Superseding Indictment please specify why the Government contends the statement
was material (11 21, 23).
Thank you in advance for your prompt response to these requests.
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
cc:
Mark S. Cohen, Esq.
Jeff Pagliuca, Esq.
Laura Menninger, Esq.
Bobbi C. Sternheim, Esq.
EFTA00030937


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=== Page 1 ===
From:
To:
Subject: In Re: Grand Jury Subpoena_19-mc-00179
Date: Wed, 15 Jul 2020 13:08:41 +0000
Attachments: 19mc00179_20.7.14_-_Order.pdf
Please see the attached PDF for an Order that was filed under seal today in 19-mc-179.
Thank you,
Courtroom Deputy to the Hon. Sarah Netburn
United States District Court
Southern District of New York
EFTA00031306


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=== Page 1 ===
4/8/2021
FD-1087
31E-MM-108062 - 1B2
Package
Copy
Split To
50D-NY-3027571
Item 1B134
(U) One (1) peach massage table.
50D-NY-3027571
Item 1B133
(U) One (1) green massage table (PBPD05-1024).
Evidence
31E-MM-108062 - 1 1B2
Item:
Evidence
General
Type:
ONE Box AND one CPU (marked 10F4)182 /31-44
(U) Box containing (1 of 2): (31) 32) ONE THRIFTY RENTAL AGREEMENT.
(32) 33) NOTE FROM
(33) 34) ELEVEN CDS - OFFICE
(34) 35) MESSAGE BOOK -
GUEST HOUSE
(49) (36) ONE MESSAGE BOOK
(50) (37) TWO COMPACT
Description: FLASH CARDS
(51) (38) SIX CDS - GUEST HOUSE
(52) (39) POWER CORD
TO CPU- GUEST HOUSE
(54) (40) CPU - OFFICE
(55) 41) ONE POWER
CORD TO CPU - OFFICE
(56) 42) THREE CDS - OFFICE
(58) 44) ONE
GREEN FRAMED PHOTO (59) Computer 2 of 2.
Location:
E03707388 - ECR8
Barcode: E4229229
Details
Collected On: 08/28/2006 11:00 AM
Receipt Item #: None
CATS ID #: None
CATS Abandonment #: None
FBI Seizure #: None
Abandonment #: None
Storage Location
Discovery Location
Holding Office: NY - NEW YORK
Area:
N/A
Finalized By:
Seizing Individual:
II
Last Inventory: 08/04/2020 12:00 AM
Specific:
N/A
Collected By:
II
Retention
Retention: No
Legal Caveats
None
Chain of Custody
Shipping Log
History
Acquisition Event
Acquisition Event: (U//FOUO) Items migrated on 2006-08-28
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/2
SDNY_GM_02753556
EFTA00029899

=== Page 2 ===
4/8/2021
FD-1087
Collected From: (U//FOUO) DET.
345 SOUTH COUNTY ROAD
P/ LM BEACH, FL, 33480
Receipt Given:
No
Holding Office: MM - MIAMI
Evidence Log:
Missing
Missing
GROO
REWOR
or
MO
(88)
lage.!
to mets
nots alupaA
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
2/2
SDNY_GM_02753557
EFTA00029900

=== Page 3 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B2
Barcode : E4229229
Accepted By:
Printed Name
Reason: Collected
Date/Time: 08/28/2006 11:00am
Accepted By:
Printed Name:
Reason: STORAGE EXCLUDING ITEMS# 35AND36.
Date/Time: 2-8-08
330PM.
Accepted By:
Printed Name:
Reason: Review of Item #s 35 and 36
Date/Time 02-08-08 3:31pm
Accepted By:
Printed Name
Reason: RELEASED To SA.
Date/Time: 01 3-6-08 /2:05PM.
Accepted By:
Printed Name
Reason: Review
Date/Time: 03/06/2008 12:06
Accepted By:
Printed Name:
Reason:
RELEASED TO SA.
Date/Time: / 04/0-08
1100AM.
Accepted By:
Printed Name:
Reason Review a 1B2 excluding Items 31+43 Date/Time: 04/10/2008 1:01am
Accepted By:
Printed Name:
Reason: Return of all 1Bs
Date/Time: 01/13/2009 3:14pm
Accepted By:
Printed Name:
Reason:
STORAGE
Date/Time: 01/13/09 315PM.
Accepted By:
Printed Name:
RF
Signature:
Reason:
6/14/14
Date/Time:
WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
SDNY_GM_02753558
EFTA00029901

=== Page 4 ===
EVIDENCE CHAIN OF CUSTODY
Relinquished Custody Fedex#: 4 18344676832
Date and
Accepted 0
Date and
Time
Time
Signature
6/17/19
Signature:
6/20/19
Printed N
FBI
Printed Nan
Reason: Transf
6:35am
Reason;
GIMIAMI
3:00PM
Relinquished 0
Date and
Accepted Custody
Date and
Time
6/24/19
Time
Signature:
Signature
6/24/19
Printed Name/A
Printed
Reason: 90
2=6dg
Reason: Evidence Kenew
2:10p
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature
7/25/19
Signature:
Printed N
Printed Name/Agency:
Reason: Seen 70 E65160221
4:00Pm
Reason:
Relinquished Custody
E6516023
Date and
Accepted Custody
Date and
Time
Time
Signature
3/15/21
Signature:
3/15/21
Printed Na
Printed N
Reason
4:30p
Reason:
Changed in
4:30pm
Relinqu
Date and
Accepted Custody
Date and
Time
Time
Signatu
3/31/21
Signature
Printed
3/31/21
Printed N
Reason
335,
Reason: Review
33Sp
Relinqu
Date and
Accepted Custody
Date and
Time
Time
Signature:
4/8/21
Signature:
Printed Name
4/8/21
Printed Nar
Reason:
2:33
Reason:
Chappecin
2:33pm
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature
6/2/21
Signature:
Printed N
Printed Name/A
6/2/21
Reason: nargea OUT
3.40
Reason:
Charged out
3:40
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
IB: 2
Barcode: E4229229
This form is incomplete without reference to the FD-1087.
SDNY_GM_02753559
EFTA00029902


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=== Page 1 ===
From:
(OIG)"
To:
Cc:
Subject: RE: Epstein Assistance Request
Date: Mon, 19 Aug 2019 20:00:01 +0000
I will provide that, please give me a few.
U.S. Department of Justice
Office of the Inspector General
New York Field Office
Original Message
From:
Sent: Monday, August 19, 2019 3:59 PM
To:
Cc:
Subject: Epstein Assistance Request
Can anyone advise as to the full names and possibly dates of birth for the following BOP employees?:
EFTA00031011

=== Page 2 ===
?
If we could have these by 5:30 it would help in piecing together some information for our analyst helping us
with the case
FBI/NYPD Violent Crimes & Joint Bank Robbery Squad C-19
EFTA00031012


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=== Page 1 ===
From:
"
(NY) (FBI)"
To:
Subject: Re: Ghislaine Maxwell Siblings
Date: Wed, 01 Jul 2020 22:01:02 +0000
Hey
Scott's DOB is
From:
Sent: Wednesday, July 1, 2020 5:11 PM
To:
(NY) (FBI)
Subject: RE: Ghislaine Maxwell Siblings
Hi
Do you have a date of birth for Scott Borgerson? Thanks.
From:
(NY) (FBI)
Sent: Wednesday, July 1, 2020 3:45 PM
To:
Cc:
Subject: RE: Ghislaine Maxwell Siblings
No problem!
The only Marriage license for Scott Borgerson was on 5/19/2001 to Rebecca Piorunneck. Checks for Ghislaine Maxwell (in
every state) were negative.
From:
)
Sent: Wednesday, July 01, 2020 3:29 PM
To:
(NY) (FBI)
Cc:
Subject: RE: Ghislaine Maxwell Siblings
Thanks very much! Somewhat related, are you able to determine whether Maxwell is married? And in particular whether
she is married to Scott Borgerson?
thanks,
From:
(NY) (FBI)
Sent: Wednesday, July 01, 2020 15:27
EFTA00031470

=== Page 2 ===
To:
Subject: FW: Ghislaine Maxwell Siblings
Good afternoon,
Below is information regarding Maxwell's siblings.
From:
(NY) (FBI)
Sent: Wednesday, July 01, 2020 2:55 PM
To:
Subject: Ghislaine Maxwell Siblings
1. Christine Maxwell
2. Isabel Maxwell
3. Karine Maxwell
Deceased
4. Ann (Anne) Maxwell (Anne Holve)
Married Lawrence Holve
No identified residence in US
i. OUTBOUND flight on 5/23/2015 to UK
5.
***Kevin Maxwell
No identified residence in US
i. INBOUND flight on 2/29/2020 to Boston from London
6. Michael Maxwell
Deceased
7. lan Maxwell
No identified residence in US
i. OUTBOUND flight on 12/27/2017 to London from Boston
8.
Philip Maxwell
EFTA00031471

=== Page 3 ===
No travel history
No identified residence in US
Let me know if you need anything else!
EFTA00031472


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=== Page 1 ===
From:
To:
Subject: RE:
Date: Fri, 21 Jun 2019 23:01:07 +0000
Importance: Normal
Attachments: SDFL_decision.pdf
Embedded: RE:_Epstein_investigation,_prosecution_memo.msg
Hey sorry, didn't realize you needed them this afternoon. They're attached - initial email with the pros memo and the
decision. And let me know if anything else would be helpful, happy to send along whatever. Thanks again.
From:
Sent: Friday, June 21, 2019 18:56
To:
Subject:
Hey
Can you please shoot me those docs when you can? Thanks very much.
Best,
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
EFTA00030230


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=== Page 1 ===
From:
)"
To:
Cc:
)"
,
)"
Subject: RE: Call this week
Date: Thu, 12 Sep 2019 20:02:09 +0000
Inline-Images: image001.jpg
Perfect, thanks very much. You can call my desk at
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From:
Sent: Thursday, September 12, 2019 3:14 PM
To:
Cc:
is
Subject: Re: Call this week
We will call you at 2:30/4:30 today -- please let me know what number is best to reach you.
Thank you,
CONFIDENTIALITY NOTICE: The information in this e-mail and in any attachment may contain information
that is legally privileged. It is intended only for the attention and use of the named recipient. If you are not the
intended recipient, you are not authorized to retain, disclose, copy or distribute the message and/or any of its
attachments. If you received this e-mail in error, please notify sender at the New Mexico Attorney General's
Office and delete this message. Thank-you.
On Tue, Sep 10, 2019 at 2:00 PM
)
wrote:
Great, thanks very much. Could we say 2:30 pm MST / 4:30 pm EST on Thursday afternoon?
EFTA00030709

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From:
Sent: Tuesday, September 10, 2019 1:32 PM
To:
Subject: Re: Call this week
Hi
How is Thursday afternoon? I'm available anytime after 2 pm MST if that works for you.
Thank you,
CONFIDENTIALITY NOTICE: The information in this e-mail and in any attachment may contain
information that is legally privileged. It is intended only for the attention and use of the named recipient. If
you are not the intended recipient, you are not authorized to retain, disclose, copy or distribute the message
and/or any of its attachments. If you received this e-mail in error, please notify sender at the New Mexico
Attorney General's Office and delete this message. Thank-you.
On Sun, Sep 8, 2019 at 3:17 PM
)
wrote:
Hi
Hope you're doing well. Would you be available for a call this week to touch base regarding the Epstein
case?
Thanks.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00030710


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: Re: Epstein investigation
Date: Fri, 21 Feb 2020 20:56:47 +0000
Inline-Images: image001.jpg
Ok.
Sent from my iPhone
On Feb 21, 2020, at 3:56 PM,
)
wrote:
No. Just to give her a full week, I can email her on Monday to check in.
From:
Sent: Friday, February 21, 2020 15:55
To:
is
Subject: FW: Epstein investigation
Just to confirm, has anyone heard from her since this email?
From: Jill Greenfield
Sent: Saturday, February 15, 2020 7:22 AM
To:
Cc: Kyle Phillips
>; ; Louise Scott
is
is
)
Subject: Re: Epstein investigation
Thanks
This is helpful. I've gone back to my client with this. I will be back in touch shortly.
Regards
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
Sent from my iPhone
EFTA00029675

=== Page 2 ===
On 14 Feb 2020, at 21:43,
wrote:
Jill,
Following up on our phone call, thank you for talking with us again, and we wanted to get back to you regarding some
of the additional follow-up questions you asked, and to describe in more detail for your client how we would expect to
approach any discussion with your client if she were comfortable meeting with us.
The absolute most important thing is that any discussion would be entirely voluntary, and by that we mean the
decision to meet with us but also as to any topic or question-your client would be absolutely free to determine what
topics she felt comfortable discussing. There is absolutely no pressure on victim witnesses to address anything that
would make them uncomfortable at any time, and even if your client was willing to meet with us, we would tell her, as
we do for any witness, that if any topic comes up that she wants to skip, or discuss with you privately, that is no
problem at all.
In fact, if you and she would prefer, we would be happy to have a meeting where we simply introduced ourselves,
explained the status of our investigation, talked about how a discussion would proceed if your client ended up being
comfortable with that, and answered in person any questions she. We have done that previously, where we do the
talking rather than asking questions in an initial meeting, and that would of course be without any requirement for
anything additional if she preferred not to. As I mentioned on the phone, we have consistently found that we are able
to reassure individuals when we have the opportunity to meet in person so they can see directly our interest in
approaching these discussions with great sensitivity and care. As I also mentioned on the phone, even if your client
were willing to speak with us, there would be absolutely no need or requirement for her to talk about any assault or
victimization she experienced. We wrote in our first email that we would primarily be interested in talking about
topics such as the general scope of her employment, directions she received from Epstein or Maxwell, etc., and as
always we would be guided by her comfort level.
In terms of who would attend a meeting, we almost always work in pairs, so two prosecutors and two officers, and
that's not to have extra people, but rather because it helps us to be as efficient as we can, and so witnesses can meet
the people on the team. Our team is also majority female, and we always tell witnesses that if topics come up in a
discussion that they would prefer to speak about just with women, that's fine and we can be flexible in the moment
and are always guided by the comfort level of the victim. But I also want to stress that in terms of your client in
particular, we don't expect to initially address issues of a very personal or sexual nature, and we certainly would tell
you in advance if there came a time when we thought that might be important to address, and how we could facilitate
that. Who exactly from our team would be at any meeting would depend on schedules, but we can assure you that
every one of us has now spoken with dozens of victims in this case, and every one of us has extensive experience more
generally working with victims and working on cases involving sex offenses. We are proud of how we have been able
to work with victims in this case especially, given all of the circumstances, and we absolutely would take the same
sensitive approach with your client as we have with the many other victims in this case who have spoken with us.
Again, if it would be helpful even for us to just come to the U.K. and introduce ourselves and explain in person how our
process works, and answer any questions your client has in person, we would absolutely be happy to do that with no
obligation at all from her. We also could do that with the possibility that if she felt comfortable, we could just address
the general subject of her employment, for example. But no obligation and no pressure. We continue to appreciate
your and her willingness to even broach the possibility of a discussion, and we hope this is helpful.
thank you very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00029676

=== Page 3 ===
From:
Sent: Saturday, February 08, 2020 14:25
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
)
is
)
Subject: RE: Epstein investigation
Jill,
Thanks for circling back, and we'll do our best to answer these questions. In terms of who would be in the room, the
most likely answer is that it would be two of the prosecutors and the two law enforcement officers on the case. The
only reason I saw "most likely" rather than having a definitive answer is that when we're interviewing in a foreign
country, it sometimes is the case the local law enforcement also insists on having representatives present. I don't
believe that's required in the U.K., but we can check on it and give you a definitive answer in the coming days if that's
useful. (Also, if she preferred to be interviewed in the U.S., we certainly could guarantee that the room would be just
the case team, and we could arrange for travel and lodging for her. Let us know if that's the case, but otherwise we're
of course happy to travel to her.)
Regarding access to notes, it would principally be the investigative team-so again, the prosecutors and the FBI team
working on the case. Our respective supervisors also theoretically have access to our files, but the reports are not
generally widely disseminated. The basic logistics are that an agent takes notes during an interview, and then types up
those notes into a formal report (called an FBI Form 302). We don't ordinarily share notes with other entities, but I
can also check on that to see if I can make a more specific representation with respect to your client.
With respect to anonymity, I confess that I'm not familiar with the distinction you're referring to. In terms of our
investigation, we don't publicly disclose the names of individuals we meet with, and we don't disclose to any other
witnesses, for example, the identities of victims or witnesses we are meeting with. (And our policies on that don't
change even for individuals who are in the position of your client, who have been widely publicly reported to have
been connected to Epstein and/or his employees or associates). But if that doesn't answer your question, we're of
course happy to discuss further. Let me know if it might be useful to have a call? Or if not, also happy to address any
follow-up via email.
thanks,
From: Jill Greenfield
Sent: Saturday, February 08, 2020 13:17
To:
Cc: Kyle Phillips
>; Louise Scott
)
is
)
Subject: Re: Epstein investigation
Hi
Thanks for this. I've been asked who would be in the room and thereafter who would have access to any
notes made. Would her permission be sought before disclosing to any other parties or officials?
As you know there is a real difficulty in relation to her anonymity in the US versus the UK. Are you able to
provide any comfort on this?
Many thanks
EFTA00029677

=== Page 4 ===
Jill
Jill Greenfield
Partner
D:
M:
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
Sent from my iPhone
On 6 Feb 2020, at 21:53,
)
wrote:
Ms. Greenfield,
Thank you again for speaking with us earlier today regarding our interest in talking with your client in connection
with our investigation into the conduct of Jeffrey Epstein.
As requested, we wanted to briefly memorialize our current views and understandings of your client, and also to
reiterate our interest in approaching any discussion with great care and sensitivity, particularly to avoid adding to her
trauma or causing re-victimization.
As we mentioned on the phone, your client is not a target of our investigation-it sounds like the analogue in the
U.K. may be the "suspect" category-and we currently do not have reason to believe that she has committed any
U.S. federal crime. As we discussed, our knowledge of your client specifically is somewhat limited, having never
spoken to her-and therefore knowing about her only through other witnesses and records-but it certainly has
been our experience that the overwhelming majority of young women and girls who were in the orbit of Jeffrey
Epstein during the relevant periods were subject to his abuse. It does not surprise us, nor do we have any trouble
believing, that your client was similarly a victim. I hope that is helpful in understanding the capacity in which we
hope to speak with her.
Separately, and as we also discussed, any discussion with our team would be entirely voluntary-and that extends
not just to whether she would be willing to meet with us at all, but also including her ability to decline to discuss
particular topics or even particular questions, and to talk with her counsel at any time, to take any breaks that would
be beneficial while we're meeting, etc.
In terms of topic areas, we would be hoping to learn about the general narrative of her interactions with Epstein and
his other associates and employees, including Ghislaine Maxwell, whom we understand she may have worked
directly for. That would broadly include how she came to be in contact with them, the nature and scope of her
employment, any instructions she was given relating to other women or girls, and just generally her experiences and
observations in interacting with them. We ordinarily would also be interested in understanding the general nature of
the abuse she was subjected to, but I want to emphasize that we would not need to discuss with her the specifics if
she weren't comfortable with that, and in particular we often don't even broach that subject in a first meeting.
Please let us know if you have any additional questions, and in particular whether any other information from us
would be useful, and we look forward to speaking with you again soon.
Regards,
Assistant U.S. Attorney
EFTA00029678

=== Page 5 ===
Southern District of New York
Fieldfisher, Riverbank House, 2 Swan Lane, London EC4R 3TT.
www.fieldfisher.com
We do not intend to change our bank details. If you receive any communication that any of our bank details have changed, telephone us and speak to your
contact at our office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstances.
This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact the
sender immediately, destroy the email and any attachments and do not use, copy, store or disclose this email and any attachments
for any purpose. Fieldfisher does not accept service of documents by electronic means without express prior agreement.
For details about what personal information we collect and why, please see our Privacy Notice on our website at
www.fieldfisher.com.
Fieldfisher is the trading name of Fieldfisher LLP, a limited liability partnership registered in England and Wales (registered number OC318472) and is authorised and regulated
by the Solicitors' Regulation Authority. A list of its members and their professional qualifications is available at its registered office, Riverbank House, 2 Swan Lane, London
EC4R 3TT. We use the term partner to refer to a member of Fieldfisher LLP or an employee or consultant with equivalent standing or qualifications.
EFTA00029679


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=== Page 1 ===
From:
To:
Subject: Questions re: 3500 and GX index for court
Date: Wed, 01 Dec 2021 03:03:03 +0000
Attachments: 2021.11.30_US_v_Maxwell_Government_Exhibit_Index_(Admitted).pdf
Hi all,
Two questions for you.
1. Do you have 3500 you want to get out tonight?
2. Khalilah asked me at the end of the day if we could send her a list of all admitted exhibits so far. I've checked my
notes of what was admitted against the transcript. Does one of you want to send her the attached (and note that
DXs LV-3A, LV-3B, LV-4, LV-5, and J-3 were also admitted), or would you like me to do so?
Thanks,
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 Saint Andrew's Plaza
New York, NY 10007
EFTA00031198


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=== Page 1 ===
From: "
(USANYS)"
To:
"
)"
Bcc: "
1"
Subject: RE:
materials
Date: Fri, 08 Jan 2021 20:05:16 +0000
Embedded: RE:
Sender:
Subject: RE:
materials
Message-Id:
<SN5P110MB0445B40B8ABF9AA1D5F5AA2682AE0@SN5P110MB0445.NAMP110.PROD.OUTLOOK.CO
M>
To:
EFTA00030948


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=== Page 1 ===
From:
To:
Cc:
Subject: GM photo on Bannon phone
Date: Fri, 11 Jun 2021 16:30:59 +0000
Attachments: GM_Screenshot_2021-06-11_122815.jpg
H
I hope you're well! I'm helping out with the responsiveness review for WBTW and I've been looking through Steve
Bannon's iPhone 7 on Cellebrite. As I was going through the images from that phone, I found an image of Trump and
Ghislaine Maxwell on Bannon's phone (see screenshot from Cellebrite, attached). I discussed with Sunny and we wanted
to flag this for you, in case it was of any importance to you, since you are on both cases.
Please let me know if you'd like anything further done with this. Thanks so much!
EFTA00030999


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=== Page 1 ===
From:
)"
To:
)"
Subject: FW: Shortened talking points
Date: Wed, 24 Jun 2020 19:44:07 +0000
Attachments: Wall_Talking_Points.v3.docx; Global_Energy_Producers_-_Talking_Points.v3.docx;
Jeffrey_Epstein_Co-Conspirators_Talking_Points.v3.docx;
AOC_Investigation_Talking_Points.v2.docx;The_Presidential_Coalition_ -
_Talking_Pointsv3.docx; NRA_Talking_Points.v2.docx
Here are revised talking points.
FYI, we should give direction at outside that TP's need to be short and crisp, esp for meeting with AG where time is of the
essence.
From:
(
Sent: Wednesday, June 24, 2020 3:04 PM
To:
)
Cc:
Subject: Shortened talking points
- as requested, I've chopped all the talking points to a page or less (except GEP, which is still much shorter).
Happy to further refine.
EFTA00030775


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=== Page 1 ===
From:
To:
Subject: Fwd: Premises SW
Date: Thu, 02 Jul 2020 10:54:45 +0000
Attachments:SDNY_Premises_Search_Warrant_Bundle_(revised).pdf; ATT00001.htm
Not going through on my laptop so trying from my phone. It's paragraph 15. Paragraph 3 defines the subject
premises
Sent from my iPhone
Begin forwarded message:
From:
)"
Date: July 2, 2020 at 6:21:58 AM EDT
To:
Subject: Premises SW
EFTA00031554


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: draft press release
Date: Sat, 27 Jun 2020 23:31:46 +0000
Attachments: 2020-06-27,_GM,_press_release,_draft.docx
I imagine this will go through many rounds of edits, but just to put something down on paper with plenty of time in
advance - see attached. I'll be out of pocket tonight (unless there's anything time-sensitive), but can turn edits tomorrow
no problem if that's useful.
thanks,
EFTA00030810


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=== Page 1 ===
From:
To:
)"
Subject: RE: new materials for Maxwell upload to Relativity
Date: Tue, 04 Aug 2020 20:29:41 +0000
Just tried you! I am not in the office but I am available on my cell-
l'll also be in all day tomorrow.
From:
Sent: Tuesday, August 4, 2020 3:56 PM
To:
Subject: RE: new materials for Maxwell upload to Relativity
Hey can you give me a call or swing by when you have a sec? Want to coordinate on discovery stuff very briefly.
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!!
EFTA00031222

=== Page 2 ===
From:
Sent: Tuesday, August 04, 2020 13:44
To:
Cc:
>;
is
is
is
>;
Subject: RE: [EXTERNAL EMAIL] - RE: Epstein Evidence status
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:
>;
>;
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.
EFTA00031223

=== Page 3 ===
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 Francesco 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?
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
>;
Subject: [EXTERNAL EMAIL] - RE: Epstein Evidence status
EFTA00031224

=== Page 4 ===
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.
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:
i
i
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.
EFTA00031225

=== Page 5 ===
thanks again,
Original Message
From:
Sent: Thursday, July 23, 2020 14:44
To:
Cc:
>;
Subject: Epstein Evidence status
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.
EFTA00031226


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=== Page 1 ===
From: "Berman, Geoffrey (USANYS)"
To:
(USANYS)"
Subject: 2020-04-10 GM prosecution memo..pdf
Date: Fri, 01 May 2020 17:23:00 +0000
Attachments: 2020-04-10_GM_prosecution_memo.pdf
EFTA00030003


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=== Page 1 ===
From:
To:
Subject: Automatic reply: United States V. Epstein
Date: Fri, 30 Aug 2019 20:07:15 +0000
I will be out of the office until September 16 with no access to email. If you need immediate assistance, please contact
EFTA00031308


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=== Page 1 ===
Event: Accepted: Epstein Image/Video File Review Protocol
Start Date: 2020-10-20 17:00:00 +0000
End Date: 2020-10-20 17:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-10-19 22:28:57 +0000
Date Modified: 2020-10-19 22:28:57 +0000
Priority: 5
DTSTAMP: 2020-10-19 21:51:50 +0000
Attendee:
EFTA00030548


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=== Page 1 ===
From:
)"
To: "Moyne, Parvin"
Cc: "Moyer, Thomas"
)"
)"
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Date: Wed, 21 Aug 2019 22:45:05 +0000
Parvin,
Not a problem. We could do any time after noon on that Tuesday (the 10th) or any time on the Thursday (the 12th).
Would either of those work?
thanks,
From: Moyne, Parvin
Sent: Wednesday, August 21, 2019 09:25
To:
Cc: Moyer, Thomas
V.
>;
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
I'm so sorry for the inconvenience but those dates are not good on our end.
The following week is relatively clear. Might September 9th work? Or other dates that week?
Best,
Parvin
From:
Sent: Tuesday, August 20, 2019 11:58 PM
To: Moyne, Parvin
Cc: Moyer, Thomas
V.
>;
)
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Parvin,
That makes good sense, thanks. Because of the scheduling issues I mentioned, we'd like to set it for a time in early
September, if we can - is there a time during the afternoon of September 5 or the morning of September 6 that would
work for you? We should be able to do either of those dates and times. Or if not, we can propose possible times the
following week.
thank you,
From: Moyne, Parvin
Sent: Tuesday, August 20, 2019 14:03
EFTA00029723

=== Page 2 ===
To:
is
)
V.
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Initially, we propose that the lawyers (myself, my colleagues at Akin Gump, and someone from DB Legal) deliver a
presentation that provides an overview of Epstein's relationship with the bank, the different accounts affiliated with
Epstein and the types of transactions found in the accounts. We would also highlight various transactions that we have
noted in our internal investigation. Our aim is that the attorney proffer would help you in sifting through the records we
have provided so you can more readily identify whatever information you are most interested in. Following the proffer, if
there are particular accounts or transactions of interest, we can identify the person within
who can best answer
questions on those areas and that person would then meet with you.
In terms of timing, I estimate 2-3 hours for the attorney proffer. (I think closer to 2 hours but I hate to underestimate.)
Best,
Parvin
From:
Sent: Monday, August 19, 2019 8:14 PM
To: Moyne, Parvin
is
>;
)
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Parvin,
Could you please let us know what format we should expect in terms of the proffer? That will help us with figuring out
scheduling. I.e., do you expect to make an attorney proffer in the first instance, or should be expect to be meeting with
personnel, etc? And approximately how long should we be planning to block out?
thanks,
From: Moyne, Parvin
Sent: Monday, August 19, 2019 12:04
To:
is
)
V.
)
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Hi
The proffer may be helpful in guiding you through the production. That said, we can be available whenever makes most
sense on your ends.
We have time this week (Thursday or Friday afternoon) and next week (Monday - Wednesday), and we have time in
September. If you give us a few options in terms of dates/times, we will sort out schedules on our ends.
Best
EFTA00029724

=== Page 3 ===
Parvin
From:
Sent: Saturday, August 17, 2019 1:59 PM
To: Moyne, Parvin
is
>;
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
EXTERNAL Email
Parvin,
We received the index, thank you. In terms of a proffer, what generally did you have in mind regarding timing? I think
we'd like to have some time with the subpoena returns to get familiarized, and our team has a combination of travel and
trials in the next couple weeks, but we could do early September if that works on your end. Thoughts?
thanks,
From: Moyne, Parvin
Sent: Thursday, August 15, 2019 09:48
To:
is
)
V.
Cc: Moyer, Thomas
Subject: 2019.8.15 - SDNY Production Index.xlsx
&
Please find attached an index to our productions to date. This is a work in progress - we will update it as we gather and
produce additional documents.
Would you like to touch base later today about scheduling a proffer? We are free after 4 p.m.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
One Bryant Park
New York, NY 10036-6745
USA
Direct: +1
I
Internal:
Fax: +1
akingump.com
Bio
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
EFTA00029725

=== Page 4 ===
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
EFTA00029726


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=== Page 1 ===
From:
"
)"
To:
"
(USANYS)"
Cc:
"
(USANYS)"
)"
=
Bcc: "USAHUB-USAJournal111"
Subject: Re: Epstein SW returns
Date: Mon, 12 Oct 2020 17:06:09 +0000
Embedded: Re:_Epstein_SW_returns.msg
Sender:
Subject: Re: Epstein SW returns
Message-Id: <CD93C5FE-429C-49C4-A55C-5884DFE3EFA2@usa.doj.gov>
To:
Cc:
Cc:
EFTA00030599


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=== Page 1 ===
From: Bruce Barket
To: "Sumar, Al-Amyn"
Aida Leisenring"
, Alexander Klein
"Donna Aldea"
Cc: David McCraw
Subject: RE: US V. Tartaglione, 16-cr-832 - Unsealing of Records
Date: Tue, 10 Sep 2019 20:52:10 +0000
Received. Thank you.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments
From: Sumar, Al-Amyn
Sent: Tuesday, September 10, 2019 4:46 PM
To:
Bruce Barket; b
Aida Leisenring; Alexander Klein;
Donna
Aldea;
Cc: David McCraw
Subject: US V. Tartaglione, 16-cr-832 - Unsealing of Records
All,
Attached is a letter on behalf of the New York Times Company and reporter Ben Weiser regarding the above-
referenced case, which was sent to the Court today by fax.
Regards,
Al-Amyn Sumar
Legal Department
The New York Times Company
New York, NY 10018
EFTA00030707


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=== 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 18:16:22 +0000
Attachments: US_v_Ghislaine_Maxwell_Indictment.pdf; Ghislaine_Maxwell_Indictment_PR.pdf
Inline-Images: image001.png
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 OBA DOMINA JUSTITIA OF SOFFICE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
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.
EFTA00031526

=== 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.
EFTA00031527

=== 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.
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=== Page 1 ===
From:
To:
Subject: Fwd: United States V. Ghislaine Maxwell --
Date: Sun, 28 Nov 2021 15:28:16 +0000
Begin forwarded message:
From:
Date: November 28, 2021 at 9:59:10 AM EST
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>, USANYS-CRIMINAL
PARALEGALS <USANYS-CRIMINALPARALEGALS@usa.doj.gov>, USANYS-INVESTIGATORS
<USANYS-INVESTIGATORS@usa.doj.gov>
Cc:
Subject: United States V. Ghislaine Maxwell -
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors
will do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine
Maxwell sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her
accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
Cc:
(USANYS)"
Subject: Gail Collins on Epstein, Acosta and "everything that happens in this country winds up in the hands
of New York prosecutors"
Date: Fri, 18 Oct 2019 19:56:38 +0000
https://www.nytimes.com/2019/07/10/opinion/acosta-epstein.html?searchResultPosition=17
Trump Doesn't Know About Labor
Thank God we've got so many inept cabinet members.
By Gail Collins
July 10, 2019
So, did you enjoy the parade for the U.S. women's soccer team? People sure did seem happy. I believe this is partly
because the players are terrific and partly because many Americans are desperate to think about something other than
Donald Trump.
And, good Lord, his crack team of cabinet members. On Wednesday, Secretary of Labor Alex Acosta tried to hold back the
outrage that's been building since people learned that, as a federal prosecutor in South Florida, he had brokered a very
lenient punishment for Jeffrey Epstein, a rich guy who liked to have sex with underage girls.
Explanation: It was a good deal. You know how this administration feels about good deals.
"The Palm Beach state attorney's office was ready to let Epstein walk free," Acosta said in his calm, sort of toneless voice.
"Our prosecutors presented the ultimatum." Which was that Epstein, who had molested a parade of teenagers, some
only 14, had to serve at least a little jail time. The punishment Acosta wrangled with his alleged best possible efforts
involved 13 months in prison, during which Epstein was free to spend most days at his office as long as he slept overnight
in the clink.
The victims had no idea that might be the end of the story. The case is now in the hands of federal prosecutors in New
York who are going after Epstein on other sex-trafficking charges. (You may have noticed that over the last few years
virtually everything that happens in this country winds up in the hands of New York prosecutors.)
Do you think Acosta ever asked himself whether he could have fought harder? Nah. The problem was the victims, who
were too "scared and traumatized" to be good witnesses. Asked by reporters if he had any regrets, he just said that was "a
very hard question."
Have you heard anybody in the Trump administration apologize for anything? Well, there was the occasion the secretary
of health and human services said he was sorry he spent $400,000 of our tax dollars to fly around in specially chartered
planes. But that was a long time and a whole lot of bad behavior ago.
About Jeffrey Epstein. He sounds like one of the worst people imaginable, so we are, of course, stunned to hear he used
to be tight with our current chief executive. "Terrific guy," Trump said in an interview with New York magazine in 2002.
"He's a lot of fun to be with. It is even said that he likes beautiful women as much as I do, and many of them are on the
younger side."
The palship no longer exists. "I had a falling-out with him. I haven't spoken to him in 15 years. I was not a fan of his, that I
can tell you," said the president, who appears to have erased the lot-of-fun-to-be-with period.
EFTA00030071

=== Page 2 ===
Are you shocked by any of this? Hey, early in our acquaintanceship we learned Trump is a guy who bragged about being so
important he could get away with grabbing women by their private parts. Who was put into office thanks to Russian
manipulation of our election. Some days you just want to sigh and talk a lot about women's soccer.
Ever since the Epstein scandal arose, Trump has been defending Acosta, stressing what an "excellent" job he's doing. After
all, the president told reporters, "our economy is so good, our unemployment numbers are at record lows." You might
have thought he was under the impression the secretary of labor had something to do with boosting the economy. As
opposed to things like workplace safety and collecting job statistics.
And oh, yeah, human trafficking. Very embarrassing that Acosta is one of the people who's supposed to protect underage
women from being sold as sex slaves.
Hmm. Before this week, what do you think Donald Trump thought the Department of Labor did?
A) Something about delivering babies.
B) Something about getting good people to, you know, mow the lawn and stuff.
C) Something.
The president is oblivious, but otherwise almost nobody likes the job Acosta's been doing. People who care about workers
are naturally outraged that he's been trying to water down everything from mine safety regulations to the rules that
prohibit restaurant managers from grabbing a piece of the waiters' tips.
Trump insiders, of course, feel undermining workers' rights is supposed to be Acosta's mission. And they complain he's
been sort of inept at it. Mick Mulvaney, the Trump Acting Chief of Staff For Life, has been trying to take control. Recently,
Acosta's chief of staff was pushed out for a lack of, um, leadership. Or, as one former administration official told Politico,
"There are times when he goes completely loony."
You've got to be appalled by Acosta's failure to stand up for vulnerable children being lured into serving as sex playthings
for a man who truly does epitomize the concept of filthy rich.
But are you upset that Trump is too much of an ethical beanbag to get rid of him? The sad truth is that we're really
probably better off with cabinet members too inept to accomplish anything at all.
Cheer up. There's always soccer.
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From:
"
(USANYS)"
To:
(USANYS)"
Subject: Accepted: Meet on Epstein
Date: Tue, 17 Sep 2019 14:01:53 +0000
Importance: Normal
Attachments: unnamed
EFTA00031631


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=== Page 1 ===
From:
Subject: Accepted: Epstein pre-meet
Date: Sat, 06 Apr 2019 19:27:33 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From:
To:
Subject: RE: Law360; Dershowitz Can Pursue Bid To DQ Boies Schiller In Sex Case
Date: Wed, 19 Jun 2019 20:37:51 +0000
Importance: Normal
Yeah the other day I asked them too, and they said no - they said they'd let us know if they got any inquiries
From:
Sent: Wednesday, June 19, 2019 16:34
To:
Subject: FW: Law360; Dershowitz Can Pursue Bid To DQ Boies Schiller In Sex Case
By the way, I called
0 ask if he'd received any inquiries from reporters about this case in general, and he said no. He
said he'd confirm with
and
From:
Sent: Wednesday, June 19, 2019 4:30 PM
To:
Subject: Law360; Dershowitz Can Pursue Bid To DQ Boies Schiller In Sex Case
Dershowitz Can Pursue Bid To DQ Boies Schiller In
Sex Case
By Andrew Strickler
Share us on: By Andrew Strickler
Law360 (June 18, 2019, 6:13 PM EDT) -- The New York federal judge who initially refused to hear Alan Dershowitz's
request to disqualify Boies Schiller Flexner LLP from representing a woman accusing the prominent attorney and retired
Harvard Law School professor of sexually molesting her said on Monday that she would consider it.
In a brief order, U.S. District Judge Loretta A. Preska allowed Dershowitz's motion to be reinstated and said he could file a
28-page memo on his request.
The order comes a week after Judge Preska said she was removing the motion because Dershowitz didn't request a
premotion conference before the filing in violation of a court rule.
Dershowitz's accuser
has alleged that convicted billionaire sex offender Jeffrey Epstein "lent her out for
sex" to Dershowitz and that Dershowitz played a role as Epstein's attorney and friend in a human trafficking scheme
during the late 1990s and early 2000s involving dozens of underage girls.
In a July 7 motion, Dershowitz argued that Boies Schiller shouldn't be allowed to continue to represent
because
the firm has "severe" conflicts in the case.
Those stem from an offer made in 2015 by Boies Schiller partner Carlos Sires to represent Dershowitz after Giuffre alleged
EFTA00030155

=== Page 2 ===
in a separate Crime Victims Rights Act suit focused on Epstein's deal with prosecutors that she had sex with Dershowitz
and others.
Dershowitz said in his motion he didn't learn Boies Schiller was representing his accuser in the current case until after he
shared with Sires a "highly confidential" memo spelling out his legal strategy in the case. The next day, Sires informed
Dershowitz that a client conflict was going to prevent him from representing Dershowitz.
Last week, Boies Schiller submitted a letter to the court stating that Dershowitz hadn't complied with the premotion
conference rule; Judge Preska agreed and ordered his filing "marked off the calendar."
"Professor Dershowitz is gratified that the court will consider the motion on its merits," said Dershowitz counsel Arthur L.
Aidala and Imran H. Ansari in a statement Tuesday.
Giuffre counsel Joshua Schiller of Boies Schiller submitted a letter to Judge Preska on Monday urging her to deny the
disqualification request without further briefing.
Dershowitz filed the "tactical" motion months into the suit despite having known for some five years that the firm
represents
Schiller said. Moreover, Dershowitz's brief contact with Sires never resulted in the formation of an
attorney-client relationship.
"Even though he knew that BSF's conflict check had not been completed, Dershowitz copied Mr. Sires into a group e-mail
attaching a memorandum, which Dershowitz now claims was confidential," Schiller wrote, adding that the memo was
addressed to Dershowitz's "friends" and contained no confidential information.
"This is an attempt to manufacture a conflict and delay the case and prevent our client from working with the counsel
she's worked with for five years," Schiller told Law360.
Dershowitz's ties to the Epstein scandal were back in the news after a February ruling by U.S. District Judge Kenneth A.
Marra, who found current Labor Secretary Alex Acosta had been among several prosecutors who mishandled a decade-
old sex crime case against Epstein when they signed a nonprosecution agreement with Epstein without notifying his
victims.
Giuffre is represented by Joshua Schiller and Sigrid McCawley of Boies Schiller Flexner LLP.
Dershowitz is represented by Imran H. Ansari and Arthur L. Aidala of Aidala Bertuna & Kamins PC.
The case is
V. Dershowitz, case number 1:19-cv-03377, in the U.S. District Court for the Southern District of New
York.
Public Affairs
United States Department of Justice
U.S. Attorney's Office Southern District of New York
Press Office: (212) 637-1020
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=== Page 1 ===
From:
To:
Subject: Final Voucher 11063042(1) has received final approval
Date: Fri, 21 Feb 2020 19:50:33 +0000
Importance: Normal
Dear
Final voucher 11063042(1) has received final approval.
Trip ID: 11063042
Voucher ID: 1
Voucher type: Final
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R20NYS13403 - Epstein Investigation - Witness interview
Destination: Pensacola, FL, United States
Dates: 2020-02-19 - 2020-02-20
Current status: Voucher Awaiting Payment
Voucher total expenses: 628.07
Estimated trip cost: 973.89
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# V0008
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.
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=== Page 1 ===
H
SICHTVERMERKE / VISAS / VISAS
CONTROL MALAGA
ENTRADA
2.
19 1 OCT. 1982
FRONTERAS
D
DIRECCION SEG. ESTADO
crimizea 28 2 NATIONALE DE MAI FRANCE GAULLE 1982 i
POLICE NATIONALE
CHARLES-DE-GAULLE 2
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1 8 JUIN 1982
A 237 FRANCE
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of GAULLE 1
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24 OCT. 1983
E 185 FRANCE
9


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From:
To:
Cc:
Subject: RE: Epstein's attorney?
Date: Wed, 10 Jul 2019 06:23:56 +0000
Importance: Normal
I'm really sorry, this totally slipped through the cracks yesterday (and just seeing it now since I'm digging out from under
the avalanche of emails) - you probably have it by now, but just in case not, the three attorneys who have appeared for
him are:
Martin Weinberg
Reid Weingarten
Marc Fernich
From:
Sent: Monday, July 08, 2019 13:13
To:
Cc:
Subject: Epstein's attorney?
Do you have his attorney info?
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
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=== Page 1 ===
From:
To:
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: FW: Question re SDFL Epstein file
Date: Mon, 22 Feb 2021 14:41:21 +0000
Embedded: FW:_Question_re_SDFL_Epstein_file.msg
Sender:
Subject: FW: Question re SDFL Epstein file
Message-Id:
<SN5P110MB0526BAB9A2E212F819F5EEC784819@SN5P110MB0526.NAMP110.PROD.OUTLOOK.COM
>
To:
Cc:
Cc:
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=== Page 1 ===
From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:23:52 +0000
Inline-Images: image001.png
Congratulations! I'm very proud of you 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
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.
EFTA00031870

=== 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.
EFTA00031871

=== 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.
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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Epstein search materials for upload and privilege review
Date: Wed, 12 Feb 2020 18:03:38 +0000
wanted to follow up on this - is the data fully uploaded, or did it get delayed? Thanks.
From:
Sent: Friday, February 07, 2020 11:25
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
Great, thank you!
From:
Sent: Friday, February 07, 2020 09:34
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
The data should be ready by Monday morning.
From:
Sent: Tuesday, February 4, 2020 6:58 PM
To:
Cc:
is
is
)
Subject: RE: Epstein search materials for upload and privilege review
Wanted to quickly check the status of the below - it's only been a couple weeks, so totally understand it may not be
complete, but hopefully we're getting close? If you could please check with the vendor and let us know, we'd be grateful
- and we'll plan to get it to
asap once we have access.
thanks,
From:
Sent: Tuesday, January 21, 2020 18:50
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
EFTA00029758

=== Page 2 ===
We've received a hard drive from FBI CART, which they've processed from devices seized and searched in connection with
the Epstein case. Can we please get those materials uploaded to Relativity, for privilege review by
(copied here)? I've
left the hard drive with the materials on your chair. (And if we could please get that hard drive back once the materials
are uploaded, the FBI has another batch they want to transmit to us for the same process, so that will also be coming
shortly.)
And then
these will be subject to just the exact same privilege review you previously ran in connection with Epstein
search warrant returns.
Please let us know if any questions or issues at all? And thanks very much as always.
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=== Page 1 ===
From:
(USANYS)"
To: Christian Everdell
)"
Cc: "Mark S. Cohen"
'BOBBI C STERNHEIM'
>, Jeff Pagliuca
>, , Laura Menninger
Subject: RE: Bill of Particulars Request
Date: Sun, 10 Jan 2021 22:00:31 +0000
Attachments: 2021-01-10_Letter_Response_to_GM_Request_for_Bill_of_Particulars_(final).pdf
Inline-Images: image001.jpg; image002.jpg
Counsel,
Please see attached.
Best,
From: Christian Everdell
Sent: Monday, December 28, 2020 9:58 AM
To:
)
is
is
(USANYS)
Cc: Mark S. Cohen
>; 'BOBBI C STERNHEIM'
>; Jeff Pagliuca
>; Laura Menninger
Subject: Bill of Particulars Request
and
-
,
I hope you all had a good holiday. Please see attached a request for a Bill of Particulars.
Regards,
Chris
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
view bio
www.cohengresser.com
New York Paris Washington DC London
CG
EFTA00030941

=== Page 2 ===
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PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
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=== Page 1 ===
Event: Accepted: Epstein pre-meet
Start Date: 2019-04-08 13:30:00 +0000
End Date: 2019-04-08 14:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-04-06 19:33:40 +0000
Date Modified: 2019-04-06 19:33:40 +0000
Priority: 5
DTSTAMP: 2019-04-06 18:28:16 +0000
Attendee:
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From:
)"
To:
(NY) (FBI)"
Subject: RE: Epstein search warrant documents
Date: Sun, 23 Feb 2020 04:06:32 +0000
He
yeah, I was in Florida on Wednesday and Thursday, thanks for checking in on this. It hasn't been resolved (and
I didn't hear back from
all week), so I'm going to send an email suggesting we all get together to talk it through. Just
yesterday we got access to the latest document dump, and it's over a million files, and we have no idea where they came
from, so we definitely want to nail it down. We're all in L.A. most of this week, but the week after should be around
(which will also provide time for people to figure out schedules).
thanks as always,
From:
(NY) (FBI)
Sent: Wednesday, February 19, 2020 16:27
To:
Subject: RE: Epstein search warrant documents
I reached out to your office line, let me know if we need to discuss. Has this issue been resolved?
From:
)
[mailto:
Sent: Monday, February 17, 2020 12:59 PM
To:
(NY) (FBI)
Subject: FW: Epstein search warrant documents
see below - just wanted to loop you into this too, since we've previously talked about the search warrant returns.
We are now finally starting to get a significant amount into the system, but the problem is we have no idea what it is,
where it's from, etc. We're just getting huge amounts of documents, but don't know what device they came from, room,
any identifying info, etc etc. So working on getting that.
Currently, both
have access on Relativity to a little over 20,000 documents from the Manhattan
residence, and I expect that will go up substantially in the next week or so once we get this next set of materials reviewed
for privilege.
Happy to chat if that'd be useful, and thanks as always.
From:
Sent: Saturday, February 15, 2020 16:30
To
(NY) (FBI)
is
(NY) (FBI)
C
(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
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=== Page 2 ===
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.
Assistant U.S. Attorney
Southern District of New York
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From:
)"
To:
Subject: RE: epstein
Date: Wed, 10 Jul 2019 02:17:48 +0000
Importance: Normal
Daily Beast is *all over* this story
From:
Sent: Tuesday, July 09, 2019 17:54
To:
Subject: Re: epstein
Fascinating article, not sure if I sent earlier:
https://www.thedailybeast.com/jeffrey-epsteins-sick-story-played-out-for-years-in-plain-sight
Sent from my iPhone
On Jul 9, 2019, at 10:09 AM, Biase, Nicholas (USANYS)
wrote:
https://www.thedailybeast.com/jeffrey-epstein-shouldnt-expect-to-wiggle-free-again-with-sdny-sex-trafficking-charges
From:
Sent: Tuesday, July 9, 2019 9:43 AM
To:
Subject: Fwd: epstein
The other one was from the second conference; this is from the first one
Sent from my iPhone
Begin forwarded message:
From: Goretti Moya <gmoya@sdreporters.com>
Date: July 8, 2019 at 17:12:36 EDT
To:
=
>,
i
Subject: epstein
Please e-mail when youg et this
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=== Page 1 ===
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=== Page 1 ===
Event: Call with Osborn (Epstein)
Start Date: 2019-10-31 19:00:00 +0000
End Date: 2019-10-31 19:30:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2019-11-01 04:43:28 +0000
Date Modified: 2019-11-01 04:43:28 +0000
Priority: 5
DTSTAMP: 2019-10-31 13:41:20 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00031405


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From:
To:
Subject: FW: US V. Jeffrey Epstein / 2018R01618 / Docket: 19-CR-00490
Date: Fri, 12 Jul 2019 17:24:57 +0000
Importance: Normal
They (she) knows. I sent this to all three just in case.
From:
Sent: Friday, July 12, 2019 1:23 PM
To:
Cc:
Subject: US V. Jeffrey Epstein / 2018R01618 / Docket: 19-CR-00490
The above captioned case has been indicted by the USAO in SDNY and is pending in Federal District Court Southern
District of New York. All notifications will be going out to the victims from the USAO SDNY. If you require a copy of the
Attorney General Guidelines in which it specifically notes when the USAO sends out notifications I can provide it.
Regards,
Victim Witness Coordinator
United States Attorney's Office
Southern District of New York
1 St. Andrews Plaza
New York, New York 10007
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=== Page 1 ===
From:
)"
To:
Cc:
(USANYS)"
Subject: Laptop for Ghislaine Maxwell (Reg. No. 02879-509)
Date: Mon, 16 Nov 2020 18:58:05 +0000
Attachments: 2020-11-17_GM_letter_to_MDC_re_laptop.pdf
Good afternoon,
I am planning to bring a laptop and charger for inmate Ghislaine Maxwell (Reg. No. 02879-509) to use when reviewing
discovery produced from my office. Attached please find the accompanying cover letter, which I will hand deliver with the
laptop. I am available to make this delivery tomorrow. Would you please let me know what time I should arrive with the
laptop?
My understanding from
is that I should bring the laptop to the East Building, located on 29th Street near
3rd Avenue and that I should go to the front lobby and ask for
who will then come and retrieve the laptop.
Please let me know if that is correct, or if I should take any different steps.
As always, I can be reached on my cellphone at
with any questions or concerns.
Thank you,
Maurene
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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From:
"
)"
To:
)"
)"
Subject:
counsel call
Date: Mon, 08 Jul 2019 02:20:24 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: updates
Date: Fri, 30 Aug 2019 18:37:46 +0000
Also, thank you for putting this together!
From:
Sent: Friday, August 30, 2019 2:07 PM
To:
(USANYS)
Cc:
(USANYS)
is
)
Subject: updates
Below is a summary update you requested regarding the investigation of co-conspirators. This does not include everything
the team is working on (for example, we have a list of legal research issues we are working through as we canvas charging
theories), and we're assuming familiarity with our recent memorandum regarding potential co-conspirators. Please let us
know if you need any additional information.
On August 27th, the team met separately with
and
and
are Victim-2 and
Victim-3 in the Indictment. During the meetings,
and
both conveyed that they are willing to cooperate
in an ongoing investigation.
and
have previously described
as the individual through whom
they scheduled all of their encounters with Epstein.
On August 27th, the team met with
,
who reported being sexually assaulted at several of
Epstein's properties while she was an adult.
described being recruited to perform massages for Epstein by
Ghislaine Maxwell.
indicated that she would cooperate with our ongoing investigation.
On August 27th, the team interviewed
who described being recruited by Ghislaine Maxwell
and caused to engage in sexualized massage sessions with Epstein, during which she was sexually assaulted.
These assaults occurred in London, Florida, the USVI, and New York, beginning when
was 17 and
continuing into her early twenties. These incidents occurred in the 1990s, before the sex trafficking statutes were
enacted.
indicated that she would cooperate with our ongoing investigation.
On August 27th, the team met with
who has previously been interviewed and has described being
sexually assaulted by Epstein at several of his properties when she was 17.
has reported that
was present during one of these encounters.
has indicated that she will cooperate with our ongoing
investigation.
On August 29th, the team met with
and
who have each
reported being sexually abused by Epstein while they were adults. We are in the process of scheduling an
interview with
, who has accused Ghislaine Maxwell of being involved in her abuse. We anticipate that
the interview will occur by videoconference, likely during the next two weeks.
Next week, the team hopes to travel to Florida for two meetings, subject to weather issues arising from
Hurricane Dorian. First, we hope to meet with
(
)
for a second proffer.
worked as an
assistant to Epstein in 2004, reporting to
Her duties included scheduling two to three "massages"
for Epstein each day he was in Florida. Second, we hope to meet with
for a reverse proffer. When
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=== Page 2 ===
was 16, Epstein proposed that she recruit girls for him, and
brought her young friends to Epstein
for "massages" for several years.
was granted immunity by SDFL and provided grand jury testimony, and
we hope to pursue
as a witness in this case. Our understanding is that
coordinated appointments
for the victims through
On September 6th, we are scheduled to meet with
defense counsel for an attorney proffer.
On September 9th, we are scheduled to interview
by videoconference.
has
accused Ghislaine Maxwell of recruiting her when she was 16.
On September 16th, we are scheduled to interview
,
who worked as Epstein's "house man" in
New York for many years. To our knowledge,
has never been interviewed before.
During the week of September 16th, the team hopes to travel to California for several meetings. We hope to
meet with
a victim who is described in our previous memorandum regarding co-conspirators.
We have previously interviewed
, and we hope to discuss whether
is willing to cooperate with
our ongoing investigation. While we are in California, we also hope to schedule follow-up interviews with
and
described above.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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From:
To:
Cc:
Subject: White Plains GJ Motion
Date: Wed, 03 Feb 2021 01:20:51 +0000
Attachments: !Memo_of_Law_ISO_Motion_to_Dismiss_Indictment_As_Obtained_In_Violation_of_Sixth
_Amendment.pdf
Hi
Ghislaine Maxwell recently filed the attached motion to dismiss the indictment in her case because it was returned by a
grand jury sitting in White Plains. Case is United States V. Maxwell, 20 Cr. 330 (AJN), and our opposition brief is due
2/26/21
Thanks,
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Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 1 of 7
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
THE NEW YORK TIMES COMPANY,
Plaintiff,
No. 20-CV-833(PAE)
V.
FEDERAL BUREAU OF PRISONS,
Defendant.
SUPPLEMENTAL DECLARATION OF RUSSELL CAPONE
I, Russell Capone, hereby declare as follows:
1.
I am Counsel to the Acting United States Attorney for the Southern District of
New York ("USAO-SDNY"). My prior declaration in this matter dated August 5, 2020, details
my service in this capacity and prior service in the USAO-SDNY. As noted therein, I am familiar
with the Freedom of Information Act requests filed by the New York Times Company (the
"FOIA Requests") that are the subject of this case, which seek records related to the
incarceration of Jeffrey Epstein at the Metropolitan Correctional Center ("MCC"). I am also
familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP") has
withheld in whole or in part pursuant to various FOIA exemptions, including BOP's
withholdings from the records provided back to BOP by the Office of the Inspector General of
the Department of Justice ("OIG") since the submission of my August 5, 2020, declaration.
2.
The statements contained in this declaration are based on my personal
knowledge, documents maintained in the files of the USAO-SDNY, conversations with members
of the Noel and Tartaglione prosecution teams at the USAO-SDNY, public court filings, and
conclusions made in accordance therewith.
1
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=== Page 2 ===
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 2 of 7
3.
I submit this declaration in further support of BOP's motion for summary
judgment in this case. Specifically, this declaration addresses the bases for the withholding in
whole or in part of certain records provided back to BOP by OIG pursuant to FOIA Exemption
7(A).
Records Withheld in Full or in Part from Disclosure Pursuant to FOIA Exemption 7(A) on
Account of Likely Interference with Noel
4.
5 U.S.C. § 522 (b)(7)(A) ("Exemption 7(A)") exempts from disclosure "records
or information compiled for law enforcement purposes, but only to the extent that the production
of such law enforcement records or information
could reasonably be expected to interfere
with enforcement proceedings
"
5.
I and the prosecutors responsible for the Noel prosecution have reviewed each of
the records provided back to BOP by OIG that BOP withheld in full or in part under Exemption
7(A) (the "7(A) Returned Records"), including those reflected as withheld in full at Entries 55-
57 and 60 on the updated index attached to the Supplemental Declaration of Kara Christenson
(the "updated BOP index"). The 7(A) Returned Records fall into four categories: documents
related to counts of inmates, staffing records, psychology records, and entries on certain BOP
logs for August 9 and 10, 2019. Each of these categories fall within the scope of Exemption
7(A).
6.
Public disclosure of the 7(A) Returned Records could reasonably be expected to
interfere with the pending Noel prosecutions. These records include information about which
numerous witnesses are expected to testify at trial, details that are not publicly known or known
to other witnesses, and information and documents prepared by potential trial witnesses. These
records also include potential trial exhibits, which some or all potential trial witnesses have not
seen. Premature disclosure of these records and/or the information contained therein could
2
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=== Page 3 ===
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 3 of 7
reasonably be expected to influence witnesses' potential testimony at trial and/or enable
witnesses to alter or shape their testimony to conform to other evidence.
7.
Further, premature public disclosure of any of the 7(A) Returned Records could
reasonably be expected to impair the government's (and the defendants') ability to seat a fair and
impartial jury in Noel. The government anticipates that some of these records will be entered
into evidence as exhibits at trial, and other records that may not be trial exhibits bear on the
contents of potential trial exhibits. Premature disclosure of these records and/or the information
contained therein could influence potential jurors' understanding of the evidence at trial and the
case overall. Similarly, premature disclosure of the records and/or the information contained
therein could prejudice potential jurors for or against the defendants in the Noel action, which
would also impair the government's (and the defendants') ability to seat a fair and impartial jury.
In addition, as noted above, these records include specific information about which witnesses are
expected to testify at trial, as well as information and documents prepared by potential trial
witnesses, such that premature public disclosure could reasonably be expected to influence
potential jurors' perception of the witnesses and the evidence to be presented at trial.
8.
The risks of interference with the Noel proceedings are heightened by the media
coverage of speculation and theories about Epstein's death. Many publicly-discussed theories of
Epstein's death are unfounded. Premature release of the withheld records, particularly if the
records are released in part or without full context, may influence the perception of jurors who
have been exposed to such media coverage of speculation and theories.
9.
The considerations discussed above apply to each of the categories of 7(A)
Returned Records.
10.
First, as discussed in my prior declaration, the government anticipates that
documents related to counts of inmates, including count slips, associated inmate rosters, and
3
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=== Page 4 ===
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 4 of 7
records of rounds and checks, for dates between and including July 23, 2019, and August 12,
2019, will be the subject of trial testimony at the Noel trial. 7(A) Returned Records containing
such documents are noted at Entry 55 of the updated BOP index. In addition, the government
anticipates that some of these documents will be trial exhibits. Releasing these materials
prematurely could reasonably be expected to influence witnesses' potential testimony at trial,
allow witnesses to alter or shape their testimony to conform to other evidence, identify potential
government witnesses at the Noel trial, and/or influence potential jurors' perceptions of witness
testimony or evidence.
11.
One subcategory of these documents are records from the Special Housing Unit
(the "SHU"), specifically rosters of inmates in the SHU on August 9 and 10, 2019, and SHU
records showing which BOP employees conducted rounds in the SHU. Although BOP had
previously withheld six pages of these records in full, included at Entries 22, 34 and 37 of the
prior index submitted by BOP, the prosecutors responsible for the Noel prosecution and I
determined that these records could be released in part without interfering with the Noel
prosecution, provided that information on these records showing details of the occupants of the
SHU on August 9 and 10, 2019, and which BOP employees conducted rounds in the SHU was
redacted. Releasing such information prematurely could reasonably be expected to influence
witnesses' potential testimony at trial, allow witnesses to alter or shape their testimony to
1
In reviewing the records returned to BOP by OIG, the prosecutors responsible for the Noel and
Tartaglione prosecutions and I determined that a one-page attorney visit room inventory log,
dated July 21, 2019, and an 18-page inmate census roster, dated August 9, 2019, each of which
BOP had previously withheld in full under Exemption 7(A), could be released without a
reasonable expectation of interference with the Noel or Tartaglione prosecutions. The attorney
visit room inventory log was previously listed at Entry 26 of BOP's index, and the census roster
was previously included among the count documents noted at Entry 24 of BOP's index.
4
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=== Page 5 ===
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 5 of 7
conform to other evidence, identify potential government witnesses at the Noel trial, and/or
influence potential jurors' perceptions of witness testimony or evidence.
12.
Second, as discussed in my prior declaration, the government anticipates that
MCC staffing records, including daily assignment rosters for the MCC on July 23, August 9, and
10, 2019, will be the subject of witness testimony at the Noel trial. 7(A) Returned Records
containing such documents are noted at Entry 56 of the updated BOP index. 2 In addition, the
government anticipates that some of these documents will be trial exhibits. Releasing these
materials prematurely could reasonably be expected to influence witnesses' potential testimony
at trial, allow witnesses to alter or shape their testimony to conform to other evidence, and/or
influence potential jurors' perceptions of witness testimony or evidence.
13.
Third, as discussed in my prior declaration, the government anticipates that
certain psychological notes and records of Epstein prepared by BOP may be trial exhibits, the
subject of witness testimony, and/or were prepared by witnesses who will testify at trial. 7(A)
Returned Records containing such documents are noted at Entry 57 of the updated BOP index.
Premature disclosure of these records could influence the testimony of potential witnesses,
including by potentially causing them to alter or shape their testimony to conform to other
evidence. In addition, premature disclosure of these records could reasonably be expected to
prejudice potential jurors for or against the defendants in the Noel action, which would impair
the government's (and the defendants') ability to seat a fair and impartial jury.
14.
Fourth, as discussed in my prior declaration, the government anticipates that
entries in certain BOP logs for August 9 and 10, 2019, may be trial exhibits, the subject of
2 The daily assignment rosters included in the 7(A) Returned Records appear identical to the
daily assignment rosters BOP previously located and withheld in response to the FOIA Requests,
except that they contain a different date stamp, which I understand to indicate when they were
electronically generated.
5
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=== Page 6 ===
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 6 of 7
witness testimony, and/or were prepared by witnesses who will testify at trial. 7(A) Returned
Records containing such documents are noted at Entry 60 of the updated BOP index. Premature
disclosure of these materials could reasonably be expected to influence witnesses' potential
testimony at trial, allow witnesses to alter their testimony to conform to other evidence, and/or
influence potential jurors' perceptions of witness testimony or evidence.
7(A) Returned Records Withheld in Part from Disclosure Pursuant to Exemption 7(A) on
Account of Likely Interference with Tartaglione
15.
The release of portions of two 7(A) Returned Records could also be reasonably
expected to interfere with the Tartaglione prosecution. First, portions of psychological records,
withheld in full as noted at Entry 57 of the updated BOP index, concerning the circumstances of
Epstein's apparent suicide attempt on July 23, 2019, could reasonably be expected to interfere
with the prosecution of Tartaglione. Second, premature release of one of the entries in a
lieutenant's log dated July 23, 2019, concerning the circumstances of Epstein's apparent suicide
attempt on that date, could reasonably be expected to interfere with the prosecution of
Tartaglione.
16.
As discussed in my prior declaration, Tartaglione's interactions with Epstein in
July 2019 have been placed at issue by Tartaglione's defense counsel, specifically in connection
with the potential penalty phase of the case against Tartaglione. See Letter dated January 13,
2010, Dkt. No. 186, United States V. Tartaglione, No. 16 Cr. 832 (KMK); Letter dated January
21, 2020, Dkt. No. 193, United States V. Tartaglione, No. 16 Cr. 832 (KMK). In light of defense
counsel's position, the information contained in the psychological records and in the entry in the
lieutenant's log may be relevant evidence in any possible penalty phase of the case against
Tartaglione. In that event, premature release of the information could reasonably be expected to
6
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=== Page 7 ===
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 7 of 7
adversely affect the Tartaglione proceedings and influence potential jurors' perceptions of
Tartaglione, thereby impairing the district court's ability to seat a fair and impartial jury.
Segregability
17.
The 7(A) Returned Records withheld in full are exempt from disclosure in their
entirety under Exemption 7(A). To the extent the records contain any non-exempt information,
such information is inextricably intertwined with information that could reasonably be expected
to interfere with the Noel prosecution for the reasons discussed above. As noted in my previous
declaration, the media coverage of speculation and theories about Epstein's death makes the
segregation of any possibly non-exempt information particularly difficult because providing
information pertaining to Epstein without complete context risks contributing to the
dissemination of speculation and theories about his death. This, in turn, could reasonably be
expected to interfere with the district court's ability to seat a fair and impartial jury in Noel, for
the reasons discussed above.
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true
and correct to the best of my knowledge and belief.
Executed this 15 day of January 2021.
Russell 6m
Russell Capone
Counsel to the Acting United States Attorney
United States Attorney's Office for the
Southern District of New York
7
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=== Page 1 ===
From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:24:16 +0000
Inline-Images: image001.png
Congratulations! I'm very proud of you 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
UNITED QUI PRO DOMINA OF JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
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.
EFTA00031479

=== 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.
EFTA00031480

=== 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.
EFTA00031481


c1: EFTA00030361
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030361.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 17:33:43 +0000
Inline-Images: image001.png
Great work!
From:
Sent: Thursday, July 02, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI ORAL 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.
EFTA00030361

=== 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.
EFTA00030362

=== 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.
EFTA00030363


c1: EFTA00030417
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030417.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
)"
(USANYS)"
Cc:
)"
Subject: RE: Maxwell Call
Date: Tue, 01 Dec 2020 22:01:55 +0000
Attachments: 020-12-01_GM_letter_regarding_defense_request_re_MDC_warden_v1.ebd.rd.docx
Thanks
,
our combined edits are attached. Thanks very much.
From:
(USANYS)
Sent: Tuesday, December 1, 2020 3:50 PM
To:
(USANYS)
is
is
(USANYS)
Cc:
Subject: RE: Maxwell Call
Chiefs - Bobbi and Chris have rejected our proposal. A draft letter (including language Bobbi sent us for the letter) and
affidavit are attached for your review. This is due today.
Thanks,
From:
(USANYS)
Sent: Monday, November 30, 2020 3:47 PM
To:
is
(USANYS)
is
(USANYS)
Cc:
Subject: RE: Maxwell Call
Ok, thanks
From:
Sent: Monday, November 30, 2020 2:52 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
)
Subject: RE: Maxwell Call
Thanks again for speaking with us earlier. I spoke with MDC legal, and they're fine with our proposal. They said they could
submit a letter to the Court by Friday. We'll let you know how our conversation with defense counsel goes-we haven't
scheduled a call with them just yet.
Thanks,
From:
(USANYS)
Sent: Monday, November 30, 2020 12:41 PM
To:
(USANYS)
EFTA00030417

=== Page 2 ===
Cc:
(USANYS)
is
>;
Subject: Re: Maxwell Call
Sure, do you mind circulating a dial in?
Sent from my iPhone
On Nov 30, 2020, at 12:33 PM,
(USANYS)
wrote:
Hi
Do you have a few minutes to speak about Maxwell? We spoke with BOP today and wanted to chat with you about next
steps as we owe a joint letter to the court tomorrow. Would 1 pm work?
Thanks!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
Tel:
EFTA00030418


c1: EFTA00030865
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030865.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Subject: relativity
Date: Wed, 10 Mar 2021 01:42:53 +0000
Attachments: 2007-03-
02 SUBPOENA_TO_TESTIFY_BEFORE_GRAND_JURY_PERTAINING_TO
The attached doc had no tags, but was marked potential Brady. That looks like an error, but in an abundance of caution,
before I switch the tag to work product, let me know if I'm missing something.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00030865


c1: EFTA00031257
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031257.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Subject: RE: Paul Kane Q&A
Date: Mon, 29 Nov 2021 06:06:27 +0000
Attachments: Kane_Q&A_v2.docx
Hey
I know you have a million other things going on, but I thought you might want to glance over the Paul Kane Q&A again at
some point, since he's going after Besselsen, who's going after Matt.
Thanks!
From:
Sent: Sunday, November 14, 2021 12:54 PM
To:
Subject: RE: Paul Kane Q&A
Great-two main comments:
1. A lot of questions about record keeping practices are about present practices, but I would guess things may have
been different in 1997, so you'll want to navigate that in your meeting with him and adjust the questions
accordingly.
2. The closing questions (after the record is in evidence) ask the witness to read out loud on the open record the
identifying information for MV1, so you'll need to adjust those.
From:
)
Sent: Sunday, November 14, 2021 1:31 AM
To:
Subject: Paul Kane Q&A
Hey
Attached is a draft Paul Kane Q&A. There are a couple questions that may seem weird - basically, since PCS didn't create
this record, the questions are aimed at a line of Second Circuit cases holding that "Records maintained but not created by
a company may be admissible as business records of that company if witnesses testify that the records are integrated into
[the] company's records and relied upon in its day-to-day operations." United States V. Kuthuru, 665 F. App'x 34, 39 (2d Cir.
2016).
Let's chat about the other hearsay issue when you have a minute?
Thanks!
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00031257

=== Page 2 ===
EFTA00031258


c1: EFTA00031191
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031191.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
Shift-Day-Date: M/W Thursday, July 25, 2019
Beginning Count: 774
SHU: 71/5
Daily Sensitive Information:
M/W
I/M Epstein #76318-054 on Psych Obs. w/inmate companion
TIME
CHRONOLOGICAL EVENTS
BC
SHU
12:00 AM
Lieutenant
assumes duties as the Morning Watch
774
71/5
Operations Lieutenant. The fire alarm and sprinkler system are
nonoperational. Fire Watch in progress. PREA announcement
conducted via the Institution Public Address System and/or Radio.
Restraint Equipment Cage inventory conducted. All equipment
accounted for. Metal Detector checks conducted. All operative
w/the exception of Rear Gate/Facilities/R&D. Roof Check
completed. All secure. Temporary Chit Inventory: #1:2; #2:5; #3:5;
#4:6; #5:5; #6:0; Hosp:0
12:00 AM
Institution Count in progress
12:00 AM
NYPD Phone Check #1463
12:15 AM
Body Alarm testing in progress
12:26 AM
Body Alarm testing completed
12:30 AM
Watch Calls/Fire Watch cont.
12:33 AM
Good Verbal count announced
12:37 AM
Clear Institution count announced
774
71/5
3:00 AM
Institution Count in progress
3:33 AM
Good Verbal count announced
3:35 AM
Clear Institution count announced
774
71/5
4:45 AM
Town Driver exits inst.
5:00 AM
Institution Count in progress
5:36 AM
Good Verbal count announced
5:43 AM
Clear Institution count announced
774
71/5
8:00 AM
Relieved of duties by Lt.
as D/W Operations Lieutenant
774
71/5
STG International Terrorist phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty:
The following Inmate (s) were placed in Administrative Detention:
Name
Reg: Number
Reason
Unit
Time
AD Order
Ending Count: 774 SHU: 71; 10-South: 05; SHU OBS: 00;
Ops Lt.
Local Hosp: 00; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00
EFTA00031191

=== Page 2 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHIFT-DAY-DATE: D/W Thursday, July 25, 2019
Beginning Count: 774
SHU: 71/5
D/W
Daily Sensitive Information:
I/M
at Gold crest nursing facility w/USMS Guards.
I/M Epstein on Psych obs. w/inmate companion
8:00 AM
Lieutenant
assumes duties as the Day Watch Operations
774
71/5
Lieutenant. The fire alarm and pump system is inoperable at this
time. Fire Watch is in Progress. Unable to conduct PREA
announcement over the Institution Public Address System, due to,
system malfunction. Restraint Equipment Cage inventory conducted.
All equipment accounted for. Metal Detector checks conducted. All
operative w/the exception of Rear Gate. Roof Check completed. All
secure. Temporary Chit Inventory: #1:0; #2:5; #3:5; #4:6; #5:6;
#6:5; Hosp:0
Daily Hand Stamp : GPKJ/LEFT HAND
8:00 AM
NYPD Phone Check #2389
8:23 AM
Body Alarm Test Initiated.
8:30 AM
AM Census Conducted
8:48 AM
Body Alarm Testing Complete.
9:00 AM
Lock Down Census Count Begin
10:10 AM
Lock Down Census Count Complete
11:00 AM
Mainline Conducted
12:30 PM
PM Census Conducted
12:30 PM
I/M
but to Court
773
71/5
12:30 PM
I/M
but to L-Hosp
772
70/5
2:00 PM
I/M
return from L-Hosp.
773
71/5
1:05 PM
-2 I/M
771
71/5
1:30 PM
I/M
Placed in SHU
771
72/5
3:23 PM
-1 Bail Bond; I/M
770
72/5
3:34 PM
+1 court return; I/M
771
72/5
3:45 PM
Institutional lockdown for count.
771
72/5
4:00 PM
Relieved of duties by Lt.
as E/W Operations Lieutenant.
Visitation: 9 North
Inmates
Adults
Children
Total
23
32
7
62
ION SCANNING TESTED HITS: 0
STG/High Alert phone calls monitored:
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
Name
Reg Number
Reason
Unit
TIME
A/D Order
Possession of Cell Phone
KN
1:30 PM
YES
Ops Lt
Ending Count: 771 ; SHU: 72; 10-South: 05; SHU OBS: 00;
Act Lt
Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00
EFTA00031192

=== Page 3 ===
UNITED STATES DEPARTMENT OF JUSTICE
METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
DAILY LIEUTENANT'S LOG
SHIFT-DAY-DATE: E/W Thursday, July 25, 2019
Beginning Count: 771
SHU: 72/5
Daily Sensitive Information.
E/W
I/M
at Goldcrest nursing facility w/USMS Guards
I/M Epstein #76318-054 on Suicide Watch. w/inmate companion
TIME
CHRONOLOGICAL EVENTS
B/C
SHU
Lieutenant
assumes duties as the Evening Watch Operations
Lieutenant. The fire alarm and sprinkler system are inoperable Fire
Watch is in progress. Unable to conduct PREA announcement over the
4:00 PM
Institution Public Address System, due to, system malfunction.
771
72/5
Restraint Equipment Cage inventory conducted. All equipment
accounted for. Metal Detector checks conducted. All operative
w/the exception of Rear Gate. Roof Check completed. All secure.
Temporary Chit Inventory: #1:0; #2:0; #3:0; #4:0; #5:1; #6:0;
4:00 PM
Institution count in progress.
4:03 PM
NYPD Phone Check #1506
4:02 PM
Body Alarm testing in progress.
4:40 PM
Body alarm testing completed.
4:44 PM
Good verbal announced.
4:51 PM
Clear institutional count.
771
72/5
5:35 PM
-1 bail bond; I/M
770
72/5
6:00 PM
Watch call in progress
6:25 PM
3 I/M to special housing;
,
770
75/5
and
8:30 PM
Trash run in progress
9:25 PM
Trash run complete
10:00 PM
Institutional count in progress.
10:55 PM
Good verbal count announced.
10:56 PM
Clear institutional count announced.
770
75/5
12:00 AM
Relieved of duties by
M/W Lieutenant.
770
75/5
VISITING: 5 NORTH
INMATES
ADULTS
CHILDREN
TOTAL
27
28
18
73
STG/High Alert phone calls monitored: 10
WITSEC inquiry (s) was/were received during my tour of duty: 0
The following Inmate (s) were placed in Administrative Detention: 0
NAME
REG NUMBER
REASON
UNIT
TIME
A/D ORDER
108
GN
6:25 PM
Yes
108
GN
6:25 PM
Yes
108
GN
6:25 PM
Yes
Ops. Lt.
Ending Count: 770 ; SHU: 75; 10-South: 05; SHU OBS: 00;
Act. Lt.
Local Hosp: 01; H/A OBS: 01; B/A OBS: 00; Dry Cell: 00;
B/A SHU: 00
EFTA00031193


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c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030076.pdf
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c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
Subject: Call re: Epstein FOIA
Date: Thu, 11 Mar 2021 20:29:17 +0000
Importance: Normal
Attachments: unnamed
EFTA00030076


c1: EFTA00030981
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030981.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
Subject: FW: EMail 1 of 2: EPSTEIN
-
signed application/affidavit
Date: Thu, 29 Oct 2020 17:45:53 +0000
Attachments: 20_MAG_11668
pdf; 20_MAG_11668.1
pdf
Inline-Images: image003.jpg
Attached are the signed warrant materials.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From:
Sent: Thursday, October 29, 2020 11:51 AM
To:
Cc:
Subject: FW: EMail 1 of 2: EPSTEIN
,
signed application/affidavit
Good Morning
,
Your signed Warrants are attached.
COURT
Arraignment Unit Clerk
United States District Court
Southern District of New York
New York, NY 10007
DISTRICT
0
From:
Sent: Wednesday, October 28, 2020 7:18 PM
EFTA00030981

=== Page 2 ===
To:
Cc:
Subject: FW: EMail 1 of 2: EPSTEIN
signed application/affidavit
From:
Sent: Tuesday, October 27, 2020 7:18 PM
To:
Subject: EMail 1 of 2: EPSTEIN
signed application/affidavit
USDC-SDNY
Sent from my mobile device
EFTA00030982


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c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031627.pdf
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c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: FW: Epstein -- Release of USMS information
Date: Fri, 13 Sep 2019 18:07:39 +0000
Do you know what she's talking about?
From:
(USANYS)
Sent: Friday, September 13, 2019 2:01 PM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Epstein -- Release of USMS information
As you are undoubtedly aware, there has been some press coverage since yesterday about the release pursuant to FOIA of
some USMS records. I just spoke with the Associate General Counsel at the USMS, who wanted to provide us with the
actual source materials (USM 11s (equivalent of 302s)) that were inadvertently released, because they were not in all
circumstances accurately reported, and he wanted to make sure that if we are concerned about any harm to our
investigation from the release, that we have the original materials. He also offered to serve as a POC if we have any
questions.
Chief, Criminal Division
United States Attorney's Office, SDNY
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From:
To:
Subject: RE: Monday
Date: Mon, 16 Sep 2019 13:58:33 +0000
Thank you!
From:
Sent: Monday, September 16, 2019 9:54 AM
To:
Subject: RE: Monday
Sure, I can do it. If one of y'all gets the call when he arrives just let me know.
From:
Sent: Monday, September 16, 2019 09:52
To:
Subject: RE: Monday
Agree that this can definitely be one person.
if you wouldn't mind handling, that would be amazing. I'm trying to
get oppositions to suppression motions drafted in Tartaglione and would be grateful for the extra time.
From:
Sent: Monday, September 16, 2019 9:50 AM
To:
Subject: RE: Monday
I think this is probably eminently handle-able by one person, unless anybody disagrees?
I'm happy to join if
you'd like, or to just handle, or if you feel like doing it then I'm totally happy to defer (and l'll just continue to prep for
California interviews). Agree with
hat certainly in the first instance it's likely to involve getting a list of names and
not particularly credibility-heavy, such that we'd want a couple people to be able to weigh in on the info up the chain.
Thoughts?
From:
Sent: Monday, September 16, 2019 09:26
To:
Subject: RE: Monday
Sorry, this got lost in my inbox. No problem at all if you still need to skip this.
From:
Sent: Friday, September 13, 2019 4:13 PM
To:
Subject: Monday
Sorry to ask, but is it okay if I don't join you guys for Monday's interview with
I'm trying to find time to
meet with another case team, and it looks like Monday morning would work best for that.
EFTA00030711

=== Page 2 ===
was Epstein's long-time house manager in NY, but we don't know anything beyond that, so the purpose of the
interview is really just to identify other employees and see what if anything he saw at the house.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
From
To
Subject: Fwd: United States V. Ghislaine Maxwell
pens
Date: Mon, 29 Nov 2021 16:46:00 +0000
Begin forwarded message:
From:
Date: November 28, 2021 at 3:04:23 PM EST
To:
Subject: RE: United States V. Ghislaine Maxwell --
opens
I LOVE this email. Even though I've only been involved tangentially as you all have moved mountains to get to
this point, I feel more invested than usual in the work you are doing. Please let me know if there is any help,
no matter what day or time it is, that I'm able to provide as the battle continues. Always remember that even
unlimited resources can't buy facts or truth.
From:
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>; USANYS-CRIMINAL PARALEGALS <USANYS-
CRIMINALPARALEGALS@usa.doj.gov>; USANYS-INVESTIGATORS <USANYS-INVESTIGATORS@usa.doj.gov>
Subject: United States V. Ghislaine Maxwell --
opens
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors
will do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine
Maxwell sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her
accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
EFTA00031297

=== Page 2 ===
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From: Kate Tuckley <Kate.Tuckley@fca.org.uk>
To:
(USANYS)"
Cc: Mark Steward <Mark.Steward@fca.org.uk>
(USANYS)"
>, , Kelly
Eldred <Kelly.Eldred@fca.org.uk>, "Harry Caldecott" <Harry.Caldecott@fca.org.uk>
Subject: RE: Confidential & Urgent
Date: Thu, 28 Nov 2019 15:30:27 +0000
Great much appreciated thanks
From:
(USANYS) [mailto:
Sent: 28 November 2019 15:30
To: Kate Tuckley <Kate.Tuckley@fca.org.uk>
Cc: Mark Steward <Mark.Steward@fca.org.uk>; Cowley, Jason (USANYS) <Jason.Cowley@usdoj.gov>;
(USANYS)
>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Okay, please call my cell:
Sent from my iPhone
On Nov 28, 2019, at 10:25 AM, Kate Tuckley <Kate.Tuckley@fca.org.uk> wrote:
Hi
I have spoken to Mark's business support and he is available at 4.15pm (UK time) today (ie in just under
an hour's time). It is quite urgent so if we could speak then it would be greatly appreciated.
If that does work please let us know what number to call you on?
Many thanks
From:
(USANYS) [mailto:
Sent: 28 November 2019 14:53
To: Mark Steward <Mark.Steward@fca.org.uk>
Cc:
(USANYS)
>; ; Kate
Tuckley <Kate.Tuckley@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Hi Mark - Thanks for reaching out. We do have an active investigation and would be happy to talk. As you likely know,
today is a holiday in the US. Is this something we could discuss on Monday or is it more urgent than that? Thanks, Ted
Sent from my iPhone
On Nov 28, 2019, at 9:28 AM, Mark Steward <Mark.Steward@fca.org.uk> wrote:
EFTA00030649

=== Page 2 ===
Dear
,
Can I ask whether this is still an active matter ? if so, I wonder if we could speak
when it is convenient.
Cheers
Mark Steward
Executive Director
Enforcement and Market Oversight
<image001.png>
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
Follow us:
<image002.png>
<image003.png>
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
From:
Sent: 28 November 2019 14:25
To: Mark Steward <Mark.Steward@fca.org.uk>;
(USANYS)
>;
(USANYS)
Cc: Kate Tuckley <Kate.Tuckley@fca.org.uk>; Kelly Eldred <Kelly.Eldred@fca.org.uk>; Harry Caldecott
<Harry.Caldecott@fca.org.uk>
Subject: Re: Confidential & Urgent
Looping in
They run our
unit and oversee the Epstein case.
Sent from my iPhone
On Nov 28, 2019, at 8:30 AM, Mark Steward <Mark.Steward@fca.org.uk> wrote:
Hi
Can you let me know, urgently, whether anyone in your office is handling the investigation into Jeffery
Epstein, especially anything in relation to JP Morgan (he was a client of their private wealth division)
and, if so, who, as we need to have a chat. If this is not in SDNY, do you know who is handling
ongoing work into Mr E's world ?
Cheers
Mark Steward
Executive Director
Enforcement and Market Oversight
<image001.png>
12 Endeavour Square
London
E20 1JN
Tel: +44 (0)20 7066 1600
www.fca.org.uk
EFTA00030650

=== Page 3 ===
Follow us:
<image002.png>
<image003.png>
Private Secretary: Harry Caldecott (harry.caldecott@fca.org.uk)
Personal Assistant: Kelly Eldred (kelly.eldred@fca.org.uk)
This communication and any attachments may contain personal information. For more information about how and
why we use personal information and who to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have received this
email in error please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further
information on the classification and handling of FCA information can be found on the FCA website
(http://www.fca.org.uk/site-info/legal/fca-classified-information)
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how and
why we use personal information and who to contact with any queries about this, please see our privacy notices: FCA
Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-
privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish,
rely on or otherwise use it without our consent. Some of our communications may contain confidential information
which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error
please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further information on
the classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-
info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
EFTA00030651

=== Page 4 ===
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email
has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how and why
we use personal information and who to contact with any queries about this, please see our privacy notices: FCA Privacy
Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-privacy-and-
data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish,
rely on or otherwise use it without our consent. Some of our communications may contain confidential information
which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error
please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further information on the
classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-
info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment
Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email
has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623. Registered
office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
This communication and any attachments may contain personal information. For more information about how
and why we use personal information and who to contact with any queries about this, please see our privacy
notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice
(https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal
privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute,
publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential
information which it could be a criminal offence for you to disclose or use without authority. If you have
EFTA00030652

=== Page 5 ===
received this email in error please notify postmaster@fca.org.uk immediately and delete the email from your
computer. Further information on the classification and handling of FCA information can be found on the FCA
website (http://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the
Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all
email communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This
email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864.
Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)
EFTA00030653


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=== Page 1 ===
From:
To:
Subject:
Date: Sun, 18 Aug 2019 17:18:11 +0000
I requested from MCC a complete list of all commissary purchases that Epstein made.
Sent from mobile device, please excuse typos.
Special Agent
Office of the Inspector General
EFTA00031009


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=== Page 1 ===
From:
To:
Subject: RE: epstein
Date: Tue, 09 Jul 2019 13:56:35 +0000
Importance: Normal
THANKS!
From
Sent: Tuesday, July 9, 2019 9:43 AM
To:
Subject: Fwd: epstein
The other one was from the second conference; this is from the first one
Sent from my iPhone
Begin forwarded message:
From: Goretti Moya <gmoya@sdreporters.com>
Date: July 8, 2019 at 17:12:36 EDT
To:
=
:
i
: i
:
Subject: epstein
Please e-mail when youg et this
EFTA00030228


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=== Page 1 ===
From:
Cc:
Subject: Re: Automatic reply: Epstein update
Date: Sat, 10 Aug 2019 14:48:07 +0000
What's a good number to call you.
On Aug 10, 2019, at 10:43 AM,
wrote:
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,
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:
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,
wrote:
BOP just provided another update- Epstein has passed. I have no additional info. I will push out updates as we
receive.
EFTA00029735

=== Page 2 ===
From:
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:
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses
may be delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
at
or
EFTA00029736


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=== Page 1 ===
From:
Subject: RE: U.S. Department of Justice investigation
Date: Tue, 07 Jan 2020 16:28:09 +0000
Inline-Images: image001.jpg; image002.jpg
Could we possibly do 9 a.m. on Friday (given the time-zone and availability). I have a proffer starting at 10. If not, no
worries, happy for you guys to go ahead if that's easier.
From:
Sent: Tuesday, January 7, 2020 11:22 AM
To:
Subject: FW: U.S. Department of Justice investigation
I'm available all day on Friday.
From: Gary Bloxsome
Sent: Tuesday, January 7, 2020 11:20 AM
To:
Daniel Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email.
Please confirm whether you would be available for a preliminary telephone call on Friday 10th January 2020.
Kind regards.
Gary
Gary Bloxsome
Partner
RANKED IN
Chambers
LEGAL
UK
x
500
KINGDOM
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.
On 4 Jan 2020, at 01:38,
wrote:
EFTA00030698

=== Page 2 ===
External email: is it safe to open attachments and links?
Mr. Bloxsome,
Thank you for your response and for confirming your representation. To respond to your question generally, in
connection with our investigation of conduct relating to Jeffrey Epstein and certain of his associates, we wish to request
a consensual, voluntary law enforcement interview with your client. Generally, we would expect to inquire about his
relationship and communications with Jeffrey Epstein and his associates, as well as certain allegations that have arisen
publicly and in our investigation to date.
Although we recognize we separately have the ability to convey such a request through diplomatic and law enforcement
channels, we understand we may also alternatively inquire directly with counsel, when an individual has legal
representation. Given your representation, we are inquiring directly with counsel in the first instance.
Certainly we can discuss our request in more detail, but we hope this will provide the information you were seeking as a
threshold matter, and we look forward to being in touch.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Friday, January 03, 2020 10:30
To:
Cc:
Daniel Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Dear Sirs,
Thank you for your email dated 2 January 2020.
I confirm that we do represent HRH the Duke of York.
I would be grateful if you could please clarify what specifically you invite us to contact you about.
Kind regards
Gary Bloxsome
Gary Bloxsome
Partner
www.blackfords.com
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.
EFTA00030699

=== Page 3 ===
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.
On 2 Jan 2020, at 18:54,
wrote:
External email: is it safe to open attachments and links?
Mr. Bloxsome,
We are the federal prosecutors investigating conduct relating to Jeffrey Epstein, under the U.S. Department of Justice,
Southern District of New York. We have been advised that you currently represent HRH The Duke of York. Could you
please advise whether that is correct? We - my colleagues
and I - can be reached
anytime at these email addresses, or please let us know if you would prefer to set up a time to discuss via phone.
Regards,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
Subject: Re: OPR Epstein Final Report
Date: Fri, 29 Jan 2021 23:06:09 +0000
Sorry I was running late to relieve my in-laws. And sounds good - good luck with everything - I should be
around.
Sent from my iPhone
On Jan 29, 2021, at 6:01 PM,
wrote:
You logged off with record speed! I have more medical stuff Monday morning so I can't do that time unfortunately, but
given how much she loves you, I'd just be a third wheel anyways.
From:
Sent: Friday, January 29, 2021 5:59 PM
To
Subject: RE: OPR Epstein Final Report
Thanks, I think that should work. We will give you a call then.
From:
Sent: Friday, January 29, 2021 5:55 PM
To:
Cc:
Subject: RE: OPR Epstein Final Report
Of course. Why don't you call me
(
)
at your convenience around 9:30 am? If another time works better,
just let me know.
From:
Sent: Friday, January 29, 2021 5:33 PM
To:
Subject: Re: OPR Epstein Final Report
Hi
- I hope this finds you well. Do you have some time to connect early next week on this matter? If there's a good
time Monday morning, in particular, please let us know. Thanks,
Sent from my iPhone
On Nov 12, 2020, at 10:06 AM,
(OPR)
wrote:
Attached please find OPR's final Report in the Jeffrey Epstein matter, and a transmittal letter.
EFTA00031620

=== Page 2 ===
<OPR-#458587-v1-Epstein_Report_transmittal_to_SDNY_(letter_signed).PDF>
<OPR-#458557-v1-Epstein_Report_of_Investigation_and_Exhibits_pdf.PDF>
EFTA00031621


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=== Page 1 ===
From:
"
)"
To:
(USANYS) 8"
Subject: RE: Press Conference Advisory, Thursday, July 2, 2020, 12:00 p.m.
Date: Mon, 06 Jul 2020 17:08:03 +0000
This is now belated, but thank you - really appreciate it!
From:
(USANYS) 8
Sent: Thursday, July 02, 2020 10:57
To:
)
>;
>;
Subject: Fwd: Press Conference Advisory, Thursday, July 2, 2020, 12:00 p.m.
You are American heroes. Congratulations!
Sent from my iPhone
Begin forwarded message:
From: "Press-Office, SDNY (USANYS)"
Date: July 2, 2020 at 9:49:14 AM EDT
Subject: Press Conference Advisory, Thursday, July 2, 2020, 12:00 p.m.
<U.S. V. Ghislaine Maxwell Indictment.pdf>
EFTA00030377


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=== Page 1 ===
From:
To:
Subject: RE: Epstein victim call
Date: Wed, 10 Mar 2021 21:16:34 +0000
Hi
Thanks very much for letting us know. We'll check in with the FBI about this.
From:
Sent: Wednesday, March 10, 2021 4:13 PM
To:
is
Cc:
Subject: RE: Epstein victim call
Just FYI, got another call from Ms.
this afternoon, looking for a follow-up. We did not discuss anything
substantive, and I said I would pass along that she had called.
From:
Sent: Thursday, February 25, 2021 12:46
To:
is
Cc:
Subject: Epstein victim call
Team, I just received a call on my desk line from a woman named
who identified herself as a former
client of
and said she was a former victim of Jeffrey Epstein. I asked if her attorney had been in touch with
either the prosecutors or the case agents, since we had previously contacted him, and she said she believed he had not
been. She said she had been in touch with an NYPD detective but had not heard back in some time. She said
represented her for purposes of the Victim Fund, but was not currently representing her. She provided her cell phone as
She did not provide any substantive information on the call, and I did not ask for any. I advised that
someone would follow up with her, hopefully in the next week or so. The call lasted less than three minutes.
For context, we were in touch with Mr.
several times in 2020 when he claimed to represent at least nine Epstein
victims, all of which he said were unwilling to speak with us. He subsequently said one victim might be willing to speak
with us, but then stopped responding to our requests for the complaints he had purportedly filed (but which we couldn't
find online). I believe the last communication we had with him was the attached.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00029857


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=== Page 1 ===
From:
To:
Subject: Re: Hi There,
Date: Tue, 29 Apr 2014 16:37:32 +0000
Hi
Thank you for getting back to me on your day off!
I just remember when the tabloids sent their photographer out, they took note of the date on the back which was in 1997 and
possibly took a picture of it but as I do not want to contact the tabloids right now, I just need the evidence to ensure that is
correct. If you can, when you get back to the office, is there any chance you could have a look to see if there in fact a date
mentioned or photographed, it would be very helpful and I would be more than appreciative.
Have a nice day!!
On Tuesday, 29 April 2014 12:23 PM,
wrote:
Hi
I'm away from the office today. I don't recall the photo having a date on it but I will review the file when I get a chance.
From:
To:
Sent: Tue Apr 29 12:18:49 2014
Subject: Hi There,
G'day
I was just wondering if by chance you might have the original dates of the photos you copied from our original meetings, oddly
enough I have every other original photo but the one with Prince Andrew and that's no good as I am in need of just the date on
the picture. You're my last chance on these dates unless by good fortune this picture shows up. Sorry to be a pain, I hope I'm
not to much a bother. Just trying to do get something accomplished!
Hope all is well!!
All the best,
EFTA00030588


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: RE: printing project
Date: Mon, 12 Aug 2019 16:40:32 +0000
Yes please - it can be labeled on the front and side as:
Epstein Financial Documents
19 Cr. 490 (RMB)
thanks!
From:
(USANYS) [Contractor]
Sent: Monday, August 12, 2019 11:44
To:
Subject: RE: printing project
Would you like this labeled?
From:
Sent: Sunday, August 11, 2019 10:41 PM
To:
(USANYS) [Contractor]
Subject: printing project
Hey
could I please ask for your help with printing some documents? If I could please get the five docs in the
following folder:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\
printed single-sided, black and white, in a binder, that would be great. It's roughly 550 pages total, I think. And if I could
please get tabs with the following labels for each respective doc:
FBAR
No rush on this, if I could please get the binder by the end of the day Tuesday that's totally fine-and feel free to farm out,
too, if you're swamped. Thank you!
Assistant U.S. Attorney
Southern District of New York
EFTA00029732


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=== Page 1 ===
From:
To:
Subject: status memo draft
Date: Wed, 06 Mar 2019 02:22:10 +0000
Importance: Normal
Attachments: 2019-03-05,_JE,_status_memo_to_ODAG.docx
Thoughts? It's a little on the long side (chiefs said ~3 pages was fine) just due to the legal analysis, but they can always cut
that down. Anyway I've never done one of these in particular before so very happy for suggestions. Thanks!
EFTA00031319


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 404 Filed 11/02/21 Page 1 of 6
USDC SDNY
UNITED STATES DISTRICT COURT
DOCUMENT
SOUTHERN DISTRICT OF NEW YORK
ELECTRONICALLY FILED
DOC #:
DATE FILED: 11/2/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
As discussed at yesterday's conference, attached is the Court's draft preliminary remarks
to be recorded and played before each voir dire session. The parties may suggest any proposed
edits or additions by letter on or before November 8, 2021, or they shall indicate by that date that
they have no objections or suggestions.
so ORDERED.
Dated: November 2, 2021
Alin D. D.Nitto
New York, New York
ALISON J. NATHAN
United States District Judge
1
EFTA00030632

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 404 Filed 11/02/21 Page 2 of 6
Draft Pre-Voir Dire Remarks - November 2, 2021
1
United States V. Maxwell, 20cr330
2
Preliminary Remarks Prior to Voir Dire
3
To be recorded and played on 11/16-11/19
4
Introduction
5
Welcome back to the Southern District. Thank you again for your time and service. As I
6
mentioned in my remarks to you when you filled out the questionnaire, I'm Judge Nathan and I
7
am the judge who will preside over this case. The questionnaire you previously filled out was the
8
first step in the jury selection process. Today will be the second step. Some of you will be
9
excused today and will not have to return for this case, although you may be directed to go
10
through a similar process in another case. Others may be directed to return tomorrow if
11
necessary. And ultimately, some of you will return for the third and final step in the process.
12
That will take place on November 29. In any event, after you complete this step of the process
13
today, you will receive instructions on next steps that are particular to you.
14
As you know from my prior remarks to you and from the questionnaire, we're here today
15
to select a jury to serve in a criminal case, called the United States against Ghislaine Maxwell. As
16
you read in the questionnaire, the Indictment alleges that Ghislaine Maxwell conspired with and
17
aided and abetted Jeffrey Epstein to entice minor females to travel to engage in criminal sex
18
activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking
19
of a minor. Ms. Maxwell has pled not guilty to all charges. Ms. Maxwell is presumed innocent,
20
and before she can be found guilty on any charge, the jury must find that the Government has
21
proven each element of that crime beyond a reasonable doubt.
22
Thank you for participating in this process. The process of selecting a jury in a criminal
23
case is a critical part of our justice system. The purpose of this process is to select those jurors who
24
can be fair and impartial to both sides in this case. Some people find that they can be fair and
EFTA00030633

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 404 Filed 11/02/21 Page 3 of 6
1
impartial in one kind of case, but for various reasons, related to their own life experiences or views,
2
can't be fair in another kind of case. The process that we use is designed to help us figure out
3
whether you can be fair and impartial to both sides in this case.
4
If during the course of this process you come to believe that because of something that
5
you have experienced or because of something you've heard or read that you cannot be fair and
6
impartial-that is that you would favor either the Government or the Defendant regardless of
7
what the evidence shows-then you must tell me. It's not unusual, and there's no reason to be
8
embarrassed about it.
9
But the system only works if all of our citizens are willing and prepared to serve as jurors
10
when they can do so fairly and impartially. I do not expect that anybody would seek to avoid this
11
important duty for any but the most compelling reasons.
12
As I mentioned in my prior remarks, the Court has taken a number of steps to help ensure
13
the process for selected jurors is as safe and easy as possible. We have masking and distancing
14
protocols. We have reconfigured courtrooms to enhance safety measures. The Court will
15
provide transportation for selected jurors to and from the courthouse each day. Breakfast,
16
snacks, and lunch will be provided for you.
17
To conduct the next phase of the process, I will ask each of you some questions
18
individually. We'll do that in a separate courtroom where I and the lawyers and the Defendant
19
are sitting now. You all will be brought in the courtroom one at a time. Bear in mind that this is
20
a public courtroom. To protect your privacy, I will only refer to you by your juror number.
21
Please do not state any identifying information. For example, if we talk about your job you
22
could say that you are a sales clerk at a large retail store, without stating the specific name of
23
your employer. This is to protect your privacy. Even with those privacy protections in place, if
2
EFTA00030634

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 404 Filed 11/02/21 Page 4 of 6
1
there is something that would be too difficult or embarrassing for you to say on the public record,
2
please let me know. And please keep in mind that if you are selected as a juror, we will continue
3
to refer to you only by your juror number throughout the process.
4
Now, if you are selected as a juror, your job is going to be to listen to the evidence and to
5
my instructions on the law and to make a determination that's based only on the law. So I want to
6
speak to you generally about some things to keep in mind.
7
The first thing is, as Ms. Maxwell sits here now, she's presumed to be innocent. She is
8
presumed innocent until and only if the jury finds that she is guilty beyond a reasonable doubt.
9
As I just explained to you, she's been indicted for a number of crimes, but an indictment is just
10
an accusation. It is not evidence and it doesn't mean that Ms. Maxwell is guilty of anything. You
11
can't assume that she is guilty or more likely to be guilty just because she's been charged with
12
committing these crimes. That's the reason we have trials, to determine whether the Government
13
can prove a defendant's guilt beyond a reasonable doubt. A defendant in a criminal case does not
14
have to prove that she is not guilty. That means a defendant does not have to testify, or to put on
15
any evidence and a juror can't hold that against a defendant if she makes that choice.
16
The next thing is that as jurors you must follow the law as I give it to you, even if you
17
don't agree with it or if you think the law should be different.
18
You also have to base your verdict on the evidence, not on something that you've read in
19
the newspapers or the internet or seen on television or heard about on social media or in
20
discussions with friends, family, or colleagues. And you can't base your decision in this case on
21
something that you might have read or heard about another case.
22
As I said before, there is significant media interest in this case. As jurors you are not
23
permitted to read any news about this case. You cannot read or watch or listen to any accounts
3
EFTA00030635

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 404 Filed 11/02/21 Page 5 of 6
1
of this case at all. If you see something in the paper or online, you're just going to have to turn
2
the page or close the browser. You can't read it.
3
Equally important, you're not permitted to discuss this case with anyone else while the
4
case is going on. Even with your fellow jurors, you can't discuss the case until you've heard all
5
the evidence and I've given my instructions on the law. Again, that's because you can only
6
consider the evidence that you hear in the courtroom, not anything outside of the courtroom. You
7
have to keep an open mind. Nor may you discuss the case with friends or family until after your
8
jury service is complete. You can tell them that you are a juror in a criminal case in federal court
9
and that the judge has told you that you are not permitted to say anything further.
10
Similarly, until you are excused from jury service, you cannot post anything about your
11
experience as a juror on Facebook, Twitter, Instagram, TikTok or any kind of social media.
12
Another instruction, you can't look up or google or do any other kind of search about anything
13
related to the case or anyone involved in the case.
14
The reason for these rules, as I am sure you understand, is they protect the integrity of the
15
trial and assure that both sides receive a fair trial.
16
Jurors in criminal cases base their verdicts on the evidence that they hear in the
17
courtroom, not on something that somebody else tells you, not on something that you see on TV
18
or on social media. That's why if you're selected as a juror, I'll be reminding you of these rules
19
regularly. You can't watch news accounts, look anything up or speak to anybody else about the
20
case. You would be violating the oath you have taken as jurors and you would be violating my
21
orders if you were to do that.
22
Finally, you must report to me through my court deputy any effort by any person to speak
23
with you about the case or to influence you about the case or to get information about the case.
4
EFTA00030636

=== Page 6 ===
Case 1:20-cr-00330-AJN Document 404 Filed 11/02/21 Page 6 of 6
1
I do want to thank all of you for the time you've invested already in this process. Our
2
system cannot function unless we have good people like you who are willing to give up their
3
time and to serve as jurors.
4
Please sit quietly until your number is called and you are brought into the courtroom for
5
questioning by me. Although you may use your electronic devices while you are waiting
6
(bearing in mind of course all of my instructions that forbid you to do any research or engage in
7
any communications about the case through any means), you must turn off and hand over any
8
electronic devices to the Jury Department staff before you are brought into the courtroom. I look
9
forward to meeting each of you in person soon. Thank you.
5
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=== Page 1 ===
From:
)"
To:
)"
Subject: Re: Discovery questions
Date: Wed, 19 Aug 2020 22:35:14 +0000
Great
Sent from my iPhone
On Aug 19, 2020, at 6:34 PM,
)
wrote:
Yep, it looks like we have all of the trash pulls-I think they did the organizational structure you asked for when they
gave it to us back in September.
From:
Sent: Wednesday, August 19, 2020 2:33 PM
To:
Subject: FW: Discovery questions
For the scans, let me know if you're seeing things like trash pulls in the scans they sent you. It should be more than just
phone message pads. If it's not in there, let's take
up on the offer to request another copy from them.
From:
(NY) (FBI)
Sent: Wednesday, August 19, 2020 2:21 PM
To:
>;
is
Cc:
is
(USANYS)
Subject: RE: Discovery questions
Hey all, below is a summary of the discovery items you've requested.
Message Pad Scans: The message pads were scanned with the post it notes on them and the very next page is the page
without the post it note, so the pages are back to back.
Papers from Miami case file (grand jury testimony): This is a disk - I can copy it and send it over to you.
Evidence scans: Are you referring to the scans from the FL file? We sent those over with the original message pad scans
last year. If you need that again, let us know and we can get another copy over to you. As far as paper evidence from
the NY and VI searches, and the paper provided by Reiter, we can get that over to you by the end of the week.
FBI file: We have that ready for you.
CART: There are no 302s regarding the extraction of devices.
Evidence from disks: This is a large volume and we've been working on this and removing nude/semi nude images. This
is the only thing that would be difficult to complete by Friday. If we could have a little more time to pull this together,
that would be very helpful.
If it's helpful to talk through some of this via phone, we are happy to do that as well.
EFTA00030986

=== Page 2 ===
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
C:
From:
Sent: Tuesday, August 18, 2020 6:41 PM
To:
is
Cc:
(NY) (FBI)
is
is
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Discovery questions
Thanks so much,
Really appreciate all the work you and
are putting in on this. Let's touch base tomorrow
to figure out the timeline for the discovery issues.
From:
Sent: Tuesday, August 18, 2020 6:40 PM
To:
)
is
)
Cc:
(NY) (FBI)
is
>;
(USANYS)
Subject: Re: Discovery questions
Hey guys,
Apologies but today I was out In the field on surveillance and
was also out of the office so we've not
been able to connect on these discovery questions. We will be back in the office tomorrow and will dive into
this as best we can. We have several calls tomorrow, one of which is with Tony Figuero but well do our best to
get on this list. That being said I don't want to make you any promises that everything will be compiled by
tomorrow and that we will have an answer to all of your questions but we can jump on a call tomorrow if you
like to square some of this away.
I did receive your "pages from Miami_case_docs" PDF.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
EFTA00030987

=== Page 3 ===
From:
Sent: Tuesday, August 18, 2020 6:03 PM
To:
is
Cc:
(NY) (FBI)
is
is
(USANYS)
Subject: RE: Discovery questions
Hi
and
Sorry to pester, but would you be able to let us know whether it is realistic to expect that you'll be able to get us these
materials tomorrow or Thursday?
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:41 PM
To:
is
Cc:
(NY) (FBI)
is
>;
(USANYS)
Subject: RE: Discovery questions
Hi
and
The drive you provided us has some scans on it (looks like they're scans of the message pads). As I recall, there was a
larger scanning project, during which the FBI scanned all of the paper that was vouchered in evidence. Are you able to
provide us with all of those scans this week?
With respect to the message pads in particular, I think you mentioned that they were scanned both with post-it notes on
them and also without the post-it notes. The version on this drive just looks like it has the post-it note scans.
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:45 AM
To:
Cc:
(NY) (FBI)
is
is
;
is
(USANYS)
Subject: RE: Discovery questions
Sorry, got a bounceback for
too. I'm just attaching the one page I referenced in my email below. Hopefully that
will go through.
From:
Sent: Tuesday, August 18, 2020 4:40 AM
To:
Cc:
(NY) (FBI)
is
>;
is
(USANYS)
Subject: FW: Discovery questions
EFTA00030988

=== Page 4 ===
I got a bounceback from your account for the below email because the attachment was too big. Hopefully it went
through for
so she can see it. If not, please let me know.
Thanks,
From:
Sent: Tuesday, August 18, 2020 4:33 AM
To:
(NY) (FBI)
Cc:
is
(USANYS)
Subject: Discovery questions
Hi
and
Thanks so much for your help with the Maxwell discovery so far. I have some follow-up questions about the most recent
batch you provided, and wanted to check in on the longer term tasks we discussed last month.
Below are some questions regarding the discovery
dropped off a few days ago with requests for additional items:
The last page of the attached appears to be a photograph of a disc. The label on the disc seems to suggest it
contains grand jury transcripts. Have you given us those transcripts?
The message pad scans you provided still have post-it notes on top of several of the message pad pages. I think
mentioned that each pad had been scanned twice, but I'm only seeing one copy of each pad-and those
copies all of post-its on them. That's true of nearly every "Notebook" pdf you provided in the "Message pad
scans" folder. Would you please get us a scans of these without post-its on them?
It looks like we're still missing SW returns for the 20 mag 6719 warrant and for the NH premises warrant.
Would you please get us copies of those returns?
Following up on our conversation last month, I think we're still waiting on the below items from you guys. Would you
please be able to get us these this week?
Full FBI sentinel file
CART paperwork regarding the extraction of data from all devices seized during the investigation
All 302s regarding the extraction of data from any seized devices and the review of images (both digital and
hard copy) seized during the investigation, including from Epstein's properties.
Scans of the files Reiter provided to the FBI and provide us with all of those scanned materials
Scans of all hard copy documents, including photos, in the possession of the FBI that have not yet been
scanned, including anything seized during any searches. Please produce to SDNY all of those scans, except any
nude or partially nude images. For nude or partially nude images, please provide us with a log detailing how
many such images were scanned, where they were from, and where they are being stored.
Copies of the contents of all the discs that were seized and searched pursuant to search warrants to a platform
for review. Then please produce to SDNY a copy all of those materials, except any nude or partially nude
images. For nude or partially nude images, please provide us with a log detailing how many such images were
located, where they were from, and where they are being stored.
Please let me know if you have any questions or if it would be useful to hop on a call.
Thanks very much,
Assistant United States Attorney
EFTA00030989

=== Page 5 ===
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00030990


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=== Page 1 ===
From:
)"
To: "Moyne, Parvin"
Cc: "DiPiero, Joseph"
"Moyer, Thomas"
)"
Subject: RE: Epstein accounts
Date: Mon, 10 Aug 2020 15:23:40 +0000
Received and understood, thanks.
From: Moyne, Parvin
Sent: Monday, August 10, 2020 10:49
To:
)
Cc: DiPiero, Joseph
Moyer, Thomas
is
Subject: Re: Epstein accounts
Thanks
I don't think not disclosing the subpoena will be an issue - we are taking that stance with respect to other
DOJ subpoenas as well.
Best,
Parvin
On Aug 10, 2020, at 10:39 AM,
wrote:
Parvin,
We don't have a view on the production of any substantive Deutsche Bank materials that may have been produced in
connection with our subpoena, but given the ongoing criminal grand jury investigation that gave rise to the issuance of
the subpoena, we request that the subpoena itself not be disclosed. To the extent the requestor has an issue with that,
please feel free to refer them to us.
thanks,
Assistant U.S. Attorney
Southern District of New York
From: Moyne, Parvin
Sent: Monday, August 03, 2020 18:59
To:
)
Cc: DiPiero, Joseph
; Moyer, Thomas
is
)
Subject: RE: Epstein accounts
EFTA00031413

=== Page 2 ===
End of week is fine - we'll check in then if we haven't heard back.
Thanks
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
Direct:
Internal
From:
)
Sent: Monday, August 3, 2020 6:57 PM
To: Moyne, Parvin
Cc: DiPiero, Joseph
Moyer, Thomas
i
Subject: RE: Epstein accounts
EXTERNAL Email
Parvin,
Thanks for letting us know, that's helpful. We're hoping to get you an answer to your questions in the coming days; if
you haven't heard back from us by the end of the week, or if you need a response sooner than that, please ping us to
remind.
thanks,
From: Moyne, Parvin
Sent: Monday, August 03, 2020 12:12
To:
Cc: DiPiero, Joseph
Moyer, Thomas
is
Subject: RE: Epstein accounts
I hope you are well and getting some time "off" this summer. I'm reaching out via email as it may be the most efficient
way to tee-up the inquiry we have received, but we can circulate a dial-in at a convenient time for you if you'd like to
discuss anything.
Deutsche Bank has received a third-party subpoena from the Attorney General's Office of the U.S. Virgin Islands in
connection with a pending civil suit they have filed against Jeffrey Epstein's estate, the executors of the estate, and
others. One of the requests is for a copy of any government subpoenas received by the Bank relating to Epstein, and a
copy of any productions made pursuant to the subpoenas. Do we have your permission to disclose your subpoena and
our production to you to the U.S.V.I. AG? Would you prefer us to refer the office to you directly or provide you with
contact information? I'm happy to send you a copy of the U.S.V.I. AG subpoena if helpful in evaluating the request.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
Direct:
Internal:
EFTA00031414

=== Page 3 ===
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
EFTA00031415


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=== Page 1 ===
From: Nick Allen
To:
Subject: Epstein enquiry
Date: Sun, 11 Aug 2019 14:29:07 +0000
Hello Mr
Sorry to bother you on a Sunday. I'm a journalist with the UK's Daily Telegraph.
Is it possible to say, on background, whether you want to question Prince Andrew and Ghislaine Maxwell [both
British citizens...]
There is also a report in the New York Post that Ms Maxwell is "cooperating with authorities". Can you confirm,
on background, if that is true?
Many thanks
Nick Allen
Nick Allen
Washington Editor
The Daily Telegraph
Cell
The contents of this message and any attachments to it are private, confidential and may be the subject of legal privilege. Telegraph
Media Group Limited is registered in England and Wales (company number 451593) at 111 Buckingham Palace Road, London, SWIW
0DT. If you are not the intended recipient of this email please inform us and the sender immediately. You must not take any action
based upon the contents of this email, nor copy it or show it to anyone. Any unauthorised disclosure, use or dissemination of the whole
or part of the message contained in such email is prohibited. Any views or opinions expressed do not necessarily represent those of
Telegraph Media Group Limited. It is the recipient's responsibility to carry out any virus checking.
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=== Page 1 ===
From:
)"
To:
Subject: RE: Maxwell
Date: Wed, 08 Jul 2020 17:55:28 +0000
Attachments: 2020-07-
02, United_States_v_Maxwell_20_Cr_330_(AJN),_detention_memorandum_(ECF).pdf;
Maxwell_Superseding_Indictment__S1_20_Cr_330_(AJN).pdf
Hi Lea,
I'm attaching our detention memorandum here, along with a copy of the superseding indictment.
Thank you,
Original Message
From:
Sent: Wednesday, July 8, 2020 11:37 AM
To: Lea Harmon
Subject: Re: Maxwell
Hi Lea,
That would work well, thanks. Talk to you then.
Sent from my iPhone
> On Jul 8, 2020, at 11:24 AM, Lea Harmon
wrote:
>
> Hi
,
V
> I'm in a staff meeting right now and then I need to address an LM issue. Are you available to talk this
afternoon? Maybe 1:30?
V
V
Original Message
> From:
> Sent: Wednesday, July 8, 2020 10:22 AM
> To: Lea Harmon
> Subject: Re: Maxwell
V
> Hi Lea,
>
> I hope you're doing well. Do you have a moment for a call today to discuss this case? If there is a time that
works best for you, please let me know. You're also welcome to call me on my cell at any time:
V
> Thanks very much,
V
V
V
> Sent from my iPhone
EFTA00030379

=== Page 2 ===
>
>>
On Jul 8, 2020, at 11:12 AM, Natasha Ramesar
wrote:
>>
Good Morning-
>> Lea Harmon copied above will conduct the interview and complete the bail report for Ms. Maxwell.
>> The request was submitted to MDC and we await the date/time of the interview. However, defense advised
that court is now scheduled for Tuesday, 7/14, so the report will be ready for that date as I anticipate the
interview being scheduled before the end of this week.
>>
Natasha Ramesar
>> U.S. Pretrial Services Officer Specialist - Intake Coordinator
Southern District of New York
Office:
Fax:
Original Message
>> From:
)
Sent: Wednesday, July 8, 2020 10:11 AM
>>
To: Natasha Ramesar
Subject: RE: Notification - - Pretrial Services Intake
Hi Natasha,
Hope you're doing well. Following up on our conversation from the other day, do you know yet who the
assigned officer will be?
>> Thanks,
>>
EFTA00030380


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=== Page 1 ===
From
To
Subject: Re: GM
Date: Wed, 01 Jul 2020 13:15:25 +0000
We did. The difference is that the courthouse was closed. I think we would do that if it were after business
hours. The question is whether the same thing applies if she is arrested at 2 p.m. today.
On Jul 1, 2020, at 9:11 AM,
wrote:
I just looked back at what we did on Epstein, because we obviously dealt with the same issue of him being arrested a
day or two before the press conference. It looks like we kept it under seal (but gave his lawyers a copy) until Monday
morning, and did the press conference shortly thereafter.
That said, I don't feel strongly, particularly if she's arrested late this afternoon, and we plan to do press conference early
tomorrow morning.
From:
Sent: Wednesday, July 1, 2020 9:07 AM
To:
Subject: Re: GM
Even 1 pm is sort of late to do a conference today. What are your thoughts about unsealing if she is arrested during
business hours while our clerk's office is open, but isn't presented until tomorrow?
On Jul 1, 2020, at 9:03 AM,
wrote:
FYI, the presentment cut off in DNH is 1pm, and if we miss it, she'll get held in a local jail until tomorrow morning.
Consistent with your views this morning, I might propose that we suggest to Audrey and the press office that if we
don't have her by 1, we plan to put off the press conference until tomorrow morning, since at that point she won't be
presented until tomorrow in any event.
EFTA00029859


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: [EXTERNAL] Re: Scheduling
Date: Tue, 02 Nov 2021 21:38:04 +0000
Attachments: 2021.11.01_JSP_Letter_to_USAO_re_Rul6_16_Disclosures_Redacted.pdf
First, I wanted to send along the defense's expert disclosure for your review. We can discuss tomorrow.
On travel arrangements, I have consulted with others internally and can approve the purchase of a business class ticket if
nothing else is available. You should attach this email to your Amtrak tickets when you submit for reimbursement.
Thanks,
From:
Sent: Tuesday, November 2, 2021 4:49 PM
To:
Cc:
is
is
Subject: Re: [EXTERNAL] Re: Scheduling
Are you planning to call now?
On Tue, Nov 2, 2021 at 12:07 PM
wrote:
Yes, I can speak for 15 minutes between 4:45-5:00
Lisa
On Tue, Nov 2, 2021 at 11:54 AM
(USANYS)
wrote:
Hi
are you free to speak after 3 pm today briefly?
From:
Sent: Tuesday, November 2, 2021 10:20 AM
To:
Cc:
is
is
Subject: Re: [EXTERNAL] Re: Scheduling
Hello
Thank you - these rates are fine for the hotel, but in order to stay within the rate limit, I need to book a non-
refundable rate. Please confirm the dates you would like me to be in NY next week as well as what dates you
anticipate working together for trial prep after the hearing (Thurs/Fri VS Fri/Sat). I need to move patients and would
like to know when to schedule them (either Thursday or Saturday). Finally, I will book myself on Amtrak, but for
many of the times, the only available options are business class seats - the coach seats are already sold out.
EFTA00030640

=== Page 2 ===
On Tue, Nov 2, 2021 at 9:11 AM
(USANYS)
wrote:
I was informed of the following: You can schedule your own travel but only at the coach/economy rate. For
Lodging and M&IE:
https://www.gsa.gov/travel/plan-book/per-diem-rates/per-diem-rates-lookup/?
action=perdiems_report&fiscal_year=2022&city=new%20york&state=NY&zip=10007
Attached is a letter for you to use to get tax exemption on lodging.
Thanks,
From
Sent: Monday, November 1, 2021 10:11 PM
To:
Cc:
is
is
;
Subject: Re: [EXTERNAL] Re: Scheduling
Let's start at 7:30pm on Wed. Also I had a typo in prior message. I have the hotel from Tue - Sat
On Nov 1, 2021, at 9:52 PM,
(USANYS)
wrote:
Thanks very much. Let's plan on about 2.5 hours. What time did you want to start?
From
Sent: Monday, November 1, 2021 9:50 PM
To:
Cc:
is
is
Subject: Re: [EXTERNAL] Re: Scheduling
EFTA00030641

=== Page 3 ===
Thank you. I reserved a room at the hotel 50 Bowery for next week, Tue - Sun with free cancellation in the event
that plans change. How much time would you like me to reserve on Wed evening?
On Nov 1, 2021, at 8:25 PM,
(USANYS)
wrote:
Here are some hotel options near our office:
Hotel 50 Bowery
New York, NY 10013 Tel
Fax:
The Friedrick Hotel
New York, NY 10007 Tel:
Fax:
frederickhotelnyc.com
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
From:
(USANYS)
Sent: Monday. November 1, 2021 12:22 AM
To:
Cc:
>;
is
;
Subject: RE: [EXTERNAL] Re: Scheduling
Yes, that should work. We will plan to call you then.
EFTA00030642

=== Page 4 ===
Thanks,
From:
Sent: Sunday, October 31, 2021 9:59 PM
To:
Cc:
>;
Subject: Re: [EXTERNAL] Re: Scheduling
Hello
I have reviewed the materials you sent - I could speak with you tomorrow evening after 7:30 - would that work
for you?
On Sun, Oct 31, 2021 at 7:53 PM
(USANYS)
wrote:
Hi
Thanks for your time earlier today. I'm attaching Daubert-related briefing in the case. After you have had a
chance to review, let's find a time to speak on the phone. Please let us know some times that work for you.
We will let you know about scheduling as soon as we know more.
Also, as I mentioned, you should book your own travel and then send the invoice for travel expenses to
Thanks,
From:
Sent: Wednesday, October 27, 2021 7:48 PM
To:
Cc:
is
Subject: Re: [EXTERNAL] Re: Scheduling
Sounds good, talk to you then.
On Wed, Oct 27, 2021 at 7:22 PM
(USANYS)
wrote:
Great, thanks so much. Let's plan to speak this Friday at 1:30. We can use the following dial-in:
As for the 12th and the 13th, if possible, it would be great to keep both of those days open and I will let
you know a start time as soon as I have more information. Happy to discuss more on Friday.
Thanks so much,
From
Sent: Wednesday, October 27, 2021 6:44 PM
To:
Cc:
in
EFTA00030643

=== Page 5 ===
is
Subject: Re: [EXTERNAL] Re: Scheduling
Thank you for getting back to me.
That plan sounds good. Are you anticipating meetings on both the 12th and the 13th? When would you
like to start on the 12th and how long do you think we will go on the 13th? I am happy to be flexible, but
would like a sense of time so that I can plan for other commitments. In addition, I would still like to speak
briefly before this Sunday so that I can adequately prepare for our meeting. My information for traveling
is as follows:
cell:
email:
DOB:
Regards,
On Wed, Oct 27, 2021 at 5:31 PM
(USANYS)
wrote:
Hi
Thanks so much for the quick reply. How about this Sunday, October 31, by Webex? I was thinking we
could start in the morning, like 10 am, but please let me know what works for you. As for meeting in-
person, let's plan on November 12 and 13. For travel logistics, I need the following information, please:
Your full name as it appears on your government-issued ID
Your date of birth
Your home address, cellphone number, and email address
Once I have that information, I will have
from our office reach out to you to coordinate
travel.
Thanks!
From:
Sent: Wednesday, October 27, 2021 2:10 PM
To:
Cc:
i
is
Subject: [EXTERNAL] Re: Scheduling
I am sorry, I meant that I am leaving for Italy on 11/17 and returning to NYC on 11/27
On Wed, Oct 27, 2021 at 2:07 PM
wrote:
Hello
I am leaving for NY on Wednesday 11/17, and returning to NYC on Saturday 11/27. I am
totally booked for all of next week, but I could arrange a 3-4 hour conference call for this Friday
after 1:30pm or during this coming weekend. With regard to an in-person meeting, I could arrange
EFTA00030644

=== Page 6 ===
to be in New York by early evening on Thursday November 11, and we could plan to meet that night
and/or on Friday the 12th. Please let me know if that works for you - Alternatively, I could also be in
NY on the Friday/Saturday the 12th and 13th. How much time in-person are you anticipating?
Prior to our video conference, I would like to chat briefly ahead of time so that I can adequately
prepare for our meeting.
Thank you,
On Wed, Oct 27, 2021 at 1:50 PM
(USANYS)
wrote:
Hi
I wanted to reach out to set up a time to meet by Webex. I expect the meeting will take 3 hours.
Can you please let me know some days and times that work for you? If a weekend is better, we
can do that as well. I also want to find a time for us to meet in person in New York before your
trip to Italy. Please let me know some dates that work for you for an in-person meeting in New
York.
Thanks very much,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00030645

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=== Page 8 ===
EFTA00030647

=== Page 9 ===
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=== Page 1 ===
From:
To:
Subject:
Date: Tue, 10 May 2016 21:56:31 +0000
Hi
I'm going through discovery on a case and part of that is a picture of me with Prince Andrew, do you recall seeing the date on the back
and was it recorded. Did I receive the original back or was it kept as evidence? I know it's been a long time but anything helps.
I hope you've been well!! Still fighting the good fight!!
Kindly,
Sent from my iPhone
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=== Page 1 ===
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
**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.
EFTA00030925


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: Re: Statements by Mr. Tartaglione
Date: Sat, 23 Nov 2019 18:36:18 +0000
Monday at 4 or anytime Wednesday works for me.
On Nov 23, 2019, at 12:11 PM,
(USANYS)
wrote:
I could do this call on Monday at 4, Tuesday late afternoon (driving up to Mass. that day), any time on Wednesday, or
when we get back from Thanksgiving. Thoughts?
Assistant United States Attorney
From: Bruce Barket
Sent: Friday, November 22, 2019 3:06 PM
To:
(USANYS)
>; Aida Leisenring
>; Tony Ricco
>; BRUCE KOFFSKY
i
; John Diaz
>; Kenneth J. Montgomery Esq
Cc:
Subject: RE: Statements by Mr. Tartaglione
Let's set up a call as I believe that the material I requested is relevant and we are entitled to it.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
From:
(USANYS) [mailto:
Sent: Friday, November 22, 2019 11:51 AM
To: Bruce Barket; Aida Leisenring; Tony Ricco; BRUCE KOFFSKY;
; John Diaz; Kenneth J.
Montgomery Esq
Cc:
)
Subject: RE: Statements by Mr. Tartaglione
All,
In response to your request for any statements made by Mr. Tartaglione during interviews at the MCC related to the
investigation into an event involving Jeffrey Epstein on or about July 23, 2019, we are producing to you a zip folder with
EFTA00030557

=== Page 2 ===
reports of those statements. The zip folder also contains reports of statements attributed to Mr. Tartaglione that were
conveyed to MCC staff by Mr. Epstein. These materials have been marked "sensitive" pursuant to the protective order in
this case and should be treated accordingly.
In response to your additional request for "all the reports and video regarding Mr. Epstein's attempted suicide on July
22-23ʳᵈ, " we do not believe these materials are relevant to this case or covered under Rule 16, and therefore will not be
producing them. If you would like to discuss further, please give us a call.
Assistant United States Attorney
From: Bruce Barket
Sent: Wednesday, November 20, 2019 8:50 AM
To:
(USANYS)
Cc:
is
>; Aida Leisenring
Subject: Re: Statements by Mr. Tartaglione
Thank you.
In addition to the statements attributed to Mr. Tartaglione we are asking did for all the reports and Video regarding
Epstein's attempted suicide on July 22-23rd.
I believe we sent a letter to the MCC shortly after the event asking that the video be preserved.
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country road
Garden City, NY 11530
Barket Epstein.com
On Nov 19, 2019, at 12:23 AM,
(USANYS)
wrote:
Bruce - To the extent your request is to the MCC/BOP, the request is governed by the procedures set forth below in
email. To the extent the request is to our office pursuant to Rule 16, as a courtesy, we will look to see what
statements are in our possession and gather and produce them to you by the end of the week. The production will
be pursuant to the protective order in this case.
Assistant United States Attorney
From:
Sent: Monday, November 18, 2019 8:50 AM
To: Bruce Barket
is
(USANYS)
is
)
Cc: Aida Leisenring
Subject: Re: Statements by Mr. Tartaglione
EFTA00030558

=== Page 3 ===
Hi Bruce,
Pursuant to FOIA/Privacy Act and Touhy regulations, we need a release from the inmate, Touhy letter, and subpoena for
the request to be considered locally. Please also be advised that we would have to seek authority under Touhy through
the USAO.
Thank you,
>>> Bruce Barket <
> 11/17/2019 5:03 PM >>>
It is my understanding that Mr. Tartaglione was interviewed by members of Bureau of Prisons in the late hours of July
22nd or the early hours of July 23, 2019 concerning Jeffrey Epstein's reported attempted suicide attempt. Pease
provide the record of any statements made by Mr. Tartaglione, any written statements made by Mr. Tartaglione and
any recording of any such statements.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not
clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
EFTA00030559


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=== Page 1 ===
From:
To:
Subject: 2019-02-07, JE, letter re all writs act application.docx
Date: Fri, 22 Feb 2019 17:44:57 +0000
Importance: Normal
Attachments: 2019-02-07,_JE,_letter_re_all_writs_act_application.docx
draft
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=== Page 1 ===
From:
Subject: updated indictment draft
Date: Tue, 09 Jun 2020 16:47:55 +0000
Attachments: 2020-06-09_Maxwell_draft_indictment.docx
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
From: "Strauss, Audrey (USANYS)"
To:
Subject: RE: Let's not forget
Date: Wed, 01 Jul 2020 13:36:29 +0000
thanks
Original Message
From:
Sent: Tuesday, June 30, 2020 10:34 PM
To
Cc: Strauss, Audrey (USANYS)
Subject: Re: Let's not forget
The number is 1-800-CALL-FBI.
Sent from my iPhone
> On Jun 30, 2020, at 9:56 PM,
wrote:
V
> Will do. Thanks, Audrey.
>
>> On Jun 30, 2020, at 9:45 PM, Strauss, Audrey (USANYS)
A
wrote:
>>
We need the telephone number I need to announce per the press remarks.
>> For some reason that was hard to get from FBI for Epstein.
>>
Sent from my iPhone
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=== Page 1 ===
Court Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the United States District Court for the Southern District of New York, 40 Foley Square, in the
Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the
following date, time and place:
Appearance Date:
November 29, 2021
Appearance Time: 9:00 a.m.
Appearance Place:
40 Foley Square, Courtroom 906
to testify and give evidence in the following matter:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
PERSONAL APPEARANCE IS REQUIRED
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
July 19, 2021
andress
AUDREY STRAUSS
United States Attorney for the
UNITED STATES DISTRICT COURT
Southern District of New York
Assistant United States Attorney
RICT FOR THE YORK
One St. Andrew's Plaza
New York, New York 10007
Email:
Telephone:
rev. 02.01.12
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=== Page 1 ===
From:
)"
To: Mark Manley
Cc:
)"
)"
,
(USANYS)"
Subject: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Date: Mon, 03 May 2021 14:24:23 +0000
Attachments: 2021-05-03_Order_Re_Third_Party_Letter.pdf
Mr. Manley,
The Court has directed us to forward you a copy of the attached Order.
Sincerely,
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From: Sigrid McCawley
To:
)"
Subject: FW:
V. Indyke, et al.
Date: Tue, 24 Mar 2020 17:41:53 +0000
Attachments:
Notice_of_Deposition_-_Maxwel.pdf
FYI.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
From: Aneisha Christie
Sent: Tuesday, March 24, 2020 1:40 PM
To: Laura Menninger
>; Jeff Pagliuca
is
Cc: Sigrid McCawley
David Boies2
>; Andrew Villacastin
>; Sabina Mariella
>; Josh Schiller
Subject:
V. Indyke, et al.
Dear Counsel,
Attached please find Plaintiff,
Notice of Deposition of Ghislaine Maxwell in regards to the above-
referenced matter.
Please don't hesitate to contact our office should you have any questions or concerns regarding this matter.
Thank You,
Aneisha Christie
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
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=== Page 1 ===
https://csamdo.iscm.doj.gov/IAMDOJSA/CardholdersApplicationsSearch/CardholdersApplications?cardholderld=749718accountAppld=0
Search...
a
-
lamDOJ Search & Reporting X
File Edit View Favorites Tools Help
Perspecta Assured Identity
DOJ internal White Pages
DOJ Net
DOJ Portal
Enterprise Apps
For Employees
Forms
IPTV
Learn DOJ
WebTA
cert1
CSAM
remedy
Travel
lamDOJ Search & Reporting Search Reports lamDOJ
CSAM Portal
Account Details
USAccess
General
Current PIV Card
Issuance ID: 3
Serial:
Last Name: THOMAS
CHUID Expires: 7/10/2024 12:00:00 AM
First Name: MICHAEL
CHUID Status: Activated
Middle Initial: A
FASC-N:
Type: Employee
UPN:
Component: Bureau of Prisoners/Federal Prison System
PIV Auth Certificate Expires: 7/17/2022 2:33:47 PM
Status: Active
Digital Signature Certificate Expires: 7/17/2022 2:33:47 PM
DOB:
Certs Expire: 7/17/2022 2:33:47 PM
SSN:
First Issued: 3/11/2015 12:56:29 PM
Gender: Male
Card Certs: 15
Race: Black or African American
PIVAuth Cert UPN:
Eye Color: Brown
Hair Color: Black
Height: 66
Sponsorship
Weight: 172
Business Email:
Status: Sponsored
Employer:
Last Update: 7/10/2019 11:08:35 AM
USAccess Role: I
Person ID:
Sponsor Organizational Identifier: Bureau of Prisoners/Federal Prison System
Current Sponsor:
Credential Option: PIV credential to be issued
Shipping Address Code: 10517
Shipping Address Name: DOJ 150 PARK ROW
UPN:
Original Sponsorship Date: 9/4/2014 12:00:00 AM
7:24 AM
8/14/2019
EFTA00030959


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 192 Filed 03/31/21 Page 1 of 3
LAW OFFICES OF BOBBI C. STERNHEIM
Main
Cell
New York, New York 10011
Fax
March 31, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
United States V. Ghislaine Maxwell
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
This week's filing of the second superseding indictment presents new and complicating
issues. In addition to expanding a three-year conspiracy to 10 years, the government has added
two serious charges that drastically change the focus of this case. That the government has made
this move late in the game - with trial set for July 12th - is obvious tactical gamesmanship.
Adding charges that were never launched against Jeffrey Epstein based on evidence that was in
the government's possession for years is shocking, unfair, and an abuse of power. More than
doubling the time period of the originally charged conspiracy from 1994 to 2004 (previously
1997) and alleging two distinctly different substantive counts requires: additional investigation;
requests for additional discovery; the need to supplement pretrial motions that have fully briefed
and are pending before the Court; and the drafting and filing of additional motions pertinent to
the new indictment. Accordingly, a new briefing schedule is required.
Even more concerning is the impact this late-breaking filing has on Ms. Maxwell's
constitutional rights. Her liberty interests now clash with her right to effective assistance of
counsel. The Court is aware of the extraordinary circumstances of Ms. Maxwell's detention, its
deleterious effect on her health and well-being, and the realistic concern whether she will be
strong enough to withstand the stress of trial.
Counsel have not yet determined whether to formally move for a continuance. This
decision is not an easy one. Ms. Maxwell and her lawyers have been diligently preparing for
trial. However, the government's continued refusal to provide the most basic discovery - names
of accusers - coupled with what amounts to a new indictment (after what was supposed to be the
close of discovery and the resolution of very complicated legal issues) has effectively prevented
trial preparation from moving forward in an orderly manner. Accordingly, we have requested
an opportunity to confer with government counsel with the goal of clarifying the necessity of
moving the trial date.
EFTA00030015

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 192 Filed 03/31/21 Page 2 of 3
LAW OFFICES OF BOBBI C. STERNHEIM
To be clear, any such request will not be made from any desire of Ms. Maxwell to delay
her trial but rests squarely on the government's late, tactical, expansion of this prosecution.
At the initial appearance on July 14, 2020, the defense agreed to the July 12th trial date
based on the government's representation that is would not file a superseding indictment:
The trial schedule that we are agreeing to, of course subject to the court's
approval, assumes there will be no substantive superseding indictment. If there is
one, which the government has advised us they don't believe is imminent or I
assume not at all, we might have to come back to the court to address not just trial
schedule but other schedule as well.
July 14, 2020 Transcript at 16 -17 (emphasis added).
In response, the Court made the following inquiry:
Let me go ahead and ask, Ms
Mr. Cohen has made a representation but I
will ask if you do anticipate at this time filing any further superseding indictments
adding either defendants or additional charges?
Id. at 17.
The government confirmed:
MS.
Your Honor, our investigation remains ongoing, but at this point we
do not currently anticipate seeking a superseding indictment.
Id.
Based on that representation, Ms. Maxwell accepted a July 12, 2021 trial date and her
lawyers planned accordingly, postponing trials in other cases to preserve this high-priority date.
It was only after considerable judicial and defense resources were expended that the government
belatedly superseded, again, with no justifiable reason given the age of these allegations. The
timing suggests that the decision to supersede was prompted by the filing of defense pretrial
motions and government concern about the now-apparent weakness of its case. The government
may be entitled to supersede but not when its decision disrupts the schedule set by the Court and
relied on by Ms. Maxwell. This delay has a prejudicial effect on counsel's readiness for trial and
Ms. Maxwell's prolonged detention.
This is no longer the "two-week" trial as represented by the government. By adding
charges that encompass dozens of additional witnesses, the government has unilaterally
destroyed the possibility that this case can be completed in the time allotted. The continual media
attention this case garners, in addition to podcasts, documentaries, books and the like, will likely
require the bulk of that time to seat a fair and impartial jury, provided that constitutional right
can be guaranteed.
2
EFTA00030016

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 192 Filed 03/31/21 Page 3 of 3
LAW OFFICES OF BOBBI C. STERNHEIM
Ms. Maxwell is entitled to a fair trial with effective assistance of counsel. If counsel feel
that additional time is required to guarantee those constitutional rights, Ms. Maxwell will suffer
the consequence by her continued detention. The Court has the power - and, indeed, the
discretion - to accommodate this constitutional clash. Granting a continuance and releasing Ms.
Maxwell on the most restrictive conditions of home detention. Surely, the Court can impose
conditions that "clip her wings" and satisfy perceived flight concerns without keeping Ms.
Maxwell locked in a BOP cage.
As counsel has notified the government, Ms. Maxwell is requesting an in-person
arraignment. She will not waive that right, most especially in light of media coverage and the
debacle that occurred during a remote proceeding in a related civil case before Judge Preska.
In addition, Ms. Maxwell is requesting a bail hearing at which witnesses will testify regarding
the purported strength of the government's case. Further, we request that these proceedings be
scheduled to coincide with an evidence review session at the U.S. Attorney's Office to be
attended by Ms. Maxwell with counsel.
Your consideration is greatly appreciated.
Very truly yours,
Babbi C. Sternbeim
BOBBI C. STERNHEIM
cc: All counsel
3
EFTA00030017


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 264 Filed 05/03/21 Page 1 of 1
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 5/3/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
On April 21, 2021, the Court's Chambers received a letter from counsel for a non-party
requesting assurances as to privacy protections for his client in any filings or proceedings in this
case. The letter requests anonymity on behalf of the client as an alleged victim of a sexual crime.
After receiving the letter, the Court forwarded it to the parties and required the Government to
respond to counsel, which it has done. The Court will take no further action based on the April
21, 2021 letter but will file it under seal to protect the privacy interests of the non-party asserting
that interest.
The Government is requested to forward this order to counsel for the non-party.
so ORDERED.
Dated: May 3, 2021
Alim D.Netto
New York, New York
ALISON J. NATHAN
United States District Judge
EFTA00031684


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=== Page 1 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. $ 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am a custodian of
records of the business named below (the "Business"), or I am otherwise qualified as a result of
my position with the Business to make this declaration.
I have reviewed records¹ of the Business, which have been provided to law enforcement
in connection with an investigation and prosecution by the United States Attorney's Office for
the Southern District of New York. Those records consist of the following (collectively, the
"Records"):
AT&T Wireless invoice dated May 5, 2004 for account number 0043811863 in the name of
Jeffrey E Epstein
Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify
that the foregoing Records of the Business:
(1) were made at or near the time of the occurrence of the matters set forth in the records,
by, or from information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
.
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
] As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any
form, of acts, events, conditions, opinions, or diagnoses. The term "business" as used in Fed. R. Evid. 803(6) and
the above declaration includes business, institution, association, profession, occupation, and calling of every kind,
whether or not conducted for profit.
EFTA00030763


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=== Page 1 ===
Event: Accepted: Questions re: Epstein ESI
Start Date: 2020-03-11 14:30:00 +0000
End Date: 2020-03-11 14:45:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-03-10 22:56:18 +0000
Date Modified: 2020-03-10 22:56:18 +0000
Priority: 5
DTSTAMP: 2020-03-10 22:32:39 +0000
Attendee:
)
EFTA00030302


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=== Page 1 ===
From:
To: Kathleen DuPont
Subject: Accepted: FW: GHISLAINE MAXWELL Removal Hearing 20mj132-01
Date: Thu, 02 Jul 2020 16:29:33 +0000
Importance: Normal
Attachments: unnamed
EFTA00031868


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=== Page 1 ===
From:
)"
To:
(USANYS)"
CRM)"
Cc:
Subject: RE: Following up
Date: Thu, 25 Jun 2020 22:45:04 +0000
Attachments: Material_Witness_PA_4.02_Final__signed.pdf
The MLAT is attached for reference, thanks.
From:
(USANYS)
Sent: Thursday, June 25, 2020 6:28 PM
To
(CRM)
is
Cc:
Subject: RE: Following up
Thanks,
I appreciate the concern and am open to working to address it, to the extent possible. We, of course,
would never simply turn this material over to a civil litigant, as you suggest. The problem is, irrespective of our intent, this
is not Rule 6 material (unless, of course, he testifies before a grand jury), and we are trying to be mindful of not simply our
criminal case, but obligations we may have under other aspects of U.S. law, FOIA and/or Touhy, spring to mind, for
example. Again, we never voluntarily turn this stuff over, and we frequently oppose FOIA requests and the like to the
extent we can under the law. But particularly given the history and concern, we don't want to make promises we may not
be able to keep.
Do you by any chance have handy a copy of the MLAT itself (if not, certainly happy to locate myself, just figured you might
have it already). I'd like to see what, if anything, the treaty says about this subject.
From:
CRM)
Sent: Thursday, June 25, 2020 2:47 PM
To:
(USANYS)
is
Cc:
Subject: RE: Following up
Thanks. This is helpful. One clarification which they will seek - because it seems to loom
large in their suspicions - is whether his statement will be provided to victims for purposes
of civil litigation. I know this is not something that ordinarily happens (I don't think I have
ever done this) - but I think we need to say something about that to move this forward.
Maybe something like, "Absent a court order directing otherwise, the SDNY will not use or
disclose the statement in any matter other than a criminal investigation, prosecution, or
related asset forfeiture action initiated by the United States government."
What do you think?
From:
(USANYS)
Sent: Thursday, June 25, 2020 7:36 PM
To:
(CRM)
is
Cc:
Subject: RE: Following up
EFTA00029796

=== Page 2 ===
Thanks for your patience. I've now had a chance to raise your suggestion on our end, and we are amenable to
discussing a confidentiality agreement along the lines you propose, with some revisions. Below is our proposed language
which we would be comfortable with. Happy to discuss our position further at your convenience. Thanks, Ted
Prior to the in-person interview:
-
From now until August 14, 2020, neither the witness nor any person representing him will
make any statement to anyone (other than counsel) about the plans for or terms of the
interview. Likewise, the SDNY agrees to make no public comment about the matter during this
period. If an interview has not been concluded by August 14, this confidentiality agreement
will not bar any further public or private comments on the matter.
After an in-person interview:
-
If the witness completes an interview with U.S. law enforcement, both parties may confirm
publicly or privately that: "the witness has met with law enforcement authorities in the United
States and answered questions about matters under investigation. We will not comment
further." Further comment by the witness or any person representing or speaking for him will
void this agreement.
-
The content of the witness's statements to law enforcement as part of any interview arranged
pursuant to the MLA will only be used or disclosed as permitted under U.S. law, including in
connection with a criminal investigation or proceeding, as ordered or authorized by a court in
the United States, or as otherwise required by law.
Nothing in this agreement will bar any party from disclosing to a Court any communications related
to setting up or executing the interview or the contents of the interview.
From
(CRM)
Sent: Tuesday, June 23, 2020 5:00 AM
To:
(USANYS)
in
Cc:
Subject: RE: Following up
Sounds good.
From:
(USANYS)
Sent: Monday, June 22, 2020 10:06 PM
To
CRM)
is
Cc:
Subject: RE: Following up
Thanks
I am in the process of raising this internally on our end, but given recent events, and as I'm sure you can
imagine, it make take me a bit more time than usual to get back to you. I can tell you the conditions below are unlikely to
be acceptable to us as drafted, but provided it is in fact a rough outline, I am working on some proposed modifications
that folks here may be able to get comfortable with. I will circle back when I know more.
From:
(CRM)
Sent: Monday, June 22, 2020 6:50 AM
To:
>;
(USANYS)
Cc:
Subject: Following up
EFTA00029797

=== Page 3 ===
Before this weekend's events, I was planning on writing an email proposing that you put together
some very specific terms for an in-person interview that we can share with the Home Office and the
police force which makes the first formal approach to the witness's solicitors. Most of the terms are
already noted in the MLA request: who will be present, where it will take place (UK), whether it will
be recorded or written, etc. What isn't covered is any kind of a description or agreement about
confidentiality. Absent this, a MLA police interview will get hung up like your efforts at a voluntary
interview.
This weekend's events, which are troubling on many levels, also provide an opportunity in this case.
Blackfords's and the witness's anger have been focused on your former USA's public statements.
They may now have some greater confidence that they can rely on any statements of confidentiality.
Or at least they can now save face by agreeing to an interview. In any event, given the history of this,
I think absent a mutual agreement on confidentiality, this matter will get mired in litigation, and you
may never get the interview.
Here is a rough outline of what might be acceptable on confidentiality. This may give you heartburn,
but I think it is the most expeditious way forward:
Prior to the in-person interview:
-
An agreement that for a period lasting no longer than eight (8) weeks, neither the witness nor
any person representing him will make any statement to anyone (other than counsel) about the
plans for or terms of the interview. Likewise, the USDOJ agrees to make no public comment
about the matter during this period. If an interview has not been concluded within eight
weeks, this confidentiality agreement will not bar any further public or private comments on
the matter.
After an in-person interview:
-
If the witness makes a statement, both parties may confirm publicly or privately that: "the
witness has provided a formal statement to law enforcement authorities in the United States
about matters under investigation. Further comment would not be appropriate." Further
comment by the witness or any person representing or speaking for him will void this
agreement.
-
The content of witness's statement will be treated in the same manner as testimony taken
before a Federal Grand Jury under Fed.R.Crim.P. 6(e). Among other things, unless used in
connection with a criminal proceeding, required to be disclosed in connection with a criminal
proceeding, or otherwise ordered disclosed by a court in the United States, the content of the
statement will not be made public.
Nothing in this agreement will bar any party from disclosing to a Court any communications related
to setting up or executing the interview or the contents of the interview.
Putting something like this together will pave the way for getting the interview done.
Thanks,
U.S. Department of Justice Attaché
EFTA00029798

=== Page 4 ===
United States Embassy - London
U.K. Mobile:
From the U.S
EFTA00029799


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=== Page 1 ===
From:
)"
To:
Subject: FW: travel approval request
Date: Thu, 13 Feb 2020 14:45:43 +0000
Embedded: Booking_Confirmation
--Beverly_Hills,_Feb_25.msg
Hi
Would you please book me for the same hotel as
for these same dates for this trip?
Thanks!
From:
Sent: Thursday, February 13, 2020 1:15 AM
To:
Cc:
is
Subject: FW: travel approval request
just FYI, in connection with this trip to Los Angeles, I just made a reservation for a hotel on E2 (see attached) - if I
did anything wrong, it can be changed, but it's a hotel that is almost never available for us so I wanted to make the
reservation tonight just in case. And will follow up with flights in the coming days. Happy to chat if that's useful, and
thanks very much.
From:
Sent: Wednesday, February 12, 2020 22:55
To:
Cc:
is
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Feb 12, 2020, at 9:14 PM,
)
wrote:
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for three interviews in Los Angeles on February 26, 27, and 28 (we have at
least one interview on each of those days). We expect to be traveling, respectively, some combination of the 25th to the
29th. Also similar to prior trips, we'd like to request approval to get a conference room for one of those dates (the 26th).
thank you,
EFTA00029663

=== Page 2 ===
From:
Sent: Tuesday, January 21, 2020 14:49
To:
Cc:
>;
V.
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), but with an added international
element, we'd like to please request permission for the team to travel next week for an interview near Stockholm,
Sweden, next week on January 29th and/or 30th. We expect to be traveling, respectively, some combination of the 27th
(overnight) to the 31st, depending on when the interview ends up being scheduled, and we'll put final dates on our
formal applications. Also similar to prior trips, we'd like to request approval to get a conference room for one of those
days at a hotel for the interview itself.
Also based on our discussion earlier we'll be mindful of looking for domestic (or domestic-flagged) carrier flights, as well
as the costs of any alternatives, in looking at possible specific bookings. Thanks as always for your help and input on
that.
thank you,
From:
Sent: Wednesday, December 11, 2019 09:58
To:
Cc:
is
V.
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16
and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior trips,
we'd like to request approval to get a conference room for one of those days.
thank you,
From:
Sent: Tuesday, November 05, 2019 16:53
To:
Cc:
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be traveling,
EFTA00029664

=== Page 3 ===
respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip).
thanks,
From:
Sent: Tuesday, October 22, 2019 13:55
To:
Cc:
is
is
i
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
, and
we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel on that Monday for the interview, please.
thanks very much,
From:
Sent: Wednesday, June 12, 2019 14:51
To:
Cc:
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference room at
the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
EFTA00029665

=== Page 4 ===
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
)
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week
for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night
and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
EFTA00029666

=== Page 5 ===
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00029667


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From:
To:
Subject: U.S. V GHISLAINE, MAXWELL
Date: Fri, 17 Jul 2020 21:35:17 +0000
Attachments: k7e2MaxC.pdf
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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
Subject: RE: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Objections to Gov't Proposed
Redactions in Omnibus Response
Date: Tue, 09 Mar 2021 19:56:11 +0000
Attachments: PROPOSED_REDACTIONS_-
2021.02.26_Government_Ommibus_Opposition_to_Maxwell_Defense_Motions_FINALpd
Attached.
From:
(USANYS)
Sent: Tuesday, March 9, 2021 2:54 PM
To:
)
is
USANYS)
Cc:
is
(USANYS)
i
Subject: RE: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Objections to Gov't Proposed Redactions in Omnibus Response
Thanks. When you can would you mind sending us our proposed redactions to pages 1-128?
From:
Sent: Tuesday, March 9, 2021 2:01 PM
To:
(USANYS)
Cc:
is
(USANYS)
is
Subject: FW: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Objections to Gov't Proposed Redactions in Omnibus Response
FYI
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 1:08 PM
To:
Cc:
is
is
(USANYS)
is
)
>; 'BOBBI C STERNHEIM'
; Jeff Pagliuca
Christian R Everdell - Cohen & Gresser LLP
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Objections to Gov't Proposed Redactions in Omnibus Response
Dear Judge Nathan -
Pursuant to Rule 2(B) of the Court's individual rules, attached is a letter setting forth Ms. Maxwell's objections to the
redactions proposed by the government to their Omnibus Response and Exhibit 5. Also attached are exhibits setting forth
Ms. Maxwell's proposed redactions.
Best regards,
Laura A. Menninger
EFTA00030069

=== Page 2 ===
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
Denver, CO 80203
EFTA00030070


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Epstein -- Release of USMS information
Date: Fri, 13 Sep 2019 18:57:12 +0000
OK
From:
(USANYS)
Sent: Friday, September 13, 2019 2:54 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: Re: Epstein -- Release of USMS information
Either works. We can come down at 330.
Sent from my iPhone
On Sep 13, 2019, at 2:46 PM,
(USANYS)
wrote:
3:30 or 4:30.
From:
(USANYS)
Sent: Friday, September 13, 2019 2:26 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein -- Release of USMS information
Let us know if you have some time this afternoon. We have something at 2:30 but are otherwise free.
From:
(USANYS)
Sent: Friday, September 13, 2019 2:01 PM
To:
(USANYS)
is
(USANYS)
V.
(USANYS)
Cc:
(USANYS)
i
(USANYS)
Subject: Epstein -- Release of USMS information
As you are undoubtedly aware, there has been some press coverage since yesterday about the release pursuant to FOIA
of some USMS records. I just spoke with the Associate General Counsel at the USMS, who wanted to provide us with
the actual source materials (USM 11s (equivalent of 302s)) that were inadvertently released, because they were not in
all circumstances accurately reported, and he wanted to make sure that if we are concerned about any harm to our
investigation from the release, that we have the original materials. He also offered to serve as a POC if we have any
questions.
Chief, Criminal Division
United States Attorney's Office, SDNY
EFTA00031629

=== Page 2 ===
EFTA00031630


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=== Page 1 ===
Original Message
From:
Sent: Monday, November 29, 2021 12:33 PM
To:
(USANYS)
Subject: [EXTERNAL] FBI Still Needing Tips Regarding Jeffrey Epstein / Ghislaine Maxwell?
Dear Ms.
-
I feel Jeffrey Epstein &/or Ghislaine Maxwell reached out to me, in July 2019, (around the time he was apprehended) via
Seeking Arrangements (probably just "Seeking" these days.) It was a brief communication out of Palm Beach, but it was
right to the point. The person/people wanted me to be a recruiter and they basically wanted to know if it seemed
appealing to go out partying and "bring home girls to Daddy." This notion seemed wholly cringeworthy with ick-factor
and I don't think I replied in any fashion.
It may be worth the while for the FBI to subpoena Seeking Arrangements' records out of Palm Beach. I feel extremely
confident that Maxwell &/or Epstein were actively using this platform for recruiting. I think they were attracted to me,
because my profile pics looked like her...we could pass for family.
From what you know, is this tidbit important? Does the FBI know about the Seeking Arrangement connection? Should I
be conveying this information to anyone in particular? I'm sort of afraid to become involved, but I also feel everything
should be done so justice can help the young victims.
Thank you,
Sent from my iPad
1
3501.551-001
Page 1 of 1
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA00031299


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: Re: Question from HQ
Date: Sat, 17 Aug 2019 18:39:58 +0000
Sounds like it.
Sent from my iPhone
On Aug 17, 2019, at 11:55 AM,
(USANYS)
wrote:
We got some clarification below. Are you comfortable with us just responding no?
From:
(OIG)
Sent: Saturday, August 17, 2019 11:43 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Question from HQ
As you may know IG
was a prosecutor in the SDNY and I believe he wants to know if the BOP disregarded
requests, directives or court orders from the prosecutors or Judge in the SDNY on the underlying case as it related to
phone use.
I believe HQ wants to know if the SDNY prosecutors office or Judge had any additional requirements, requests, directives
or court orders that the BOP needed to comply with that are above standard BOP policy for his phone use. Such as
specific recording of phone calls made, reporting to the SDNY of when phone calls were made, to whom, discussion
topics, observing or monitoring phone calls, writing memorandums of what they BOP staff may of heard.
U.S. Department of Justice
Office of the Inspector General
New York Field Office
From:
(USANYS)
Sent: Saturday, August 17, 2019 11:28 AM
To:
(OIG)
Cc:
(USANYS)
Subject: Re: Question from HQ
Does "memorialize Epstein's phone calls" mean was SDNY required to keep its own log of Epstein's calls at MCC?
On Aug 17, 2019, at 10:01 AM,
(OIG)
wrote:
EFTA00031007

=== Page 2 ===
I just received clarification on the question that OIG HQ has regarding the underlying case. The question and
clarification are below.
In addition to BOP policies, did SDNY have requirements to memorialize Epstein's phone calls related to the
underlying case? If so, were they followed?
Did BOP need to take notes on the conversation (since it's not recorded) or were they just required to keep a
phone number log?"
U.S. Department of Justice
Office of the Inspector General
New York Field Office
From:
(USANYS)
Sent: Friday, August 16, 2019 8:10 PM
To:
(OIG)
Cc:
(USANYS)
Subject: Re: Question from HQ
What do you mean by "memorialize phone calls"?
On Aug 16, 2019, at 7:17 PM,
(OIG)
wrote:
and
My HQ has the following question on the underlying case, can you please forward this to the prosecutors on the
underlying case? Thank you.
In addition to BOP policies, did SDNY have requirements to memorialize Epstein's phone calls related to
the underlying case? If so, were they followed?
U.S. Department of Justice
Office of the Inspector General
New York Field Office
EFTA00031008


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 20-3061 United States of America V. Maxwell "Oral Argument Statement LR34.1(a) FILED"
Date: Thu, 08 Oct 2020 20:57:12 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 10/08/2020
Case Name:
United States of America V. Maxwell
Case Number: 20-3061
Document(s): Document(s)
Docket Text:
ORAL ARGUMENT STATEMENT LR 34.1 (a), on behalf of filer Attorney
Esq. for Appellant
Ghislaine Maxwell, FILED. Service date 10/08/2020 by CM/ECF. [2948491] [20-3061]
Notice will be electronically mailed to:
Notice will be stored in the notice cart for:
, Deputy Clerk
Calendar E-Box, -
The following document(s) are associated with this transaction:
Document Description: Oral Argument Statement LR34.1(a) FILED
Original Filename: 2020.10.08 Oral argument statement Form 12-2011-FLAT.pdf
Electronic Document Stamp:
EFTA00030581

=== Page 2 ===
[STAMP acecfStamp_ID=1161632333 [Date=10/08/2020] [FileNumber=2948491-0]
[49c2e9b06ae1ad7d5b3231e43cdc6bfe111f974428504321ec7cc545c45f66d5614508a2e424332b967c0d4d3338c
aa5e5a4c52495968837427e0b5a65761fd0]]
EFTA00030582


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=== Page 1 ===
From:
To:
Subject: RE: presentment of Jeffrey Epstein
Date: Mon, 08 Jul 2019 12:49:05 +0000
Importance: Normal
Attachments: 2019-07-08,_JE,_government_unsealing_request_and_proposed_order.pdf
Hi
We sent it to Judge Pitman yesterday but it's also attached - but we scheduled a meeting with Judge Pitman at 9:15 to
unseal and wheel so we'll be down in 15 minutes or so.
thanks,
From:
Sent: Monday. July 08. 2019 08:35
To:
Subject: RE: presentment of Jeffrey Epstein
please present unsealing order at your earliest
From:
To:
Cc:
Date:
07/07/2019 11:11PM
Subject:
RE: presentment of Jeffrey Epstein
Good evening,
We will formally call this in tomorrow morning, but we wanted to advise you that we expect that defendant Jeffrey Epstein will be
presented tomorrow in United States V. Epstein, 19 Cr. 490. We expect the indictment to be unsealed first thing tomorrow morning,
and we'll get you a copy immediately when that occurs. Mr. Epstein is represented by retained counsel, including Martin Weinberg
and Reid Weingarten.
We are available anytime tomorrow to provide any useful information in connection with your report, either at the email addresses
here or via phone at the following numbers:
thank you,
EFTA00030226


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10621156 approved by
, now awaiting further
approval
Date: Thu, 12 Sep 2019 16:52:40 +0000
Importance: Normal
Dear
Travel authorization 10621156 has been approved by
now awaiting further approval.
Trip ID: 10621156
Traveler name:
Purpose: R19NYS13832 - U.S. V. Epstein (2018R0618) - Victim Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-09-09 - 2019-09-10
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0007
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00031310


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=== Page 1 ===
From:
)"
To:
Cc:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
(USANYS)"
Subject: Maxwell - new discovery production
Date: Tue, 20 Oct 2020 13:51:14 +0000
Attachments: 2020.10.20_MDC_-_Maxwell_MAIN.pdf;2020.10.20_MDC_-_Maxwell_PASSWORD.pdf
Hi
Today we are sending a new drive containing additional discovery materials for Ghislaine Maxwell to the MDC via FedEx.
Attached please find the accompanying cover letters to the MDC.
Would you please keep an eye out for the drive and let us know when it has been given to Maxwell?
Thanks very much,
Assistant United States Attorney
Southern District of New York
EFTA00030550


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=== Page 1 ===
From:
"
)"
To:
"
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Cc:
"
)"
(USANYS)"
,
)"
Subject: testifying witness notes
Date: Mon, 16 Aug 2021 23:28:33 +0000
Attachments: 2021.08.16
prep_notes.pdf
Hi
and
Would you please save the attached pdf in
testifying witness 3500 folder and in his witness folder on the
Epstein share?
Thanks,
EFTA00030490


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=== Page 1 ===
From:
)"
To:
Subject: Read: Question re Epstein Relativity
Date: Mon, 15 Mar 2021 14:08:47 +0000
EFTA00031905


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=== Page 1 ===
From:
To:
Cc:
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) Renewed Bail Motion and Exhibits (to be
Filed Under Seal)
Date: Tue, 08 Dec 2020 22:26:12 +0000
Attachments: Memorandum_re_Second_Bail_Application_Final_Redacted.PDF;
Exhibit_A_Redacted.pdf_Exhibit_B_Redacted.pdf;_Exhibit_C_Redacted.pdf
Exhibit_D_Redacted.pdf; Exhibit_E_Redacted.pdf
Inline-Images: image001.gif; image004.jpg
Dear Judge Nathan -
Attached please find the following documents submitted to the Court and all counsel under seal pursuant to the Court's
order (Dkt. 89):
1. Renewed bail motion (redacted)
2. Accompanying exhibits A-E (redacted)
Regards,
Christian R Everdell
COHEN & GRESSER LLP
I
view bio
www.cohengresser.com
New York I Paris I Washington DC I London
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.
EFTA00030756


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: Tuesday - tasks
Date: Tue, 04 Feb 2020 00:58:54 +0000
From:
(USANYS)
Sent: Monday, February 3, 2020 7:58 PM
To:
(USANYS)
Subject: Tuesday - tasks
3.
Epstein trust documents
EFTA00030787


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=== Page 1 ===
Independent
Epstein Victims' Compensation Program
PROTOCOL
DRAFT1
December 13, 2019
I.
Purpose and Overview
The Epstein Victims' Compensation Program (the "Program") is a voluntary, independent Program that
has been established to compensate and resolve the claims of victims/survivors of sexual abuse by Jeffrey
Epstein ("Epstein").
The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims
administration experts Kenneth R. Feinberg, Camille S. Biros and Jordana H. Feldman to design the
Program. Ms. Feldman will also serve as the Administrator of the Program (the "Administrator").
Through the Program, the Estate wishes to acknowledge the wrongs endured by victims/survivors and
offer them an opportunity to voluntarily resolve their individual claims for such sexual abuse.
The Program is governed by the following non-exclusive guiding principles:
The Program is purely voluntary. It does not affect any rights a victim may have
unless and until the Claimant accepts the offered compensation and executes a
Release. A Claimant may reject the offer of compensation and may stop participating
in the Program and withdraw the claim at any time prior to execution of the Release.
The Program is independent and will in no way be administered, controlled or
overseen by the Estate. The Administrator is responsible for all decisions relating to
the review, processing and evaluation of individual claims submitted to the Program.
The Administrator will have final, binding and exclusive authority to determine
Claimant eligibility and the valuation of each eligible individual claim. Decisions of
the Administrator made pursuant to this Protocol are not subject to review or
modification in any way by the Estate or any other party or entity.
There is no cap or limitation on the aggregate amount of funds available to
compensate all eligible Claimants or on the amount of compensation to be made to
each individual Claimant. Each individual claim will be evaluated separately by the
Administrator. The Administrator will determine, in her sole and exclusive discretion,
issues of eligibility and the amount of compensation.
1 This document is a draft of the Protocol governing the Program and is subject to input from victims/survivors, their lawyers,
other potentially interested parties, and representatives of the Estate.
1 I Page
EFTA00030441

=== Page 2 ===
All Claimants will be treated with respect, dignity and fairness without regard to race,
color, sexual orientation, national origin, religion, gender or disability. To ensure
claims will be adjudicated fairly, the Administrator will manage the process so that
all Claimants can equally access the Program's claim process. Individuals with
disabilities will be given the opportunity to effectively communicate their claims and
to request special process accommodations.
The Program will be effective within 90 days of approval by the Superior Court of the U.S. Virgin Islands
("Effective Date")² and is available to all victims/survivors regardless of where they were harmed, when
they were harmed, whether the claim is time-barred by the applicable statute of limitations, and whether
they have previously filed a lawsuit against or settled with Epstein and/or the Estate.
The exclusive claims period for filing a claim pursuant to this Protocol shall commence on the to-be-
determined Effective Date and shall conclude nine (9) months after that date ("Filing Deadline"). All
individual claims filed with the Program must be postmarked within this period.
II.
Eligibility Requirements
A. Eligibility Criteria
The persons eligible to participate in this Program are individuals who allege they were sexually abused
by Epstein. In addition, the following criteria apply:
The claim of sexual abuse must be directed against Epstein.
An individual whose claim is time-barred by the applicable statute of limitations may participate
in the Program provided that other eligibility criteria are met.
An individual who previously entered into a settlement agreement resolving a claim of sexual
abuse against Epstein may participate in the Program provided that other eligibility criteria are
met.
An individual who allegedly assisted Epstein in procuring other victims/survivors may participate
in the Program where there is a credible basis to determine that the individual acted under
duress as a result of her own sexual abuse by Epstein, provided that other eligibility criteria are
met.
If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with
prejudice any existing lawsuits or legal actions or claims filed against the Estate or related entities
and/or individuals. The Claimant must provide proof of such dismissal along with or prior to the
signed acceptance letter and executed Release in order to receive payment.
2 The final version of the Protocol will include dates certain identifying the commencement date of the Program and
registration and filing deadlines, as explained below.
2 I Page
EFTA00030442

=== Page 3 ===
B. Legal Representatives of Claimants
An individual may file a claim on a victim's behalf where that individual has been granted legal authority
to act in a representative capacity pursuant to appropriate law. The "Legal Representative" of an
individual Claimant shall mean: (1) in the case of a Claimant who is currently a minor, a parent or legal
guardian authorized by law to serve as the minor's legal representative; (2) in the case of an incompetent
or legally incapacitated Claimant, a person who has been duly appointed as the Claimant's legal
representative in accordance with applicable law; or (3) an attorney authorized to represent the Claimant
for purposes of pursuing a claim through this Program.
Legal Representatives must provide proper documentation demonstrating representative capacity. Such
proof may include a power of attorney, documentation showing the individual's appointment as guardian
or guardian ad litem, or a copy of a retainer agreement showing legal representation signed by both the
Claimant and the attorney.
III.
Claims Administration - Submission, Evaluation and Determination
A. Claims Submission Process
Individuals who have filed a lawsuit, legal action or claim against Epstein and/or the Estate on or before
the Effective Date will be sent a Claim Form and other relevant Program information, including
Instructions for completion and submission of the Claim Form and a list of Frequently Asked Questions.
Individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the Estate on or
before the Effective Date may register to participate in this Program on the Program's website at
www.EpsteinVictimsCompensationProgram.com.3 To register, such individuals must complete a
questionnaire setting forth their name, contact information, a summary description of the nature of the
claim and other requested information. Upon registration, the Administrator will perform a preliminary
review to consider if the individual is eligible to participate in the Program. If the Administrator deems
that the individual is eligible to participate in the Program, she will then send that individual a Claim Form
and other relevant Program information.
Note: The fact that an individual is sent a Claim Form and other relevant Program information indicates
that the Administrator has determined that such individual is eligible to participate in the Program. It
does not indicate that the Administrator has determined that such individual is eligible to receive
compensation. That determination is made only after a Claim Form and all required documentation has
been submitted and evaluated by the Administrator.
Registrations will be accepted by the Administrator from the Effective Date through a date that is 45 days
prior to the Filing Deadline ("Registration Deadline"). It is important to note that the Registration Deadline
is separate from, and precedes, the Filing Deadline. As explained above, all claims must be filed by the
Filing Deadline.
3 This website is in the process of being developed and is yet operational.
3 I Page
EFTA00030443

=== Page 4 ===
All Claim Forms must be completed and postmarked no later than the Filing Deadline. Claim Forms
should be mailed via overnight courier (a pre-paid courier voucher will be included with each packet) to
the Administrator at the following address or uploaded to the Program website at
www.EpsteinVictimsCompensationProgram.com
Epstein Victims' Compensation Program
c/o Jordana H. Feldman, Administrator
[Address - To Be Inserted]
Claimants are invited to provide documentation identified in the Claim Form, and any other corroborating
or supporting information sufficient to substantiate the claim, satisfy eligibility requirements, and allow
the Administrator to review, process and evaluate the claim. If the claim is being presented by a Legal
Representative, then the Legal Representative will be responsible for submitting the necessary
documentation relating to the represented Claimant.
Additional documentation may be requested at the discretion of the Administrator. Both the Claimant
and the Estate will be afforded the opportunity to submit to the Administrator any information deemed
relevant to the Administrator's evaluation and determination of the claim before the Administrator's final
disposition of the claim.
If a Claimant submits an incomplete or deficient claim, the Administrator will notify the Claimant, explain
the additional information that is needed, and work with the Claimant or the Claimant's Legal
Representative (where applicable) to assist in submitting a complete claim.
B. Claims Evaluation and Determination
Claims will be evaluated in the order in which they are received, with the Administrator evaluating each
submitted individual claim in a prompt and fair manner. Claims will only be determined once all required
documentation has been submitted to the Administrator
1. Factors Considered in Evaluating Claims
As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
information available, whether the allegations of sexual abuse are credible. The Administrator will
consider appropriate factors and corroborative support, including but not limited to:
The level of documentation, corroboration or other circumstantial evidence regarding the nature
and extent of the abuse, the frequency, location and other details of the abuse, and the age of
the victim at the time of the abuse. Non-exhaustive examples of such evidence include (i)
medical or psychiatric counseling/therapy records relevant to the abuse, and
(ii) contemporaneous written notification or other correspondence (e.g., letters, emails) of the
abuse by the Claimant to law enforcement authorities, parents, friends or others.
Whether there exists any information and/or pertinent findings offered by the appropriate
Office of the District Attorney or other law enforcement agency.
4 I Page
EFTA00030444

=== Page 5 ===
Whether the Administrator finds the claims of the individual to be credible after complete review
of all relevant documentation and other evidence provided by the Claimant and the Estate.
As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
information available, the amount of compensation that should be offered to each eligible Claimant. The
Administrator will consider appropriate factors and corroborative support, including but not limited to:
The nature, duration and extent of the sexual abuse suffered by the Claimant.
The age of the Claimant at the time of the sexual abuse.
The nature and extent of the Claimant's physical or psychological damage resulting from the
sexual abuse, and the effect of the sexual abuse on the Claimant.
The credibility of the claim based upon all of the facts and circumstances, supporting
documentation and corroborating evidence.
Whether the claim is time-barred under the applicable statute of limitations.
Whether the Claimant previously entered into a settlement agreement with Epstein and received
a payment pursuant to such agreement.
The Administrator will confidentially send the Claimant a compensation determination letter including the
following: (1) the Administrator's eligibility decision regarding the claim; (2) the amount of compensation
offered; (3) a Release to be signed by the Claimant if the Claimant accepts the offered compensation; and
(4) a Payment Option Form. The Administrator's offer shall be valid for 60 days from the date of the
compensation determination letter.
The Administrator's determinations in this Program will not be binding on any potential criminal
investigation involving the same or similar allegations or Claimant.
2. Opportunities to be Heard
The Claimant will be afforded an opportunity to be heard, either before or after the Administrator renders
her determination. Upon request by the Claimant, the Administrator will be available to meet in person,
by video conference/Skype, or by teleconference to further discuss the claim. These meetings are
completely optional and voluntary. Requests to meet with the Administrator should be sent by email
claimantservices@epsteinvictimscompensationprogram.com and will be scheduled at a mutually
convenient time and location. The Administrator may also request a meeting with a Claimant or her Legal
Representative at a reasonable mutually convenient time and location, though the Claimant is not
obligated to attend any such meeting.
4 This email address is not yet active.
5 I Page
EFTA00030445

=== Page 6 ===
3. Release
By submitting a claim to the Program, a Claimant is seeking to resolve all claims relating to allegations of
sexual abuse against Epstein and/or the Estate, related entities and/or individuals. If a Claimant chooses
to accept the offer of compensation pursuant to the Program, the Claimant will be required to sign and
execute a full Release, in a form satisfactory to the Estate, of all past and future claims relating to such
allegations of sexual abuse against the Estate, related entities and/or individuals. A Claimant may reject
the offer of compensation and may stop participating in the Program and withdraw the claim at any time
prior to the execution of the Release.
The Release will waive any rights the Claimant and her heirs, descendants, legatees or beneficiaries
may have to assert any claims relating to allegations of sexual abuse against the Estate, related entities
and/or individuals, to file an individual legal action relating to such allegations, or to participate in any
legal action associated with such allegations, except as a witness. However, the Release will not
operate to preclude or limit the Claimant's ability to report and discuss allegations of sexual abuse with
law enforcement officials or anyone else.
Before signing a Release, the Claimant must consult with an attorney. If the Claimant is not represented
by an attorney, the Program will provide an attorney to provide free legal counseling to the Claimant
for the sole purpose of advising the Claimant concerning the language and binding nature of the
Release.
No one affiliated with the Program will provide tax or legal advice to those receiving payments under
the Program. Claimants are urged to consult with a tax advisor concerning any questions regarding tax
liability for payments pursuant to the Program.
4. Payments
Upon the Claimant's acceptance of the Administrator's determination, the Administrator's receipt of
the Claimant's executed Release and, where applicable, dismissal with prejudice of any existing lawsuit
or legal actions or claims against the Estate or related entities and/or individuals, the Administrator will
initiate payment by check or electronic funds transfer to each eligible Claimant as directed by the
Claimant. Checks will be sent to Claimants via overnight courier service.
C. Program Integrity
For the purpose of protecting both the integrity of the Program and financial resources for eligible
Claimants, the Administrator will institute all necessary measures to prevent payment of fraudulent
claims, including taking steps to verify claims and analyze submissions for inconsistencies, irregularities
or duplication.
6 I Page
EFTA00030446

=== Page 7 ===
Each Claimant who signs the Claim Form at the time of submission certifies that the information provided
in the Claim Form is true and accurate to the best of the Claimant's knowledge, and that the Claimant
understands that false statements or claims made in connection with such submission may result in fines,
imprisonment and/or any other remedy available by law. Claims that appear to be potentially fraudulent
or to contain false information will be forwarded to federal, state or local law enforcement agencies
and/or the appropriate Office of the District Attorney for possible investigation and prosecution.
D. Confidentiality/Privacy
The Program is confidential. By filing a claim with the Program, the Claimant or her Legal
Representative (where applicable) agrees that information submitted by the Claimant pursuant to the
Program will be used and/or disclosed by the Administrator and her designees only for the following
purposes:
1) Processing and evaluating the Claimant's claim;
2) Administering the Program and other Program-related work; and
3) Reports to law enforcement where appropriate.
When documents maintained or submitted by the Estate become part of a Claimant's file for purposes
of the Program, such materials will be reviewed by the Administrator to assist in processing and
evaluating the claim, but will otherwise remain confidential. These files are not available for inspection,
review or copying by the Claimant or her representatives during or after the Program, and all pertinent
settlement privileges and other privileges apply.
To protect the privacy of Claimants participating in the Program, all personal information provided by
the Claimant during this process will be returned or destroyed within one year after the conclusion of
the Program.
Individual Claimants are not bound by any rules of confidentiality. Claimants may, at their sole and
voluntary option, disclose information in their possession regarding their claim, their compensation and
their experience with the Program.
All confidentiality requirements are subject to law, regulation and judicial process.
The Administrator may, on a periodic basis, publish reports regarding the Program's claims processing or
other activities in an effort to provide transparency. Such reports will report on an aggregate level only.
No individual Claimant information will be published or disclosed in a way that compromises Claimant
confidentiality.
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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
(USANYS)
[Contractor]"
Subject: RE: Maxwell discovery
Date: Tue, 22 Dec 2020 16:55:44 +0000
Thanks so much,
Really appreciate you staying on top of this.
From:
(USANYS) [Contractor]
Sent: Tuesday, December 22, 2020 11:43 AM
To:
)
is
(USANYS) [Contractor]
Subject: RE: Maxwell discovery
Hey
!
I checked with IT a couple times last week, and since
has been out of the office for quite a bit, it
seems as if many projects have been put on hold. My understanding, though, is that
/IT have been working on
creating a copy of the Confidential items on a hard drive for us to give to the FBI, as well as a separate hard drive for our
office to have that will contain everything we produced in the Sixth Production.
Unfortunately, for the last two weeks or so, I've been having trouble connecting with anyone and getting a clear answer
on its progress. I talked with Ken two weeks ago, and he said he'd confirm with
and get back to me. I followed up,
but still have heard nothing. Then, I talked with
from IT on Friday morning, and he said that he would give
a call
Friday afternoon to check on the drive we had requested. He thought that it was still copying, but he was going to double
check on its status. I followed up with
Friday afternoon and again yesterday afternoon, but haven't heard anything
back. l'll follow up again today and hopefully will get a response! I'll keep you posted.
Thank you for your patience! Hopefully we'll get this resolved soon.
From:
Sent: Tuesday, December 22, 2020 11:34 AM
To:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: Maxwell discovery
Hi
and
No rush at all, but I wanted to check in to see what the plan is for getting copies of all the identified Confidential
images/videos from Epstein's devices over to the FBI. I'd like the case agents to have a complete set of those materials,
but it is certainly not time sensitive. Whenever you get a chance to update me on the plan, I'd appreciate it.
Thanks,
EFTA00030178


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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: draft letter to Netburn
Date: Wed, 22 Jul 2020 18: 19:09 +0000
Attachments: 2020-07-22_JE_letter_to_Netburn_re_order_on_unsealing.moe.docx
Here are some proposed edits. Thanks for drafting this.
From:
Sent: Wednesday, July 22, 2020 1:55 PM
To:
Cc:
Subject: RE: draft letter to Netburn
No problem, totally understand.
From:
Sent: Wednesday, July 22, 2020 13:55
To:
Cc:
Subject: Re: draft letter to Netburn
Sorry guys I can't. I keep getting kicked off the vpn, and I'm fighting with my computer, so I haven't been able to do nearly
as much work as I had planned this afternoon.
On Jul 22, 2020, at 1:52 PM,
wrote:
So I obviously had to do this pretty quickly today, and it doesn't help that Westlaw has been down all afternoon, but one
way or the other we gotta get something filed. Does either of you have a moment to take a look at this in the next hour
or so?
I'm sorry, I know you have something at 2:00! If the answer is no, totally understand, I can just pass it
up to
and
Thanks either way and talk soon.
<2020-07-22, JE, letter to Netburn re order on unsealing.docx>
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=== Page 1 ===
From:
)"
To:
)"
Subject: Look into
Date: Sat, 27 Jul 2019 15:38:38 +0000
Epstein
EFTA00030519


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=== Page 1 ===
From:
Subject: RE: MCC case
Date: Tue, 22 Oct 2019 17:01:50 +0000
Yep, I'm around.
From:
Sent: Tuesday, October 22, 2019 1:01 PM
To:
Subject: RE: MCC case
That would be great, thanks - can I swing by?
From:
Sent: Tuesday, October 22, 2019 12:59 PM
To:
is
Subject: RE: MCC case
Will take a look. In the interim, have something else you may be interested in if you have a moment.
From:
Sent: Tuesday, October 22, 2019 11:
AM
To:
is
Subject: MCC case
I just read the attached opinion in a civil case (it came on my radar because Judge Pauley made a comment about
Epstein's death at MCC) - I was wondering if you knew whether our office ever investigated the guards involved in this.
This was a 2015 incident, but it's still within the statute of limitations, and seems quite serious.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
Event: Call/Meeting on Epstein
Start Date: 2018-12-07 16:00:00 +0000
End Date: 2018-12-07 17:00:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Date Created: 2018-12-07 02:58:21 +0000
Date Modified: 2018-12-07 02:58:21 +0000
Priority: 5
DTSTAMP: 2018-12-07 02:48:09 +0000
Attendee:
(USANYS) [Contractor]
i
(USANYS)
EFTA00029656


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=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:12:44 +0000
Inline-Images: image001.png
Thanks man!
From:
Sent: Thursday, July 02, 2020 13:28
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congrats! I was in NH visiting my parents yesterday. If I had only known, I would have offered to handle 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 SOFFICE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
EFTA00031482

=== Page 2 ===
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00031483

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
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=== Page 1 ===
From:
"
)"
To:
"
Cc:
)"
)"
(
)"
Bcc: "USAHUB-USAJournal111"
Subject: Re: Epstein investigation
Date: Mon, 26 Oct 2020 21:46:17 +0000
Embedded: Re:_Epstein_investigation.msg
Sender:
Subject: Re: Epstein investigation
Message-Id: <F97D5997-BD3F-467E-A3D4-4F8733AED00B@usa.doj.gov>
Cc:
Cc:
EFTA00030565


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=== Page 1 ===
From:
)"
To:
Subject: Fact witness travel form - Maxwell victim & family
Date: Mon, 16 Aug 2021 14:09:56 +0000
Attachments:
-_Fact_Witness_Travel_Request.docx
Hi
Attached please find the fact witness travel form for the Maxwell victim we've previously discussed. l'll swing by your
office ot chat about this in a bit.
Thanks,
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=== Page 1 ===
From: Sigrid McCawley
To:
)"
Subject: RE: Filing
Date: Tue, 15 Dec 2020 14:49:15 +0000
Thanks
- is your filing date today or tomorrow?
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Tuesday, December 15, 2020 9:41 AM
To: Sigrid McCawley
Subject: RE: Filing
Hi again,
My colleagues just pointed out that a letter addressed to Judge Nathan may be the most natural format for this pdf. But
we of course defer to you and
regarding how she would like to format this statement.
Best,
From:
Sent: Tuesday, December 15, 2020 9:35 AM
To: Sigrid McCawley
Subject: RE: Filing
Hi Sigrid,
Thank you very much for sending this along. We do not need this to be a signed declaration, but it would helpful if you
could please provide
statement in a separate pdf with whatever attribution she is comfortable with. We will plan
to publicly file that pdf as an exhibit to our memorandum of law in opposition to the bail motion.
Feel free to call my cell
if you'd like to discuss or have any questions.
Best,
From: Sigrid McCawley
Sent: Monday, December 14, 2020 8:39 PM
To:
Cc: Sigrid McCawley
Subject: Filing
Hello
I hope you are doing great. This is the statement that
would like to submit. What format would you like me to send
it in? Should it be as a signed declaration? She is comfortable having it attributed to her name.
"I appreciate the opportunity to again be heard by the Court in this matter and once more request that
Ghislaine Maxwell not be released prior to her trial. I write this not only on behalf of myself, but all of the other
girls and young women who were victimized by Maxwell. Ghislaine Maxwell sexually abused me as a child and
the government has the responsibility to make sure that she stands trial for her crimes. I do not believe that will
happen or that any of her victims will see justice if she is released on bail. She has lived a life of privilege,
abusing her position of power to live beyond the rules. Fleeing the country in order to escape once more would
fit with her long history of anti-social behavior.
EFTA00031821

=== Page 2 ===
Drawing on my personal experience with Maxwell and what I have learned of how she has lived since that time,
I believe that she is a psychopath. Her abuse of me and many other children and young women is evidence of
her disregard for and violation of the rights of others. She has demonstrated a complete failure to accept to
responsibility in any way for her actions and demonstrated a complete lack of remorse for her central role in
procuring victims for Epstein. She was both charming and manipulative with me during the grooming process,
consistent with what many of her victims have described. She has frequently lied to others, including
repeatedly lying about me and my family. Maxwell has for decades lived a parasitic lifestyle relying on Epstein
and others to fund her lavish existence.
Maxwell has repeatedly demonstrated that her primary concern is her own welfare, and that she is willing to
harm others if it benefits her. She is quite capable of doing so once more. She will not hesitate to leave the
country irrespective of whether others will be on the hook financially for her actions because she lacks
empathy, and therefore simply does not care about hurting others. She would in fact be highly motivated to flee
in order to reduce the possibility of continued imprisonment, the conditions of which she has continuously
complained. Her actions over the last several years and choice to live in isolation for long periods suggest that
being comfortable is more important to her than being connected. Even more concerning, is if she is let out she
has the ability to once again abuse children and the painful consequences of that type of trauma can last a
lifetime. I implore the Court to make sure that Ghislaine Maxwell does not escape justice by keeping her
incarcerated until her trial."
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among
other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not
the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or other use
of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this
electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
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From:
To:
Subject: civil complaint
Date: Fri, 21 Feb 2020 20:53:25 +0000
Attachments: civil_complaint.pdf
Do you happen to know which victim/accuser this is? The allegations are from 1999.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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From:
To:
Subject: RE: Maxwell
Date: Thu, 02 Jul 2020 21:22:45 +0000
Thanks C
From:
Sent: Thursday, July 2, 2020 10:52 AM
To:
Subject: FW: Maxwell
Congrats! I know it's been challenging, in so many ways. And it's a huge accomplishment.
From:
Sent: Thursday, July 02, 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.
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From:
"
=
To:
)"
Subject: Accepted: Meet re Epstein forfeiture
Date: Wed, 04 Dec 2019 19:04:24 +0000
Importance: Normal
Attachments: unnamed
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Case 1:20-cr-00330-AJN Document 81 Filed 12/03/20 Page 1 of 2
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 12/3/20
SOUTHERN DISTRICT OF NEW YORK
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
On November 25, 2020, counsel for Defendant Ghislaine Maxwell filed a letter request
seeking an in camera conference for the presentation of a renewed motion for release on bail and
a request to seal the November 25, 2020 letter in its entirety. The Court required justification for
the sealing request. On November 30, 2020, the defense counsel filed a second letter no longer
fully pressing the unsupported request to file the letter entirely under seal and instead proposing
redactions to both the November 25th and November 30th letters. The Government has
indicated that it does not oppose the redactions. Dkt. No. 80.
After due consideration, the Court will adopt the Defendant's proposed redactions, which
are consented to by the Government. The Court's decision is guided by the three-part test
articulated by the Second Circuit in Lugosch V. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir.
2006). Under this test, the Court must: (i) determine whether the documents in question are
"judicial documents;" (ii) assess the weight of the common law presumption of access to the
materials; and (iii) balance competing considerations against the presumption of access. Id. at
119-20. "Such countervailing factors include but are not limited to 'the danger of impairing law
enforcement or judicial efficiency' and 'the privacy interests of those resisting disclosure." Id.
at 120 (quoting United States V. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) ("Amodeo II")).
1
EFTA00030910

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 81 Filed 12/03/20 Page 2 of 2
The proposed redactions satisfy this test. First, the Court finds that the Defendant's letter
motions are "relevant to the performance of the judicial function and useful in the judicial
process," thereby qualifying as a "judicial document" for purposes of the first element of the
Lugosch test. United States V. Amodeo ("Amodeo "), 44 F.3d 141, 145 (2d Cir. 1995). And
while the Court assumes that the common law presumption of access attaches, in balancing
competing considerations against the presumption of access, the Court finds that the arguments
the Defendant has put forth-including, most notably, the privacy interests of the individuals
referenced in the letters-favor her proposed and tailored redactions. The Defendant is hereby
ORDERED to docket the redacted versions of the two letters by December 4, 2020.
For the reasons outlined in the Government's letter dated December 2, 2020, Dkt. No. 80,
the Court DENIES the Defendant's request for an in camera conference. In order to protect the
privacy interests referenced in the Defendant's November 25, 2020 letter, the Court will permit
the Defendant to make her submission in writing and to propose narrowly tailored redactions.
The parties are hereby ORDERED to meet and confer and to jointly prepare a briefing
schedule for the Defendant's forthcoming renewed motion for release on bail.
so ORDERED.
Alim D. Netto
Dated: December 3, 2020
New York, New York
ALISON J. NATHAN
United States District Judge
2
EFTA00030911


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
)"
(USANYS)"
Cc:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Subject: Sixth Production
Date: Mon, 09 Nov 2020 19:06:58 +0000
Attachments: US_v_Maxwell_Discovery_Index.xlsx; 2020.11.09_Maxwell_Discovery_Letter.docx
Hi all!
Great news - after I've reviewed, the drive going to defense today has all the required items for production! I believe we
will be uploading NYC024318 1B71 (iPhone) to this drive (and I've noted the tentative bates number for that on the index,
attached here and updated on the shared, and in the cover letter, attached) - but other than that, we are all set.
I've attached a (very basic) cover letter for defense, for your review and relevant additions. Since we are reproducing so
much to MDC, I also created a unique index for the MDC drive on the shared index. I can attach that chart to defense's
cover letter when it goes out, if that would be helpful, or I can just keep the MDC index section for our internal
organization.
is still working on copying the MDC drive. Hopefully we'll have an update soon. I'm happy to make any changes
within the cover letter and/or index as necessary. Thank you all!
Paralegal Specialist
U.S. Attorney's Office
SDNY
EFTA00030562


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=== Page 1 ===
Fron
T
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:27:47 +0000
Inline-Images: image001.png
Hey thanks very much!!
From:
Sent: Thursday, July 02, 2020 13:25
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congrats, team!
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 OFFICE SESTICE
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,
EFTA00031485

=== Page 2 ===
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00031486

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00031487


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=== Page 1 ===
From:
To:
Subject: Final Voucher 10894369(1) has received final approval
Date: Fri, 10 Jan 2020 15:35:55 +0000
Importance: Normal
Dear
Final voucher 10894369(1) has received final approval.
Trip ID: 10894369
Voucher ID: 1
Voucher type: Final
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R20NYS13261 - U.S. V. Epstein - Witness Interviews
Destination: Santa Monica (City), CA, United States
Dates: 2019-12-15 - 2019-12-17
Current status: Voucher Awaiting Payment
Voucher total expenses: 1296.43
Estimated trip cost: 1662.95
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# V0008
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.
EFTA00031826


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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From: AUSA
Date: August 16, 2021
Re:
United States V. Ghislaine Maxwell
Court Docket No: 20 Cr. 330 (AJN)
USAO No: 2018R01618
Witness-1 Name:
Witness-1 DOB:
Witness-1 Address:
Witness-1 TelNos
Witness-1 e-mail:
Witness-2 Name:
Witness-2 DOB:
Witness-2 Address:
Witness-2 TelNos
Witness-2 e-mail:
Witnesses Needed to Appear in SDNY on Dates: August 25-27, 2021
Witness Needed to Appear for:
Trial ( )
Date:
Grand Jury ( )
Date:
Trial Prep (X)
Dates: Both witnesses needed for prep on 8/25, 8/26, and 8/27
Estimated Dates Witness will Arrive: August 24, 2021
Depart: August 29, 2021
Is the person a Fact Witness and not an Expert Witness?
(Yes/No):
Yes for both
Current Federal Civilian or Military Employee?
(Yes/No):
No for both
Is the Witness Facing Criminal Charges?
(Yes/No):
No for both
Does the Witness Reside Outside the Continental United States?
(Yes/No):
No for both
Is this Witness a Victim-Witness?
(Yes/No): Yes fo
No for
Hotel Required?
(Yes/No):
Yes for both
rev. 2019.11.19
EFTA00031454

=== Page 2 ===
Has the Witness advised you of any unusual travel expenses?
(Yes/No):
Yes
Unusual expenses of fact witnesses can include
special travel arrangements
care for dependent child or incapacitated family member left at home
kennel fees for pets
necessary travel companion
extra baggage (more than one bag)
Please describe the unusual expense:
We are requesting that
husband and three minor children travel with
and
for this trip. The process of preparing to testify about years of childhood sexual abuse is
extremely traumatizing for
and she relies heavily on her family, including her husband
and mother, for emotional support.
has struggled significantly with flashbacks and relived
trauma as a result of trial preparation and the significant extent of the sexual abuse she suffered at
the hands of Jeffrey Epstein, so the presence of her husband and mother on this trip is essential for
her wellbeing and ability to prep.
her husband, and
are the sole caretakers for
minor children. In order for
her husband, and
to travel together to
New York, where we will prepare both
and
to testify at trial, they will also need
to bring
minor children.
The husband's information is below:
Name:
DOB:
Addres
TelNos
e-mail:
Information for minor children is below:
Name:
DOB:
Name:
DOB:
Name:
DOB:
For Victim-Witness Coordinator:
1. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW
is apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
rev. 2019.11.19
EFTA00031455

=== Page 3 ===
2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should
be used.
For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to
court/GJ testimony.
Witnesses may only be brought in under the FEWS appropriation for grand jury testimony that
has been scheduled and where the witness is expected to testify before the grand jury; court
testimony; or preparation for same. Any other witness travel, e.g., for investigative interviews,
must be covered by the investigating component from litigative funds. See Ed Tyrrell.
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
EFTA00031456


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=== Page 1 ===
COHEN & GRESSER LLP
File Request from Thomas Powers at COHEN & GRESSER LLP
D==
SDNY_GM_02742044-2742183.zijp
Uploaded
3.55 MB


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=== Page 1 ===
From
To:
Subject: Epstein production question
Date: Sat, 09 Nov 2019 22:29:08 +0000
Hey there's no rush or emergency on this, but after the weekend I want to get just a quick rundown of what we've given
to
in terms of
- he said he didn't have some stuff so I just want to get a handle
on what went over to him. Thanks man.
Assistant U.S. Attorney
Southern District of New York
EFTA00030751


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
November 24, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
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 materials are
stamped with control numbers SDNY_GM_02775073 through SDNY_GM_02775777.
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. The Department of Justice directed this office to cease the dissemination of materials
marked with the word "confidential" in order to avoid potential confusion with markings reserved
for classified documents. Accordingly, in order to note the appropriate designation of this
production under the operative Protective Order in this case, the materials being produced today
are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,
8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective
Order that govern today's production.
An index of the materials contained in this production is below:
EFTA00031111

=== Page 2 ===
Page 2
Bates Start
Bates End
Summary Description
Confidential Designation
SDNY GM 02775073
SDNY GM 02775087
JPMC records
Confidential
SDNY GM 02775088
SDNY GM 02775777
Lockheed Martin records
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,
DAMIAN WILLIAMS
United States Attorney
by: s/
Assistant United States Attorneys
EFTA00031112


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=== Page 1 ===
From:
(ODAG)"
To:
(USANYS)"
Subject: FW: Epstein MCC CO charges
Date: Fri, 11 Oct 2019 17:55:31 +0000
Hi Audrey - I received the question below a little earlier, so am reaching out to inquire. Thanks.
***
When is SDNY planning to indict?
EFTA00029999


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Voucher for Trip 10643456-2 is late
Date: Sun, 13 Oct 2019 04:03:03 +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: 10643456-2
Traveler name
Destination: Santa Monica
Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews
Trip Dates: 2019-09-17 - 2019-09-20
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.
EFTA00031098


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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: RE: Epstein search materials for upload and privilege review
Date: Thu, 20 Feb 2020 19:28:58 +0000
Attachments: STR_Epstein_Privilege_Terms_02.14.2020.pdf
Here's the STR and the data should be released soon, it's just taking a while because the load is so large.
From:
Sent: Thursday, February 20, 2020 11:42 AM
To:
is
Cc:
in
Subject: RE: Epstein search materials for upload and privilege review
New data is loaded and we've segregated the PP hits; you should have access to the new data today. Will keep you
posted.
Thanks,
From:
Sent: Wednesday, February 12, 2020 1:04 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
wanted to follow up on this - is the data fully uploaded, or did it get delayed? Thanks.
From:
Sent: Friday, February 07, 2020 11:25
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
Great, thank you!
From:
Sent: Friday, February 07, 2020 09:34
To:
Cc:
is
is
)
Subject: RE: Epstein search materials for upload and privilege review
EFTA00029775

=== Page 2 ===
The data should be ready by Monday morning.
From:
Sent: Tuesday, February 4, 2020 6:58 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
Wanted to quickly check the status of the below - it's only been a couple weeks, so totally understand it may not be
complete, but hopefully we're getting close? If you could please check with the vendor and let us know, we'd be grateful
- and we'll plan to get it to
asap once we have access.
thanks,
From:
)
Sent: Tuesday, January 21, 2020 18:50
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
We've received a hard drive from FBI CART, which they've processed from devices seized and searched in connection with
the Epstein case. Can we please get those materials uploaded to Relativity, for privilege review by
(copied here)? I've
left the hard drive with the materials on your chair. (And if we could please get that hard drive back once the materials
are uploaded, the FBI has another batch they want to transmit to us for the same process, so that will also be coming
shortly.)
And then
these will be subject to just the exact same privilege review you previously ran in connection with Epstein
search warrant returns.
Please let us know if any questions or issues at all? And thanks very much as always.
EFTA00029776


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=== Page 1 ===
From: Nathan NYSD Chambers
To: Christian Everdell
Cc:
Laura Menninger
"Jeff Pagliuca"
bcsternheim_mac
Subject: Re: Letter re: Electronic Device Permission
Date: Tue, 13 Apr 2021 15:20:29 +0000
Attachments: Electronic_Device_Permission_signed.pdf
Counsel,
Please find attached an order signed by Judge Nathan.
Respectfully,
Juan Ruiz Toro
Law Clerk to the Hon. Alison J. Nathan
From: Christian Everdell
Sent: Tuesday, April 13, 2021 7:58 AM
To: Nathan NYSD Chambers
Cc:
; Laura Menninger
; Jeff Pagliuca
>; bcsternheim
Subject: Re: Letter re: Electronic Device Permission
CAUTION - EXTERNAL:
Dear Judge Nathan -
Defense counsel would like to bring the electronic devices described in the letter into the courthouse today for
the evidence views, which will begin shortly. We respectfully request that you authorize the CSOs at the Worth
Street entrance
t
to allow us into the courthouse with these devices.
Regards,
Chris Everdell
Sent from my iPhone
On Apr 8, 2021, at 11:43 AM, Christian Everdell
wrote:
Dear Judge Nathan -
Attached please find defense counsels' request to bring personal electronic devices into the courthouse as well as a
request to bring certain electronic equipment into the courthouse for the upcoming evidence views.
EFTA00031428

=== Page 2 ===
Regards,
Christian R Everdell
<image005.jpg>
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
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PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
<2021.4.8 Cover Letter re Electronic Device Permission.pdf>
<Electronic Device Permission.pdf>
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
EFTA00031429


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=== Page 1 ===
From:
(USANYS)"
To: "Hutner, Florence (OCME)"
Cc:
(USANYS)"
Subject: Epstein File - Redactions
Date: Mon, 09 Sep 2019 21:20:56 +0000
Attachments: 2019.09.09_USAO_Redactions_to_OCME_Report_and_File.pdf;
2019.09.09_Letter_to_OCME.pdf
Florence,
Please see the attached letter and attachment. Please let us know if you have any questions.
Thanks,
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00030609


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein
Date: Mon, 29 Jun 2020 22:49:54 +0000
Sorry, I've been jammed. If you want, I can probably look at something after this Thursday.
From:
(USANYS)
Sent: Monday, June 29, 2020 2:24 PM
To:
YS)
Cc: F
USANYS) <LFogelman@usa.doj.gov>
Subject: RE: Epstein
Okay, I've never done anything like this. Anything I can look at?
From: McEnany, John (USANYS)
Sent: Monday, June 29, 2020 2:14 PM
To:
(USANYS)
Cc: Fogelman, Lawrence (USANYS) <LFogelman@usa.doj.gov>
Subject: RE: Epstein
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:
Cc:
ANYS) <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:
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
Tel.
EFTA00029810


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=== Page 1 ===
From:
)"
To: Laura Menninger <Imenninger@hmflaw.com>,
)"
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP
(ceverdell@cohengresser.com)" <ceverdell@cohengresser.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Mon, 15 Mar 2021 21:59:40 +0000
Inline-Images: image001.jpg
Laura,
I expect to be able to answer all of your questions about the evidence review by tomorrow.
We have been looking into the discovery request you made last week, and we hope to have a response ready to provide
to you by next week.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <lmenninger@hmflaw.com>
Sent: Monday, March 15, 2021 3:01 PM
To:
)
is
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of
when you would have answers, it could help me answer your question.
At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the
attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their
evidence when they seized it from NY and LSJ, so I don't think we need to wait for them to now prepare an inventory
before we start reviewing evidence.
Also, when do you believe you will have a response regarding the discovery I requested last Monday?
EFTA00030084

=== Page 2 ===
Thanks,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
i
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
EFTA00030085

=== Page 3 ===
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 3:44 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you. Is that the only index of physical evidence available?
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
EFTA00030086

=== Page 4 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
Code:
Best,
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
)
is
y.
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
>;
EFTA00030087

=== Page 5 ===
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
EFTA00030088

=== Page 6 ===
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00030089


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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein T&E Meeting
Date: Wed, 08 Jan 2020 23:39:28 +0000
Importance: Normal
Attachments: unnamed
EFTA00031615


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From:
To:
Subject: RE: Epstein -- travel approval form
Date: Mon, 09 Mar 2020 16:02:54 +0000
No problem at all - I'm flexible this afternoon, so let me know whenever is good for you and l'll stop by. Thanks!
From:
Sent: Monday, March 09, 2020 10:52
To:
Subject: Re: Epstein -- travel approval form
Sorry. I've been preoccupied- this afternoon?
On Mar 6, 2020, at 10:30 AM,
wrote:
My chiefs talked with me yesterday about the status of this and I was wondering if I could stop by very briefly when you
have a free moment, just to complete the loop? Thanks!
From:
Sent: Tuesday, February 04, 2020 14:13
To:
Subject: RE: Epstein -- travel approval form
Totally understand - no worries and we'll link up when you're able.
From:
Sent: Tuesday, February 04, 2020 14:12
To:
Subject: Re: Epstein -- travel approval form
Got it. I'm so sorry - tied up with Geoff.
Sent from my iPhone
On Feb 4, 2020, at 2:10 PM,
wrote:
I'm going to make some calls so if I don't pick up when you call, that's why, but I'm here and will get off the
phone and come down whenever you're available.
EFTA00029707

=== Page 2 ===
thanks,
From:
Sent: Tuesday, February 04, 2020 13:02
To:
Subject: Re: Epstein -- travel approval form
No problem, I'm around whenever you're back.
On Feb 4, 2020, at 12:44,
wrote:
I may run late. Don't come till I call!
Sent from my iPhone
On Feb 3, 2020, at 5:45 PM,
wrote:
That works, thanks - just let me know if your schedule changes, otherwise l'Il come by at 1:00 tomorrow. Thanks
again and looking forward to it.
From:
Sent: Monday, February 03, 2020 16:07
To:
Subject: RE: Epstein -- travel approval form
Right now 1 p.m. looks open.
From:
Sent: Monday, February 3, 2020 1:33 PM
To:
Subject: RE: Epstein -- travel approval form
No problem at all, and I'm very flexible tomorrow afternoon - whatever time is good for you I can make work, so
just let me know and l'll put it in the calendar.
From:
Sent: Monday, February 03, 2020 13:31
To:
Subject: RE: Epstein -- travel approval form
So sorry for the delay. Maybe tomorrow? I have time in the afternoon.
From:
Sent: Friday, January 31, 2020 1:09 PM
EFTA00029708

=== Page 3 ===
To:
Subject: RE: Epstein -- travel approval form
Totally understand, and next week would be fine - let me know if it's helpful to set a time, and otherwise l'll touch
base midweek if we haven't connected by then.
And thanks very much re: the memo.
From:
Sent: Friday, January 31, 2020 12:53
To:
Cc:
Subject: RE: Epstein -- travel approval form
Already signed and sent upstairs
I will do my best to ensure signature immediately.
Re: this afternoon: it may be best to kick it to next week. If some time develops before 3, I'll let you know, but
right now it is iffy.
From:
Sent: Friday, January 31, 2020 12:21 PM
To:
Cc:
Subject: Epstein -- travel approval form
We dropped off the Sweden travel memo for you - we were unexpectedly significantly delayed in getting OIA
approval, but it finally came this morning, so with apologies for the short turnaround, hoping to get Office and final
DOJ approval this afternoon. Thank you!
And separately, if you still wanted to meet up today, I'll be around until about 3:00, but I'm also flexible next week if
that's easier.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00029709


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=== Page 1 ===
From:
To:
Subject: RE: Ghislaine Maxwell defense motion (Out Of Office)
Date: Thu, 13 Aug 2020 15:42:50 +0000
I will be out of the office, with limited access to email.
If this is an urgent matter, please call the institution at
and ask for the relevant department.
You may also email
with any urgent legal matters.
Thank you!
EFTA00031828


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From:
To:
Subject: media has it
Date: Thu, 02 Jul 2020 13:20:20 +0000
Tom Winter per usual - he has some great source at FBI
https://www.nbcnewyork.com/news/local/crime-and-courts/ghislaine-maxwell-arested-jeffrey-epstein-aide/2495762/
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: RE: Here's the Thing w/Alec Baldwin
Date: Tue, 18 Jun 2019 22:03:47 +0000
Importance: Normal
Embedded: RE:_Epstein_investigation,_prosecution_memo.msg
Thanks!
And if you're curious about the million legal issues we've been diving into, attached is the prosecution memo we just sent
to the front office folks
From:
(USANYS)
Sent: Tuesday, June 18, 2019 17:15
To:
(USANYS)
Subject: Here's the Thing w/Alec Baldwin
https://www.wnycstudios.org/story/how-julie-brown-broke-open-jeffrey-epstein-story/
Public Affairs
U.S. Attorney's Office for the Southern District of New York
(office)
(direct)
Email:
Website: www.justice.gov/usao-sdny
Facebook: https://www.facebook.com/usaosdny
Follow us on Twitter: @SDNYnews
EFTA00030499


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: travel approval request
Date: Fri, 13 Dec 2019 15:14:11 +0000
Okay
I know the issue. The TDY needs to be changed to Santa Monica, CA instead of Los Angeles, CA since you're
actually staying in a hotel that's in Santa Monica, CA, which has a per diem of $248. Los Angeles, CA has a per diem of
$181 only. I'll make the amendments and resend your Travel Authorization to Budget ASAP.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Thursday, December 12, 2019 6:02 PM
To:
Cc:
Subject: FW: travel approval request
I've booked my travel in E2 - once again it's saying the hotel is over the per diem, but that's not correct (it's a dollar
under) but let me know if you need any more info. Otherwise should be good to go, thanks!
From:
Sent: Wednesday, December 11, 2019 10:01
To:
Cc:
is
is
is
is
Subject: RE: travel approval request
Approved
From:
Sent: Wednesday, December 11, 2019 9:58 AM
To:
Cc:
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16
EFTA00030448

=== Page 2 ===
and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior trips,
we'd like to request approval to get a conference room for one of those days.
thank you,
From:
Sent: Tuesday, November 05, 2019 16:53
To:
Cc:
is
is
A.
Alleyne
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be traveling,
respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip).
thanks,
From:
Sent: Tuesday, October 22, 2019 13:55
To:
Cc:
is
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and
we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel on that Monday for the interview, please.
thanks very much,
From:
Sent: Wednesday, June 12, 2019 14:51
To:
>
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
EFTA00030449

=== Page 3 ===
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference room at
the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
)
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week for
EFTA00030450

=== Page 4 ===
meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and
return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Subject:
- Epstein
Date: Sun, 07 Jul 2019 02:54:58 +0000
Begin forwarded message:
From:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
Cc:
Subject:
) - Epstein
Mr.
My former partner,
, represented
(now known as
), prior to his passing in 2018.
Agent
served Ms.
with a grand jury subpoena earlier today, and as
former partner and
FL Bar appointed inventory attorney, she has contacted me. Unfortunately, I am unable to meet with her until
Tuesday, but I would appreciate a few minutes of your time at your convenience as I am getting up to speed.
Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
EFTA00030171


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=== Page 1 ===
Court Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the United States District Court for the Southern District of New York, 40 Foley Square, in the
Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the
following date, time and place:
Appearance Date:
November 29, 2021
Appearance Time: 9:00 a.m.
Appearance Place:
40 Foley Square, Courtroom 906
to testify and give evidence in the following matter:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
PERSONAL APPEARANCE IS REQUIRED
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
July 6, 2021
andress Struss/MI
AUDREY STRAUSS
United States Attorney for the
Southern District of New York
Handme
Lulr UNITED STATES DISTRICT COURT
Assistant United States Attorney
RICT FOR THE NEW THEN YORK
New York, New York 10007
Email:
Telephone:
rev. 02.01.12
EFTA00030962

=== Page 2 ===
ME
February 12, 2015
Farmer, Jaffe, Weissing, Edwards Fistos & Lehrman, P.L.
Re:
/ File# 14-000107
To Whom it May Concern:
Please be advised that the historical employment records you are requesting, for the time
period of "1999-2001" are no longer available.
I can confirm that a
appears on a spreadsheet dated back to 2000 which
lists terminated employees for that time (year 2000). Unfortunately, I am unable to
confirm whether or not this is the same person due to the fact no other information is listed
such as a social security number, address, position, etc. The only information listed is a
first and last name.
Should you have any further questions, please feel free to contact me at
Sincerely,
Director of Human Resources
PALM BEACH, FLORIDA
1100 South Ocean Boulevard, Palm Beach, Florida 33480 (561) 832-2600 Fax (561) 832-2669
EFTA00030963

=== Page 3 ===
U.S. DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF INVESTIGATION
Special Agent
1
26 Federal laza
Telephone:
New York, NY 10278
Email:
NYPD/FBI
CHILD EXPLOITATION
HUMAN TRAFFICKING TASK FORCE
Detective
Office:
Cell:
Fax:


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=== Page 1 ===
Event: Accepted: Meet re: Epstein
Start Date: 2019-04-03 16:00:00 +0000
End Date: 2019-04-03 16:30:00 +0000
Organizer:
Class: X-PERSONAL
Comment:
Date Created: 2019-04-02 17:36:23 +0000
Date Modified: 2019-04-02 17:36:23 +0000
Priority: 5
DTSTAMP: 2019-04-02 17:24:59 +0000
EFTA00030266


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=== Page 1 ===
From:
To:
Subject: Call in Epstein FOIA
Date: Tue, 13 Apr 2021 14:42:56 +0000
Importance: Normal
Attachments: unnamed
please let us know if we need to move the time. Thanks!
EFTA00031426


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=== Page 1 ===
From:
To:
)"
)"
Cc:
)"
Subject: RE: Application for Amended SW
Date: Fri, 23 Oct 2020 12:41:36 +0000
Thanks
no further edits on this. Please let us know how it goes next week, and thank you to all of you for all of
your incredibly hard work on the discovery in this case (and the case in general!).
From:
Sent: Thursday, October 22, 2020 8:26 PM
To:
is
Cc:
is
Subject: RE: Application for Amended SW
Thanks very much. Revised version incorporating your edits attached.
From:
Sent: Thursday, October 22, 2020 7:19 PM
To:
is
Cc:
is
Subject: RE: Application for Amended SW
Nice work on this, our combined edits are attached.
From:
Sent: Thursday, October 22, 2020 1:07 PM
To:
is
Cc:
is
Subject: Application for Amended SW
Chiefs,
Thanks very much for talking this morning. As discussed, attached is a draft application for an amended search warrant
correcting the FBI barcode numbers for 3 devices that were seized from Epstein's NY residence. In case it's useful, I'm also
attaching the exhibits that are referenced in the draft application.
Thanks,
EFTA00030607


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=== Page 1 ===
From:
To:
Bcc: "USAHUB-USAJournal111"
Subject: RE: Maxwell / Transition
Date: Tue, 29 Dec 2020 21:30:10 +0000
Embedded: RE: Maxwell Transition.msg
Sender:
Subject: RE: Maxwell / Transition
Message-Id:
M>
To:
To:
EFTA00031579


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=== Page 1 ===
From:
"
)"
To:
)"
Subject: memos
Date: Wed, 06 May 2020 22:20:49 +0000
Memos:
-
memo on co-conspirators we could potentially charge, the Monday after Epstein's death (delivered that Wednesday)
(seven pages)
-
co-conspirator update memo, December (86 pages)
-
corporate prosecution memo, December (13 pages) - never discussed
-
prosecution memo, April (26 pages) - hasn't been discussed in the three weeks since we sent it
-
perjury / NM memo, will be another 30 pages
Assistant U.S. Attorney
Southern District of New York
EFTA00030339


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
(USANYS)"
Subject: PCU Case Tracker Update
Date: Mon, 25 Jan 2021 18:41:16 +0000
Attachments: PCU_Case_Tracker.xlsx
Hi
I hope you both had a nice weekend. Attached is the updated version of the PCU case tracker. Everyone but
has
provided the details of their cases.
Thanks,
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
EFTA00029990


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=== Page 1 ===
From:
To:
)"
Subject: Manifest 7.6.19
Date: Sat, 06 Jul 2019 15:29:04 +0000
Attachments: TravelerList-8226863899.pdf
EFTA00030176


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: First stab at document subpoenas
Date: Fri, 02 Aug 2019 16:52:29 +0000
Attachments: 2019-08-02,_JE,_individual_subpoena,
docx; 2019-08-
02,JE,_individual_subpoena,
docx; 2019-08-
02,JE,individual_subpoena, Ghislane Maxwell.docx; 2019-08-
02,_JE,_individual_subpoena,
.docx; 2019-08-
02,_JE,_individual_subpoena,
docx; 2019-08-
02,_JE,_individual_subpoena,
x; 2019-08-
02,_JE,_individual_subpoena,
docx
I threw together the attached as a first attempt to put together some document subpoenas. Please let me know if there's
anything you think I should add/remove/rephrase. Also not sure whether we actually want to serve all of these people, or
if there are others that we will also want to subpoena, but let me know.
Assistant United States Attorney
Southern District of New York
007
EFTA00030517


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=== Page 1 ===
From:
To:
Cc:
Subject:
Date: Mon, 19 Aug 2019 22:47:22 +0000
Attachments:
Mr. Figgins,
Thank you for speaking with us earlier. Attached please find the grand jury subpoena directed to your client,
Please contact us with any questions.
Regards,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00030965


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=== Page 1 ===
I knew Ghislaine Maxwell for over 10 years. It was her calculating
and sadistic manipulation that anaesthetized me, in order to
deliver me, with full knowledge of the heinous and
dehumanizing abuse that awaited me, straight to the hands of
Jeffrey Epstein. Without Ghislaine, Jeffrey could not have done
what he did. She was in charge. She egged him on and
encouraged him. She told me of others she recruited, and she
thought it was funny. She pretends to care, only to garner
sympathy and enjoys drawing her victims in with perceived
caring, only to entrap them and make them feel some sense of
obligation to her through emotional manipulation. She was the
predator and a monster.
The sociopathic manner in which she nurtured our relationship,
abused my trust and took advantage of my vulnerability, makes
it clear to me that she would have done anything to get what she
wanted, to satisfy Mr. Epstein. I have great fear that Ghislaine
Maxwell will flee, since she has demonstrated, over many years,
her sole purpose is that of self-preservation. She blatantly
disregards and disrespects the judicial system, as demonstrated
by her perjuring herself and bullying anyone who dared accuse
her.
I have great fear that she may seek to silence those whose
testimony is instrumental in her prosecution. In fact, when I was
listed as a witness in a civil action involving Maxwell, I received a
phone call in the middle of the night, threatening my then 2-year
old's life if I testified.
EFTA00031357

=== Page 2 ===
I have fear speaking here today, even anonymously. However,
I
have chosen to implore the court not grant bond for Ms.
Maxwell because I know the truth. I know what she has done,
I
know how many lives she has ruined and because I know this,
I
know she has nothing to lose, has no remorse and will never
admit what she has done.
Please do not let us down by allowing her the opportunity to
further hurt her victims, or evade the consequences that surely
await her if justice is served. If she believes she risks prison, she
will never come back. If she is out, I need to be protected. I
personally know her international connections, that would allow
her to go anywhere in the world and disappear at a moment's
notice, or make others disappear, if she needs to.
EFTA00031358


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=== Page 1 ===
From:
)"
To:
,
(USANYS)"
Subject: RE: Maxwell GPS
Date: Thu, 27 Aug 2020 13:45:18 +0000
Attachments: Maxwell_GPS_Combo_v3.docx
Yep, here you go.
From:
Sent: Thursday, August 27, 2020 9:43 AM
To:
is
(USANYS)
Subject: Maxwell GPS
Can you send me the GPS from Maxwell? I will adapt it for
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00031421


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=== Page 1 ===
From:
Subject: RE: GJ Question
Date: Fri, 16 Oct 2020 17:23:01 +0000
Embedded: RE:_GJ_Question.msg
Sender:
Subject: RE: GJ Question
Message-Id:
To:
EFTA00030600


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=== Page 1 ===
From
To
Subject: RE: Maccow tomorrow
Date: Wed, 06 Nov 2019 14:26:30 +0000
Got it.
From:
Sent: Tuesday, November 05, 2019 6:48 PM
To:
Subject: Maccow tomorrow
Hi, For tomorrow, I have a 9:30 meeting with the attorneys for Epstein's estate, which may run past 10am. l'll join
Maccow as soon as I can, and should also be there for all of Fedora after.
EFTA00031505


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=== Page 1 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND ARCURITY
Person Encounter Detail
06/30/2020 13:26 EDT
Generated By:
Page 1 of 1
Encounter Person Detail
Last Name
First Name
Middle Initial
Gender
Date of Birth
MAXWELL
GHISLAINE
NOELLE
F
Document Number
Document Type
Document Country
Class of Admission
Admit Until Date
PASSPORT
FRANCE
Encounter Person Detail
Encounter Line Type
Encounter Date
Encounter Time (Eastern)
Terminal Lane
Site/Encounter Location
ADVANCED PASSENGER
01/19/2010
00:00
RECORD
Inbound/Outbound
Inspector
Processing Result
Primary Query Result
Referred To Agency
OUTBOUND
No Name No Name /
3
NOT REFERRED
178201
Manifest Data
Manifest Indicator
Passenger Status
Flight/Vessel Number
Departure Location
R
PASSENGER
N17ND
KSA KOSRAE, CAROLINE
IS. #ARPT, P. OCEAN
Transmitted By
Carrier Code
Arrival Location
APGA9786
*GA
XXX UNKNOWN AIRPORT (USED ONLY WHEN
THE AIRPORT CODE IS UNKNOWN)
For Official Use Only / Law Enforcement Sensitive
EFTA00030345


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=== Page 1 ===
From:
)"
To: "Christian R Everdell - Cohen & Gresser LLP
(
)"
>, "Mark S. Cohen"
>, , Bobbi
Sternheim
>, 'BOBBI C STERNHEIM'
,
Laura Menninger
, Jeff Pagliuca
Cc:
)"
(USANYS)"
i
(USANYS) [Contractor]"
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Date: Fri, 12 Mar 2021 17:14:24 +0000
Attachments: 2021.03.12_Maxwell_Discovery_Letter.pdf
Counsel,
Pursuant to the Court's Order dated November 18, 2020, today we are producing materials regarding victims who are not
referenced in Indictment number S1 20 Cr. 330 (AJN). Attached please find the accompanying cover letter. The
production is small enough to produce via an FTP site. Would you please send us a link to use for this production?
We will send a CD containing a copy of this production to the MDC for your client to review as well.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00030083


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=== Page 1 ===
From:
(USANYS)"
To:
JSANYS)"
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
,
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: Re: Epstein FOIA case, Times V. BOP, 20-cv-833
Date: Thu, 31 Dec 2020 22:32:42 +0000
Embedded: Re:_Epstein_FOIA_case,_Times_v_BOP,_20-cv-833.msg
Sender:
Subject: Re: Epstein FOIA case, Times V. BOP, 20-cv-833
Message-Id: <8D6D8671-6F58-44A1-9E55-AD4557EA09EC@usa.doj.gov>
To:
Cc:
Cc:
Cc:
Cc:
Cc:
Cc:
EFTA00031612


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=== Page 1 ===
From:
To: Christian Everdell
Cc: "Mark S. Cohen"
Bobbi Sternheim
Jeff Pagliuca
Laura Menninger
Bcc:
Subject: RE: Redactions
Date: Wed, 30 Dec 2020 16:12:05 +0000
Embedded: RE: Redactions.msg
Sender:
Subject: RE: Redactions
Message-Id:
<BN3P110MB03391A6968BD033D90E7898592D70@BN3P110MB0339.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
EFTA00030052


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: OPR
Date: Fri, 14 Aug 2020 17:41:43 +0000
Works for me, thanks.
Sent from my iPhone
On Aug 14, 2020, at 1:24 PM,
wrote:
Okay, assuming 6pm works for
let's do that. Thanks
,
From:
Sent: Friday, August 14, 2020 1:19 PM
To:
>;
>;
is
Subject: RE: OPR
6 works for me too
From:
Sent: Friday, August 14, 2020 13:18
To:
is
>;
is
Subject: RE: OPR
Thanks, I'm wide open Monday, but also happy to chat at 6 today.
From:
Sent: Friday, August 14, 2020 1:15 PM
To:
>;
is
>;
Subject: RE: OPR
That works for me, we also think this could wait until Monday if better for all of you.
From:
Sent: Friday, August 14, 2020 1:12 PM
To:
is
;
Cc:
Subject: RE: OPR
I could do 6 if that worked for others.
EFTA00030433

=== Page 2 ===
From:
Sent: Friday, August 14, 2020 1:09 PM
To:
is
>;
Cc:
Subject: RE: OPR
I have a witness interview for Prutech from 3pm to 5pm, and then
and I have a call with
at 5 to
discuss the priv review for the Epstein devices. Could we do a call after 5:30 this evening?
From:
Sent: Friday, August 14, 2020 1:00 PM
To:
is
is
Cc:
Subject: RE: OPR
That works for me.
From:
Sent: Friday, August 14, 2020 11:36
To:
is
y
Cc:
Subject: OPR
Does 4pm work for a call on this and a few other issues?
Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00030434


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=== Page 1 ===
Event: Call/Meeting on Epstein
Start Date: 2018-12-07 16:00:00 +0000
End Date: 2018-12-07 17:00:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Date Created: 2018-12-07 02:59:25 +0000
Date Modified: 2018-12-07 02:59:25 +0000
Priority: 5
DTSTAMP: 2018-12-07 02:48:09 +0000
Attendee:
(USANYS) [Contractor]
i
(USANYS)
EFTA00029658


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=== 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
June 22, 2021
BY EMAIL
Lockheed Martin Co.
6801 Rockledge Drive
Bethesda, MD 20817
RE:
Court Subpoena
Dear Ms. Bennett:
Please see the attached Court subpoena. You can reach me at the below phone number or
at
if you have any questions. Thank you for your cooperation in
this matter.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
/s/
Assistant United States Attorney
EFTA00029700

=== Page 2 ===
Court Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Lockheed Martin
6801 Rockledge Drive
Bethesda, MD 20817
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the United States District Court for the Southern District of New York, 40 Foley Square, in the
Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the
following date, time and place:
Appearance Date:
November 29, 2021
Appearance Time: 9:00 a.m.
Appearance Place:
40 Foley Square, Courtroom 906
to testify and give evidence in the following matter:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
Records of any transactions by Lockheed Martin or Sikorsky with the following entities and individuals:
Jeffrey Epstein
Ghislaine Maxwell
Air Ghislaine Inc., a/k/a Shititka Air Inc., a/k/a Freedom Air International Inc.
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
June 22, 2021
Audres
AUDREY STRAUSS
United States Attorney for the
UNITED STATES DISTRICT COURT
Southern District of New York
THE
RICT
YORK
NEW
Assistant United States Attorney
One St. Andrew's Plaza
New York, New York 10007
Telephone:
Rev. 02.01.12
EFTA00029701


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=== Page 1 ===
From:
To:
Cc:
Subject: Maxwell testifying witness materials
Date: Sat, 24 Jul 2021 01:04:29 +0000
Attachments:
Hi all,
Attached please find notes from trial prep with testifying witnesses for Maxwell. Would one of you please save these in
the 3500 folder and the witness folder for the relevant testifying witness named in the file name for each pdf?
Thanks,
EFTA00029865


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=== Page 1 ===
From:
To:
Subject:
former chef
,
Date: Wed, 30 Jan 2019 22:13:59 +0000
Importance: Normal
former chef, was on board the plane
some people said he knew lots of stuff; was on the plane when girls were being shuttled
Jeff Golenblock was his atty,
not sure if Golenblock was paid by Epstein
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From: "
To: "
Cc:
"
)"
Bcc:
"
Subject: Re: Epstein FOIA case, Times V. BOP, 20-cv-833
Date: Fri, 08 Jan 2021 00:21:41 +0000
Embedded: Re:_Epstein_FOIA_case,_Times_v_BOP_20-cv-833.msg
Sender:
Subject: Re: Epstein FOIA case, Times V. BOP, 20-cv-833
Message-Id:
To:
Cc:
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
July 31, 2019
CONFIDENTIAL
Boston, MA 02116
New York, NY 10036
New York, NY 10019
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Counsel:
Please note that the Government is designating this letter as Confidential pursuant to the
Protective Order in the above-referenced case. This letter provides discovery pursuant to Rule
16(a) of the Federal Rules of Criminal Procedure ("Fed. R. Crim. P."), and seeks reciprocal
discovery.¹
Disclosure by the Government
Based on your request for discovery in this case, enclosed please find copies of the
materials listed in the index below, which materials are stamped with control numbers
USAO_000001 through USAO_004518:
1
In addition to the information provided herein, please note that this Office periodically posts
content on social media platforms including Twitter, Facebook, and YouTube. Members of the
public may post comments in response to the Office's postings. We do not control these user-
generated comments, nor do we monitor or regularly review such comments. You may directly
access these social media platforms in the event you believe someone may have posted information
relevant to this case.
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=== Page 2 ===
Page 2
Description
Bates Range
American Express Records
USAO 000001-USAO 000041
Apple Records
USAO 000042-USAO 000043
Database Searches & Property Records
USAO_000044-USAO_000964
Deutsche Bank Records
USAO 000965-USAO 002252
Epstein Arrest
USAO 002253-USAO 002278
Florida Search Warrant Photos
USAO_002279-USAO_002643²
Florida Search Warrant Walkthrough Video
USAO 002644-USAO 0026523
Google Records
USAO 002653-USAO 002660
Microsoft Records
USAO_002661
2019.07.06 & 2019.07.07 Search Photos
USAO 002662-USAO 0034994
2019.07.11 Inventory Search Photos
USAO 003500-USAO 003509
2019.07.11 Search Photos
USAO_003510-USAO_0041755
Applications & Warrants
USAO 004176-USAO_004380
Reports & Logs
USAO 004381-USAO 004445
SORNA materials
USAO_004446-USAO_004505
Travel Records
USAO 004506-USAO 004518
As noted in footnotes 2 through 5, the Government is designating certain of portions of
these materials as Confidential pursuant to the Protective Order in this case.
2 Please note that the Government is designating the pages of these materials stamped with the
following control numbers as Confidential under the Protective Order: USAO_002416,
USAO_2451, USAO_002452, USA_002509, USAO_002530, USA0_002531, USAO_002532,
USAO_002533, USAO_002535, USAO_002536, USAO_002541, USAO_002542,
USAO_002543, USAO_002547, USAO_002548, USAO_002566, USAO_002575,
USAO_002578, USAO_002579, USAO_002580, USAO_002581, and USAO_002624.
3 Please note that the Government is designating the pages of these materials stamped with the
following control numbers as Confidential under the Protective Order: USAO_002650 and
USAO_002651.
4Please note that the Government is designating the pages of these materials stamped with the
following control numbers as Confidential under the Protective Order: USAO_002817,
USAO_002822, USAO_002824, USAO_002826, USAO_002827, USAO_002833,
USAO_002848, USAO_002849, USAO_002858, USAO_002859, USAO_002933,
USAO_002934, USAO_003142, USAO_003148, USAO_003153, USAO_003154,
USAO_003155, USAO_003156, USAO_003157, USAO_003177, USAO_003179,
USAO_003192, USAO_003193, USAO_003276, USAO_003300, and USAO_003327.
5 Please note that the Government is designating the pages of these materials stamped with the
following control numbers as Confidential under the Protective Order: USAO_003729,
USAO_003742, USAO_004029, and USAO_004092.
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=== Page 3 ===
Page 3
If you wish to inspect any of the physical evidence referenced in these materials, including
items listed on search inventories, please let us know, and we will make arrangements for you to
do so.
The defendant also made oral statements when he was arrested on or about July 6, 2019.
Notes memorializing those statements are included in this production and are marked with control
number USAO_002273.
The Government recognizes its obligations under Brady V. Maryland, 373 U.S. 83 (1963),
and its progeny. Pursuant to those obligations, we are disclosing the information below. This
disclosure should not be taken to indicate that the Government believes the enclosed information
constitutes Brady material. Rather, we make this disclosure in an abundance of caution.
Specifically, the Government discloses the following:
The victim identified in the Indictment as "Victim-1" received a grand jury subpoena
from the Southern District of Florida ("SDFL") in or about 2008. However, Victim-1
was never interviewed by law enforcement, including the West Palm Beach Police
Department, Federal Bureau of investigation ("FBI"), or SDFL in connection with their
investigation, and Victim-1 did not testify before the grand jury in SDFL. Victim-1 was
first interviewed by law enforcement regarding the defendant in or about 2019, after FBI
agents from the New York Field Office working with this Office approached Victim-1.
The victims identified in the Indictment as "Victim-2" and "Victim-3" were both
interviewed by law enforcement in connection with the SDFL investigation on multiple
occasions between in or around 2006 and in or around 2008. Victim-2 and Vicitm-3
were both identified as victims in the July 10, 2008 letter from SDFL to counsel for the
defendant. Victim-1 was not included on that list. Please note that all three of these
victims are currently represented by counsel.
During an interview with FBI agents in West Palm Beach, Florida in or around 2007, the
victim identified in the Indictment as "Victim-2" stated that during her first contact with
the defendant, she told the defendant that she had just turned eighteen, when in fact she
was younger than eighteen at the time. In subsequent interviews, Victim-2 has told law
enforcement that the first time she met the defendant, she told him that she was 16, when
in fact she was younger than sixteen. Victim-2 further stated that she brought other
victims to the defendant's residence for sexualized massages. She initially told these
victims that they should tell the defendant that they were older than they in fact were.
Over time, however, Victim-2 stopped telling other victims this because she came to
understand that the defendant had a specific preference for underage girls.
During the Palm Beach Police Department's investigation of the defendant in 2005, a
witness ("Witness-1") disclosed to detectives that the defendant had paid Witness-1 to
bring girls for sexualized massages, and that the defendant told her: "the younger the
better." Witness-1 described bringing multiple girls who were under the age of eighteen
to the defendant's residence in Florida. Witness-1 recalled bringing a girl who was over
eighteen, and that the defendant told Witness-1 that this girl was too old. Witness-1
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=== Page 4 ===
Page 4
remarked of the defendant: "He likes the girls that are between the ages of 18 and 20."
Please note that Witness-1 is also represented by counsel, Rita Glavin,
The Government will provide material under Giglio V. United States, 405 U.S. 150, 154
(1972), and its progeny, in a timely manner prior to trial and consistent with the schedule agreed
upon by the parties or set by the Court.
Disclosure by the Defendant
In light of your request for discovery in this case, the Government hereby requests
reciprocal discovery under Fed. R. Crim. P. 16(b). Specifically, we request that you allow
inspection and copying of: (1) any books, or copies or portions thereof, which are in the
defendant's possession, custody or control, and which the defendant intends to introduce as
evidence or otherwise rely on at trial; and (2) any results or reports of physical or mental
examinations and of scientific tests or experiments made in connection with this case, or copies
thereof, which are in the defendant's possession or control, and which the defendant intends to
introduce as evidence or otherwise rely on at trial or which were prepared by a witness whom the
defendant intends to call at trial.
The Government also requests that the defendant disclose prior statements of witnesses he
will call to testify. See Fed. R. Crim. P. 26.2; United States V. Nobles, 422 U.S. 225 (1975). We
request that such material be provided on the same basis upon which we agree to supply the
defendant with 3500 material relating to Government witnesses.
Sentence Reduction for Acceptance of Responsibility
This Office will oppose the additional one-point reduction under the Sentencing Guidelines
available for defendants who plead prior to the Government's initiation of trial preparations
pursuant to U.S.S.G. $ 3E1.1(b), in the event your client has not entered a plea of guilty six weeks
prior to trial. We will follow this policy whether or not suppression or other pretrial motions
remain outstanding after this date and even if the trial date has not been announced by the Court
six weeks in advance of the trial.
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=== Page 5 ===
Page 5
Finally, please be advised that pursuant to the policy of this Office concerning plea offers,
no plea offer is effective unless and until made in writing and signed by authorized representatives
of the Office. In particular, discussions regarding the pretrial disposition of a matter that are not
reduced to writing and signed by authorized representatives of the Office cannot and do not
constitute a "formal offer" or a "plea offer," as those terms are used in Lafler V. Cooper, 132 S. Ct.
1376 (2012); Missouri V. Frye, 132 S. Ct. 1399 (2012).
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
by:
Assistant United States Attorneys
Enclosure
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EFTA00030536


