# docs_fts_content

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=== Page 1 ===
From: "Berman, Geoffrey (USANYS)
To: "Shappert, Gretchen (USAVI)"
Cc:
Subject: Re: From the USVI--Jeffrey Epstein matter
Date: Mon, 08 Jun 2020 12:30:39 +0000
Inline-Images: image001.jpg
Hi Gretchen, I hope all is well. I am copying
and
on this email who will help the
coordination. Best, Geoff
On Jun 8, 2020, at 7:34 AM, Shappert, Gretchen (USAVI)
wrote:
Good morning, Geoff and greetings from St. Thomas:
We are having some coordination issues here, regarding the SDNY and USVI investigations of the Jeffrey
Epstein matter. I realize that you have a huge number of pressing issues to address and was hoping that you
could direct me to one of your supervisors, with whom I could discuss this matter.
Thanks so much,
Gretchen
Gretchen C.F. Shappert
U.S. Attorney for the Virgin Islands
Office of the U.S. Attorney
Ron De Lugo Federal Building
5500 Veterans Drive, Suite 260
Charlotte Amalie, St. Thomas
VI 00802-6214
340-774-5757( (front desk)
https://www.justice.gov/usao-vi
<image001.jpg>
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=== Page 1 ===
From:
To:
Cc:
Subject:
3500
Date: Fri, 27 Aug 2021 22:31:20 +0000
Attachments:
Hi,
Would you please save the attached in
3500 and witness folders on the Epstein share?
Thanks!
EFTA00017843


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: FW: US V Epstein
Date: Wed, 14 Aug 2019 15:28:39 +0000
I'm free for a call then, although not sure if we'll be ready on our end to pick up this conversation tomorrow. But at the
very least we could hear them out.
From: Martin G. Weinberg
Sent: Wednesday, August 14, 2019 11:23 AM
To:
>;
is
>; 'Miller, Michael'
>; ; Reid Weingarten
>; 'Martin G. Weinberg'
Subject: US V Epstein
Mike and I are authorized to continue the discussion of potential civil forfeiture issues with you. Are you available at
930 tomorrow morning? Thanks
Martin G. Weinberg, Esq.
Boston, MA 02116
- Cell
This Electronic Message contains information from the Law Office
of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee
only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents
of this message is prohibited.
EFTA00019762


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=== Page 1 ===
From: White Collar Law360 <news-alt@law360.com
To:
Subject: FDIC Staffer 'Accidentally' Took Bank Secrets, Jury Told
Date: Wed, 05 Dec 2018 09:35:44 +0000
Law360 White
Collar
WHITE COLLAR
The Data-Driven Lawyer
Meet the 2018 award winners and get insights into their innovative practices.
Wednesday, December 5, 2018
Follow Law360
TOP NEWS
Law360 Pro Say Podcast
FDIC Staffer 'Accidentally' Took Bank Secrets, Jury Told
Federal prosecutors and a lawyer for ex-FDIC employee Allison Aytes gave a
Brooklyn jury competing narratives Tuesday about what drove Aytes to make
copies of secret regulatory records before quitting, the feds saying she used
them for job interviews and Aytes saying she accidentally swept them up with
other personal files. Read full article
2nd Circ. Nixes $8.9M Restitution From Gambler Billy Walters
A Second Circuit panel on Tuesday vacated and remanded back to trial $8.89
million in restitution ordered against professional sports gambler Billy Walters
for insider trading. Read full article
Epstein Ducks Victim Testimony With Eve-Of-Trial Settlement
Listen to our new podcast here
Convicted billionaire sex offender Jeffrey Epstein on Tuesday settled a
LAW FIRMS
dispute with the attorney who represented his teenage victims, avoiding a
trial that was to have featured testimony from the women. Read full article
Arnold & Itkin
Baker McKenzie
Flynn Gave 'Firsthand' Info, Could Avoid Time, Mueller Says
Boies Schiller
Former national security adviser Michael Flynn, who pled guilty to lying to the
Carlton Fields
FBI about his conversations with Russia's ambassador, provided "firsthand
information" about the contact between President Donald Trump's team and
Cosgrove Eisenberg
Russian officials and should be sentenced leniently, special counsel Robert
Covington & Burling
Mueller said Tuesday. Read full article
Dechert
DiMuroGinsberg PC
Secrets Spilled In Panama Papers Lead To Indictment Of 4
Flachsbart & Greenspoon
New York federal prosecutors announced the indictment of a lawyer and
Gibson Dunn
three other men on Tuesday on charges of wire fraud, tax evasion and
money laundering, tying the case to the 2016 leak of documents from the law
Hogan Lovells
firm Mossack Fonseca called the Panama Papers. Read full article
Holland & Knight
Jackson Lewis
SERIES SPOTLIGHT
K&L Gates
Data-Driven Lawyer: Littler's Scott Forman
Kirkland & Ellis
Littler Mendelson PC shareholder Scott Forman's innovative case
Kramer Levin
management platform helps his firm analyze litigation data, craft defense
Krieger Kim
strategies, predict outcomes and greatly reduce client costs, earning him a
Link & Rockenbach
spot on our 2018 list of Data-Driven Lawyers. Read full article
Littler Mendelson
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=== Page 2 ===
POLICY & REGULATION
McDermott Will
Murphy & King
DC Circ. Asks Why Gov't Legal Opinions Are FOIA-Exempt
Murphy & McGonigle
The U.S. Justice Department faced pointed questions from D.C. Circuit
Paul Hastings
judges Tuesday about its rationale for keeping legal advice to federal
agencies from public view. Read full article
Searcy Denney
Shapiro Arato
SECURITIES
Shipley Snell
Sidley Austin
Fla. Broker To Serve 6½ Yrs For $16M Precious Metals Fraud
Tucker Ellis
Former Fort Lauderdale, Florida, broker Salvatore Colonna was sentenced to
6½ years in prison and ordered to pay $13.1 million in restitution for his role
COMPANIES
in a $16 million precious metals and securities fraud scheme, the U.S.
Altman Weil Inc.
attorney's office, the FBI and the IRS announced Tuesday. Read full article
American Conference Institute
Fund Manager's Firms Ordered To Pay $23M In Restitution
Bank Leumi le-Israel Ltd.
Three investment firms affiliated with admitted fraudster Haena Park were
Bass Pro Shops
ordered to pay $22.9 million in restitution by a New York federal judge
Burford Capital LLC
Monday for their role in defrauding dozens of Park's friends and family out of
Cabela's Inc.
more than $23 million over a six-year span. Read full article
California Teachers Association
Energy Broker Fights 'Misguided' CFTC Insider Trading Suit
Chicago Bulls
A Houston-based energy commodities brokerage on Monday asked a New
Citizens for Responsibility and
York federal judge to drop claims and dismiss one of its brokers entirely from
Ethics in Washington
a "misguided" U.S. Commodity Futures Trading Commission suit accusing
Counsel on Call Services Inc.
the broker of using a friend's account to profit on nonpublic information about
Deutsche Bank AG
his clients' block trades. Read full article »
General Motors
FCPA
Goldman Sachs Group Inc.
Harbour Litigation Funding Ltd.
NY Jury To Weigh Bribery Charges Against Hong Kong Doc
Hilton Worldwide Inc.
A Manhattan jury was on track Tuesday to begin deliberating bribery and
IMF Bentham Ltd.
money laundering charges against a Hong Kong doctor accused of boxing up
$2 million in cash for the president of Chad to facilitate an oilfield investment
Lehman Brothers Holdings Inc.
on behalf of a Chinese energy giant. Read full article
LexisNexis Group
Linkedln Corp.
PUBLIC INTEGRITY
Manchester United
National Basketball Association
1st Circ. Focuses On Extortion Benefit In Boston Aides' Case
The First Circuit on Tuesday peppered attorneys for both the government and
National Collegiate Athletic
Association
a pair of Boston City Hall aides on whether prosecutors need to show that
someone accused of extortion personally benefits from the alleged act,
New England Compounding
during a hearing seeking to revive indictments against the mayor's
Pharmacy Inc.
lieutenants. Read full article
Planned Parenthood Federation
Quill Corp.
CYBERSECURITY
Reed Elsevier
Hilton Sued Over Secret Filming Of NY Bar Exam Taker
Tampa Bay Buccaneers
A law school graduate who stayed at a New York hotel before taking the bar
The American Legion
exam has sued Hilton and its affiliates for $100 million in Virginia state court,
The Florida Bar
claiming that secretly filmed footage of her showering in her room was posted
Twitter Inc.
on pornographic websites and emailed to her friends and colleagues. Read
UnitedLex Corp.
full article
Wayfair LLC
LEGAL ETHICS
YouTube Inc.
Zillow Inc.
Former DA Didn't Mean To Intimidate Witness, Pa. Panel Told
A former Allegheny County prosecutor did not intend to intimidate a
GOVERNMENT AGENCIES
defendant's possible character witness when he phoned her during a trial in
Commodity Futures Trading
2016, but only meant to see what traits she intended to testify to and how
Commission
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=== Page 3 ===
well she really knew the defendant, a Pennsylvania Superior Court panel
Federal Bureau of Investigation
heard Tuesday. Read full article
Federal Deposit Insurance Corp.
HEALTH
Federal Reserve System
6 NECC Workers Had Role In Drug Fraud, Feds Say In Closing
Food and Drug Administration
Internal Revenue Service
Prosecutors on Tuesday urged a jury after seven weeks of testimony to
convict six former employees of the Massachusetts compounding pharmacy
Office of Foreign Assets Control
whose steroids sparked a deadly meningitis outbreak in 2012, saying they
Social Security Administration
participated in a scheme to defraud federal regulators and ship out unsafe
U.S. Attorney's Office
drugs to medical facilities around the country. Read full article
U.S. Department of Homeland
Pain Doc's 'Fame' Questioned In TM Suit Over Same Name
Security
A doctor accused of running a pill mill told an Illinois federal court Monday
U.S. Department of Justice
that a same-named pain doctor isn't "famous" enough to maintain claims for
U.S. Department of the Treasury
unfair competition alleging his business suffered due to confusion after the
U.S. Patent and Trademark Office
indictment. Read full article
U.S. Supreme Court
PEOPLE
United Nations
Carlton Fields Picks Up K&L Gates Litigator In Miami
Carlton Fields said Monday it has added a K&L Gates LLP trial lawyer as a
shareholder in its business litigation and white collar crime practice groups in
Miami. Read full article
EXPERT ANALYSIS
A Welcome DOJ Shift On Cooperation Credit
Changes announced last week by Deputy Attorney General Rod Rosenstein
will likely make it easier for a company to obtain cooperation credit in criminal
and civil cases, while also potentially reducing some of the costs and
burdens associated with complying with the prior U.S. Department of Justice
policy, says John Nowak of Paul Hastings LLP. Read full article
Crypto Addresses As OFAC Identifiers
Last week, the Office of Foreign Assets Control took the significant step of
adding two digital currency addresses to its list of identifiers for certain
individuals related to an Iranian hacking enterprise. This should immediately
alert entities that transact in digital assets, says Maxwell T.S. Thompson of
Murphy & McGonigle PC. Read full article
LEGAL INDUSTRY
Feature
NewLaw Is Wooing BigLaw's Young Talent
In search of new experiences and more flexibility, some young lawyers are
pointing their career paths toward alternative legal service providers. Read
full article
Scottie Pippen Claims Atty-Comedian Trashed Fla. Mansion
NBA Hall of Famer and former Chicago Bulls star Scottie Pippen hit a South
Florida attorney-comedian and her husband with a lawsuit in state court
Monday, accusing them of trashing his $10 million mansion, stealing cutlery
and allowing their pets to urinate all over the property. Read full article
Litigation Funder Validity Poaches Pair From Bentham IMF
Litigation funder upstart Validity Finance LLC said Tuesday it has poached
two ex-litigators from rival Bentham IMF to oversee risk management and
underwriting. Read full article
Insights From 2017-2018 High Court Term And What's Ahead
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=== Page 4 ===
Many expect the U.S. Supreme Court's new conservative majority to track
rightward, while others wonder if any justices might assert a moderating
influence as the new "swing vote." The court's recent decisions and
upcoming docket provide the best clues about its trajectory, says Chad
Eggspuehler of Tucker Ellis LLP. Read full article »
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EFTA00018657


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=== Page 1 ===
From:
To:
Subject: RE: United States V. Ghislaine Maxwell --
opens
Date: Mon, 29 Nov 2021 01:56:36 +0000
Thanks a lot,
From:
Sent: Sunday, November 28, 2021 2:24 PM
To:
Subject: RE: United States V. Ghislaine Maxwell
opens
Good luck tomorrow, Andrew! You're going to be great, and it will be such a relief for the victims to finally get a measure
of justice. Will be cheering you on!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
1 Saint Andrew's Plaza
New York NY 10007
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>
Cc:
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.
EFTA00017892

=== Page 2 ===
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:
To:
Subject: 21-58 United States of America V. Maxwell "Defective Document CURED"
Date: Mon, 05 Apr 2021 16:27:57 +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 04/05/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Docket Text:
CURED DEFECTIVE MOTION FOR BAIL[39], on behalf of Appellant Ghislaine Maxwell in 21-58, 21-770,
FILED.[3070280] [21-58, 21-770]
Notice will be electronically mailed to:
Notice will be stored in the notice cart for:
Quality Control 1
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=== Page 1 ===
From:
)"
To:
(USAVI)"
@usa.doj.gov>
Cc:
(NY) (FBI)"
Subject: Search Warrant Application
Date: Thu, 08 Aug 2019 22:37:30 +0000
Attachments: Exhibit D.pdf; Exhibit_A.pdf; Exhibit_B.pdf; Exhibit_C.pdf;
2019.08.08_USVI_Search_Warrant_Application.docx
Hi
Thanks very much for your assistance with this search warrant. I've attached the application, along with the exhibits to
the affidavit.
The affiant will be Special Agent
who is copied here. She is available tomorrow at any
time that is convenient for Judge Miller.
Thanks again for your help, and please let us know if you need any additional materials.
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:
)"
To:
Cc:
)"
Subject: RE: US V. Epstein
Date: Fri, 23 Aug 2019 03:52:43 +0000
Great - thanks very much!
(And for
- these are the docs from the FOIA office, which likely are largely duplicative of the Florida
case files that are currently separately being processed, but we obviously wanted to get them uploaded in any event.)
From:
Sent: Thursday, August 22, 2019 09:11
To:
Subject: US V. Epstein
Hello
The first set of PDF files that was processed by the vendor has been loaded to Relativity and is available for review. Please
let me know if there are any questions.
Thank you.
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=== Page 1 ===
DAG Meeting Case Overview
Acting U.S. Attorney Audrey Strauss
November 5, 2020
I.
Anticipated Charges and Investigative Steps
EFTA00018544

=== Page 2 ===
DAG Meeting Case Overview
Acting U.S. Attorney Audrey Strauss
November 5, 2020
II.
Charged Cases
U.S. V. Maxwell, 20 Cr. 330 (AJN): This summer, we charged Ghislaine Maxwell with
conspiring to entice minors to travel for the purpose of sexual abuse in connection with helping
Jeffrey Epstein to abuse his many victims. The case focused on three specific victims that
traveled to be abused by Epstein, including instances in which Maxwell herself participated in
the acts of abuse. Trial is set for this coming July. We are finishing discovery, and motions are
scheduled for December. Motion practice could generate further press; for example, the
defendant continues to press for the identity of the specific victims, and if she is successful, that
would surely lead to a round of press about the victims and the details of our case. Relatedly, we
are in plea negotiations with counsel for
another Epstein co-conspirator.
who scheduled hundreds of sexual massages with minors for Epstein but was also a victim of his
sexual abuse, may plead to an obstruction of justice-related count.
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=== Page 1 ===
PROFFER AGREEMENT
With respect to the meeting of
("Client") and her attorney, Jennifer Beidel,
Esq., with Assistant United States Attorney
to be held with the Office of the
United States Attorney for the Southern District of New York on April 27, 2021 ("the meeting"),
the following understandings exist:
(1) THIS IS NOT A COOPERATION AGREEMENT. The Client has agreed to
provide the Government with information, and to respond to questions, so that the Government
may evaluate Client's information and responses in making prosecutive decisions. By receiving
Client's proffer, the Government does not agree to make a motion on the Client's behalf or to enter
into a cooperation agreement, plea agreement, immunity or non-prosecution agreement. The
Government makes no representation about the likelihood that any such agreement will be reached
in connection with this proffer.
(2) In any prosecution brought against Client by this Office, except as provided below the
Government will not offer in evidence on its case-in-chief, or in connection with any sentencing
proceeding for the purpose of determining an appropriate sentence, any statements made by Client
at the meeting, except (a) in a prosecution for false statements, obstruction of justice or perjury
with respect to any acts committed or statements made during or after the meeting or testimony
given after the meeting; or (b) if, at any time following the meeting, Client becomes a fugitive
from justice.
(3) Notwithstanding item (2) above: (a) the Government may use information derived
directly or indirectly from the meeting for the purpose of obtaining leads to other evidence, which
evidence may be used in any prosecution of Client by the Government; (b) in any prosecution
brought against Client, the Government may use statements made by Client at the meeting and all
evidence obtained directly or indirectly therefrom for the purpose of cross-examination should
Client testify; and (c) the Government may also use statements made by Client at the meeting to
rebut any evidence or arguments offered by or on behalf of Client (including arguments made or
issues raised sua sponte by the District Court) at any stage of the criminal prosecution (including
bail, all phases of trial, and sentencing) in any prosecution brought against Client.
(4) The Client understands and agrees that in the event the Client seeks to qualify for a
reduction in sentence under Title 18, United States Code, Section 3553(f), United States
Sentencing Guidelines, Sections 2D1.1(b)(18) or 5C1.2, or Fed. R. Crim. P. 35(b), the Office may
offer or use at any stage of the criminal proceeding any statement made by Client during the
meeting, and all evidence obtained directly or indirectly therefrom, to the extent such use is
consistent with Section 402 of the First Step Act of 2018.
(5) To the extent that the Government is entitled under this Agreement to offer in evidence
any statements made by Client or leads obtained therefrom, Client shall assert no claim under the
United States Constitution, any statute, Rule 410 of the Federal Rules of Evidence, or any other
federal rule that such statements or any leads therefrom should be suppressed. It is the intent of
this Agreement to waive all rights in the foregoing respects.
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=== Page 2 ===
(6) If this Office receives a request from another prosecutor's office for access to
information obtained pursuant to this Proffer Agreement, this Office may furnish such information
but will do so only on the condition that the requesting office honor the provisions of this
Agreement.
(7) It is further understood that this Agreement is limited to the statements made by Client
at the meeting and does not apply to any oral, written or recorded statements made by Client at
any other time. No understandings, promises, agreements and/or conditions have been entered
into with respect to the meeting other than those set forth in this Agreement and none will be
entered into unless in writing and signed by all parties.
(8) The understandings set forth in paragraphs 1 through 7 above extend to the continuation
of this meeting on the dates that appear below.
(9) Client and Attorney acknowledge that they have fully discussed and understand every
paragraph and clause in this Agreement and the consequences thereof.
Dated: New York, New York
4/27/21
AUDREY STRAUSS
United States Attorney for the
Southern District of New York
by
Client
Assistant United States Attorney
Juf Attorney Client Budt
Witness
Dates of Continuation
Initials of counsel, Client, AUSA, witness
8/19/21
2020.12.11
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=== Page 1 ===
From: "Miller, Michael"
To:
)"
Cc: "Martin G. Weinberg"
"Weingarten, Reid"
Subject: Re: US V Epstein
Date: Sat, 10 Aug 2019 18:16:27 +0000
Thank you
Mike
Sent from my iPhone
On Aug 10, 2019, at 2:14 PM,
)
wrote:
Following up on the below, wanted to make sure the attached letter from the Warden immediately got to Mike as well
(in addition to Marty and Reid having been copied and emailed). As the letter indicates, there are now investigations
ongoing, including as initiated by the Attorney General himself. Separately, we have not received additional information
on topics such as the apparent cause of death, the status of observation of Mr. Epstein at the time, etc., but we will
continue to be in touch immediately if that changes.
thank you,
From:
Sent: Saturday, August 10, 2019 11:57
To: Miller, Michael
>; ; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
Subject: Re: US V Epstein
Mike, Marty, Reid,
Following up on my conversations with Mike and Marty this morning, and my discussion with Mike moments
ago, attached is a press release just sent to us (and I believe also issued publicly) some minutes ago. It
represents all the information we have from BOP so far, but of course if we are successful in our continuing
efforts to get additional information we will pass it along immediately.
Separately, we can tell you that the reports that an FBI investigation into the death has been initiated are
accurate, and I fully expect that investigation to be extremely rigorous.
As always please don't hesitate to reach out to us directly at any time if that would be useful.
thank you,
<mltC634.pdf>
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Jeffrey Epstein: About the sex trafficking case & accusations I Miami Herald
Date: Sat, 01 Dec 2018 00:11:38 +0000
Importance: Normal
Is it staffed already?
Original Message
From:
Sent: Friday, November 30, 2018 7:06 PM
To:
Cc:
Subject: Re: Jeffrey Epstein: About the sex trafficking case & accusations I Miami Herald
Yes. As of today. On the d/l for now.
Sent from my iPhone
> On Nov 30, 2018, at 6:56 PM,
wrote:
>
> Are we open on this? Can we be?
>
>
https://www.miamiherald.com/news/local/article220097825.html
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=== Page 1 ===
LexisNexis®
21-58, United States of America V. Maxwell
US Circuit Court of Appeals - 02nd Circuit
This case was retrieved on 04/28/2021
Header
Case Number: 21-58
Date Filed: 01/12/2021
Date Full Case Retrieved: 04/28/2021
Status: Terminated 04/27/2021
Misc: (0) 0: ; Appeal
Participants
Litigants
Attorneys
Ghislaine Maxwell
Christian Romeyn Everdell, Assistant U.S. Attorney
Defendant - Appellant
Defendant Appellant
AKA: Sealed Defendant 1
Cohen & Gresser LLP New York 21st Floor 800 3rd Avenue New
York New York, NY 10022 -212-957-7600
Cohen & Gresser LLP
800 3rd Avenue
New York, NY 10022
AttorneyLabel: [COR-LD-NTC Retained]
David Oscar Markus, Esq., -
Defendant - Appellant
Markus & Markus, PLLC Penthouse 1 40 NW 3rd Street Miami,
FL 33128 305-379-6667
Markus & Markus, PLLC
40 NW 3rd Street
Miami, FL 33128
AttorneyLabel: [NTC Retained]
Bobbi C. Sternheim, Esq., -
Defendant - Appellant
Law Offices of Bobbi C. Sternheim 4th Floor 33 West 19th Street
New York, NY 10011 212-243-1100
Law Offices of Bobbi C. Sternheim
33 West 19th Street
New York, NY 10011
AttorneyLabel: [NTC Retained]
Proceedings
Availability
Date
#
Proceeding Text
Details
04/26
CASE, before PNL, RJL, RJS, HEARD [3086027] [21-58,
/2021
21-770]
EFTA00018232

=== Page 2 ===
Page 2 of 2
21-58, United States of America V. Maxwell
Availability
Date
#
Proceeding Text
Details
Free
04/27
/2021
MOTION ORDER, granting motion to be relieved as
attorney filed by Appellant Ghislaine Maxwell, by RJL,
FILED. [3087472][82] [21-58, 21-770]
04/27
ATTORNEY, Christian R. Everdell, for Ghislaine
/2021
Maxwell, TERMINATED [3087477] [21-58, 21-770]
Free
04/27
/2021
NEW CASE MANAGER, Khadijah Young,
ASSIGNED. [3087699] [21-58, 21-770]
Free
04/27
/2021
MOTION ORDER, denying motion for bail filed by
Appellant Ghislaine Maxwell, by PNL, RJL, RJS, FILED.
[3087715][86] [21-58, 21-770]
Free
04/27
/2021
APPEAL, pursuant to court order, dated 04/27/2021.
AFFIRMED.[3087718] [21-58, 21-770]
Copyright © LexisNexis CourtLink, Inc. All Rights Reserved.
*** THIS DATA IS FOR INFORMATIONAL PURPOSES ONLY ***
End of Document
EFTA00018233


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
(USANYS)"
Cc:
(USANYS)"
Subject: FW: Phone Call Follow-Up
Date: Fri, 30 Oct 2020 18:24:23 +0000
Inline-Images: image001.png
See below for the update from PAE. The good news is that they're getting this back to us on a rolling basis, and it looks
like we'll have at least some of this stuff in time to produce it by 11/9. The bad news is it does not seem like we'll have all
of it by that date. It does seem like we'll have greater clarity by early next week.
I confess, I don't feel like I fully understand all of the steps in this process or why it takes as long as it does, but I'm happy
to go back to
with additional questions if that would be helpful. I'm also happy to ask that he set up a call with us and
PAE if that would be helpful. Please let us know what we can do.
From:
(USANYS)
Sent: Friday, October 30, 2020 12:51 PM
To:
(USANYS)
is
(USANYS)
Subject: FW: Phone Call Follow-Up
Some of the data is being sent to use today by FedEX. However, there is a ton of stuff still being processed. That stuff is
still being imaged. Then it gets marked. Then copied to us. I have spoken to
He thinks it is not possible to
meet the November 9 date. He thinks the next step might be done on Tuesday, and then a better estimate of completion
might be possible.
From: Koontz, Nicholas [US]
Sent: Friday, October 30, 2020 12:25 PM
To:
(USANYS)
Cc:
(USANYS) [Contractor]
Subject: Phone Call Follow-Up
Good Afternoon
Following up on our earlier phone conversation, a hard drive with the following productions is being sent to SDNY via
FedEx with the following productions in the US V. Epstein workspace:
1) SDNYPROD008
2) SDNYPROD009
3) SDNYPROD010
4) SDNYPROD011 (Note: this is a six-part production)
5) SDNYPROD012
6) SDNYPROD013
7) SDNYPROD014
There are approximately 1.2 million records currently being imaged. The images will be available on Monday, November
2, 2020 at the earliest. The production of the records will begin as soon as the images are available in the workspace.
EFTA00019137

=== Page 2 ===
Please feel free to contact me if you have any questions.
Thanks,
Nick
Nicholas D. Koontz
Lead E-Discovery Analyst
e.
Falls Church, Virginia 22043
PAE
IMPORTANT: The information contained in this message may be privileged, business sensitive, proprietary,
copyrighted, protected from disclosure and/or subject to US export controls. If you are not the intended recipient,
you are hereby notified that any dissemination, distribution or copying of this communication is strictly
prohibited. If you have received this communication in error, please notify me immediately by replying to the
message and deleting it from your computer. #-SEC-#
EFTA00019138


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Subject: Cross
Date: Fri, 01 Oct 2021 01:42:48 +0000
Attachments:
Here is an outline of cross riffs for tomorrow. Let me know if any of these are off the mark, or if there is something I
should add
Deputy Chief, Public Corruption Unit
Southern District of New York
Office:
Cell:
Email:
EFTA00018777


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=== Page 1 ===
From:
To:
Subject: RE: United States V. Ghislaine Maxwell --
opens
Date: Mon, 29 Nov 2021 01:55:33 +0000
Thanks,
From:
Sent: Sunday, November 28, 2021 10:43 AM
To:
Subject: Fwd: United States V. Ghislaine Maxwell
opens
GOOD LUCK!!! You all will crush it.
Sent from my iPhone
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>
Co
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
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019220

=== Page 2 ===
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=== Page 1 ===
From:
To:
Subject: Epstein
Date: Thu, 09 May 2019 20:41:16 +0000
Importance: Normal
Would you swing by when you have a second?
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00017960


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=== Page 1 ===
From:
To:
(USANYS)"
Subject: Accepted: SDNY-ODAG Call (Epstein/Maxwell)
Date: Tue, 18 Aug 2020 16:27:29 +0000
Importance: Normal
Attachments: unnamed
EFTA00017838


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=== Page 1 ===
From:
(USAVI)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Jeffrey Epstein: Possible IML Violation
Date: Mon, 08 Jul 2019 17:58:41 +0000
Importance: High
Attachments: 2019_07_08_13_17_05.pdf;2019_07_08_13_31_10.pdf
Inline-Images: image001.jpg
Good afternoon:
As you know, Jeffrey Epstein's primary residence is the USVI. The USMS has an ongoing investigation of a
possible International Megan's Law violation. The USMS investigation is being led by
whose email
,
appears below.
Sincerely,
U.S. Attorney for the Virgin Islands
Office of the U.S. Attorney
Ron De Lugo Federal Building
https://www.justice.gov/usao-vi
V
From:
(USMS)
Sent: Monday, July 08, 2019 1:36 PM
To:
(USAVI)
Cc:
is
(USMS)
Subject: IML Violation
Hey
Here are the documents you requested in regards to my investigation into Mr. Epstein.
On March 15, 2019 Mr. Epstein signed the Virgin Islands sex offender registry Notification of Duty to Report Travel (IML)
form.
EFTA00018159

=== Page 2 ===
On March 22, 2019 Mr. Epstein travelled to Vienna, Austria where he and three (3) female passengers went to coffee and
it appears this travel was not reported.
On April 25, 2019 Mr. Epstein travelled to Morocco and it appears this travel was not reported.
Please note if this information is made public I strongly believe it may hamper our ability to confirm this information as
the investigation is ongoing. Especially with his resources.
Any questions, please contact me.
Senior Inspector
United States Marshal Service
IOD-Sex Offender investigations Branch
Florida/Caribbean Region
EFTA00018160


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=== Page 1 ===
From:
)"
To: Gloria Allred
Cc:
)"
)"
Subject: Re: Urgent. I have a new alleged victim of E I have a new client who was a victim of
Epstein. She is willing to fly to New York for the victim meeting on Oct. 23. May I call you
at 5:45 P.M. to discuss ?
Date: Wed, 23 Oct 2019 15:54:52 +0000
Inline-Images: image005.jpg; image006.png; image007.jpg; image008.png; image009.jpg; image010.png;
image006(1).png; image007(1).jpg; image008(1).png
Gloria we were slightly delayed by questions but are heading over now
Sent from my iPhone
On Oct 23, 2019, at 08:57, Gloria Allred
wrote:
I will not have a means to communicate with you after 9:30 this morning, because I will be at the F.B.I. Victim Services
meeting and they will take my phone. Would you please respond to my message below prior to that time in order that I
may know the plan for meeting with
and me today?
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image005.jpg>
Martindale-Hubbell'
PREEMINENT
AV
Peer
Rated
for
Highest
of Professional Excellence
2019
From: Gloria Allred
Sent: Tuesday, October 22, 2019 8:26 PM
To:
Cc:
is
)
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Is there a place at the FBI for you to interview
at the end of the meeting with Victim Services ? I am on a tight
schedule tomorrow. Please advise if you want to interview her there at 11:A.M or 11:30.at the end of their meeting or
do wish to use my office at 305 Broadway? I need to leave the interview with her by 12:30. I must take the 2P.M. train to
D.C.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
EFTA00019719

=== Page 2 ===
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
Best Lawyers
AV\PREEMINENT
From:
Sent: Tuesday, October 22, 2019 1:08 PM
To: Gloria Allred
Cc:
is
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gloria Allred
Sent: Tuesday, October 22, 2019 4:03 PM
To:
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
I have asked her when we can reschedule, but I do not have an answer yet.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image009.jpg>
<image010.png>
From:
Sent: Tuesday, October 22, 2019 11:54 AM
To: Gloria Allred
Cc:
is
Subject: Re: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
EFTA00019720

=== Page 3 ===
Gloria,
Is
still available for our 4pm call, or do we need to reschedule?
Thanks,
On Oct 22, 2019, at 12:26 PM,
)
wrote:
Ok thanks, please keep us posted. We are happy to accommodate
schedule.
And yes, we can speak with
at your office from noon to 1pm tomorrow.
will be the AUSA
handling that meeting.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gloria Allred
Sent: Tuesday, October 22, 2019 12:24 PM
To:
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to
fly to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Just a heads up. I think she is needing to reschedule and is cancelling for today. I will let you know a.s.a.p. or by 2P.M.
at the latest. Sorry. Also, re
for tomorrow.can you speak to her from noon to 1 P.M. at my office at 305
Broadway? I need to leave at 1P.M. to catch the train to D.C.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image003.jpg>
<image004.png>
From:
Sent: Tuesday, October 22, 2019 8:19 AM
To: Gloria Allred
Cc:
is
)
EFTA00019721

=== Page 4 ===
is
(NY) (FBI)
Subject: Re: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to
fly to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Hi Gloria,
We are find with a conference call this afternoon if that is ok with your client. We can use the below dial-in:
Passcode
And your proposed time for
interview works on our end.
Thanks,
On Oct 21, 2019, at 8:11 PM, Gloria Allred
wrote:
I have 2 questions. First, would it be o.k. with all of you if we did the call with
tomorrow at 4P.M. e.s.t as a
conference call rather than as a Skype call? We will be in at least 4 different locations and I think it will be easier if we
did it that way. If so, please send us the number to dial. Daniel from my CO counsel Marianne Wang's office will also
be joining us on the call. Also ,re
my client who is flying in for victim services will be happy to speak with you,
but I have a very tight schedule on Wednesday, because I need to be on a 1 or at the latest 2 P.M. train to D.C. that
day. Could we have the meeting from noon to 1P.M.? My office is only one block away from the FBI meeting.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.jpg>
<image002.png>
From:
Sent: Monday, October 21, 2019 6:40 AM
To: Gloria Allred
is
Cc:
is
(NY) (FBI)
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to
fly to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria,
We will make ourselves available to meet with your new client on 10/23. Because the victim meeting is being run by
the FBI, their victim services folks are handling travel logistics. I'm cc'ing
who should be able to
hopefully help coordinate travel. Would you please provide
with your new client's name as it appears on her
ID, date of birth, email address, and phone number?
Thanks,
EFTA00019722

=== Page 5 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gloria Allred
Sent: Friday, October 18, 2019 5:02 PM
To:
Cc:
)
Subject: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image003.jpg>
<image004.png>
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED
THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED
THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
EFTA00019723

=== Page 6 ===
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
ALLRED. MAROKO & GOLDBERG
2019
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
ALLRED. MAROKO & GOLDBERG
2019
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
ALLRED. MAROKO & GOLDBERO
2019
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
EFTA00019724


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS) [Contractor]"
(USANYS)"
Subject: RE: New Epstein Search?
Date: Thu, 11 Jul 2019 19:33:51 +0000
Importance: Normal
Yes. But correct to decline.
From:
(USANYS)
Sent: Thursday, July 11, 2019 3:34 PM
To:
(USANYS)
>;
(USANYS)
Cc:
USANYS) [Contractor]
is
(USANYS)
Subject: New Epstein Search?
The Journal just got a tip that about a dozen FBI agents in jackets were back at the mansion at around 2:50 this afternoon.
I obviously declined, but is this a thing?
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
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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
December 17, 2020
BY FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Enclosed is discovery pertinent to the following inmate:
Ghislaine Maxwell:
Please allow her access to the materials enclosed.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
Enclosure
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=== Page 1 ===
From:
)"
To: "Miller, Michael"
"Martin G. Weinberg"
,
"Weingarten, Reid"
Cc:
)"
)"
Subject: RE: US V Epstein
Date: Sat, 10 Aug 2019 20:53:05 +0000
Attachments: Jeffrey_Epstein_Statement_8.10.19_PR.pdf
Mike,
I know we just spoke but I wanted to memorialize the information for everyone in one place - regarding your question
about the
(phonetic) who called an individual associated with Mr. Epstein regarding next steps for
recovery of Mr. Epstein's body, we confirmed with BOP that the call was not a hoax; Mr.
does work for BOP / MCC
and his contact number is in fact
The slight divergence of the BOP account from your understanding is that BOP advised us that Mr.
had contacted
Mr. Epstein's brother to advise that when the body is ready, part of BOP's responsibility is to arrange for its transport (and
possibly other notifications or logistics for next-of-kin). They were not trying to convey that the body is ready now; rather,
they expect it will be some time until that is the case, but they wanted to contact next-of-kin immediately. So you and/or
Mr. Epstein's brother should feel free to be in touch with BOP at that number if and when that would be useful.
Separately, it is in process for us to determine whether we are able to provide a contact name and number for the new
investigation(s), but in the interim, as we discussed, you should feel free to refer any individuals to the FBI tip line, which
will continue to do intake on all Epstein-related matters including the new investigation; that number is 1-800-CALL-FBI.
Finally, attached is a statement put out by our office this afternoon, so you have it directly. Given the active investigation
into the circumstances of Mr. Epstein's death, I think it is possible we will not receive additional substantive information in
the immediate future (or that if we do, it will be information we're not permitted to share outside our Office because of
the nature of the investigation), but we will continue to convey any substantive information that we can.
thank you,
From:
Sent: Saturday, August 10, 2019 11:57
To: Miller, Michael
>; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
Subject: Re: US V Epstein
Mike, Marty, Reid,
Following up on my conversations with Mike and Marty this morning, and my discussion with Mike moments
ago, attached is a press release just sent to us (and I believe also issued publicly) some minutes ago. It represents
all the information we have from BOP so far, but of course if we are successful in our continuing efforts to get
additional information we will pass it along immediately.
Separately, we can tell you that the reports that an FBI investigation into the death has been initiated are
accurate, and I fully expect that investigation to be extremely rigorous.
EFTA00019956

=== Page 2 ===
As always please don't hesitate to reach out to us directly at any time if that would be useful.
thank you,
EFTA00019957


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=== Page 1 ===
From: New York Law360 <news-alt@law360.com>
To:
Subject: AGs, Carriers' Cooperation Won't Stem Robocall Litigation
Date: Tue, 27 Aug 2019 08:05:03 +0000
Law360 New York
NEW YORK
Tuesday, August 27, 2019
Follow Law360
TOP NEWS
Law360 Pro Say Podcast
Analysis
AGs, Carriers' Cooperation Won't Stem Robocall Litigation
A new information-sharing partnership between major phone carriers and
attorneys general across the country is expected to expedite the tracking and
prosecution of robocall scammers and the networks that enable them, but
questions remain about how it will work in practice, experts said.
Read full article
NY Judge Dodges Most Of Ex-Clerk's Bias, Retaliation Suit
A New York state judge has beaten a former chief clerk's allegations that he
was bullied for being gay, but not his claim that he was illegally demoted after
reporting that she kept improperly meddling in the administration of criminal
Listen to our new podcast here
matters while her husband was Staten Island's district attorney, according to
a recent federal court ruling.
LAW FIRMS
Opinion attached Read full article
Aidala Bertuna
Alston & Bird
Religious Parents Can't Get Freeze On NY Vaccination Law
A New York state judge has denied a bid from a group of parents to block a
Arnold & Porter
recent law repealing a religious exemption to mandatory vaccinations in
Baker Botts
Empire State schools, finding they haven't shown they are likely to eventually
Ballard Spahr
succeed in the case.
Boutin Jones
Decision attached Read full article
Bryan Cave
Cadwalader Wickersham
NY Extends Clock For Bringing Martin Act Suits To 6 Years
Clyde & Co
New York Gov. Andrew Cuomo signed into law on Monday a bill that brings
back a six-year time window for the state's attorney general to bring financial
Cohen & Frankel LLP
fraud claims under the Martin Act, undoing a landmark decision from the
Davis Polk
state's highest court that had held a three-year statute of limitations applied.
Debevoise & Plimpton
Bill attached Read full article
Duval & Stachenfeld
Eagan Avenatti
Dollar Stores Will Pay $1.2M For Selling Expired Products
Epstein Becker Green
Dollar General, Family Dollar and Dollar Tree have agreed to pay $1.2 million
Eversheds Sutherland
in fines after an undercover investigation caught the discount retailers selling
expired drugs and useless motor oil, New York Attorney General Letitia
Freshfields Bruckhaus
James announced Monday.
Friedman Suder
Read full article
Gair Gair
Gibson Dunn
INTELLECTUAL PROPERTY
Goldstein & Russell
Shuttered Golf Co. Owner Must Pay Rival $8.9M In Patent Suit
Goodwin
Greenberg Traurig
EFTA00018860

=== Page 2 ===
The owner of a shuttered golf company must pay a rival nearly $8.9 million
Harris Beach
for infringing a golf bag patent, a New York federal judge has ruled, almost 10
Hodgson Russ
years after he stashed the company's money in a personal bank account and
Kahn Swick
declared bankruptcy.
1 document attached Read full article
Kennedys Law LLP
Kirkland & Ellis
EMPLOYMENT
Kobre & Kim
Kennedys Beats Appeal In Client Poaching Suit
Levi & Korsinsky
An attorney failed to establish that a Kennedys lawyer poached his clients in
Littler Mendelson
a freight business dispute, as he didn't back up his "bald assertions" that his
Lowenstein Sandler
former clients were fed lies, a New Jersey state appellate court held Monday.
Manatt Phelps
Read full article
McDermott Will
SECURITIES & WHITE COLLAR
Meunier Carlin
Morgan & Morgan
December Insider-Trading Trial Set For Ex-SAC Capital Exec
Orrick Herrington
Former SAC Capital portfolio manager Richard Lee will stand trial on insider
Paul Weiss
trading charges beginning Dec. 9, a Manhattan federal judge said Monday,
Quinn Emanuel
scheduling a swift conclusion in a six-year-old case that has been reshaped
Reed Smith
by changes in controlling law.
Robbins Geller
Read full article
Serrins & Associates
Avenatti Gets May Trial Date In Calif. Embezzlement Case
Sidley Austin
Michael Avenatti will get his day in court next spring, a California federal
Skadden
judge decided Monday, scheduling a May 19 trial date in the government's
Snell & Wilmer
embezzlement case against the embattled attorney.
Sullivan & Cromwell
Read full article
Thompson Hine
Harvey Weinstein Again Denies Charges, Trial Moved To 2020
Troutman Sanders
A New York state judge on Monday delayed the criminal trial of disgraced film
Venable LLP
mogul Harvey Weinstein until January, after Weinstein pled not guilty to a
Vinson & Elkins
new indictment accusing him of predatory sexual assault.
Wachtell Lipton
Read full article
Watson Farley
Zebra Gets Investor Suit Over $3.5B Motorola Buy Sent To III.
Willkie Farr
A New York federal judge has transferred a proposed class action brought by
Zuckerman Spaeder
Zebra Technologies Corp. investors over the data technology company's
$3.45 billion buy of a Motorola division, sending the case to Illinois, where
COMPANIES
Zebra is headquartered.
A.W. Chesterton Co.
Order attached Read full article
Aegerion Pharmaceuticals Inc.
American Civil Liberties Union
MERGERS & ACQUISITIONS
American International Group Inc.
Amgen Inc.
5 Firms Shape Amgen's $13.4B Celgene Drug Buy
Apollo Commercial Real Estate
Amgen will shell out $13.4 billion in cash to snap up Celgene's psoriasis and
psoriatic arthritis drug, a deal shaped by five law firms that is aimed at
Apple Inc.
lessening competition concerns with Bristol-Myers Squibb's Celgene
BB&T Corp.
takeover.
BlackBerry Ltd.
Read full article
Bristol-Myers Squibb Co.
Brookfield Properties Corp.
BANKRUPTCY
CBRE Group Inc.
US Trustee Skeptical As Aegerion Creditors OK Ch. 11 Plan
Celgene Corp.
Aegerion Pharmaceuticals Inc. has reported that the overwhelming majority
Center for Constitutional Rights
of its creditors have approved its Chapter 11 plan, while a government
Chicago Bridge & Iron Co. NV
bankruptcy watchdog said he was awaiting proof the vote was set up fairly.
Citigroup Inc.
2 documents attached
Read full article
Columbia Sportswear Co.
Community Bank
EFTA00018861

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CONTRACTS
ConocoPhillips Co.
Credit Suisse Group AG
Conoco Details Venezuela Service Efforts In $8.75B Award Suit
Deutsche Bank AG
ConocoPhillips on Monday outlined its attempts to serve Venezuela with a
Dollar General Corp.
suit seeking to enforce an $8.75 billion award, responding to a New York
Dollar Tree Inc.
federal court order that asked for details on its efforts.
1 document attached Read full article
Dynamex, Inc.
Eaton Vance Corporation
TAX
Enterprise Holdings Inc.
Equifax Inc.
NY Urges Justices To Skip Designer Edelman's Tax Challenge
Goldman Sachs Group Inc.
New York's tax department has told the U.S. Supreme Court it shouldn't hear
HP Inc.
designer Sam Edelman's challenge to its taxation of intangible income of dual
Habib Bank Ltd.
residents without an offsetting credit because there's no conflict with court
precedent.
Hearst Corp.
Brief attached Read full article
International Centre for Settlement
of Investment Disputes
IMMIGRATION
JPMorgan Chase & Co.
Landau Uniforms Inc.
20 State AGs Challenge Trump Rule To Detain Migrant Kids
Levi Strauss & Co.
California and 19 other states announced Monday that they will sue the
LexisNexis Group
Trump administration over its move to eliminate a 20-day limit on the
Linkedln Corp.
detention of immigrant children, claiming it ignores standards of care
established in a decades-old settlement agreement.
Los Angeles Times
Read full article
Major Lindsey & Africa
Manulife Financial Corp.
ENERGY & ENVIRONMENTAL
Marsh & McLennan Companies
Inc.
Investor Suit Over CB&I Failed Nuke Projects Trimmed
Microsoft Corp.
Engineering and construction firm Chicago Bridge & Iron Co. NV dodged one
Morgan Stanley
of four fraud claims brought by investors over its "disastrous" acquisition of
Nardello & Co.
Shaw Group Inc. and the decline of its nuclear business Friday when a New
York federal judge ruled it time barred.
New York Times Co.
Order attached Read full article
New York University
Nike Inc.
REAL ESTATE & DEVELOPMENT
PNC Financial Services Group Inc.
Paypal Holdings Inc.
NYC Real Estate Week In Review
Point72 Asset Management LP
Jeffrey Zwick, Keusch Law and Ballard Spahr were among more than half a
RELX PLC
dozen law firms that steered the largest New York City real estate deals that
Rent-A-Center Inc.
hit public records last week, a group of transactions led by a $95 million
Brooklyn deal.
S&P Global Inc.
Read full article
S.A.C. Capital Advisors LP
SVB Financial Group
Real Estate Rumors: Brookfield, RREEF, III. Condo Complex
Shaw Industries Group Inc.
A Brookfield Properties venture has reportedly landed $807 million in
State Bar of California
financing for the Crown Building in Manhattan, Deutsche Bank arm RREEF is
said to have paid $178 million for a Florida industrial property and an Illinois
Sterling National Bank
residential condo complex is for sale and could be converted to apartments.
Tax Foundation
Read full article
The Bank of New York Mellon
Corp.
PEOPLE
The Kraft Heinz Co.
The Sherwin-Williams Co.
Gibson Dunn Grabs Banking Partner From Debevoise
Trader Joe's Co.
Gibson Dunn & Crutcher LLP has swiped a new partner from Debevoise &
Plimpton LLP's banking team, with Matthew Biben now co-chairing Gibson
University Bancorp Inc.
Dunn's financial institutions practice group in New York.
Vornado Realty Trust
Read full article
Westinghouse Electric Co. LLC
EFTA00018862

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EXPERT ANALYSIS
Yahoo! Inc.
Zebra Technologies Corp.
Investment Company Act Circuit Split Exposes Mutual Funds
iFinex Inc.
The Second Circuit's opinion in Oxford University Bank V. Lansuppe Feeder
that mutual fund investors can bring private actions to rescind contracts they
GOVERNMENT AGENCIES
allege violate the Investment Company Act creates an unconventional circuit
California Supreme Court
split, and poses litigation risk for mutual funds, say attorneys at Goodwin.
Chicago Department of Aviation
Opinion attached Read full article
European Union
The Growing Trend Of State Transfer Pricing Scrutiny
Federal Reserve System
Federal Trade Commission
Taxpayers that are prepared with contemporaneous, Internal Revenue Code
Section 482-compliant documentation supporting the arm's-length nature of
Georgia Department of Revenue
their transactions will be in the best position to defend against the
Internal Revenue Service
increasingly aggressive and coordinated state taxing authority attacks on
National Labor Relations Board
intercompany transaction pricing, say attorneys at Eversheds Sutherland.
New York Attorney General's Office
Read full article
New York State Department of
LEXIS PRACTICE ADVISOR
Financial Services
New York State Department of
Using Clawback Provisions For Employee Incentive Pay
Taxation and Finance
An employer's ability to use clawback or forfeiture provisions in employee
New York State Unified Court
compensation agreements depends on applicable state wage-and-hour laws.
System
Jeffrey Ruzal and Carly Baratt at Epstein Becker review the types of incentive
North Carolina Department of
compensation often subject to such provisions and provide drafting
Revenue
considerations for incentive compensation agreements.
Rhode Island Division of Taxation
Read full article
Securities and Exchange
Commission
LEGAL INDUSTRY
State of Rhode Island Department
of Revenue
Analysis
Texas Supreme Court
As Demand For Contract Attys Grows, Firms Outsource Risk
U.S. Attorney's Office
As the federal government and states like California split over who might
qualify as independent contractors, law firms and businesses are turning to
U.S. Bankruptcy Court for the
legal services agencies to provide a layer of protection between themselves
Southern District of New York
and their hired legal help.
U.S. Court of Appeals for the Fifth
Read full article
Circuit
U.S. Court of Appeals for the
Georgia Says It's Not Trying To Copyright Law Itself
Second Circuit
The state of Georgia has filed its opening shot in a U.S. Supreme Court case
U.S. Court of Appeals for the Third
over whether annotations to legal texts can be protected under copyright law,
Circuit
stressing it was not asking the justices to rule that "the law can be
U.S. Department of Homeland
copyrighted."
Security
Read full article
U.S. Department of Justice
U.S. District Court for the Central
Texas Free Speech Law Doesn't Apply In Fed. Court: 5th Circ.
District of California
A Texas free speech law that contains a provision to bring an early end to
U.S. District Court for the Eastern
lawsuits aimed at curbing public participation is in conflict with the Federal
District of New York
Rules of Civil Procedure and therefore cannot be used in federal court, the
Fifth Circuit has ruled.
U.S. District Court for the Southern
District of New York
Read full article
U.S. District Court for the Western
Skadden GC: Craig Defied Calls To Register As Foreign Agent
District of New York
Skadden general counsel Lawrence Spiegel told a Washington, D.C., federal
U.S. Supreme Court
jury Monday that his former colleague Gregory Craig had repeatedly defied
calls to register his work for the Ukrainian government because it would
cause him and others at the law firm to lose out on future potential job
opportunities with the U.S. government.
Read full article
EFTA00018863

=== Page 5 ===
Vinson & Elkins Atty Tapped For Texas High Court
A seat on the Texas Supreme Court that will soon be vacated by a justice
who has been confirmed to the federal bench will be filled by a former state
appellate judge and current Vinson & Elkins LLP attorney, Texas Gov. Greg
Abbott said Monday.
Read full article
Former Bryan Cave Partner Appointed Cred General Counsel
Cryptocurrency lending and borrowing company Cred has hired as its
general counsel an attorney who previously served as head of Bryan Cave
Leighton Paisner LLP's fintech practice, the company announced on Monday.
Read full article
Interview
15 Minutes With AIG's General Counsel
When people ask Lucy Fato how she spends her time as the general counsel
at AIG, she says she connects dots for others within the finance and
insurance corporation to complete tasks more quickly and efficiently. Here,
she shares the importance of her law firm experience, a lesson about
leadership, and how she helped Tilda Swinton win an Oscar.
Read full article
JOBS
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elite lit boutique II mid level assoc
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Patent/life sciences PhD NYC
BIG LAW seeks mid-level L&E assoc NYC
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Stellar mid-sized firm seeks outstanding
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JD/Chief of Staff Music Law Firm
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NYC, New York
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Insurance Coverage Associate
ECVC Associate Attorney
Skarzynski Marick & Black LLP
Perkins Coie LLP
New York, New York
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Employment Associate (3+ yrs)
NY/NJ Employment Attorney (3-6 yrs)
Gordon & Rees
Gordon & Rees
New York, New York
New York, -
Attorney - Commercial
Real Estate Mid to Senior Attorney
Litigation/Professional & General Liability
Hunton Andrews Kurth
(3-6 yrs)
New York, New York
Gordon & Rees
New York, New York
EFTA00018864

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=== Page 1 ===
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
U.S. ATTORNEY GEOFFREY S. BERMAN
FOR IMMEDIATE RELEASE
CONTACT: U.S. ATTORNEY'S OFFICE
Tuesday, November 19, 2019
http://www.justice.gov/usao/nys
DOJ OIG
FBI
CORRECTIONAL OFFICERS CHARGED WITH FALSIFYING RECORDS
ON AUGUST 9-10 AT THE METROPOLITAN CORRECTIONAL CENTER
Defendants Allegedly Created Records Falsely Attesting to Required Checks of Inmates the
Defendants Never Did in the Special Housing Unit on the Night Inmate Jeffrey Epstein
Committed Suicide
Geoffrey S. Berman, the United States Attorney for the Southern District of New York,
Michael Horowitz, the U.S. Department of Justice ("DOJ") Inspector General, and William F.
Sweeney Jr., Assistant Director-in-Charge of the New York Field Office of the Federal Bureau
of Investigation ("FBI"), announced today the unsealing of an indictment charging federal
correctional officers TOVA NOEL and MICHAEL THOMAS with making false records and
conspiring to make false records and to defraud the United States by impairing the lawful
functions of the Metropolitan Correctional Center ("MCC"), a Manhattan detention facility that
houses federal inmates. NOEL and THOMAS surrendered this morning. The case is assigned to
Southern District of New York U.S. District Judge
-
U.S. Attorney Geoffrey S. Berman said: "As alleged, the defendants had a duty to ensure
the safety and security of federal inmates in their care at the Metropolitan Correctional Center.
Instead, they repeatedly failed to conduct mandated checks on inmates, and lied on official forms
to hide their failures. These defendants will now be held accountable for their brazen attempt to
shirk their responsibilities and conceal their conduct."
DOJ Inspector General Michael Horowitz said:
FBI Assistant Director William F. Sweeney Jr. said:
EFTA00017912

=== Page 2 ===
According to the Indictment filed today in Manhattan federal court:
On August 10, 2019, NOEL and THOMAS repeatedly failed to complete mandated
counts of prisoners under their watch in the MCC's Special Housing Unit ("SHU"). Instead, for
substantial portions of their shifts, NOEL and THOMAS sat at their desk, browsed the internet,
and moved around the common area of the SHU. To conceal their failure to complete their
duties, NOEL and THOMAS repeatedly signed false certifications attesting to having conducted
multiple counts of inmates that they did not do. As a result of those false statements, the MCC
believed prisoners in the SHU were being regularly monitored when, in fact, as a result of the
defendants' conduct, no correctional officer conducted any count or round of the SHU from
approximately 10:30 p.m. on August 9 until approximately 6:30 a.m. on August 10, at which
time, NOEL and THOMAS discovered the body of MCC inmate Jeffrey Epstein, who had
committed suicide while unobserved earlier that morning.
Background on Relevant Individuals & Entities
The MCC is a federal administrative detention facility located in Manhattan that is run by
the Federal Bureau of Prisons. The MCC employs correctional officers, whose primary duty is
to ensure the care, custody, and control of the inmate population of the MCC. NOEL has been
employed as a correctional officer at the MCC since approximately 2016, and THOMAS has
been employed as a correctional officer at the MCC since approximately 2007. Both NOEL and
THOMAS were regularly assigned to work shifts in the SHU at the MCC.
Correctional officers assigned to guard inmates in the SHU - and throughout the MCC -
are required to conduct institution-wide counts of inmates at regular, scheduled intervals to
ensure that each inmate is alive and accounted for within the MCC. Two officers are required to
complete the institutional count for each housing unit, including the SHU, and are further
required to document their performance of the count on an official MCC form called a count slip.
In addition to the institutional count, MCC correctional officers assigned to the SHU are required
to complete rounds every thirty minutes to ensure that each inmate is alive and accounted for
within his cell. Correctional officers working in the SHU are required to complete a form
documenting the date and time of each 30-minute round in each area of the SHU.
On July 6, 2019, Epstein was arrested and detained at the MCC on sex trafficking
charges, and was subsequently assigned to the SHU due to risk factors for suicidality and safety
concerns. After an apparent suicide attempt on July 23, 2019, Epstein was transferred to suicide
watch and then psychological observation. Upon being moved back to the SHU on July 30,
2019, the MCC took steps to guard against future suicide attempts by Epstein, including by
assigning Epstein to the cell closest to the correctional officers' desk. Conducting the required
institutional counts and thirty-minute rounds in the SHU were also part of the MCC's procedures
for ensuring the safety of inmates, including Epstein.
The Events of August 9-10, 2019
On August 9, 2019, NOEL was assigned to work in the SHU from 4 p.m. on August 9,
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.
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=== Page 3 ===
2019 to 8 a.m. on August 10, 2019. THOMAS was assigned to work with NOEL in the SHU
from 12 a.m. until 8 a.m. on August 10, 2019. From 4 p.m. on August 9 to 8 a.m. on August 10,
the officers on duty in the SHU, including NOEL and THOMAS, were responsible for
conducting five institutional counts at 4 p.m. and 10 p.m. on August 9, and at 12 a.m., 3 a.m.,
and 5 a.m. on August 10. NOEL and THOMAS were also responsible for completing forms
attesting to the completion of each of those counts. In fact, NOEL, and then NOEL and
THOMAS, repeatedly failed to complete mandated counts in the SHU. Instead for substantial
portions of their 12-8 a.m. shifts, in particular, NOEL and THOMAS sat at their desk, browsed
the internet, and moved around the common area of the SHU. During that time period, NOEL
and THOMAS were the only correctional officers assigned to the SHU. Aside from two other
officers who briefly visited the common area of the SHU, as confirmed by video surveillance, no
one else entered the SHU, no one conducted any counts or rounds throughout the night, and no
one entered the area in which Epstein was housed.
To conceal their failure to complete their duties, NOEL signed false certifications
attesting to having conducted counts of inmates at 4 p.m. and 10 p.m., and NOEL and THOMAS
signed false certifications attesting to having conducted counts of inmates at 12 a.m., 3 a.m., and
5 a.m. when, in truth and in fact, they never conducted such counts. As a result of those false
reports, the MCC believed prisoners in the SHU were being regularly monitored and accounted
for when, in fact, no correctional officer conducted any count or round of the SHU from
approximately 10:30 p.m. on August 9 until approximately 6:30 a.m. on August 10, at which
time, NOEL and THOMAS discovered the body of Epstein, who had committed suicide by
hanging himself earlier that morning while unobserved.
NOEL, 31, and THOMAS, 41, are each charged with one count of conspiring to defraud
the United States by impairing, obstructing, and defeating the lawful functions of the MCC, and
to make false records, which carries a maximum sentence of five years in prison. NOEL is also
charged with five counts of making false records, and THOMAS is also charged with three
counts of making false records, each of which carries a maximum sentence of five years in
prison.
The statutory maximum and mandatory 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.
Mr. Berman praised the outstanding investigative work of DOJ OIG and the FBI.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S.
Attorneys
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendants are
presumed innocent unless and until proven guilty.
19-XXX
###
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From:
To:
Subject: RE: 2021.10.04 Maxwell Jury Questionnaire [with Defense Additions Formatted and Gov't
Response].docx
Date: Sun, 10 Oct 2021 21:27:00 +0000
Attachments: JOINT_Proposed_Voir_Dire_Sent_(Reponse_to_Defense_v2).docx
It's in the share too. I'm most worried about making sure I accurately did red->green and blue->purple!
From:
Sent: Sunday, October 10, 2021 5:08 PM
To:
Subject: 2021.10.04 Maxwell Jury Questionnaire [with Defense Additions Formatted and Gov't Response].docx
EFTA00019194


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 266 Filed 05/03/21 Page 1 of 3
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:
Last summer, the Court scheduled trial in this matter to commence on July 12, 2021. On
March 29, 2021, three and a half months before trial, the Government filed an S2 Superseding
Indictment. As a result of the late filing of the S2, counsel for Defendant Ghislaine Maxwell
request a continuance of the trial date until either fall 2021 or January 2022. I The Government
opposes any continuance, but requests that if one is granted it be until March of 2022. Having
carefully considered the parties' respective positions, the Court GRANTS Maxwell's request for
a short continuance until the fall of 2021 to allow the defense to prepare for the additional
charges brought in the S2 indictment. The Court rejects Maxwell's alternative request to
continue the trial date until January of 2022 and the Government's alternative proposal that the
Court adjourn trial until March of 2022.
The Court bases its decision on a number of factors. First, the filing of the S2 indictment
has added a significant burden to the defense's preparation for trial. The new indictment alleges
I The alternative request by Maxwell resulted from a conflict among lawyers involved in both this case and a
criminal matter before Judge Furman, which is discussed in defense counsel's letter. Dkt. No. 246 at 4. The Court
has been informed that Judge Furman has adjourned the trial date with respect to two defendants. The Court
presumes that this eliminates the September through December conflict for one of Maxwell's defense counsel. It
presumably does not eliminate the conflict for one of the AUSAs involved in both cases. Dkt. No. 235 at 10 n.5.
EFTA00020307

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 266 Filed 05/03/21 Page 2 of 3
that the conspiracies charged in Counts 1 and 3 extended to 2004 (the S1 charged through 1997),
identifying a fourth alleged victim, Minor Victim-4. It also adds two new charges: Count 5 of
the S2 Indictment charges Maxwell with participating in a sex trafficking conspiracy between
2001 and 2004, and Count 6 charges Maxwell with participating in the sex trafficking of a minor
or aiding and abetting the same. Dkt. No. 187. These additions will require the defense to (1)
review a substantial amount of discovery that is now potentially relevant as a result of the S2
Indictment; (2) re-review discovery that it had previously considered in light of the changes to
the case against her; (3) conduct new investigations based on the new charges, including
potential interviews of new witnesses; and (4) re-evaluate her trial preparation and strategy.
Second, although jury trials have resumed in the district and conditions in MDC and around the
country are improving, the defendant's and defense counsel's preparation efforts to date have
been and to some extent continue to be hampered by the effects of the COVID-19 pandemic. As
the Government indicated in explaining the delay in filing the new charges, travel constraints and
other safety concerns resulting from the pandemic have slowed trial preparation and complicated
the logistics of conducting investigations. See Dkt. No. 199 at 2. Third, defense counsel must
balance preparing for trial with considering and preparing any supplemental pre-trial motions in
response to the new charges contained in the S2 Indictment. Although the perjury counts were
recently severed, the Court cannot conclude that this sufficiently offsets the additional burdens
placed on the defense as a result of the new charges and expanded timeframe resulting from the
S2 indictment.
The Court is very mindful of the countervailing considerations that require that any
adjournment be no longer than necessary. For one, the Defendant, whose counsel strenuously
request the adjournment, is detained pre-trial. Moreover, with many lawyers on both sides of
EFTA00020308

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 266 Filed 05/03/21 Page 3 of 3
this case, any adjournment runs the risk of precluding some attorneys from being able to
participate and/or requiring them to seek adjustments to schedules in other matters. And,
importantly, any victims and the public more broadly have a strong interest in trial proceeding
without undue delay. It is the Court's obligation to ensure that the case proceed to that trial as
expeditiously as possible, taking into account the interests of justice and all relevant
circumstances. See 18 U.S.C. §3161(h)(7)(A); 18 U.S.C. § 3771(a)(7).
Having balanced all of the factors outlined above, the Court concludes that the interests
of justice justify granting a short continuance. The Court deems an adjournment until fall 2021
to be reasonable. Such an adjournment would plainly give the defense team sufficient time to
prepare for trial in light of the additional charges contained in the S2 indictment while also
ensuring that the trial proceeds without undue delay. No additional delay is necessary or in the
interests of justice.
The parties are hereby ORDERED to meet and confer and by May 10, 2021, they shall
jointly propose a trial start date for the Court to request of the Clerk's Office (as is required by
COVID protocols). The Court urges counsel to agree to the earliest possible date this fall and to
seek adjustments to other schedules in order to facilitate an early fall trial start date. The parties
shall also discuss and propose any adjustments necessary to the pre-trial schedule in place. Dkt.
No. 250. The Government may move in the letter for any requested exclusion of time under the
Speedy Trial Act.
so ORDERED.
Dated: May 3, 2021
New York, New York
Alim D.Netto
ALISON J. NATHAN
United States District Judge
EFTA00020309


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From: BOBBI C STERNHEIM
To:
Cc:
Bcc:
"
Subject: Ghislaine Maxwell (02879-509)
Date: Sun, 01 Nov 2020 17:41:30 +0000
Embedded: Ghislaine_Maxwell_(02879-509).msg
Sender:
Subject: Ghislaine Maxwell (02879-509)
Message-Id: <CCC9E11D-9E92-49B2-B2CC-345A0D6C31D4@mac.com>
Recipient:
EFTA00019139


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ORIGINAL
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
Doettz In the Matter of the Search of
UNITED STATES DISTRICT COURT
for the
Southern District of New York
)
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case No.
See Attachment A
)
)
19MAG
6573
)
SEARCH AND SEIZURE WARRANT
To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Southern
District of
New York
(identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before
7.20.19
(not to exceed 14 days)
in the daytime 6:00 a.m. to 10 p.m.
at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USMJ Initials
I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box)
for
days (not to exceed 30).
until, the facts justifying, the later specific date of
Date and time issued:
7.6.19
Robertlens
Judge's signature
City and state:
New York, NY
Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and title
EFTA00020134

=== Page 2 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Case No.:
Date and time warrant executed:
Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
EFTA00020135

=== Page 3 ===
ATTACHMENT A
I. Premises to be Searched-Subject Premises
1.
The premises to be searched (the "Subject Premises") are described as a nearly
19,000 square foot multi-story single-family residence located at
New York,
New York, and include all locked and closed containers found therein. A photograph of the front
entrance to the Subject Premises is included below:
Google
II. Items to Be Seized
1. This warrant authorizes executing agents to photograph, video record and otherwise
document the full interior of the Subject Premises, including any items, furnishings, or possessions
therein.
2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows:
a. Evidence concerning occupancy or ownership of the Subject Premises,
including utility and telephone bills, mail envelopes, addressed correspondence,
diaries, statements, identification documents, address books, telephone
directories, and photographs of its occupant(s).
b. Evidence concerning the layout, furnishings, decorations, and floor pattern of
the Subject Premises, including photographs and blueprints of the Subject
Premises.
2017.08.02
EFTA00020136


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BHT
SEAL
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 28, 2019
Florence Hutner, Esq.
General Counsel
Office of the Chief Medical Examiner
421 East 26th Street
New York, New York
Re: Autopsy Report and File for Jeffrey Epstein
Dear Ms. Hutner:
As you are aware, the United States Attorney's Office for the Southern District of New
York ("USAO") and the Federal Bureau of Investigation ("FBI") are conducting an ongoing
criminal investigation into the events related to Mr. Epstein's August 10, 2019 suicide at the
Metropolitan Correctional Center ("MCC") (the "Criminal Investigation"). As you are also aware,
between August 10, 2019, and August 16, 2019, at OCME's request and in order to assist OCME
in determining the cause and manner of Mr. Epstein's death, the USAO and FBI gave OCME
access to certain materials and information gathering during the Criminal Investigation.
As discussed by phone, while the OCME autopsy is now complete, the Criminal
Investigation remains ongoing. As such, and in order to avoid compromising the Criminal
Investigation, we request that OCME withhold from disclosure to any third party any documents,
evidence or information made available to OCME by the USAO or FBI-including documents,
records, or materials from the MCC-or created by OCME or within the OCME case file that
include, reflect, or contain information made available to OCME by the USAO or FBI. We also
request that you withhold from any disclosure the names and identifying information of any federal
law enforcement agents or employees who were interviewed by the OCME, along with the
substance of any statements or interviews made by those agents or employees.
EFTA00018944

=== Page 2 ===
Page 2
We appreciate your willingness to comply with this request. Should you decide at any
future point, notwithstanding this request, to produce any of the above-referenced material to any
third party, we request that you notify us before you do so, so that we may seek additional process.
Please contact us with any further questions.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
by:
/s/
Assistant United States Attorneys
EFTA00018945


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From:
)"
To:
)"
)"
Subject: Fwd: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein.
She is willing to fly to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to
discuss ?
Date: Fri, 18 Oct 2019 23:16:40 +0000
Gloria just left me a vm- she said the client is a victim form the 90s and is willing to be interviewed on
Wednesday. I think she wants to know soon whether we want to do that, because it affects trial arrangements. I'll
be on trial on Wednesday, so defer to you as to whether that fits your schedules.
Sent from my iPhone
Begin forwarded message:
From: Gloria Allred
Date: October 18, 2019 at 5:02:17 PM EDT
To:
)"
Cc:
)"
Subject: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is
willing to fly to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.jpg>
<image002.png>
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
EFTA00019717


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=== Page 1 ===
From:
)"
To:
Subject: RE: Fedex
Date: Fri, 16 Jul 2021 14:12:09 +0000
Inline-Images: image001.jpg
Thanks,
I'll loop back in in a couple of months and let you know where things stand.
Thanks again, and have a nice weekend.
From:
Sent: Friday, July 16, 2021 10:11 AM
To:
Subject: RE: Fedex
Good morning,
Sorry for my late response. I have been out of the office all week. I can testify if need be. Let me know if you need
anything further.
Thank you,
Senior Paralegal
Federal Express Corporation
FedEx®
Express
Legal Department
Memphis, TN 38125
(t)
From:
)
Sent: Tuesday, July 13, 2021 2:34 PM
To:
Cc:
Subject: [EXTERNAL] RE: Fedex
Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown
or suspicious origin.
Thanks,
We'd like to identify a records custodian who could testify, in the event that it would be necessary.
We found the attached cover letter and certification from FedEx in 2008, in case they are helpful in finding the specific
production on your end.
Thanks,
EFTA00018186

=== Page 2 ===
From:
Sent: Wednesday, July 7, 2021 11:07 AM
To:
Cc:
Subject: RE: Fedex
Good morning,
Please see attached. Let me know if you need anything further.
Thank you,
Senior Paralegal
Federal Express Corporation
FedEx®
Express
Legal Department
Memphis, TN 38125
(t)
From:
Sent: Tuesday, July 6, 2021 12:33 PM
To:
Cc:
Subject: [EXTERNAL] RE: Fedex
Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown
or suspicious origin.
Hi
We'd like someone to sign an affidavit for now, but we'd also like to identify someone who could testify at trial if need be.
The trial is for Ghislaine Maxwell, scheduled to start in New York in November.
I've attached a proposed declaration, though if FedEx has its own standard format, that will likely work too.
Thanks,
From:
Sent: Tuesday, July 6, 2021 10:49 AM
To:
Cc:
Subject: RE: Fedex
Good morning,
EFTA00018187

=== Page 3 ===
I have reviewed the records and they seem to be our records. Are you needing someone to sign an affidavit or appear in
person at trial? (is this "the" Jeffrey Epstein?)
Thank you,
Senior Paralegal
Federal Express Corporation
FedEx®
Express
Legal Department
Memphis, TN 38125
(t)
From:
Sent: Tuesday, July 6, 2021 9:25 AM
To:
Cc:
Subject: [EXTERNAL] RE: Fedex
Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown
or suspicious origin.
Hi
I hope you had a nice weekend, and thanks again for the call last week. I've attached the FedEx records for which we are
looking for a records custodian. According to a log, the U.S. Attorney's Office for the Southern District of Florida sent
FedEx a subpoena in February 2008, and the FedEx point of contact wa
If we find any front matter, like an
internal tracking number, we'll let you know.
Thanks again for your assistance with this. Please let me know if you have any questions.
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
From:
Sent: Friday, July 2, 2021 11:08 AM
EFTA00018188

=== Page 4 ===
To:
(CTR)
is
Subject: RE: Fedex
Thanks,
!
would you mind giving me a call when you have a chance? My number is
Thanks,
From:
(CTR)
Sent: Friday, July 2, 2021 11:05 AM
To:
;
) <
Subject: Fedex
Hi
You have been extremely helpful in the past with me I was hoping you can lend assistance to the assistant United States
attorney,
I'm working with.
is ccd on this email, if you want to reply and see what she can help
with.
Thank you in advance for al your help,
Sent with BlackBerry Work
(www.blackberry.com)
EFTA00018189


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From:
To:
Subject: 20cr330, US V. Maxwell
Date: Wed, 03 Nov 2021 16:02:18 +0000
Attachments: 20cr330_FINAL_Jury_Questionnaire_11.3.21.pdf
Counsel:
Attached is the final copy of the Court's jury questionnaire, which will be distributed by the Jury Department to
prospective jurors beginning tomorrow. The final version incorporates the redline changes from Dkt. No. 365.
Otherwise, a few minor non-substantive formatting changes were made to pages 1 and 5.
Sincerely,
Chambers of the Hon. Alison J. Nathan
EFTA00019061


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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:
to testify and give evidence in the following matter:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
PERSONAL APPEARANCE IS REQUIRED
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
July 13, 2021
andy
AUDREY STRAUSS
United States Attorney for the
UNITED STATES DISTRICT COURT
Southern District of New York
Assistant United States Attorney
RICT FOR THE YORK
New York, New York 10007
Telephone:
rev. 02.01.12
EFTA00019872


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=== Page 1 ===
From:
(USANYS)"
To:
[Contractor]
Cc:
)"
)"
Subject: FW: SDFL Epstein-related documents
Date: Wed, 17 Mar 2021 16:12:06 +0000
Attachments: Epstein_box_inventory_8-21-2020.pdf
From:
Sent:
To:
(USANYS)
Cc:
USANYS)
is
>;
is
(USANYS)
is
[Contractor]
Subject: RE: SDFL Epstein-related documents
Hello
I can do a call this afternoon. Any time between 2:00 p.m. and 4:00 p.m. is best. Alternatively, I am available tomorrow
during the same time period. Let me know which time is more convenient for you and your team. If these times don't
work, let me know and we will work out an alternate time.
In the meantime, we have all the materials in a secure room on our second floor in West Palm Beach. There are the case
files and also boxes of files that were gathered for the OPR inquiry. We have an inventory of our materials and also OPR
has their own inventory of the materials.
When OPR was here earlier, we had a scanner on that floor dedicated for their exclusive use. They were able to scan the
documents that they wanted and have those documents sent directly to their own DOJ accounts. I was overseas at the
time on detail, but I was told that this worked rather well.
A copy of our inventory is attached.
I look forward to assisting you in this matter.
Best regards,
Managing Assistant United States Attorney
West Palm Beach Regional Office - SDFL
EFTA00018995

=== Page 2 ===
From:
(USANYS)
Sent: Tuesday, August 25, 2020 9:00 AM
To:
Cc
SANYS)
is
>;
is
(USANYS)
is
[Contractor]
Subject: SDFL Epstein-related documents
- We supervise the team in New York that is currently prosecuting Ghislaine Maxwell, and
suggested
we reach out to you. As discussed briefly with
we are hoping to locate the boxes of documents and other records
regarding the prior SDFL investigation into Jeffrey Epstein and his co-conspirators that we understand are currently being
stored in the West Palm Beach office. In particular, we would like to make arrangements to review and scan those
materials in connection with our own case, and
suggested that we touch base with you on how best to do so.
I've copied the trial team here. Please let us know if you have time for a call in the near future to discuss further.
Alternatively, if there is a more appropriate point of contact on this issue, please feel free to point us in that direction.
Thanks very much,
Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00018996


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From:
)"
To:
(USANYS)"
Subject: RE: Cooperator info re Epstein
Date: Wed, 28 Aug 2019 22:20:33 +0000
I'd be willing to bet some money that today will not be the last time you'll be hearing about
and
From:
(USANYS)
Sent: Wednesday, August 28, 2019 6:07 PM
To:
,
Subject: FW: Cooperator info re Epstein
All roads lead to you. FYI.
From:
(USANYS)
Sent: Saturday, August 24, 2019 2:54 PM
To:
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
>;
(USANYS)
i
(USANYS)
Subject: Re: Cooperator info re Epstein
He did, but
is the one who spoke directly with him, so he can give you the most detail. (I took
off this, so he
doesn't respond with the substance and create needless 3500.) The most significant takeaway I recall from
summary was that
said he gave Epstein the sheets he used. But again, this is second-hand, and
has his own
issues we can discuss separately.
Sent from my iPhone
On Aug 24, 2019, at 2:38 PM,
(USANYS)
wrote:
Thanks. Did he provide more substance beyond he heard information relating to Epstein? If so, let's talk Monday.
From:
(USANYS)
Sent: Saturday, August 24, 2019 1:52 AM
To:
(USANYS)
Cc:
(USANYS)
in
(USANYS)
>;
Stefano (USANYS) <SBraccini@usa.doj.gov>;
(USANYS)
is
(USANYS)
Subject: Re: Cooperator info re Epstein
Let me know if you want to meet with
He's
nd we haven't yet
decided whether to extend him a cooperation agreement.
Sent from my iPhone
On Aug 23, 2019, at 6:12 PM,
(USANYS)
wrote:
Hi
and
I just spoke with
who got a call from an aspiring cooperator at MCC named
reported that another MCC inmate known as
EFTA00019699

=== Page 2 ===
gave him information relating to Epstein. For
several months,
has been desperately trying to figure out how he can cooperate, often relying on second- and
third-hand information that's not actionable unless another inmate also cooperates. We can also talk in person next
week about the relative quality of his information.
I leave it to you guys to follow up with
as you see fit. I'm sure someone on this email can make
available
to you, if you want, once you get a sense of what he's about. I just don't want to unilaterally sit on this.
Have a nice weekend!
Assistant United States Attorney
Southern District of New York
EFTA00019700


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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein Meeting (Please hold the time)
Date: Wed, 15 Jan 2020 23:17:41 +0000
Importance: Normal
Attachments: unnamed
EFTA00019229


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
-V.-
GHISLAINE MAXWELL,
Defendant.
INSTRUCTIONS TO FOCUS GROUP
1
EFTA00018008

=== Page 2 ===
Summary of Indictment
The Indictment contains three counts, or "charges," against GHISLAINE MAXWELL,
the defendant.
Count One of the Indictment charges the defendant, with conspiring-that is, agreeing-
with others to transport a minor in interstate and foreign commerce, with intent that the minor
engage in sexual activity for which a person can be charged with a criminal offense. Count One
relates to multiple minor victims during the time period 1994 to 2004.
Count Two of the Indictment charges the defendant with conspiring to engage in sex
trafficking of minors. Count Two relates to multiple minor victims during the time period 2001
to 2004.
Count Three of the Indictment charges the defendant with sex trafficking of minors.
Count Three relates to Minor Victim-4, during the time period 2001 to 2004.
2
EFTA00018009

=== Page 3 ===
Burden of Proof and Multiple Counts
In a moment, I will describe those three counts in more detail. Before I do, however, let
me explain that the Government has the burden of proving the defendant's guilt on each count by
a preponderance of the evidence. That means that the Government must show that it is more
likely than not that the defendant is guilty of each count.
You must consider each count separately and return a separate verdict of guilty or not
guilty for each. Whether you find the defendant guilty or not guilty as to one offense should not
affect your verdict as to any other offense charged.
You have no doubt heard that a defendant's guilt in a criminal case must be proved
beyond a reasonable doubt. That is not the standard we are applying in today's exercise. As I
said, the question for you today is whether it is more likely than not that the defendant is guilty
of each count.
3
EFTA00018010

=== Page 4 ===
Count One: Conspiracy to Transport Minors
As I mentioned, Count One of the Indictment charges the defendant with conspiracy to
transport minors between 1994 and 2004.
In order to satisfy its burden of proof with respect to the allegation of conspiracy, the
Government must establish each of the following elements:
First, the existence of the conspiracy charged in the Indictment; that is, as to Count One, a
conspiracy to transport a minor with intent that the minor engage in sexual activity for which a
person can be charged with a criminal offense. You should know that a conspiracy just means that
the defendant you are considering agreed with at least one other person to violate the law.
Second, that the defendant intentionally and knowingly became a member of the
conspiracy. That is, she knowingly participated in the conspiracy with knowledge of its object
and with an intent to further the aims of the conspiracy. The defendant's mere presence at the
scene of the alleged crime does not, by itself, make her a member of the conspiracy. Similarly,
mere knowledge or acquiescence, without participation, in the unlawful plan is not sufficient. In
other words, knowledge without agreement and participation is not sufficient. On the other
hand, it is not necessary for the Government to show that a defendant was fully informed as to all
the details of the conspiracy in order for you to infer knowledge on her part, and it does not
matter whether the defendant's role in the conspiracy may have been more limited than or
different in nature or in length of time from the roles of her co-conspirators, provided she was
herself a participant.
With respect to Count One, in order to sustain the charge that the defendant conspired to
transport an individual with intent that the person engage in sexual activity for which a person can
be charged with a criminal offense, the Government must prove that the purpose of the conspiracy
was to transport an individual with intent that the individual engage in sexual activity for which a
4
EFTA00018011

=== Page 5 ===
person can be charged with a criminal offense, which contains three elements:
First, that the defendant knowingly transported an individual in interstate or foreign
commerce. This means that the Government must prove that the defendant knew both that she
was causing the individual to be transported, and that the individual was being transported in
interstate commerce. The Government does not have to prove that the defendant personally
transported the individual across a state line or international border. It is sufficient to satisfy this
element that the defendant acted through an agent or was engaged in the making of the travel
arrangements, such as by purchasing tickets necessary for the individual to travel as planned.
Second, that the defendant transported the individual with the intent that the individual
engage in any sexual activity for which any person can be charged with a criminal offense. Count
One alleges sexual activity for which a person could be charged with a crime under the criminal
law of New York. Specifically, a person commits sexual abuse of a minor in the third degree
when he or she subjects another person to sexual contact without the latter's consent. Under New
York law, "sexual contact" means any touching of the sexual or other intimate parts of a person
for the purpose of gratifying the sexual desire of either party. Also under New York law, a person
less than seventeen years old is incapable of consent.
Third, the individual must be less than seventeen years old, and the defendant must know
that the individual is less than seventeen years old.
It is not a defense to the crime of sexual abuse of a minor in the third degree that the minor
voluntarily participated or consented.
5
EFTA00018012

=== Page 6 ===
Count Two: Conspiracy to Commit Sex Trafficking
Count Two charges the defendant with conspiracy to commit sex trafficking between 2001
and 2004.
As with Count One, in order to satisfy its burden of proof with respect to the allegation of
conspiracy, the Government must establish the following elements:
First, the existence of the conspiracy charged in the Indictment; that is, as to Count Two, a
conspiracy to commit sex trafficking.
Second, that the defendant intentionally and knowingly became a member of the
conspiracy. That is, she knowingly participated in the conspiracy with knowledge of its object
and with an intent to further the aims of the conspiracy.
With respect to Count Two, in order to sustain the charge that the defendant conspired to
commit sex trafficking, the Government must prove by a preponderance of the evidence that the
purpose of the conspiracy was to commit sex trafficking, which contains four elements:
First: The defendant knowingly recruited, enticed, harbored, transported, provided, or
obtained a person. Those terms have their ordinary, everyday meanings.
Second: The defendant knew that the person was under the age of eighteen years.
Third: The defendant knew the person would be caused to engage in a commercial sex
act. The term "commercial sex act" means "any sex act, on account of which anything of value
is given to or received by any person." The thing of value may be money or any other tangible
or intangible thing of value that may be given to or received by any person, regardless of whether
the person who receives it is the person performing the commercial sex act. It is not required
that the person actually have performed a commercial sex act, and it is not a defense that the
person consented.
Fourth: The defendant's acts were in or affecting interstate commerce. I instruct you
6
EFTA00018013

=== Page 7 ===
that acts and transactions that cross state lines, or which affect the flow of money in the stream of
commerce to any degree, however minimal, are acts and transactions affecting interstate
commerce. For instance, it affects interstate commerce to use products that traveled in interstate
commerce. Proof of actual travel is not required.
7
EFTA00018014

=== Page 8 ===
Count Three: Sex Trafficking of Minor Victim-4
Count Three charges the defendant with the sex trafficking of Minor Victim-4 between
2001 and 2004. I have just reviewed the four elements of sex trafficking with you. In order to
satisfy its burden of proof with respect to Count Three, the Government must establish by a
preponderance of the evidence that the defendant committed those elements in the sex trafficking
of Minor Victim-4.
In addition, you may find the defendant guilty of Count Three under a theory of
liability called "aiding and abetting," which permits a defendant to be convicted of a specified
crime if the defendant, while not herself committing the crime, assisted another person or
persons in committing the crime. To aid or abet another to commit a crime, it is necessary that
the Government prove that the defendant willfully and knowingly associated herself in some way
with the crime committed by the other person and willfully and knowingly sought by some act to
help the crime succeed.
8
EFTA00018015


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=== Page 1 ===
From: "Margolin, James (USANYS) [Contractor]"
To:
Subject: Opinion | Julie Brown's Fight to Expose Epstein's Crimes - and Earn a Living - The New York
Times
Date: Sun, 18 Jul 2021 12:00:50 +0000
https://www.nytimes.com/2021/07/17/opinion/julie-brown-epstein-book.html
James Margolin
Chief Public Information Officer
U.S. Attorney's Office, SDNY
(office)
(cell)
EFTA00019648


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=== Page 1 ===
From: "
To:
Cc:
Subject: Re: Epstein
Date: Mon, 08 Jul 2019 11:06:30 +0000
Importance: Normal
Looping in assigned AUSA,
On Jul 8, 2019, at 06:55,
wrote:
Hey
Do you have any info about the presentment etc for this case that we can forward to the Marshal.
Thank you
Supervisory Deputy U.S. Marshal
Southern District of New York
EFTA00018150


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=== Page 1 ===
From:
"
(NY) (FBI)"
To:
(USANYS)"
Cc:
(OIG)"
Subject: Finalized 302
Date: Wed, 18 Sep 2019 18:58:03 +0000
Attachments:
.pdf
Special Agent
FBI New York Field Office
Violent Crimes Task Force
Desk:
Cell:
EFTA00017785


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=== Page 1 ===
From:
(USANYS)"
To:
(OIG)"
Cc:
(USANYS)"
(USANYS)"
N
(USANYS)"
,
(OIG)"
(OIG)"
Subject: Re: MCC NY - Epstein Matter
Date: Mon, 12 Aug 2019 12:52:35 +0000
Just spoke to
Sent from my iPhone
On Aug 12, 2019, at 8:40 AM,
,
(OIG)
wrote:
Good Morning,
I tried calling
but his message indicates he is out. Can one of you please call me to briefly
discuss the interviews planned for today? I am currently on my cell phone and my contact information is
below.
Thank you.
Special Agent in Charge
U.S. Department of Justice
Office of the Inspector General
New York Field Office
New York, NY 10004
(Office)
(Cell)
EFTA00019066


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=== Page 1 ===
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Main: 212-243-1100
Cell: 917-912-9698
Fax: 888-587-4737
bcsternheim@mac.com
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
On Mar 16, 2021, at 6:33 PM, BOBBI C STERNHEIM <bcsternheim@mac.com wrote:
Good evening-
As set forth in the attached cover letter (to be filed via ECF)
and pursuant to Rule 2(B) of the Court's individual rules,
attached for the Court and government is an unredacted version
of the Reply Memorandum In Support of Ms. Maxwell's pending bail application.
Thank you.
Best-
Bobbi
<Maxwell Cover Letter 3-16-21.pdf>
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Main: 212-243-1100
Cell: 917-912-9698
Fax: 888-587-4737
bcsternheim@mac.com
**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.
EFTA00018992

=== Page 2 ===
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.
EFTA00018993


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-58 United States of America V. Maxwell "Notice of Telephonic Date Acknowledgment FILED"
Date: Fri, 09 Apr 2021 14:39:30 +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 04/09/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Document(s): Document(s)
Docket Text:
NOTICE OF HEARING DATE ACKNOWLEDGMENT, on behalf of Appellant Ghislaine Maxwell, FILED.
Service date 04/09/2021 by CM/ECF. Note: Listed counsel must log on to CM/ECF in order to view the
attachment. [3074153] [21-58]
Notice will be electronically mailed to:
Calendar E-Box, -: calendar@ca2.uscourts.gov
Notice will be stored in the notice cart for:
Calendar E-Box, -
The following document(s) are associated with this transaction:
Document Description: Notice of Telephonic Date Acknowledgment FILED
Original Filename: Case Calendaring Notice.pdf
Electronic Document Stamp:
EFTA00018247

=== Page 2 ===
[STAMP acecfStamp_ID=1161632333 [Date=04/09/2021] [FileNumber=3074153-0]
[214a4c2f4ef37767dc7db496766ef39f13644ae2aba7a16c99d155acb3597a39e6b994e2ea3160fb76805b220ad1
746d97c4d6479b26c48a229754b7c6b4909]]
EFTA00018248


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=== Page 1 ===
Event: Accepted: Proffer:
Start Date: 2019-09-10 15:30:00 +0000
End Date: 2019-09-10 18:00:00 +0000
Location: WPB Hilton
Class: X-PERSONAL
Comment:
Date Created: 2019-12-18 02:47:16 +0000
Date Modified: 2019-12-18 02:47:16 +0000
Priority: 5
DTSTAMP: 2019-09-05 15:17:20 +0000
Attendee:
)
EFTA00019875


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=== Page 1 ===
Steptoe
STEPTOE & JOHNSON LLP
Michael C. Miller
212 506 3955 direct
212 506 3950 fax
1114 Avenue of the Americas
New York, NY 10036
212 506 3900 main
www.steptoe.com
August 20, 2019
Via Electronic Mail
, Esq.
, Esq.
, Esq.
United States Attorney's Office, Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Re:
United States v. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.)
Dear
,
We represent Jeffrey Epstein, Reg No. 76318-054, who was previously
incarcerated at the Metropolitan Correction Center in New York, New York (the "MCC")
while awaiting trial on federal charges in the above-captioned case. We have been
authorized by his estate to write pursuant to 28 C.F.R. §§ 16.21-16.26 to request
documents and records from the U.S. Department of Justice related to Mr. Epstein.
Specifically, we are seeking: any (1) protocols relating to the response
to/investigation of inmate deaths within the MCC; (2) video recordings of all entrances
and exits to the MCC; (3) entry and exit logs for the MCC; (4) video recordings of the
hallways of the floor on which Mr. Epstein's cell was located; and (5) logs related to the
guards on duty at the MCC (collectively, the "Requested Evidence"). The applicable
time period for the requests is from 7:00 am on Friday, August 9, 2019 until 8:00 am on
Saturday, August 10, 2019. As required by the regulations, we set forth below a
summary of the relevance of the Requested Evidence.
Mr. Epstein died in federal custody in his cell at the MCC. We are troubled by the
circumstances of his death and by reports of irregularities at the facility. According to a
statement issued by the Federal Bureau of Prisons:
EFTA00019407

=== Page 2 ===
August 20, 2019
Page 2
On Saturday, August 10, 2019, at approximately 6:30 a.m., inmate Jeffrey
Edward Epstein was found unresponsive in his cell in the Special Housing Unit
from an apparent suicide at the Metropolitan Correctional Center (MCC) in New
York, New York. Life-saving measures were initiated immediately by responding
staff. Staff requested emergency medical services (EMS) and life-saving efforts
continued. Mr. Epstein was transported by EMS to a local hospital for treatment
of life-threatening injuries, and subsequently pronounced dead by hospital staff.
The FBI is investigating the incident.
In a separate statement, Attorney General William P. Barr indicated that "Mr. Epstein's
death raises serious questions that must be answered." On August 12, Mr. Barr further
stated, "We are now learning of serious irregularities at this facility that are deeply
concerning and that demand a thorough investigation."
Moreover, there was initial uncertainty about the cause and manner of Mr.
Epstein's death. The New York City Office of Chief Medical Examiner ("OCME")
declined to immediately release a determination, citing the need for "further
information." Days later, the OCME announced that it had reached a conclusion
following a "careful review of all investigative information."
We intend to conduct our own investigation into the circumstances of Mr.
Epstein's death. In order to do so, we ask that the Requested Evidence be made
available to counsel.
Please let us know if you would like to discuss this request.
Sincerely,
include
Michael C. Miller
Steptoe & Johnson LLP
1114 Avenue of the Americas
New York, NY 10036
Martin G. Weinberg
Martin G. Weinberg, P.C.
20 Park Plaza, Suite 1000
Boston, MA 02116
EFTA00019408


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=== Page 1 ===
From:
)"
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Date: Mon, 02 Nov 2020 15:03:58 +0000
Hi Jeff,
Does now still work? Thanks-
Sent from my iPhone
On Oct 30, 2020, at 11:14 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me. I will call in at 10am Monday.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
II
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>, "
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line:
Thanks,
EFTA00019142

=== Page 2 ===
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00019143

=== Page 3 ===
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still
be grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
EFTA00019144

=== Page 4 ===
From:
"
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com>, "Donnini, George B." <donnini@butzel.com>
Cc:
)"
i
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would you
please confirm that your production included all records of any tuition payments that Epstein (or his entities) made for
any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow
and will have limited availability this week, but my colleagues
and
(both cc'd) should be
able to coordinate with you as needed.
Best
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
>
Cc:
)
is
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
EFTA00019145

=== Page 5 ===
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
)"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey Epstein
and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00019146


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=== Page 1 ===
From: "Miller, Michael"
To:
)"
"Martin G. Weinberg"
,
"Weingarten, Reid"
Cc:
)"
)"
Subject: RE: US V Epstein
Date: Sat, 10 Aug 2019 15:57:56 +0000
Thank you,
Mike
From:
Sent: Saturday, August 10, 2019 11:57 AM
To: Miller, Michael
>; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
)
Subject: Re: US V Epstein
Mike, Marty, Reid,
Following up on my conversations with Mike and Marty this morning, and my discussion with Mike moments ago,
attached is a press release just sent to us (and I believe also issued publicly) some minutes ago. It represents all the
information we have from BOP so far, but of course if we are successful in our continuing efforts to get additional
information we will pass it along immediately.
Separately, we can tell you that the reports that an FBI investigation into the death has been initiated are accurate, and I
fully expect that investigation to be extremely rigorous.
As always please don't hesitate to reach out to us directly at any time if that would be useful.
thank you,
EFTA00019951


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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
December 17, 2020
BY FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the disc containing discovery materials pertinent to Ghislaine Maxwell
) is
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
EFTA00019284


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)
[Contractor]"
Subject: Re: The Judge in Epstein's Case Should Not Turn the Dismissal Into a Drama for the Victims
Date: Tue, 27 Aug 2019 14:58:16 +0000
The judge addressed it in his first ten minutes of addressing the court. He also mentioned that one of the authors
- though not disclosed in the article- is counsel in one of the civil cases.
Sent from my iPhone
On Aug 27, 2019, at 10:35 AM,
(USANYS)
wrote:
The Judge in Epstein's Case Should Not Turn the Dismissal Into a Drama for the Victims
NY Law Journal
By Bruce Green and Rebecca Roiphe
8/26/19
Last week, Judge Richard Berman ordered a hearing on the prosecutors' decision to dismiss the indictment against
Jeffrey Epstein, who had been charged with multiple counts of sex trafficking and assault before he committed
suicide in a Manhattan prison. The judge announced that he intends to allow victims to speak at the hearing, which
is scheduled for August 27th. Berman stated: "The court believes that where, as here, a defendant has died before
any judgment has been entered against him, the public may still have an informational interest in the process by
which the prosecutor seeks dismissal of an indictment."
This is an odd moment for transparency in a criminal case. Normally, if a prosecutor seeks to dismiss an
indictment for such an obviously worthy reason, the court would simply grant the request. The judge would not
schedule a hearing and he definitely would not allow the victims to speak. And if he did hold a hearing, whatever
informational interests the victims may have would be served by affording them a chance to attend the hearing, not
by giving them a speaking role.
The procedural rules governing federal criminal cases do not provide for posthumous trials. If the accused dies
before trial, the federal court has no choice but to dismiss the indictment and end the case. Indeed, if an accused is
tried and found guilty but dies while his appeal is pending, the federal court must set the conviction aside, as if it
had never occurred. If a party to a civil lawsuit dies, his estate may step into his shoes. But in a criminal
prosecution, the defendant's estate cannot be asked to answer for the defendant's alleged crimes.
And so it is odd for the judge in this case to delay the inevitable dismissal, seemingly for dramatic effect. He has no
choice but to dismiss the charges. At the hearing he scheduled, Epstein's lawyers will not oppose the prosecution's
motion to dismiss the indictment. It is doubtful whether Epstein's former lawyers could oppose the prosecution's
motion even if they thought there were grounds to do so. Epstein's defense lawyers no longer have authority to
speak on his behalf: the lawyer-client relationship ended with his death. Nor would the victims have any plausible
grounds to ask the judge to continue the proceedings.
People are right to be both outraged and frustrated after Epstein's suicide. He was a true villain, as both sides of
the political divide agree: Epstein was hated by the #MeToo movement and conservatives alike. His suicide denied
the public an accounting for his egregious crimes. It left us all without a clear sense of how this rich and powerful
EFTA00018867

=== Page 2 ===
man evaded justice the first time, when he served a meager sentence, much of it on home arrest, for similar
charges.
That said, now that he is dead, the criminal justice system is not the place for Epstein to be called to account. The
fact that the public has an interest in learning more about the process, as Berman suggested, does not mean that
victims have the right to speak at a criminal proceeding scheduled for no obvious purpose but to give them a
forum. One might think that there is no harm done in giving victims a chance to express themselves in the
scheduled hearing, but that is wrong for two reasons.
First, the criminal justice system is designed to determine whether defendants are guilty of alleged crimes beyond a
reasonable doubt in a fair process in which both the prosecution and defendant participate. While many people
assume that Epstein is guilty of the crimes alleged in the indictment and worse, our courts and constitution require
that we presume him innocent until proven otherwise. Individuals charged with crimes must be allowed a chance to
confront their accusers and put the government to its burden. Frustrating as it is that the government will never get
the chance to present its case in a trial against Epstein, it is important to preserve the institutional structures
nonetheless. Faith in the outcomes of run-of-the-mill cases require as much.
It is often important to hear from victims-for example, at a trial where the accused contests his guilt or in a
sentencing hearing after a defendant is found guilty. But conducting a hearing on an uncontested question solely to
give victims a chance to tell their stories would be a rare if not unprecedented use of the courtroom-one that not
only veers from the norm but also weakens the institutional commitments that are necessary to ensure that all
individuals accused of a crime are afforded proper protection.
Second, this seems more like a show than a real hearing. Judge Berman isn't really trying to obtain information
about why the government is dismissing its case. We all know why. The defendant is no longer alive. So the hearing
would necessarily be serving a different purpose: It might serve as a kind of theater at which the public works
through its frustration and unresolved need for retribution. It might afford a collective catharsis for the victims
who may be allowed to tell their stories in court and for other victims of sexual assault. These are both noble goals,
but they are outside of the criminal justice system's mandate.
We don't necessarily have to give up the goal of a public accounting. Not entirely anyway. Prosecutors in the
Southern District of New York have indicated that they are not done with the investigation, leaving many to
speculate that Epstein's co-conspirators will be charged. If so, the victims will get to tell their stories, at least
partially. In civil lawsuits and forfeiture actions, they may also have an opportunity for their day in court. But we
should not distort the criminal justice process by importing this perceived societal need into the criminal
courthouse when there is no proceeding in which hearing from the victims serves a legitimate criminal justice
purpose.
Bruce Green is the Louis Stein Chair at Fordham Law School where he directs the Louis Stein Center for
Professional Ethics. He formerly served as a federal prosecutor in the Southern District of New York. Rebecca
Roiphe is a professor of law at New York Law School, where she serves as the co-dean for faculty scholarship. She
formerly served as an Assistant District Attorney in the New York County District Attorney's Office.
EFTA00018868


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
INDICTMENT
UNITED STATES OF AMERICA
:
19 Cr.
V. -
:
TOVA NOEL and
:
19 CRIM
830
MICHAEL THOMAS,
:
Defendants.
X
INTRODUCTION
1.
On or about August 10, 2019, TOVA NOEL and MICHAEL
THOMAS, the defendants, in dereliction of their duties as
correctional officers at the Metropolitan Correctional Center
("MCC"), repeatedly failed to perform mandated counts of prisoners
under their watch in the MCC's Special Housing Unit ("SHU").
Instead, for substantial portions of their shifts, NOEL and THOMAS
sat at their desk, browsed the internet, and moved around the
common area of the SHU. To conceal their failure to perform their
duties, NOEL and THOMAS repeatedly signed false certifications
attesting to having conducted multiple counts of inmates when, in
truth and in fact, they never conducted such counts. As a result
of those false statements, the MCC believed prisoners in the SHU
were being regularly monitored and accounted for when, in fact, as
a result of the defendants' conduct, no correctional officer
conducted any count or round of the SHU from approximately 10:30
EFTA00017915

=== Page 2 ===
p.m. on August 9 until approximately 6:30 a.m. on August 10, at
which time, as alleged herein, NOEL and THOMAS discovered the body
of an MCC inmate, Jeffrey Epstein, who had committed suicide
overnight while unobserved.
RELEVANT INDIVIDUALS AND ENTITIES
2. The MCC is a federal administrative detention
facility located in Manhattan that is run by the Federal Bureau of
Prisons ("BOP"). The MCC is one of several facilities used to
house inmates who have been charged with federal crimes in the
Southern District of New York and are awaiting trial. The MCC
employs correctional officers, whose primary duty is to ensure the
care, custody, and control of the inmate population of the MCC.
3. TOVA NOEL, the defendant, has been employed as a
correctional officer at the MCC since approximately 2016. As of
August 2019, NOEL's primary assignment was the SHU. On August 9,
2019, NOEL worked a regular shift from 4 p.m. to 12 a.m. in the
SHU, and then worked an overtime shift from 12 a.m. to 8 a.m. on
August 10, 2019, also in the SHU. NOEL had also worked a regular
shift in the SHU the day before, August 8, 2019, from 12 p.m. to
8 p.m.
4. MICHAEL THOMAS, the defendant, has been employed as
a correctional officer at the MCC since approximately 2007.
Beginning in approximately 2013, THOMAS was assigned to work as a
2
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=== Page 3 ===
materials handler supervisor, although THOMAS regularly worked
overtime shifts as a correctional officer, including in the SHU.
THOMAS worked an overtime shift in the SHU on August 10, 2019,
from 12 a.m. to 8 a.m. THOMAS did not work his regular shift on
August 8 or August 9, 2019, but did work an overtime shift in the
SHU on August 9, 2019 from 12 a.m. to 8 a.m.
5. As detailed herein, Jeffrey Epstein was
incarcerated at the MCC between his arrest on July 6, 2019, and
his suicide on August 10, 2019. Epstein was detained pending
trial in the Southern District of New York on sex trafficking
charges.
THE MCC AND INSTITUTIONAL COUNTS
6. The MCC, which houses approximately 750 inmates at
any given time, assigns inmates to various housing units within
the MCC. The SHU is a housing unit within the MCC where inmates
are securely separated from the general inmate population to ensure
their own safety as well as the safety of staff and other inmates.
The SHU is located on the ninth floor of the MCC, and access to
that floor is controlled by a locked door that can be opened
remotely only by an officer in the MCC's centralized control center
(the "Control Center"), which is located on the first floor of the
MCC. Access into the SHU is also controlled by a second locked
door to which only correctional officers assigned to the SHU have
3
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=== Page 4 ===
keys while on duty. Within the SHU, inmates are assigned to six
separate tiers, each of which can be accessed only via a single
locked door to which the correctional officers assigned to the SHU
have keys while on duty. Each tier has eight cells, each of which
can house either one or two prisoners, and each individual cell -
which is made of cement and metal - is accessed only through a
single locked door, to which only correctional officers assigned
to the SHU have keys while on duty.
7. The BOP requires correctional officers assigned to
guard inmates at the MCC to conduct institution-wide counts of
inmates at regular, scheduled intervals to ensure that each inmate
is alive and accounted for within the MCC (the "institutional
count"). On weekdays, the MCC conducts five institutional counts
at 4 p.m., 10 p.m., 12 a.m., 3 a.m., and 5 a.m. Performing an
institutional count is one of the most basic and essential aspects
of a correctional officer's job, and the count is one of the most
basic and essential functions of daily operation of the MCC. Two
officers are required to perform the institutional count for each
housing unit, including the SHU, and are further required to
document their performance of the count on an official MCC form
called a count slip. To perform the institutional count in the
SHU, two officers must walk from tier to tier to observe and count
each individual inmate.
4
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=== Page 5 ===
8. On the count slip, both correctional officers are
required to fill in the date and time the count was performed,
write the total number of inmates physically present in the unit
counted, and then sign the count slip. Once the correctional
officers have completed and signed the count slips, the count slips
are then collected and delivered to the Control Center, where
officers within the Control Center are responsible for comparing
the count slips from each housing unit to the institution's inmate
roster to ensure that each inmate is accounted for. Only after
all the count slips are collected from each housing unit, and the
numbers on the slips are matched to the institution's inmate
roster, can the institutional count be deemed "cleared" or
completed. If a housing unit's count slip is incorrect or
incomplete, then the institution cannot "clear" the count.
Instead, the count must be completely redone in that housing unit
via a more-intensive version of the institutional count called a
"bed book count," in which officers must compare every individual
inmate to the institution's inmate roster. Records of each
institutional count, including the count slips, are provided to a
supervising official and retained by the MCC.
9. In addition to the institutional count, the BOP
requires correctional officers assigned to the SHU to walk each of
the tiers of the SHU - which is called a "round" - every thirty
5
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=== Page 6 ===
minutes ("30-minute rounds"). Like the institutional counts,
correctional officers conduct 30-minute rounds to ensure that each
inmate is alive and accounted for within his cell. Correctional
officers working in the SHU are required to complete a form, which
is reviewed and signed by their supervisor, documenting the date
and time of each 30-minute round in each tier of the SHU.
EPSTEIN'S PRIOR APPARENT SUICIDE ATTEMPT
10. On July 6, 2019, inmate Jeffrey Epstein was
arrested and detained at the MCC on sex trafficking charges. On
July 10, 2019, Epstein was assigned to the SHU due to, among other
things, risk factors for suicidality and safety concerns relating
to housing him with the MCC's general population.
11. On July 23, 2019, while Epstein was housed in the
SHU, MCC officers responded to an emergency call, and found Epstein
on the floor of his cell with a strip of bedsheet around his neck.
MICHAEL THOMAS, the defendant, was one of the MCC officers who
responded to the incident. Epstein was subsequently transferred
out of the SHU and was placed on suicide watch. Inmates placed
on suicide watch are housed in a cell on the hospital wing floor
of the MCC, and are watched twenty-four hours a day by a staff
member or a specially trained inmate companion.
12. Epstein remained on suicide watch for approximately
twenty-four hours, and then was transferred to psychological
6
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=== Page 7 ===
observation, until July 30, 2019. Psychological observation is
less restrictive than suicide watch, but inmates are still housed
in the hospital wing of the MCC and watched twenty-four hours a
day.
13. On July 30, 2019, Epstein was transferred back to
the SHU, and, at the direction of the MCC's psychological staff,
was required to have an assigned cellmate. Epstein was also
assigned to the cell closest to the correctional officers' desk in
the common area of the SHU, which was approximately fifteen feet
from the cell. Conducting the required institutional counts and
thirty-minute rounds in the SHU were also part of the MCC's
procedures for ensuring the safety of inmates, including Epstein.
EVENTS OF AUGUST 9-10, 2019
14. On August 9, 2019, Epstein's cellmate was
transferred out of the MCC in a routine, pre-arranged transfer at
approximately 8 a.m. Despite the MCC's psychological staff's
direction that Epstein have a cellmate, no new cellmate was
assigned to Epstein's cell.
15. TOVA NOEL, the defendant, was one of the assigned
officers on duty in the SHU from 4 p.m. on August 9, 2019 to 8
a.m. on August 10. From 4 p.m. to 12 a.m., two other officers
were on duty with NOEL in the SHU: one officer was assigned to
work from 2 p.m. to 10 p.m. ("Officer-1"), and one officer was
7
EFTA00017921

=== Page 8 ===
assigned to work from 4 p.m. to 12 a.m. ("Officer-2"). MICHAEL
THOMAS, the defendant, started his shift in the SHU at 12 a.m. on
August 10. From 12 a.m. until 8 a.m. on August 10, NOEL and THOMAS
were the only two officers on duty in the SHU.
16. During the time period from 4 p.m. on August 9 to
8 a.m. on August 10, the officers on duty in the SHU, including
TOVA NOEL and MICHAEL THOMAS, the defendants, were responsible for
conducting five institutional counts: 4 p.m. and 10 p.m. on August
9; and 12 a.m., 3 a.m., and 5 a.m. on August 10. NOEL, THOMAS and
the other officers on duty were also responsible for completing
paperwork attesting to each of those counts. While, as detailed
herein, count slips were completed for each institutional count,
in fact, not a single one of those institutional counts was done.
17. TOVA NOEL, the defendant, and Officer-1 were
responsible for conducting the 4 p.m. institutional count in the
SHU. As video from the MCC's internal video surveillance system
makes clear, NOEL and Officer-1 did not perform the 4 p.m. count.
Nonetheless; NOEL and Officer-1 completed and signed a count slip
that falsely stated that the 4 p.m. institutional count had been
performed. In reliance on that falsified count slip, at
approximately 5:03 p.m., the Control Center cleared the 4 p.m.
count.
8
EFTA00017922

=== Page 9 ===
18. That evening, Epstein returned to the SHU from his
attorney visit and was escorted into his cell by TOVA NOEL, the
defendant, and another officer at approximately 7:49 p.m. NOEL
and the other officer left the tier in which Epstein was housed
immediately thereafter.
19. By or before 10 p.m., all inmates in the MCC were
locked in their cells for the night. At or around that time, TOVA
NOEL, the defendant, and Officer-2 were responsible for conducting
the 10 p.m. institutional count in the SHU. However, video from
the MCC's internal video surveillance system shows that NOEL and
Officer-2 did not perform the 10 p.m. count. Nonetheless, NOEL
and Officer-2 completed and signed a count slip falsely stating
that the 10 p.m. institutional count had been performed. In
reliance on that falsified count slip, at approximately 10:36 p.m.,
the Control Center cleared the 10 p.m. count.
20: As reflected on video obtained from the MCC's
internal video surveillance system, at approximately 10:30 p.m. on
August 9, 2019 - after TOVA NOEL, the defendant, had signed and
submitted the 10 p.m. count slip and the institutional count had
been completed - NOEL briefly walked up to, and then walked back
from, the door to the tier in which Epstein was housed. As
confirmed by the video obtained from the MCC's internal video
surveillance system, this was the last time anyone, including any
9
EFTA00017923

=== Page 10 ===
correctional officer, walked up to, let alone entered, the only
entrance to the tier in which Epstein was housed until
approximately 6:30 a.m. on August 10.
21. Officer-1's shift ended at approximately 10 p.m.,
and at approximately 12 a.m., MICHAEL THOMAS, the defendant,
replaced Officer-2, joining TOVA NOEL, the defendant, as the only
two correctional officers on duty in the SHU. NOEL and THOMAS
were responsible for conducting the 12 a.m. institutional count in
the SHU. As confirmed by video from the MCC's internal video
surveillance system, NOEL and THOMAS did not perform the 12 a.m.
count. Nonetheless, NOEL and THOMAS completed and signed a count
slip for the 12 a.m. count that falsely stated that the
institutional count had been performed. In reliance on that
falsified count slip, at approximately 12:49 a.m., the Control
Center cleared the 12 a.m. count.
22. TOVA NOEL and MICHAEL THOMAS, the defendants, were
additionally responsible for conducting the 3 a.m. and 5 a.m.
institutional counts in the SHU. As confirmed by video from the
MCC's internal video surveillance system, NOEL and THOMAS did not
perform either the 3 a.m. or the 5 a.m. counts. NOEL and THOMAS
nonetheless completed and signed count slips for both counts that
falsely stated that they had performed the 3 a.m. and 5 a.m.
institutional counts. In reliance on those falsified count slips,
10
EFTA00017924

=== Page 11 ===
at approximately 3:24 a.m. and 5:30 a.m., the Control Center
cleared the 3 a.m. and 5 a.m. counts, respectively.
23. Moreover, despite the requirement that officers on
duty in the SHU conduct and document regular, 30-minute rounds,
TOVA NOEL and MICHAEL THOMAS, the defendants, did not perform any
of the required 30-minute rounds during their shift between
approximately 12 a.m. and 6:30 a.m. Nonetheless, NOEL completed
and signed more than 75 separate 30-minute round entries falsely
affirming that they had, in fact, conducted such rounds.
24. During the night, instead of completing the
required counts and rounds, TOVA NOEL and MICHAEL THOMAS, the
defendants, were seated at the correctional officers' desk in the
SHU common area (as noted above, approximately 15 feet from
Epstein's cell), used the computers, and moved around the SHU
common area. For a period of approximately two hours, NOEL and
THOMAS sat at their desk without moving, and appeared to have been
asleep. NOEL used the computer periodically throughout the night,
including to search the internet for furniture sales and benefit
websites. THOMAS used the computer briefly around 1 a.m., 4 a.m.,
and 6 a.m. to search for motorcycle sales and sports news.
25. At approximately 4 a.m., the overnight supervisor
briefly visited NOEL and THOMAS in the SHU, and conferred with
NOEL and THOMAS, who were seated at and around the officers' desk,
11
EFTA00017925

=== Page 12 ===
before leaving. At approximately 5:30 a.m., another correctional
officer briefly walked through the SHU common area. Aside from
those two officers, as confirmed by video surveillance, no one
else entered the SHU, no one conducted any counts or rounds
throughout the night, and no one entered the tier in which Epstein
was housed.
26. Shortly after 6 a.m. on August 10, 2019, MICHAEL
THOMAS and TOVA NOEL, the defendants, received a delivery of
breakfast carts into the SHU, after which time they were again the
only officers in the SHU. Shortly after 6:30 a.m., NOEL and THOMAS
walked up to and entered the tier in which Epstein was housed to
serve breakfast. At approximately 6:33 a.m., an alarm was
activated in the SHU. Epstein was alone in his cell and not
responsive, with a noose around his neck. A supervisor who had
just started his shift ("Supervisor-1") responded to the alarm
almost immediately thereafter, and as NOEL approached the door to
the SHU to open the door for Supervisor-1, NOEL told Supervisor-1
that "Epstein hung himself." After arriving in the SHU,
Supervisor-1 spoke with THOMAS and NOEL. NOEL told Supervisor-1
"we did not complete the 3 a.m. nor 5 a.m. rounds." THOMAS stated,
"we messed up," and "I messed up, she's not to blame, we didn't do
any rounds."
12
EFTA00017926

=== Page 13 ===
27. Epstein was transferred to a local hospital where
he was declared dead shortly thereafter. The Office of the Chief
Medical Examiner of the City of New York conducted an autopsy and
determined that Epstein had committed suicide by hanging himself.
STATUTORY ALLEGATIONS
COUNT ONE
(Conspiracy)
The Grand Jury charges:
28. The Grand Jury incorporates the allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
29. In or about August 2019, in the Southern District
of New York, TOVA NOEL and MICHAEL THOMAS, the defendants,
knowingly conspired with each other to:
a. Knowingly defraud the United States by
impairing, obstructing, and defeating the lawful functions of a
department or agency of the United States, to wit, the MCC's
function to ensure the care, custody, and control of its inmate
population.
b. Knowingly make and use a false writing or
document knowing the same to contain a materially false,
fictitious, and fraudulent statement and entry with the intent to
impede, obstruct, or influence the investigation or proper
administration of any matter within the jurisdiction of any
13
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=== Page 14 ===
department or agency of the United States, in violation of Title
18, United States Code, Section 1001 (a) (3).
30. In furtherance of the conspiracy and to effect the
illegal objects thereof, TOVA NOEL and MICHAEL THOMAS, the
defendants, committed the following overt acts, among others, in
the Southern District of New York:
a. On August 10, 2019, NOEL and THOMAS falsely
certified, on an MCC count slip, that they had performed the 12
a.m. institutional count of the SHU, when they had not in fact
done SO.
b. On August 10, 2019, NOEL and THOMAS falsely
certified, on an MCC count slip, that they had performed the 3
a.m. institutional count of the SHU, when they had not in fact
done SO.
C. On August 10, 2019, NOEL and THOMAS falsely
certified, on an MCC count slip, that they had performed the 5
a.m. institutional count of the SHU at MCC, when they had not in
fact done SO.
d. On August 10, 2019, NOEL falsely certified that
she and THOMAS had performed a series of 30-minute rounds of the
SHU between 12 a.m. and 6:30 a.m., when they had not in fact done
SO.
(Title 18, United States Code, Section 371)
14
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=== Page 15 ===
COUNT TWO
(False Records - 4 p.m. Count)
The Grand Jury further charges:
31. The Grand Jury incorporates the allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
32. On or about August 9, 2019, in the Southern District
of New York, TOVA NOEL, the defendant, willfully and knowingly did
make and use a false writing or document knowing the same to
contain a materially false, fictitious, and fraudulent statement
and entry with the intent to impede, obstruct, or influence the
investigation or proper administration of any matter within the
jurisdiction of any department or agency of the United States, and
did attempt to do the same, to wit, NOEL created, signed, and
submitted to the MCC a materially false count slip indicating that
she had performed the 4 p.m. institutional count of the SHU, when
she had not in fact done SO.
(Title 18, United States Code, Sections 1001 (a) (3) and 2)
COUNT THREE
(False Records - 10 p.m. Count)
The Grand Jury further charges:
33. The Grand Jury incorporates the allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
15
EFTA00017929

=== Page 16 ===
34. On or about August 9, 2019, in the Southern District
of New York, TOVA NOEL, the defendant, willfully and knowingly did
make and use a false writing or document knowing the same to
contain a materially false, fictitious, and fraudulent statement
and entry with the intent to impede, obstruct, or influence the
investigation or proper administration of any matter within the
jurisdiction of any department or agency of the United States, and
did attempt to do the same, to wit, NOEL created, signed, and
submitted to the MCC a materially false count slip indicating that
she had performed the 10 p.m. institutional count of the SHU, when
she had not in fact done SO.
(Title 18, United States Code, Sections 1001 (a) (3) and 2)
COUNT FOUR
(False Records - 12 a.m. Count)
The Grand Jury further charges:
35. The Grand Jury incorporates the allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
36. On or about August 10, 2019, in the Southern
District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants,
willfully and knowingly did make and use a false writing or
document knowing the same to contain a materially false,
fictitious, and fraudulent statement and entry with the intent to
impede, obstruct, or influence the investigation or proper
16
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=== Page 17 ===
administration of any matter within the jurisdiction of any
department or agency of the United States, and did attempt to do
the same, to wit, NOEL and THOMAS created, signed, and submitted
to the MCC a materially false count slip indicating that they had
performed the 12 a.m. institutional count of the SHU, when they
had not in fact done SO.
(Title 18, United States Code, Sections 1001 (a) (3) and 2)
COUNT FIVE
(False Records - 3 a.m. Count)
The Grand Jury further charges:
37. The Grand Jury incorporates the allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
38. On or about August 10, 2019, in the Southern
District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants,
willfully and knowingly did make and use a false writing or
document knowing the same to contain a materially false,
fictitious, and fraudulent statement and entry with the intent to
impede, obstruct, or influence the investigation or proper
administration of any matter within the jurisdiction of any
department or agency of the United States, and did attempt to do
the same, to wit, NOEL and THOMAS created, signed, and submitted
to the MCC a materially false count slip indicating that they had
17
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=== Page 18 ===
performed the 3 a.m. institutional count of the SHU, when they had
not in fact done SO.
(Title 18, United States Code, Sections 1001 (a) (3) and 2)
COUNT SIX
(False Records - 5 a.m. Count)
The Grand Jury further charges:
39. The Grand Jury incorporates the allegations
contained in paragraphs 1 through 27 of this Indictment as though
fully set forth herein.
40. On or about August 10, 2019, in the Southern
District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants,
willfully and knowingly did make and use a false writing or
document knowing the same to contain a materially false,
fictitious, and fraudulent statement and entry with the intent to
impede, obstruct, or influence the investigation or proper
administration of any matter within the jurisdiction of any
department or agency of the United States, and did attempt to do
the same, to wit, NOEL and THOMAS created, signed, and submitted
to the MCC a materially false count slip indicating that they had
18
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=== Page 19 ===
performed the 5 a.m. institutional count of the SHU, when they had
not in fact done SO.
(Title 18, United States Code, Sections 1001 (a) (3) and 2)
FOREPERSON
lazy math
GEOFFREY BERMAN
Geoffing
United States Attorney
19
EFTA00017933

=== Page 20 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
- V. -
TOVA NOEL and
MICHAEL THOMAS,
Defendants.
INDICTMENT
19 Cr.
Title 18, United States Code,
Sections 371, 1001 (a) (3), and 2.
GEOFFREY S. BERMAN
United States Attorney
A
TRUE
BILL
Mary Mith
Foreperson.
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=== Page 1 ===
From:
To:
Subject: 2021.10.04 Maxwell Jury Questionnaire [with Defense Additions Formatted and Gov't
Response].docx
Date: Sun, 10 Oct 2021 21:07:39 +0000
Attachments: 2021.10.04_Maxwell_Jury_Questionnaire_[with_Defense_Additions_Formatted_and_Govt
_Response].docx
EFTA00019193


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
Subject: RE: Discovery Issues
Date: Tue, 30 Mar 2021 14:30:19 +0000
Inline-Images: image001.jpg; image002.jpg
Yes, thank you. I will send a calendar invite.
From:
(USANYS) [Contractor]
Sent: Tuesday, March 30, 2021 10:26 AM
To:
)
Cc:
>;
(USANYS)
Subject: RE: Discovery Issues
Hello
Can we meet tomorrow morning at 10:00 am tomorrow to discuss the below production?
Thank you.
From:
Sent: Monday, March 29, 2021 4:00 PM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: Discovery Issues
Thanks very much.
From:
(USANYS) [Contractor]
Sent: Monday, March 29, 2021 3:04 PM
To:
Cc:
is
(USANYS)
Subject: RE: Discovery Issues
Hello
I will send this information to PAE and set up a time for a phone call.
Thank you.
From:
Sent: Monday, March 29, 2021 2:59 PM
To:
(USANYS) [Contractor]
EFTA00019092

=== Page 2 ===
Cc:
is
(USANYS)
Subject: FW: Discovery Issues
Hi
We just received the below and attached regarding discovery in the Maxwell case. Many of these questions relate to
productions that PAE prepared. Would you please take a look and let me know when would be a good time this week for
a call to discuss?
Thanks,
From: Christian Everdell
Sent: Monday, March 29, 2021 2:40 PM
To:
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; Laura Menninger
>; Bobbi Sternheim
Subject: Discovery Issues
and
-
We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a
call to discuss.
1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created
(without the highly confidential items). You had said you would check to see if you could facilitate this. We have
not heard back from you. Are you able to send Ms. Maxwell the hard drive?
2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and
must use the prison computer. But the prison computer cannot read some of the files. We can include these files
on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please
advise which way you would like to proceed.
3. A number of the emails in the discovery - over 109,000 - were produced without their attachments (see tab 1 of
the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the
missing attachments, if they exist.
4. A number of electronic documents - over 110,000 - that were extracted from one of Epstein's devices, as identified
by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or
afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with the original
metadata for these files.
5. A number of photographs - over 6500 - were produced in native format, but do not have a CART number and have
"date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please
provide the CART number for these photographs or specify which device they came from. Also, we request that
you produce a metadata overlay with the original metadata for these files.
6. A number of the audio/visual files - over 460 - have similar metadata issues (see tab 4 of the attached Excel file).
These fall into the following buckets:
a. SDNY GM SUPP: these have CART numbers, but were produced without metadata load files and have
"date created" and "date last modified" dates in September-November 2020, after the date the device was
seized. We request that you produce a metadata overlay with the original metadata for these files.
EFTA00019093

=== Page 3 ===
b. SDNY005 (October 20, 2020 production): these are a few videos from the SDFL or PBPD investigations that
were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that
you produce a metadata overlay with the original metadata for these files.
C. SDNY011 (November 9, 2020 production): these were produced in native form with load files, but do not
reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these
files or indicate their source. Also, we request that you produce a metadata overlay with the original
metadata for these files.
7. There is a gap between 11/18 and 12/18 production numbers (SDNY_GM_02742044 to 2742183). Was that
intentional or are we missing those documents?
Please let us know your responses as soon as possible.
Thanks,
Chris
Christian R Everdell
COHEN & GRESSER LLP
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
GG
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.
EFTA00019094


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: Epstein update
Date: Sat, 10 Aug 2019 15:32:19 +0000
Give me a call on my cell.
Sent from my iPhone
On Aug 10, 2019, at 11:31 AM,
wrote:
Just FYI. Will let you know if we get any additional information. I'll be in the subway for the next half hour or
so but then at my desk today.
Sent from my iPhone
Begin forwarded message:
From:
Date: August 10, 2019 at 11:30:02 EDT
To:
Cc:
Subject: Re: Epstein update
It is frankly unbelievable to me that BOP is issuing public press releases on this before telling us basic
information so that we can relay it to his attorneys who can relay it to his family. When can we expect to get
either some sort of statement we can pass along to counsel as accurate and reliable or have a call with
someone?
I understand from the Marshals that they have been unsuccessful in reaching anyone with authority at BOP,
and given the BOP press release that was just put out I assume we need to speak with someone there. Please
advise.
Thank you.
On Aug 10, 2019, at 10:43,
wrote:
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
EFTA00018966

=== Page 2 ===
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.
From:
(USMS)
Sent: Saturday, August 10, 2019 7:52 AM
To:
)
Subject: Re: Automatic reply: Epstein update
FYI:
The BOP just informed us that Epstein is being taken by ambulance to the hospital from another apparent suicide
attempt- no other information was provided.
They will update us as more info becomes available.
On Aug 10, 2019, at 7:26 AM,
)
wrote:
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
EFTA00018967


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c0:
=== Page 1 ===
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
July 2, 2020
The Honorable Katharine H. Parker
United States District Court
Southern District of New York
500 Pearl Street
New York, New York 10007
Re:
Unsealing of Indictment 20 Cr. 330
Dear Judge Parker:
The Government respectfully requests that Indictment 20 Cr. 330 be unsealed and that a
United States District Judge be assigned to the case. A proposed order to that effect is attached.
This case is designated as a Wheel C case.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By:
/
/
Assistant United States Attorneys
Tel.:
Enclosure
EFTA00020359

=== Page 2 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
Unsealing Order
— V. —
20 Cr. 330
GHISLAINE MAXWELL,
Defendant.
Upon the application of the United States, by the Acting United States Attorney for the
Southern District of New York, Audrey Strauss, by Assistant United States Attorney
;
It is found that the Indictment in the above-captioned case is currently sealed and the United
States Attorney's Office has applied to have that Indictment unsealed, and it is therefore:
ORDERED that the Indictment in the above-captioned action be unsealed and remain
unsealed pending further order of the Court.
Dated:
New York, New York
July 2, 2020
Kathaw H Parker
HONORABLE KATHARINE H. PARKER
UNITED STATES MAGISTRATE JUDGE
SOUTHERN DISTRICT OF NEW YORK
EFTA00020360

=== Page 3 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
GHISLAINE MAXWELL,
Defendant.
ORDER
20 Cr. 330 ( )
(18 U.S.C. $$ 2422, 2423 (a), 1623, 371, & 2.)
AUDREY STRAUSS
Acting United States Attorney.
EFTA00020361


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=== Page 1 ===
From:
To:
Cc:
Subject: CD for Maxwell
Date: Thu, 29 Oct 2020 19:57:16 +0000
Attachments: 2020.10.29_MDC - Maxwell_PASSWORD.pdf
Hi
Today our office sent a CD with some replacement discovery files to the MDC for Ghislaine Maxwell via FedEx overnight
delivery. The password letter is attached. Would you please keep an eye out for it?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00018262


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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
December 16, 2020
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
In recognition of the Government's ongoing discovery obligations, today we are producing
the materials listed in the below index. These discovery materials are stamped with control
numbers SDNY_GM_00274187 through SDNY_GM_0274302.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case.¹ This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. An index of the materials contained in this production is below:
1 Files in PDF format designated as "confidential" under the protective order have been stamped
"confidential." However, certain files cannot be individually labeled as confidential on the
documents themselves due to their file format.
06.20.2018
EFTA00019422

=== Page 2 ===
Page 2
Bates Start
Bates End
Summary Description
Confidential
Designation
UBS Subpoena Return, 12-15-2020
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 or if you wish to
arrange a time to review physical items in the FBI's custody.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
by:
Assistant United States Attorneys
06.20.2018
EFTA00019423


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=== Page 1 ===
From:
"
)"
To: "
(USANYS) [Contractor]"
Cc:
"
(USANYS) [Contractor]"
(USANYS)"
)"
Bec: "USAHUB-USAJournal111"
Subject: RE: Epstein/Maxwell Upload
Date: Fri, 25 Sep 2020 15:17:44 +0000
Embedded: RE:_Epstein_Maxwell_Upload.msg
Sender:
Subject: RE: Epstein/Maxwell Upload
Message-Id:
<CY1P110MB0342F7FBF3C983C8E5C52CD892360@CY1P110MB0342.NAMP110.PROD.OUTLOOK.CO
M>
To:
Cc:
Cc:
Cc:
EFTA00019850


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: [EXTERNAL] Proposed Jury Questionnaires
Date: Fri, 08 Oct 2021 15:09:07 +0000
Attachments: 2021.10.04_Maxwell_Jury_Questionnaire_Sent_to_Defense_LAM_edits.docx;
ATT00001.htm; Defense_Proposed_Questioaire.docx; ATT00002.htm
Good morning-
The melding of our respective questionnaires has posed difficulties.
For purposes of today's conferral, attached is your version of the questionnaire with slight edits in track change.
Also attached is draft of our (far more robust) proposed questionnaire in Word (formatting to be corrected.)
Our proposed questionnaire incorporates portions of your proposed voir dire, which would be redundant if
covered by a written questionnaire.
We are working on a more inclusive version of proposed voir dire questions for this afternoon's conferral.
EFTA00019043


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=== Page 1 ===
From: Jeffrey Pop
To:
)"
Cc:
)"
)"
Subject: RE: SDNY investigation,
Date: Fri, 27 Dec 2019 03:33:05 +0000
Inline-Images: image001.jpg
Thank you for your clarification.
was a victim. This process is emotionally very difficult for her.
I
feel that we can safely comply with her wishes to assist the investigation in the areas you have outlined without any
criminal exposure to her.
I will begin to compile an attorney proffer.
Jeff
Jeffrey S. Pop, Esq.
JEFFREY S. POP & ASSOCIATES
Beverly Hills, California 90212-3429
fax
www.poplawyer.com
www.vaccineinjuryteam.com
JEFFREY S. POP & ASSOCIATES
A LAW CORPORATION
Since 1980
CONFIDENTIALITY
This e-mail is for the personal and exclusive use of the recipient(s) named above. It contains confidential information from Jeffrey S. Pop & Associates. Its contents are not only to
remain absolutely confidential, but may also be subject to the attorney-client privilege or coverage under the work-product doctrine. If you have received this transmission and
are not the intended recipient(s) or his/her agent, please be advised that any disclosure, use, review, copying, selling, dissemination, publication, or distribution of this
transmission is strictly unauthorized and prohibited. If you have received this transmission in error, please notify the sender at the number above, return the original e-mail by
mail, and delete the e-mail file from your computer. Postage is guaranteed. Your cooperation is appreciated. Thank you.
From:
)
[mailto:
Sent: Monday, December 23, 2019 9:34 PM
To: Jeffrey Pop
Cc:
);
)
Subject: RE: SDNY investigation,
Jeff,
Following up on our phone conversation today, I wanted to memorialize that, as discussed, we do not currently have
reason to believe Ms.
has criminal exposure based on what we are aware of in connection with her interactions
with Jeffrey Epstein, and your brief attorney proffer regarding the circumstances of those interactions are consistent with
that view. In your further discussions with Ms.
in advance of a further attorney proffer to address the general
EFTA00019908

=== Page 2 ===
nature of her relationship with Mr. Epstein, as well as his employees or relevant close associates, if you have any concerns
about additional possible exposure you should please feel free to be in touch with us again. As we also discussed, I
believe any non-federal offenses would be well outside the relevant statute(s) of limitation, but of course if you wish to
further research that issue, or consult with criminal counsel, we defer to you entirely.
Please let us know if any other information would be useful at this stage, and hopefully we can be in touch in the coming
weeks about productive next steps.
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00019909


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=== Page 1 ===
From:
To:
Subject: Epstein Trust Analysis
Date: Wed, 29 Jan 2020 22:51:18 +0000
Attachments: Epstein_Trust_Analysis_v5.xlsx
Hi everyone,
I've attached a summary/analysis of the Epstein trust documents we received. This document incorporates the analysis of
the trusts from 2019 I did previously.
On the bottom, you'll see each trust has a tab and then further amendments to the trust (if any) go chronologically to the
right. There's also key and summary tabs at the beginning of the document.
Please let me know if you have any questions, or if you'd like me to walk you through how to use the document, in case it
isn't clear.
Thanks,
p.s. I wouldn't recommend printing the document, just due to the size of the excel tables.
EFTA00018109


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=== Page 1 ===
ST. EDMUND HALL
Telephone
FROM THE TUTOR FOR ADMISSIONS
OXFORD
Fax
OX1 4AR
7th November, 1995
Dear Miss
We have now received your UCAS form. I am writing to confirm
that you will not be required to come again for interview. We
shall in due course make you an offer in the same terms as we did
last year.
Yours sincerely,
Dongt
D. A. WYATT
,
Belgravia,
London SWIN 9DF.
EFTA00017868


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=== Page 1 ===
From:
To:
Subject: Jeffrey EPSTEIN
Date: Thu, 25 Jul 2019 01:35:05 +0000
All,
Please be advised that we received he following report from the Bureau of Prisons MCC New York at 2115 hours on this
date:
Associate Warden (AW)
at MCC New York advised that Jeffrey EPSTEIN was found in his cell this
morning at 0127 hours in a fetal position with a noose around his neck. EPSTEIN was escorted to medical and was
assessed. EPSTEIN was initially placed on suicide watch and subsequently downgraded to suicide observation, where he
currently remains. Additionally, AW
advised that EPSTEIN's cell mate reported threated to kill him. No
further information was provided.
The above incident is currently under investigation with the BOP.
Supervisory Deputy United States Marshal
Southern District of New York
EFTA00019328


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
Subject: RE: OPR Matter
Date: Fri, 07 Aug 2020 15:09:43 +0000
Got it. I'm going to copy the file locally and try a few things. I will keep you updated on my progress.
From:
(USANYS)
Sent: Friday, August 7, 2020 11:05 AM
To:
(USANYS) [Contractor]
Subject: RE: OPR Matter
I'm still having the issue. The appendix (the last 30 pages or so) is searchable, but the report (the first 370+ pages) isn't.
So, for example, if you CTRL+F "Epstein" the first hit I get is on page 384, even though he is repeatedly referred to in the
first 370+ pages.
From:
(USANYS) [Contractor]
Sent: Friday, August 7, 2020 11:02 AM
To:
(USANYS)
Subject: RE: OPR Matter
What is the exact issue you were facing? The searches that I am conducting in the document are happening without issue.
Copying the file over to the new location may have solved the issue.
From:
(USANYS)
Sent: Friday, August 7, 2020 10:57 AM
To:
(USANYS) [Contractor]
Subject: RE: OPR Matter
Should now be here:
Thanks
From:
(USANYS) [Contractor]
Sent: Friday, August 7, 2020 10:45 AM
To:
(USANYS)
Subject: RE: OPR Matter
I believe just the
drive.
From:
(USANYS)
Sent: Friday, August 7, 2020 10:44 AM
To:
(USANYS) [Contractor]
Subject: RE: OPR Matter
Great, thanks. Did I add you to the
share? Or only the
drive?
EFTA00018568

=== Page 2 ===
From:
(USANYS) [Contractor]
Sent: Friday, August 7, 2020 10:24 AM
To:
(USANYS)
Subject: RE: OPR Matter
It hasn't yet made it through. Yes, I'd be happy to help once I have shared access.
From:
(USANYS)
Sent: Friday, August 7, 2020 10:22 AM
To:
(USANYS) [Contractor]
Subject: RE: OPR Matter
I don't know if my email below came through - the attachment is huge and has been very difficult to send - but if not,
and if you're able to help, l'll put it on a share directory you have access to instead. Thanks!
From:
(USANYS)
Sent: Friday, August 7, 2020 10:09 AM
To:
(USANYS) [Contractor]
Subject: FW: OPR Matter
Do you have time today to help with a quick but time sensitive project? The attached report is not searchable for
whatever reason (the short appendix at the end is, but the first 380+ page report is not). Do you know/are you able to
resave or convert this in some manner that would make it searchable? Thanks
From:
(OPR)
Sent: Thursday, August 6, 2020 2:49 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: OPR Matter
Acting United States Attorney
for the Southern District of New York
New York, New York
Dear Ms.
Please find attached a letter from OPR Director
regarding OPR's draft report regarding the handling of the
Jeffrey Epstein matter by the U.S. Attorney's Office for the Southern District of Florida in 2006-2008. A copy of the draft
report, for your review, is also attached.
With regards,
Counsel
Office of Professional Responsibility
U.S. Department of Justice
950 Pennsylvania Avenue, N.W. - Room 3266
Washington, D.C. 20530
CC:
AUSA
EFTA00018569

=== Page 3 ===
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=== Page 1 ===
MCC NEW YORK
Saturday August 10, 2019
NEW YORK, NY
Page 1
Daily Assignment Roster
6 07:00 15:00
9 12:00-20:00
3 06:00- 14:00
8 08:00 16:00
10 14:00- 22:00
12
16:00- 00:00
Post
Split Shift 2 00:00 - 08:00
OPS LT
ACT LT
SHU LT
SIS TECH #1
PHONE MONITOR
SEARCH OFFICER
LOBBY
CONTROL #1
CONTROL #2
INTERNAL
INTERNAL #2
ATTY CONF
UNIT 2
UNIT 3
5 NORTH
5 SOUTH
7 NORTH
7 SOUTH
9 NORTH
SHU #1
"2 Noel, T
oT
SHU #2
**2 Thomas, M
OT (NC)
SHU #3
SHU #4
10 SOUTH #1
10 SOUTH #2
11 NORTH
11 SOUTH
11 SOUTH #2
OSP #1
SANITATION OFF
VISIT #1
VISIT #2
VISIT #3
****Special Assignments****
10/2019 10:46:54 AM
EFTA00019798

=== Page 2 ===
Saturday August 10, 2019
Page 2
PHONE RM
STAFF SEARCH
LOBBY #2
DRY CELL
ESCORT #1
ESCORT #2
****Back Page Categories****
DAY OFF
SICK LEAVE
ANNUAL LEAVE
COP
****Change Records****
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft
Changed By
OPS LT
12
OPS LT
8
Assignment Swap
11 SOUTH #2
12
[Sick / Annual]
9 NORTH
8
[Inserted NCS]
Thomas, M
[Sick/Annual]
RW 8/5 08:34
SHU #2
2 <Unassigned>
Thomas, M
[Sick / Annual]
RW 8/5 08:34
[Inserted NCS]
Thomas, M
[Sick/Annual]
RW 8/5 08:35
INTERNAL
8 <Unassigned>
Thomas, M
[Sick / Annual]
RW 8/5 08:36
10/2019 10:46:56 AM
EFTA00019799

=== Page 3 ===
Saturday August 10, 2019
Page 3
Relieved Officer's
Relieving Officer's
Ret
Post
New Status
Relleving Officer
Previous Status
Shft Changed By
Splt Shft Officer
SHU #3
3
CONTROL #2
3
VISIT #3
8
7 SOUTH
2
[Inserted NCS]
5 SOUTH
2
[Inserted NCS]
CONTROL #1
2
INTERNAL #2
2
[Inserted NCS]
11 SOUTH
2.
10 SOUTH #1
2
ACT LT
3
[Inserted]
[Inserted]
[Inserted]
[Inserted]
[Sick / Annual]
[Sick / Annual]
[Sick / Annual]
[Sick / Annual]
5 SOUTH
1
7 NORTH
1
ACT LT
3
ACT LT
[Inserted NCS]
7 SOUTH
[Inserted NCS]
10/2019 10:46:57 AM
EFTA00019800

=== Page 4 ===
Saturday August 10, 2019
Page 4
Relieved Officer's
Relieving Officer's
Ret
Post
New Status
Relieving Officer
Previous Status
Shft Changed By
Splt Shft Officer
7 SOUTH
12
[Sick / Annual]
7 SOUTH
2
7 SOUTH
2
7 NORTH
2
[Inserted NCS]
VISIT #2
8
SHU #2
8
[Sick / Annual]
INTERNAL #2
2
7 NORTH
12
[Inserted NCS]
SHU #1
8
11 SOUTH
12
INTERNAL
12
INTERNAL #2
2
OSP #1
2
(sp)DRY CELL
2
OSP #1
2
SHU #1
2 <Unassigned>
Noel, T
12 SHU #1
Y
MC 8/9 17:19
Shift
Staff
OT/CT Start End
SHU #1
Noel, T
oT
SHU #1
Noel, T
[Sick / Annual]
11 SOUTH
2
11 SOUTH
2
(sp)LOBBY #2
8
10/2019 10:46:57 AM
EFTA00019801

=== Page 5 ===
Saturday August 10, 2019
Page 5
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
5 SOUTH
8
[Inserted NCS]
(sp)LOBBY #2
8
LOBBY
3
LOBBY
10
(sp)PHONE RM
8
SEARCH OFFICER
8
CONTROL #1
8
9 NORTH
8
OSP #1
8
Sick Leave
0
11 SOUTH
8
OSP #1
8
LOBBY
10
(sp)DRY CELL
8
11 SOUTH
8
(sp)DRY CELL
8
5 NORTH
8
[Sick / Annual]
11 SOUTH
12
LOBBY
3
[Sick / Annual]
SHU #3
3
[Sick / Annual]
CONTROL #2
3
SHU #3
3
SEARCH OFFICER
8
UNIT 2
8
5 NORTH
8
[Sick / Annual]
10/2019 10:46:57 AM
EFTA00019802

=== Page 6 ===
Saturday August 10, 2019
Page 6
Relieved Officer's
Relieving Officer's
Ret
Post
New Status
Relieving Officer
Previous Status
Shft Changed By
Splt Shft Officer
5 NORTH
8
CONTROL #1
8
UNIT 3
8
End
ACT LT
10
[Sick / Annual]
ACT LT
10
ACT LT
3
7 NORTH
8
End
[Sick / Annual]
UNIT 2
8
[Inserted NCS]
UNIT 2
8
(sp)ESCORT #1
8
End
(sp)ESCORT #2
8
End
[Inserted NCS]
SHU #3
3
SHU #3
3
End
16:00
SHU #2
8
[Sick / Annual]
SHU #2
8
SHU #4
8
End
CONTROL #2
3
End
LOBBY
3
[Sick / Annual]
SJ
8/10 10:35
[Sick / Annual]
Thomas, M
[Removed]
INTERNAL
8 Thomas, M
[Sick / Annual]
<Unassigned>
SJ
8/10 10:35
[Inserted NCS]
INTERNAL
8
[Inserted NCS]
10/2019 10:46:58 AM
EFTA00019803

=== Page 7 ===
Saturday August 10, 2019
Page 7
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
SJ 8/10 10:38
10 SOUTH #2
3
SJ 8/10 10:38
10 SOUTH #2
3
OT/CT Start End
oT
08:00 14:00
SJ
8/10 10:38
SHU #1
8
SJ 8/10 10:38
[Sick / Annual]
SJ 8/10 10:38
SHU #1
8
SJ 8/10 10:39
UNIT 3
8
SJ 8/10 10:39
[Sick / Annual]
Y
SJ 8/10 10:39
UNIT 3
8
OT/CT Start End
oT
SJ 8/10 10:40
[Sick / Annual]
SJ 8/10 10:40
VISIT #2
8
SJ 8/10 10:40
[Sick / Annual]
SJ 8/10 10:40
VISIT #3
8
SJ 8/10 10:41
5 SOUTH
12
SHU #1
12 Noel, T
Sick Leave
<Unassigned>
SJ 8/10 10:41
**Recapitulation****
Morning Watch
8
AM Watch
1
Day Watch
10
PM Watch
3
Evening Watch
12
**Back Page Categories**
Day Off
64
Sick Leave
11
Annual Leave
5
COP
2
Total Correctional Svcs. Staff: 116
Non Correctional Svcs. Staff: 7
Overtime Occurrences: 25
Comptime Occurrences: 0
Ops Lt. Evening Watch Signature:
Captain's Signature:
10/2019 10:46:58 AM
EFTA00019804


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=== Page 1 ===
From:
To:
Menninger
Cc:
Jeff Pagliuca
Ann
Lundberg
Subject: RE: [EXTERNAL] RE: questionnaires
Date: Sun, 07 Nov 2021 21:49:12 +0000
Attachments: 2021-11-08_joint_letter_regarding_juror_questionnaires.pdf
Attached is a draft of a joint letter. Please let us know if you have any edits - we'll check for accuracy on our end as well,
but we wanted to circulate so that we could all check at the same time. Please note that, for three jurors, we've
withdrawn our objection and joined your position that those jurors should proceed to voir dire. Those juror numbers are:
127, 151, and 458.
Thanks,
From:
Menninger
Sent: Sunday, November 7, 2021 3:03 PM
To:
Cc:
Jeff Pagliuca
Ann Lundberg
Subject: RE: [EXTERNAL] RE: questionnaires
Sorry
but we did not use Excel to prepare our list, so I don't know how to convert it. There may be a way to convert
the pdf to Excel.
From:
Sent: Sunday, November 7, 2021 11:54 AM
To:
Menninger
Cc:
eff Pagliuca
Ann Lundberg
Subject: RE: [EXTERNAL] RE: questionnaires
With apologies for the delay (we ran into an excel glitch), I'm attaching our current list of proposed strikes. Could you
please send us your list in excel? It makes merging the two lists faster. Thanks!
From:
Menninger
Sent: Sunday, November 7, 2021 1:03 PM
To:
leff Pagliuca
(
EFTA00018893

=== Page 2 ===
Ann Lundberg
Subject: RE: [EXTERNAL] RE: questionnaires
Please find attached Defendant's position on jurors 1-566.
As I understand it, you will be putting ours into the categories described by the Court (joint keeps, joint strikes, gov't only
strikes and defense only strikes) and then re-circulating so that we can both check to ensure ours are entered correctly.
Let me know if you have any questions.
Thanks,
From:
Sent: Sunday, November 7, 2021 10:57 AM
To:
Menninger
Cc:
eff Pagliuca
Subject: Re: [EXTERNAL] RE: questionnaires
Thanks very much, sounds good, just let us know when you're ready.
On Nov 7, 2021, at 12:11 PM,
Menninger
wrote:
Thanks,
We are finalizing ours as well and should be done shortly.
From:
Sent: Sunday, November 7, 2021 10:08 AM
To:
Menninger
Jeff Pagliuca
Subject: RE: questionnaires
Hi Chris,
That's fine, we've completed our review and our paralegal is compiling a list to send over, which shouldn't take much
longer.
Thanks,
From: Christian Everdell
Sent: Sunday, November 7, 2021 1:06 AM
To:
Menninger
; Jeff Pagliuca
EFTA00018894

=== Page 3 ===
Cc:
Subject: [EXTERNAL] RE: questionnaires
We are still planning to send you our strikes by noon. But we would like to have a simultaneous exchange of strike lists.
Please send us your list at noon as well.
Thanks,
Chris
From: Christian Everdell
Sent: Saturday, November 6, 2021 2:30 PM
To:
Menninger
Jeff Pagliuca
Cc:
Subject: RE: questionnaires
That's fine,
We should be able to get you our strikes by then. Thanks.
From:
Sent: Saturday, November 6, 2021 12:53 PM
To:
Christian Everdell
;
Menninger
Jeff Pagliuca
Subject: questionnaires
All,
Our joint submission is due to the Court tomorrow outlining four categories of juror numbers. We're happy to take on
the task of compiling data for our joint submission. To that end, could you please email us your list of strikes by noon
tomorrow? Once we receive your list, we will compile that data into a letter outlining the four categories of juror
numbers the Court has requested, and we'll send that back to you so that you can double check the accuracy of the
chart. We estimate that process will take a fair amount of time, which is why we'll need your data by noon tomorrow if
you'd like us to coordinate the process.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00018895


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Press Inquiry Re Jeffrey Epstein
Date: Sat, 12 Jan 2019 22:09:41 +0000
Importance: Normal
Copy, and thanks. M
Original message
Subject: Press Inquiry Re Jeffrey Epstein
All,
Just wanted to let you I know got a call on my personal cell from a writer with The New Yorker
Magazine on the Epstein case. She has interviewed
The reporter asked me to verify that I was an agent and that
and myself traveled to Australia and
interviewed
and that she disclosed that she had sex with Epstein and Allan/Allen Dershowitz. I told her I
was an agent and all inquiries about the case would have to through
and
I gave her both your email
addresses. She said she had emailed
previously.
Have a feeling these calls may become more frequent.
, can't get
email to pop up. Don't know if you want to forward so she's in the loop.
Thanks,
EFTA00019167


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: RE: Epstein Sharing Order Part II
Date: Fri, 31 Jan 2020 14:53:26 +0000
Attachments: 2019.12.19_Epstein_6(e)_App_Order.ebd.ajr.docx_(002)_(002).ebd.docx.
Yes, this looks good, thanks - I made one more typo correction in the attached (in the new Trust Two language, "and
revocations" got repeated in the footnote and the order) but otherwise no changes.
From:
(USANYS)
Sent: Friday, January 31, 2020 09:48
To:
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
Thanks for flagging,
I made a few small changes (which I highlighted since we've got a fair bit of track already) which
I think should make this broad enough to cover the Trust Il stuff. Can you take a quick look and if everyone is okay with
this, perhaps we can plan to get this to CM on Monday morning? Thanks
From:
Sent: Thursday, January 30, 2020 7:22 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
I apologize for the delay on this - I've added the relevant language about revocations to both the application and the
order, and corrected a stray typo, so that stuff is good to go. But two quick things to note, not to belabor this, but - it
doesn't look like there's any reference to the Trust Two documents - that may be because they're not referenced in any
will? At a glance I don't see Trust Two in any of the wills, but I'd want to go back and look more thoroughly unless
somebody already made the decision on that basis. And second, it references a 2019 Trust but I don't see any documents
on that? I have to run out tonight but can certainly circle up with
and/or
tomorrow on any of this, or just ignore
it if I've misread.
thanks,
From:
(USANYS)
Sent: Thursday, January 30, 2020 12:05
To:
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
Just wanted to circle back on this -
are you signed off? Is this something we could get over to Part I today or
tomorrow? Thanks
EFTA00018080

=== Page 2 ===
From:
Sent: Wednesday, January 29, 2020 3:56 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
is it the intent to share those? If so, l'll just add it to every mention of each document, but if not then it's
unnecessary. I don't think those are substantive docs but I defer.
From:
(USANYS)
Sent: Wednesday, January 29, 2020 15:55
To:
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
Please add it in the right place and send me the order. Remember, I'm not a T&E lawyer. But you are getting to
be
From:
>
Sent: Wednesday, January 29, 2020 3:22 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
Yes, I think this document accurately describes the materials we've received, with just a note that it doesn't appear to
include revocations, so to the extent those are intended to be shared, I think that word may need to be added.
thanks,
From:
(USANYS)
Sent: Wednesday, January 29, 2020 10:40
To:
(USANYS)
is
Subject: Epstein Sharing Order Part Il
- I've updated the sharing order application to be one to share the additional trust and will documents we have now
received. Would you take a look when you can?
- I've tried to describe the various materials we have gotten from the estate attorneys over the last two weeks.
Would you mind taking a look (or asking a paralegal to take a look) to make sure I've accurately described/characterized
the new stuff we're looking to share?
Thanks,
EFTA00018081


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Epstein/Maxwell FOIA
Date: Wed, 10 Mar 2021 20:13:38 +0000
Importance: Normal
Attachments: unnamed
-- Do not delete or change any of the following text. --
When it's time, join your Webex meeting here.
More ways to join:
Join from the meeting link
https://usao.webex.com/usao/j.php?MTID=mc1bb5eed0ec0ce74c174ac88e8ccbd53
Join by meeting number
Meeting number (access code): 199 962 1511
Meeting password: PMxMsPua532
Tap to join from a mobile device (attendees only)
+1-929-251-9612,,1999621511## USA Toll 2
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Join by phone
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Global call-in numbers
Join from a video system or application
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You can also dial 207.182.190.20 and enter your meeting number.
Join using Microsoft Lync or Microsoft Skype for Business
Dial 1999621511.usao@lync.webex.com
If you are a host, click here to view host information.
EFTA00018727

=== Page 2 ===
Need help? Go to https://help.webex.com
EFTA00018728


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=== Page 1 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
To:
)"
Cc:
)"
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Date: Fri, 30 Oct 2020 13:05:33 +0000
Hi
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be available
for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00018430

=== Page 2 ===
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still be
grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
EFTA00018431

=== Page 3 ===
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com> "Donnini, George B." <donnini@butzel.com>
Cc:
)"
)"
=
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would you
please confirm that your production included all records of any tuition payments that Epstein (or his entities) made for
any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow and
will have limited availability this week, but my colleagues
and
(both cc'd) should be able to
coordinate with you as needed.
Best,
Maurene
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
Cc:
is
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Maurene -
Receipt confirmed.
Thanks,
Jeff
EFTA00018432

=== Page 4 ===
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey Epstein and
Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Maurene
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00018433


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=== Page 1 ===
From:
To:
Subject: pic
Date: Mon, 08 Jul 2019 18:57:59 +0000
Importance: Normal
https://www.washingtonexaminer.com/news/comeys-daughter-named-to-epstein-prosecution-team
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
EFTA00018397


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=== Page 1 ===
Event: Tentative: Call with PAE re Epstein
Start Date: 2021-03-25 20:30:00 +0000
End Date: 2021-03-25 21:00:00 +0000
Location: Dial-in:
Code:
Class: X-PERSONAL
Comment:
Date Created: 2021-03-25 20:37:20 +0000
Date Modified: 2021-03-25 20:37:20 +0000
Priority: 5
DTSTAMP: 2021-03-25 20:07:17 +0000
Attendee:
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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
September 15, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
The Government expects to offer testimony from Computer Forensic Examiner
of the Federal Bureau of Investigation's ("FBI") Computer Analysis Response Team
("CART"). Although the Government believes that Examiner
testimony will not require
admission through Rule 702 of the Federal Rules of Evidence, the Government nevertheless
provides notice of Examiner
anticipated testimony in an abundance of caution. A copy
of Examiner
curriculum vitae is being produced to you today bearing Bates number 3503-
001.¹
The Government anticipates that, if called as a witness, Examiner
will testify about
his extraction of devices seized pursuant to court-authorized search warrants; user information
associated with certain of those devices; and documents and photographs extracted from certain
1 Examiner
has previously testified regarding similar topics in federal court. As a courtesy,
the Government notifies you that Examiner
has previously testified in federal court in
United States V. DiTomasso, 14 Cr. 160 (SAS), United States V. Hirst, 15 Cr. 643 (PKC), United
States V. Stasiv, 18 Cr. 259 (PKC), and United States V. Kelly, 19 Cr. 286 (AMD) (E.D.N.Y.).
EFTA00019459

=== Page 2 ===
Page 2
of those devices. The Government further anticipates that Examiner
will also testify that
some of the devices on which he performed extractions were clones of device extractions that had
previously been performed by someone else.
The Government reserves the right to call additional expert witnesses and will promptly
provide notice if the Government elects to do so.
Request for Reciprocal Discovery and Expert Notice
The Government reiterates its April 23, 2021 request for reciprocal notice under Rule
16(b)(1)(C) of the Federal Rules of Criminal Procedure regarding any expert witness that the
defendant intends to rely upon, including a written summary of any testimony that the defendant
intends to use under Rules 702, 703, or 705 of the Federal Rules of Evidence, as well as the
witness's qualifications.
Additionally, the Government reiterates its August 5, 2020 request for reciprocal discovery
under Fed. R. Crim. P. 16(b). Specifically, we request that you allow inspection and copying of:
(1) any books, papers, documents, data, photographs, tangible objects, buildings or places, 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 reiterates its August 5, 2020 request that the defendant disclose prior
statements of witnesses she will call to testify, including expert witnesses. See Fed. R. Crim. P.
26.2; United States V. Nobles, 422 U.S. 225 (1975).
Very truly yours,
AUDREY STRAUSS
United States Attorney
by: s/
Assistant United States Attorneys
EFTA00019460


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
)"
)"
Subject: FW: Epstein 6(e) Order Signed and Ready to Pick Up
Date: Mon, 03 Feb 2020 16:25:44 +0000
Were you guys able to pick this up? If not, can you send a paralegal over to do so today? Thanks.
From:
(USANYS)
Sent: Friday, January 31, 2020 5:23 PM
To:
is
(USANYS)
Cc:
is
Subject: Epstein 6(e) Order Signed and Ready to Pick Up
I just got a call from Judge Nathan's clerk that she signed the order and it's ready to be picked up from her
chambers, if one of you want to engineer that right now.
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=== Page 1 ===
From: Laura Menninger <lmenninger@hmflaw.com>
To:
(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, 22 Mar 2021 21:18:42 +0000
Inline-Images: image001.jpg
All,
We have considered your proposal. Unfortunately, it does not permit us an adequate ability to review the evidence in the
case and does not permit our client to meaningfully participate in her own defense.
First, we are unable to meaningfully review the evidence without the benefit of our laptops and other electronic devices
which are needed to take notes of our review. We also need access to our devices during the review to compare the
physical evidence with the electronic discovery and with our work product.
Second, we need to provide our client the ability to review all discovery, including any recordings, in order to assist in her
own defense. Presuming that she will not be taken to the FBI downtown office, then your proposal offers no means by
which she can both inspect a recording in its physical form and listen to the recording at the same time.
In order to address the deficiencies in your proposal, we believe the following are necessary:
Physical Evidence
All of the physical evidence currently located in the FBI Bronx warehouse will be transported to 500 Pearl Street
and made available during the week of April 12, with our client present, in a room sufficiently large to
accommodate 8 attorneys and investigators.
We do not need the "bulky" massage tables transported; if there are any other extremely large evidence
pieces, let us know what they are and we can consider whether we can have someone review and
photograph those at the Bronx warehouse at an earlier time.
From your email, it appears that only two items are not located at the Bronx warehouse - both envelopes
with cash. Please confirm this. We do not need the two "cash" evidence items transported to 500 Pearl.
If there are other evidence items housed somewhere other than the Bronx, please let us know what they are
and where they are.
We will be permitted to bring our laptops, and a camera, into 500 Pearl Street; we are happy to seek permission
from Judge Nathan to do so.
Either the FBI can provide the equipment necessary to listen to any of the recordings at 500 Pearl Street or we can
bring the necessary equipment. If we are to provide the equipment, we will need to know in advance the formats
of each recording so that we can be prepared. You can note that on your Excel spreadsheet by the item number by
March 29 to give us adequate time to secure the necessary equipment.
The FBI can segregate any physical evidence that you deem "highly confidential." You can identify any "highly
confidential" physical evidence items on your Excel spreadsheets by April 5 (one week before the evidence view). If
we need to photograph or reproduce any such item for expert evaluation, we will seek leave of court. Otherwise,
we will not photograph any such items during the review during the week of April 12. This will ensure the evidence
review proceeds smoothly and there will not be any need to ask permission to photograph on an item by item
basis.
The FBI also can segregate any recordings which we will be able to inspect, but not listen to, during the evidence
view the week of April 12. You can note such designation on your Excel spreadsheet. If we disagree, we can seek
EFTA00020322

=== Page 2 ===
leave of the Court in advance.
We understand that an FBI Agent and/or AUSA may be present during our physical evidence review at 500 Pearl
Street but of course must ensure that no recordings are made of our conversations and also ensure that there is a
separate, secure room in which we can confer with our client during the evidence view without monitoring by the
government.
Please confirm whether all electronic recordings (other than the highly-confidential images and videos described
below) have previously been produced to us, and if not, please explain which ones were not produced by the
discovery deadlines last fall and why.
Highly Confidential Electronic Evidence
Can you please explain why 2,100 + 7 "highly confidential" images have not been shared with us yet? It was our
understanding that you previously provided all "highly confidential" images to our client - and to defense counsel -
for review at the MDC in November. We are confused about where these previously undisclosed items were
located and why they have not yet been made available for inspection and review.
During the week of April 19, Ms. Maxwell should be produced to 500 Pearl Street to review (with counsel and a
defense staff member, on the 1 laptop provided) all of the 5,507 electronic images and video marked "highly
confidential". These should be segregated into the three categories you describe (never-before produced,
previously produced, and the 7 hard-copy images).
Please let us know if you will not agree to any of these steps so that we can address the issues with the Court.
Thank you.
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 16, 2021 4:40 PM
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
All,
Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding
discovery cover letter. We are sending a copy of these files to the MDC for your client as well.
In response to your questions, the FBI has informed me of the following:
Regarding the Highly Confidential nude/partially nudge images to be reviewed at 500 Pearl:
There are three categories of these images:
Approximately 2,100 electronic images and videos seized from Epstein's electronic devices (which have not
been previously provided to you)
Approximately 3,400 electronic images from discs seized from Epstein's residences in 2019 (which have
previously been provided to you and your client for review at the MDC)
Approximately 7 hard copy nude images located in the file from the FBI Florida office's investigation of
Epstein (which have not been previously provided to you)
The FBI will make all three of those categories available to you. The electronic files will be provided on hard drives,
and the FBI will provide you with the hard copy images for review as well.
EFTA00020323

=== Page 3 ===
All electronic images should be viewable as thumbnails, except those seized from Apple devices, which must
be viewed using Cellebrite.
The Cellebrite software will be provided on the drive for your review of images and videos seized from Apple
devices.
The electronic files have the same metadata on the hard drive that was available when the FBI seized each
image. For images that were carved or deleted, no metadata was recovered, so none is viewable. For all
other images, the metadata recovered should be viewable on the hard drive.
The approximately 2,100 electronic images and videos seized from Epstein's devices are separated by folder
to indicate which device each image was seized from.
Because these images are considered obscene material, the FBI is not permitted to make duplicates of them, and
there is a limited number of clean laptops on which these images can be reviewed. As a result, the FBI is only able
to provide a single laptop for review of these images.
Regarding the physical evidence:
Attached are two lists of all physical items in the FBI's custody relating to this case. The first list relates to items
associated with the FBI Florida office's investigation of Epstein. The second list relates to items associated with the
FBI New York office's current investigation.
The vast majority of physical evidence in the FBI's custody is located at the FBI's warehouse in the Bronx. Two
items (1B 77 & 1B 79) are located at 26 Federal Plaza, but the case agents can check those items out from 26
Federal Plaza and bring them to the Bronx warehouse on whatever day you choose to conduct your review so that
you will have all evidence in one place.
The FBI is able to arrange for the defense team to review all physical evidence at the Bronx warehouse under the
following conditions:
The warehouse requires at least two weeks' notice in order to pull all of the items for the entire case and
place them in a location where a large group of people can view them.
The warehouse is open during normal business hours between 9am and 5pm on weekdays.
At least two FBI agents and an AUSA will be present at the Bronx warehouse to assist and answer questions.
The evidence will be placed in a loading dock at the warehouse to provide additional space for the review.
To ensure that there is sufficient space, please let me know how many members of the defense team intend
to be physically present for this review.
Electronic devices such as cellphones and laptops are not permitted in the warehouse. The defense team
may bring a digital camera that is not connected to the Internet or a cellular network into the warehouse. If
the defense team wishes to photograph an item of evidence, the defense will need to inform the agents who
are present, so that they may confirm that the photographed item is not Highly Confidential based on the
presence of nudity.
Electronic media such as VHS tapes, cassette tapes, and CDs will not be playable at the warehouse.
To the extent the defense requests that the FBI bring any physical items to 500 Pearl Street for your client to review,
the FBI is prepared to bring items that are reasonably sized to 500 Pearl Street. With respect to bulky or large
items, the defense team should be able to photograph those for your client to review, unless they are deemed
Highly Confidential, in which case the FBI can make arrangements to transport the item to 500 Pearl Street if
necessary.
The FBI is in the process of confirming that it can provide devices to play all of the electronic media in the case in a
single location at the FBI's offices in downtown Manhattan. We are also double-checking to confirm that all media
that does not contain witness statements have already been produced to you and your client in discovery. The FBI
anticipates that we can arrange for you to review all non-witness statement electronic media at the FBI's office in
downtown Manhattan in approximately three weeks.
To the extent you wish to review all of the discs containing photographs, which were seized from Epstein's
residences in 2019, we note that all of those images have already been produced to you in discovery. For
your awareness, the FBI has informed me that it took their team several weeks to review all of the images on
all of those discs.
Please let me know how you wish to proceed.
Best,
EFTA00020324

=== Page 4 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, March 15, 2021 6:00 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
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
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.
EFTA00020325

=== Page 5 ===
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?
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>;
)
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,
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)
EFTA00020326

=== Page 6 ===
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
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 | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <lmenninger@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,
EFTA00020327

=== Page 7 ===
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,
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>;
)
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
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
)
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
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.
EFTA00020328

=== Page 8 ===
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>;
)
>;
(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
(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
EFTA00020329

=== Page 9 ===
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
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.
EFTA00020330


c1: EFTA00018720
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018720.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Subject: RE: GM - Draft Third Bail Opposition
Date: Mon, 08 Mar 2021 03:03:48 +0000
Attachments: 2021-03-09_GM_Government_Third_Bail_Opposition_v4.rd.ebd.docx
Some combined comments and questions in track. I would like to see again at some point, and I think
will want to
see as well. But hopefully this should permit you to get the relevant section to OIA in the morning.
From:
Sent: Sunday, March 7, 2021 8:16 PM
To:
Subject: GM - Draft Third Bail Opposition
Chiefs,
Hope you both had a nice weekend. Attached for your review is a draft of our opposition to the third bail application, also
attached for your convenience. As noted in the draft, we are still waiting on feedback from OIA re France so that section
is subject to change. We also plan to send the section on citizenship renunciation to OIA to make sure they review for
accuracy (as we did with our last opposition). Given the time difference and our filing deadline of Tuesday, we are hoping
to send this to them sometime tomorrow morning, but of course, happy to discuss.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
Tel:
EFTA00018720


c1: EFTA00018845
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018845.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
NEW
Office of
YORK
Claim Application and
STATE
Victim Services
Instructions
How to Apply for Compensation
Who can apply for compensation?
Innocent victims of crime, certain relatives, dependents,
What if I don't have some of the papers OVS
legal guardians and eligible Good Samaritans can apply
needs?
to the Office of Victim Services (OVS) for compensation
Send your application in right away. You can send the
of out-of-pocket expenses not covered by insurance or
other documents later.
other resources.
What if my property was lost, damaged or
What kind of expenses can I get compensated
destroyed because of the crime?
for?
If you are under 18, 60 or over, disabled or were injured,
OVS offers compensation related to personal injury,
you may apply for benefits to replace your essential
death and loss of essential personal property.
personal property or cash that was not covered by any
The specific expenses OVS may cover include:
other resource.
Medical, pharmacy and counseling expenses
Essential means necessary for your health and welfare,
Loss of Essential Personal Property (up to $500,
like eyeglasses and clothes.
including $100 for cash)
What if I move?
Burial or Funeral Expenses (up to $6,000)
Send OVS a signed letter right away. Tell us your new
Lost Wages or Lost Support (up to $30,000)
address and phone number. Also let us know if your
(Parents or guardians of hospitalized minor children
email address changes.
may be eligible for this benefit.)
Transportation (court/medical)
Who can sign the claim?
Occupational/Vocational Rehabilitation
Generally, the victim must sign the claim. However, if the
Security Devices and DV Shelter Costs
victim is under 18, or is physically or mentally incapable
Crime scene clean-up (up to $2,500)
of signing, then the legal guardian (the person receiving
Good Samaritan property losses (up to $5,000)
the benefits) must fill out section 2 of the claim and sign
the claim.
Moving expenses (up to $2,500)
If the victim died, the person asking for benefits must fill out
How do I ask for compensation?
section 2 of the claim and sign the claim.
Send us your completed OVS application along with
Is there another way to apply?
copies of:
Police reports
Yes. Visit ovs.ny.gov to access the secure Victim Service
Medical bills
Portal (VSP) and file an application on line.
Correspondence with insurance companies
Do I have to fill out the attached HIPPA form?
or benefits plan saying if they will cover your loss
Insurance cards
Yes. Fill out one HIPAA form for each service provider.
Receipts for essential personal property
You can photocopy a blank form to make extra copies.
Death certificate and funeral contract
Victim's birth certificate
Proof of age (driver's license, birth certificate etc.)
Legal guardianship papers
80 S. Swan Street
55 Hanson Place
Albany, NY 12210-8002
Brooklyn, NY 11217-1523
(518) 457-8727
(718) 923-4325
ovs.ny.gov
800-247-8035
Rev. September 2015
EFTA00018845

=== Page 2 ===
Court Ordered Restitution Information
What is restitution?
Restitution is compensation paid to a victim by the perpetrator of a criminal offense for the losses or injuries incurred as a
result of the criminal offense. It must be ordered by the Court at the time of sentencing, and is considered part of the sentence.
Restitution is NOT for payment of damages for future losses, mental anguish or "pain and suffering."
When the District Attorney's (DA) office advises the Court that you have requested restitution or when the victim impact
statement contained in the probation investigation report (pre-sentence, pre-plea or pre-disposition report) indicates that the
victim seeks restitution, the Court must order restitution unless the interests of justice dictate otherwise. When the judge does
not order restitution, the judge must clearly state his/her reasons on the record.
What can I request as restitution?
You can ask for any expense you incur as a result of the criminal offense - even for items the OVS may not be able to
reimburse. Restitution may include, but is not limited to, reimbursement for medical bills, counseling expenses, loss of
earnings, funeral expenses, insurance deductibles and the replacement of stolen or damaged property.
Who is entitled to restitution?
Anyone who has been the victim of a criminal offense and has suffered injuries, economic losses or damages can seek
restitution. Many times, victims who deserve restitution do not request it. This can occur because victims are not aware that
they are entitled to restitution, or do not know what steps to take to go about receiving the restitution they deserve.
How do I ask for restitution?
You should contact the DA's office and advise them of the extent of your injury, your out-of-pocket losses and the amount of
damages you are requesting.
It is your responsibility to give the police, DA and, upon request, the local probation department copies of the bills and
other documents showing the extent of your injuries, your out-of-pocket losses and the amount of damages you want
considered by the Court. Your claim for restitution will be included in any probation investigation report (pre-sentence, pre-plea
or pre-disposition report). Be sure to:
Keep accurate records such as original receipts of any expenses you have as a direct result of the criminal offense.
Give copies of these receipts to the police, DA and local probation department.
You need to clearly explain your need for restitution as soon as possible to the DA, the victim/witness advocate, and the
probation department. Plea agreements can occur within days of the actual criminal offense. If this information is not provided
before the plea agreement and sentencing, you may have to pursue the perpetrator in Civil Court.
The DA is under an obligation to petition the Court to order restitution on your behalf.
In all felony criminal cases, many misdemeanor criminal cases and all juvenile delinquency and persons in need of supervision
(PINS) cases, a pre-sentence or predisposition investigation report is required. The local probation department will contact you
about the issue of restitution as it pertains to your case.
How is restitution determined?
The amount of restitution is based on proof of your out-of-pocket losses incurred as a result of the criminal offense. The
perpetrator has a right to object to the amount of restitution. The Court may hold a hearing on the issue of restitution where the
Court may consider the perpetrator's ability to pay. The DA's office may contact you and ask you to testify at the restitution
hearing. If you have a concern about appearing personally in Court, you should explore alternatives with the DA assigned to
your case.
If the OVS has paid your bills, the Court may order that restitution payments be made to the OVS for those paid items. It is
important that you advise the DA's Office that you filed a claim with the OVS.
If you filed a claim with the OVS, it is important that you advise the OVS if the Court orders the perpetrator to pay restitution.
Rev. September 2015
EFTA00018846

=== Page 3 ===
Read
Application for Compensation
How to Apply for
New York State Office of Victim Services
Compensation before
filling out this form.
Please print. Answer all questions. It is a crime to file a false claim!
Victim Assistance Program Use Only
Advocate Name/Email
OVS VAP ID#
Program Name/Phone
1
Tell us about the victim.
2
If you are not the victim, and you are signing this claim, you are the claimant. Tell us about you. (See "Who can sign the claim?" on the
instructions page.)
First Name
MI
Social Security #
Date of Birth
Last Name
Check here if you do not have one.
Mailing Address:
Street Apt. # (or P.O. Box)
City
County
State (or Foreign Country) Zip Code
What is your relationship to the victim? (Check only one.)
Parent
Spouse
Child
Legal Guardian
Attorney
Other (Explain):
3
Tell us about the crime. (Check only one.)
The victim died because of:
The victim was injured because of:
The victim lost essential personal property
Assault
Stalking
because of:
Motor Vehicle (DUI/DWI)
Sexual Assault
Kidnapping
Burglary
Arson
Motor Vehicle (Other)
Child Physical Abuse/Neglect
Terrorism
Motor Vehicle (DUI/DWI)
Criminal
Terrorism
Child Sexual Abuse
Arson
Motor Vehicle (not DUI/DWI)
Mischief
Arson
Motor Vehicle (DUI/DWI)
Robbery
Human Trafficking
Motor Vehicle (not DUVDWI)
Human Trafficking
Human Trafficking
Fraud/Financial
Child Pomography
Robbery (No injury)
Crime
Other Homicide
Other (Explain):
Other (Explain):
Where did the crime happen? (Check only one.)
Work
Owned residence
Apt. Bldg.
Public Street
Subway/Bus
Parking Lot
Restaurant/Bar
School/School grounds
Shopping Mall
Other (Explain):
Was this a crime related to domestic violence?
Yes
No
Unknown
Was this a crime related to bullying?
Yes
No
Unknown
Was this a crime related to elder abuse/neglect?
Yes
No
Unknown
Was this a hate crime?
Yes
No
Unknown
Was the victim driving a livery cab when the crime happened?
Yes
No
Unknown
Was the victim's property lost or damaged while trying to prevent or stop a
crime against someone else or while helping the authorities stop the crime?
Yes
No
Crime Report #:
Police or criminal justice agency reported to:
County where crime happened:
Date of crime:
Date crime was reported:
If more than 7 days between the date of crime and date the crime was reported, explain why:
If more than 1 year between the date of crime and the date you are filing this claim, explain why:
Describe the crime in your own words:
Rev. September 2015
EFTA00018847

=== Page 4 ===
4
Te
Has the suspect been arrested for this chime?
Has the suspect been prosecuted for this crime?
Yes
No
Not Yet
Does the suspect live in the same house as the victim
OR is the suspect a member of the victim's family?
Yes
No
Has the court issued an order of protection in this case?
Yes
No (If Yes, attach a copy.)
Has the DA asked the court to order restitution?
Yes
No
Not Yet
Yes (Amount $
)
No
Not Yet
Did the court order the suspect to pay restitution?
NOTE If are eligible for compensation, the OVS may be able to reimburse for the expenses listed below. These items should criminal also be
requested you as part of court ordered restitution. Applicants are encouraged to share this information with prosecutors if there is a
case. See the Court Ordered Restitution Information page for important information about restitution.
5
Tell us about your expenses related to this crime. (Check all that apply.)
Lost Wages
Personal Transportation
Medical/Ambulance
Loss of Support
(Death Claim Only)
DV Shelter
Medical/Counseling
Crime Scene Cleanup
Security Device/System
Vocational/Rehabilitation
Moving/Storage
Court
Counseling
Funeral/Burial
Essential Personal Property
Other (Explain):
6
List any essential personal property, like cash, eyeglasses, or clothing that needs to be replaced because of
this crime. (If none, skip to 7.)
Describe what was lost/damaged:
Cost
Describe what was lost/damaged:
Cost
1.
$
3.
$
2.
$
4.
$
3.
$
6.
$
Policy or ID #
Deductible
Homeowner/Renter Insurance Company
$
Auto/Other Insurance Company
Policy or ID #
Deductible
$
- If there were no injuries and you are only asking for essential personal property benefits, skip to 15. -
7 Tell us about the victim's or the parent's employment and insurance for Lost Wages.
If you do not want us to contact your employer, you cannot ask to be reimbursed for Lost Wages. (Skip to 8.)
Was the victim/parent of hospitalized minor victim employed when the crime happened?
Yes
No (If No, skip to 8.)
Did the victim/parent of hospitalized minor victim miss work because of the crime?
Yes
No
Was the victim/parent self-employed?
Yes
No (If Yes, attach copies of last year's federal tax return and all schedules.)
Employer's Name, Address, and Phone #:
(
)
Employer
Street
City
State
Zip Code
Phone #
Other Employer's Name, Address, and Phone #:
(
)
Street
City
State
Zip Code
Phone #
Employer
Name, Address, and Phone # of doctor who certified victim could not go to work:
(
)
Phone #
Doctor
Street
City
State
Zip Code
Tell us about any insurance company that will cover the victim's lost time at work. (If none, write "None" below and skip to 8.)
Policy or ID # or "None"
Policy or ID # or "None"
1. Unemployment Insurance
5. Workers' Compensation
2. Disability Insurance
6. Other insurance
7. Social Security Benefits (ssn
SSN
3. Pension Plan
required)
4. Other insurance
8. SSI Benefits (ssn required)
SSN
8
If the victim died, fill out below if you have any burial expenses. (If not, skip to 9.)
Also. attach a copy of the funeral home contract, other bills for burial expenses, and a photocopy of the Death Certificate, if you have them.
Name of Funeral Home:
Phone #:
(
)
Address:
Street
City
State
Zip Code
2015
Page 2 of 4
EFTA00018848

=== Page 5 ===
9
If the victim was injured or died because of this crime, fill out below.
Describe the victim's injuries, briefly:
Did the victim receive any medical treatment?
Yes
No (If No, skip to section 10.)
Tell us about the health professionals who treated the victim for injuries related to this crime:
Phone #
Full Name
Complete Address
(
)
First Hospital
(
)
Other Hospital
First Doctor
( )
(not in hospital)
( )
Other Doctor
(
)
First Dentist
(
)
Victim's Counselor
10 Tell us about the victim's dependents or others who depended on the victim for support. (If none. skip to 11.)
Name
Social Security #
Date of Birth
Relationship to Victim
Dependent
Are you the legal
Address
guardian?
Yes
No
Name
Social Security #
Date of Birth
Relationship to Victim
Other
Dependent
Are you the legal
Address
guardian?
Yes
No
Name
Social Security #
Date of Birth
Relationship to Victim
Other
Dependent
Address
Are you the legal
guardian?
Yes
No
If more than 3 dependents, attach a separate sheet and check here:
11 Did anyone besides the victim receive counseling because of this crime? (If no, skip to 12.)
Who received counseling?
Relationship to Victim
Insurance company billed for counseling
Policy or ID #
Counselor's name, address and phone #:
Who else received counseling?
Relationship to Victim
Insurance company billed for counseling
Policy or ID #
Counselor's name, address and phone #:
If more than 2 people received counseling because of this crime, check here and attach a separate sheet to describe.
12 List any insurance covering the victim or the victim's dependents. If no insurance, write "None" below.
If you have applied but are not covered yet, write "Pending" under Policy or ID #.
Policy or ID #
Name of person(s) covered by this insurance:
Primary Insurance Company
Major Medical Insurance Company
Other Insurance (Union, Dental, Vision, etc.)
Medicare
Medicaid
Workers' Compensation
Auto Insurance
Other insurance
Rev. September 2015
Page 3 of 4
EFTA00018849

=== Page 6 ===
13 If the victim died, tell us about any life insurance and death benefits.
(If the victim did not die, or does not have any life insurance or death benefits, skip to 14.)
Company Name
Address
Phone #
Policy or ID #
Life Insurance
(
)
Pension Plan
(
)
Other
Insurance/Plan
(
)
Medicaid
(
)
Workers'
Compensation
1
)
If any other insurance or death benefits, list here:
Do any of these policies cover the victim's burial expenses?
Yes
No
Has anyone applied for the Social Security Death Benefit?
Yes
No
14 Tell us about your financial situation. You MUST fill out ALL sections below. If none, enter zero (0).
How many dependents do you have?
What is your total annual income (from ALL sources)? If you are not sure, estimate: $
List ALL your assets and ALL your debts below. If you are not sure, estimate. Attach additional pages, if needed.
Your Assets - If none, enter zero (0).
Your Debts - How much do you owe now?
Savings, stocks, bonds
$
If none, enter zero (0).
Real Property (house, etc.)
$
Mortgage
$
Loans
$
Proceeds from life insurance
$
15 Is a private lawyer (not DA) representing you?
Yes
No
If Yes:
OVS Claim
Civil Suit
Both
(
)
Address
Phone #
Lawyer's Name
16 Authorization to speak with representative:
If you would like to give permission to a family member, friend or other person to speak to OVS regarding ( your claim, ) enter here.
Address
Phone #
Name of Person
17 Victim/Claimant's Authorization:
ACKNOWLEDGE that accepting an award from the Office of Victim Services (OVS) creates a lien in favor of the State of New York on any recovery relating to
I crime which this claim is based, including any judgment, settlement or order of restitution. I further authorize any funeral director, attorney, OVS employer, its
police the following information: Workers Compensation records, information relating to the crime or any injuries or death suffered I as also authorize the
the or other upon public authority, insurance company or any person who rendered services to the above, or having knowledge of the same, to furnish the the result of or the
representatives and information relating to this claim. If an award is made, I authorize the OVS to make payments directly to the provider of services. the OVS in
OVS crime, to share information and records compiled for this claim with the local Victim Assistance Program (VAP) in order for the VAP to assist and records
processing for my this claim with the lawyer in order for him/her to act as my representative. I understand a separate Notice of Appearance my lawyer and records
my claim and making its determination If a private lawyer has been indicated above, I also authorize the OVS to share my information from will be
needed compiled in addition to this authorization. If a family member, friend or other person is indicated above, I authorize the OVS to share my information
compiled for this claim with that person in order that they assist me with this claim.
To process your claim, mail us the following documents. (Keep a copy for your records.)
All bills and receipts for services listed on this form
Your completed, signed claim form
One completed HIPAA form for each service provider listed on this form (You can photocopy the HIPAA form.)
Letters from any insurers denying or authorizing payment for the services listed on this form.
Remember: You must bill your insurance company or benefits plan before the OVS can pay.
Mail your documents to:
New York State Office of Victim Services
AE Smith Building
80 S. Swan Street
Albany, NY 12210-8002
Page 4 of 4
tev. September 2015
EFTA00018850

=== Page 7 ===
OCA Official Form No.: 960
*HIPAA*
AUTHORIZATION FOR RELEASE OF HEALTH INFORMATION PURSUANT TO HIPAA
[This form has been approved by the New York State Department of Health]
Patient Name
Date of Birth
Social Security Number
XXX-XX-
Patient Address
I. or my authorized representative, request that health information regarding my care and treatment be released as set forth on this form:
In accordance with New York State Law and the Privacy Rule of the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
I understand that
1. This authorization may include disclosure of information relating to ALCOHOL and DRUG ABUSE, MENTAL HEALTH
TREATMENT. except psychotherapy notes, and CONFIDENTIAL HIV* RELATED INFORMATION only if I place my initials on
the appropriate line in Item 9(a) In the event the health information described below includes any of these types of information. and I
initial the line on the box in Item 9(a). I specifically authorize release of such information to the person(s) indicated in Item 8
2. If I am authorizing the release of HIV-related, alcohol or drug treatment, or mental health treatment information, the recipient is
prohibited from redisclosing such information without my authorization unless permitted to do so under federal or state law. I understand
that I have the right to request a list of people who may receive or use my HIV-related information without authorization If I experience
discrimination because of the release or disclosure of HIV-related information, I may contact the New York State Division of Human
Rights at (212) 480-2493 or the New York City Commission of Human Rights at (212) 306-7450 These agencies are responsible for
protecting my rights.
3. I have the right to revoke this authorization at any time by writing to the health care provider listed below. I understand that I may
revoke this authorization except to the extent that action has already been taken based on this authorization
4. I understand that signing this authorization is voluntary. My treatment, payment, enrollment in a health plan, or eligibility for benefits
will not be conditioned upon my authorization of this disclosure.
5. Information disclosed under this authorization might be redisclosed by the recipient (except as noted above in Item 2). and this
redisclosure may no longer be protected by federal or state law.
6. THIS AUTHORIZATION DOES NOT AUTHORIZE YOU TO DISCUSS MY HEALTH INFORMATION OR MEDICAL
CARE WITH ANYONE OTHER THAN THE ATTORNEY OR GOVERNMENTAL AGENCY SPECIFIED IN ITEM 9 (b).
7. Name and address of health provider or entity to release this information:
8. Name and address of person(s) or category of person to whom this information will be sent:
NYS OFFICE OF VICTIM SERVICES - AE SMITH BLDG., 80 S. SWAN ST., ALBANY, NY 12210-8002
9(a). Specific information to be released:
Medical Record from (insert date)
to (insert date)
Entire Medical Record, including patient histories, office notes (except psychotherapy notes), test results, radiology studies, films,
referrals, consults, billing records, insurance records, and records sent to you by other health care providers.
Other
Include: (Indicate by Initialing)
Alcohol/Drug Treatment
Mental Health Information
Authorization to Discuss Health Information
HIV-Related Information
(b)
By initialing here
I authorize
Initials
Name of individual health care provider
to discuss my health information with my attorney, or a governmental agency, listed here:
NEW YORK STATE OFFICE OF VICTIM SERVICES
(Attorney/Firm Name or Governmental Agency Name)
10 Reason for release of information:
11. Date or event on which this authorization will expire:
At request of the individual for purposes of establishing
This authorization will expire upon the termination of the
eligibility for New York State Office of Victim Services
individual's eligibility for Office of Victim Services benefits.
benefits.
12 If not the patient, name of person signing form:
13. Authority to sign on behalf of patient:
All it
opy
of the
Sig
Human Immunodeficiency Virus causes AIDS. The New York State "ublic Law protects which
reasonably could identify someone as having HIV symptoms or infection and information regarding a person's contacts.
EFTA00018851


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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
Subject: RE: Boies Schiller-Jeffrey Epstein Supposedly Sealed Order
Date: Tue, 30 Mar 2021 14:34:50 +0000
This is a 2019 order that was recently unsealed. We made an application to modify a protective order in a civil
case, and Judge Netburn denied the application.
Original Message
From:
(USANYS)
Sent: Tuesday, March 30, 2021 10:21 AM
To:
)
)
Subject: Boies Schiller-Jeffrey Epstein Supposedly Sealed Order
Do you know what this is about?
Original Message
From:
(USAGAN)
Sent: Tuesday, March 30, 2021 9:08 AM
To:
(USANYS)
Subject: FW: IN RE APPLICATION TO UNSEAL CIVIL DISCOVERY MATERIALS, USAO Reference No.
2018R01618.
This is weird to me. The order says it is sealed, but it's quite public, as you can see.
Original Message
From: Westlaw@westlaw.com <Westlaw@westlaw.com>
Sent: Tuesday, March 30, 2021 9:06 AM
To:
(USAGAN)
Subject: IN RE APPLICATION TO UNSEAL CIVIL DISCOVERY MATERIALS, USAO Reference No.
2018R01618.
sent you content from Westlaw Edge.
Please see the attached file.
Item: IN RE APPLICATION TO UNSEAL CIVIL DISCOVERY MATERIALS, USAO Reference No.
2018R01618.
Citation: Slip Copy
Sent On: Tuesday, March 30, 2021
Sent By:
Client ID: DOJ
Note:
Westlaw © 2021 Thomson Reuters. No claim to original U.S. Government Works.
EFTA00019095


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=== Page 1 ===
From:
To:
Cc:
Subject: Times: Jeffrey Epstein Offers Mansion and Jet as Bond to Avoid Jail Before Trial
Date: Thu, 11 Jul 2019 16:58:57 +0000
Importance: Normal
Inline-Images: image001.jpg; image002.png
https://www.nytimes.com/2019/07/11/nyregion/jeffrey-epstein-bail.htm?
action=click&module=Well&pgtype=Homepage&section=New%20York
Jeffrey Epstein Offers Mansion and Jet as Bond to
Avoid Jail Before Trial
Prosecutors have argued that the financier, who is accused of abusing dozens of underage girls, posed "an
extraordinary risk of flight."
U.S. v. Jeffrey Epstein
JEFFREY ALLEGED EPSTEIN HAS BEEN
THE
/ 1 AND
IF BE YOU A VICTIM, RECOGNIZE THIS PERSON
PLEASE CALL THE AND FEL YOU MUMBER:
1-800-CALL FBI
Image
Geoffrey S. Berman, the United States attorney in Manhattan, announced the indictment on
Monday.CreditCreditJason Szenes/EPA, via Shutterstock
EFTA00018172

=== Page 2 ===
By Benjamin Weiser
July 11, 2019
Jeffrey Epstein, the financier facing sex-trafficking charges in New York, has been described by
prosecutors as a man of enormous wealth: He owns a $77 million mansion on the Upper East Side, a $12
million estate in Palm Beach, Fla., a private island in the Caribbean and a private jet, they said.
And on Thursday, Mr. Epstein, 66, asked a federal judge to allow him to use some of his wealth to stay out
of jail while he awaits trial, filing a detailed bail proposal with the court.
Mr. Epstein asked the court to release him on substantial bond and pledged to put up his palatial
Manhattan townhouse and his private jet as collateral. He also proposed he be allowed to remain under
house arrest in his Upper East Side house, and said he would agree to electronic monitoring of his
location. He said he would surrender his passport and ground his jet.
In addition, his lawyers proposed that Mr. Epstein would hire private round-the-clock security guards who
would "virtually guarantee" that he would not flee his house and would show up for court.
A handful of superrich defendants have sought and occasionally obtained, over sharp objections from the
government, similar bail provisions that allow them to finance a kind of personal jail rather than being
held in a government lockup.
Such bail packages have prompted intense debate about their fairness. The judge in Mr. Epstein's case,
Richard M. Berman, rejected a similar proposal in 2016 from a wealthy Turkish-Iranian gold trader in a
money laundering case.
At the time, Judge Berman wrote that the proposal was "unreasonable because it helps to foster inequity
and unequal treatment in favor of a very small cohort of criminal defendants who are extremely wealthy."
Prosecutors had said on Monday after the charges were announced that they would ask to have Mr. Epstein
held in jail until his trial. They said in court that he posed "an extraordinary risk of flight and danger," and
that he had "nearly infinite means" and "tremendous incentives to use those means to flee prosecution."
Judge Berman of Federal District Court in Manhattan is scheduled to take up Mr. Epstein's bail proposal at
a hearing on Monday.
Mr. Epstein was arrested Saturday night aboard a private jet at Teterboro Airport after arriving from Paris.
He has been detained at the Metropolitan Correctional Center, a high-security facility in Lower Manhattan
where accused terrorists, mobsters and, most recently, the Mexican drug lord known as El Chapo, have
awaited trial.
If convicted, Mr. Epstein faces up to 45 years in prison on sex-trafficking and conspiracy charges. The
indictment unsealed on Monday by Geoffrey S. Berman, the United States attorney in Manhattan, said that
between 2002 and 2005, Mr. Epstein recruited dozens of underage girls to engage in sex acts with him,
after which he paid them hundreds of dollars in cash.
The indictment also accused Mr. Epstein of encouraging some of his victims to recruit other underage girls
that he could then abuse, and paying his "victim-recruiters" hundreds of dollars for each girl that they
brought to him. "In so doing, Epstein maintained a steady supply of new victims to exploit," the
indictment said.
EFTA00018173


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=== Page 1 ===
From:
)"
To:
Cc:
)"
i
(USANYS)"
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Date: Thu, 19 Nov 2020 17:33:55 +0000
Chris,
I have asked our paralegal and IT staff how large a drive we will need, and I hope to have an answer for you by our 1:30
call today.
As for the most recent production, the hard drive contains the production prepared by our vendor, which includes
approximately 1.2 million documents. The CD contains the final portion of the responsive images from Epstein's iPhone.
So they were produced separately because they were prepared by different offices: the hard drive was prepared by the
vendor, and the CD was prepared by our paralegals.
Because we are planning to put all productions onto a single hard drive, as you requested, the files from the CD will be
included on that new drive, so Ms. Maxwell will have those files both on a CD and on a hard drive.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Christian Everdell
Sent: Wednesday, November 18, 2020 10:39 PM
To:
is
Cc:
is
(USANYS)
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Thanks,
We will provide another drive to load the full production. We just have to figure out how big it needs to be. If you have
any thoughts on that, please let me know.
Also, can you explain the difference between the hard drive and the CD? Did you just need a little more space than what
the hard drive offered? Or is there a reason you put certain files on the CD? I note that the laptop does not contain a disk
EFTA00017813

=== Page 2 ===
drive, so I assume Ms. Maxwell will have to use the prison computer to review the files on the CD?
Thanks,
Chris
From:
) [mailto:
Sent: Wednesday, November 18, 2020 2:23 PM
To: Christian Everdell; Mark S. Cohen; Laura Menninger; Jeff Pagliuca; BOBBI C STERNHEIM
Cc:
);
(USANYS)
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Chris,
I have asked MDC staff to provide Ms. Maxwell with the drive containing the November 9th discovery production and will
follow up with them again about it.
We can certainly make a copy of all productions to date on a single hard drive for Ms. Maxwell to review at the MDC. My
apologies, I did not appreciate that you were requesting a full reproduction of all past discovery. My understanding was
that the reproductions contained on the November 9th drive would address your concerns. If you would prefer to have a
single drive containing all productions, we can certainly accommodate that request. Please let me know if you would like
us to use one of the drives already at the MDC for this purpose, or if you would like to provide my office with a new drive.
My understanding from the MDC is that for security purposes, the laptop will be kept in a locker to which only two
lieutenants have access. Those two lieutenants work Monday through Friday 8:30am to 3:30pm, which is when Ms.
Maxwell will have access to the laptop. For the remainder of the 13 hours of review time, Ms. Maxwell may review her
discovery on the MDC computer. The laptop is being provided to allow Ms. Maxwell to open files that she could not open
on the MDC computer. 35 hours per week should be more than sufficient to review any excel files or other file types that
cannot be viewed on the MDC computer.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Christian Everdell
Sent: Wednesday, November 18, 2020 2:11 PM
To:
)
is
Cc:
is
(USANYS)
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
EFTA00017814

=== Page 3 ===
-
We will send someone to pick up the new production. But as we discussed, if Ms. Maxwell has to rely on the existing hard
drives to view the discovery on the new laptop, that is not going to work.
For one thing, Ms. Maxwell still has not received the hard drive you produced on November 9, which was supposed to
contain replacement copies of the files on the hard drive produced on September 3 (which was broken in MDC) and the
files in the October 2 production (see attached email). We cannot rely on a drive that has not been made available to Ms.
Maxwell.
Also, when we spoke about the laptop, my understanding was that if you could not load the files directly onto the laptop,
you would create a new hard drive that contained the entire discovery production and that you would verify that the files
on that hard drive were readable on the new laptop. That way, we would not have to rely on a patchwork of prior hard
drives which had a lot of problems.
To be clear, I don't think the laptop solution you have proposed will solve the problems that Ms. Maxwell has been
experiencing and is not consistent with what we discussed. If there is no way to load the full discovery on the laptop
itself, then please advise if you are able to create a new hard drive that contains the complete production (without the
highly confidential materials) that can be made available to Ms. Maxwell in the MDC.
Also, I have been informed by Ms. Maxwell, that the MDC told her today that she will only be able to use the laptop to
review discovery from 8:30am-3:30pm on weekdays. That is only seven hours a day, as opposed to the 13 hours a day
(plus weekends) that the BOP had agreed to before. There is no reason for this restriction. It is also not acceptable. In
this latest production alone, there are over 2 million pages to review. Ms. Maxwell cannot possibly review that much
material by trial if her review is restricted in this way. Please confirm that she will be able to have the full 13 hours per
day (plus weekends) to review the discovery, as previously agreed.
Thanks,
Chris
From:
) [mailto:
Sent: Wednesday, November 18, 2020 9:25 AM
To: Christian Everdell; Mark S. Cohen; Laura Menninger; Jeff Pagliuca; BOBBI C STERNHEIM
Cc:
);
(USANYS)
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Counsel,
A drive and a CD containing a new discovery production in the above-referenced case are now available for pickup at One
St. Andrew's Plaza. Attached please find the accompanying discovery letter.
This morning, I hand delivered a copy of this production and a laptop to the MDC for Ms. Maxwell. My understanding
from the MDC is that Ms. Maxwell will be permitted to use this laptop and a power cord to review her discovery drives.
Our IT staff, paralegal staff, and I have all confirmed that this laptop is able to open every file type contained in the
discovery productions to date. The laptop does not have sufficient storage space to save the productions on the laptop
itself, but we have saved all discovery cover letters to date on the desktop for ease of access. Ms. Maxwell will need to
use the hard drives with the laptop to review her discovery.
Best,
EFTA00017815

=== Page 4 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
)"
To: Michael Bachner
Subject: Automatic reply: Epstein investigation /
Date: Wed, 07 Aug 2019 17:32:12 +0000
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
or
EFTA00019857


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=== Page 1 ===
From:
To:
Subject: Meet re: Epstein Investigation
Date: Wed, 05 Dec 2018 00:22:08 +0000
Importance: Normal
Attachments: unnamed
EFTA00019425


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c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018265.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Questionnaires are ready
Date: Sat, 13 Nov 2021 16:23:09 +0000
Attachments:US_v_Maxwell_Juror_Questionnaire_Review_-_MASTER_CHART_copy_AR.xlsx
Hey
- here's my completed review of the questionnaires. Thanks!
From:
Sent: Friday, November 12, 2021 3:30 PM
To:
in
is
is
Subject: RE: Questionnaires are ready
FYI, I just dropped the questionnaires and the updated 3500+GX (produced last night to defense) off at chambers. I am
meeting the C&G paralegal for her to pick up the defense hard copies in about an hour.
From:
Sent: Friday, November 12, 2021 2:01 PM
To:
is
is
Cc:
Subject: RE: Questionnaires are ready
,
Please save your own version of this spreadsheet, fill out your notes and objections for your assigned set, and email it to
by 11 a.m. tomorrow.
will merge the data into a single spreadsheet.
From:
Sent: Friday, November 12, 2021 1:53 PM
To:
is
is
is
Cc:
(USANYS) [Contractor]
Subject: RE: Questionnaires are ready
Questionnaires from this morning saved here:
Assignments are in the attached spreadsheet. The questionnaires are uploaded to USAfx and are ready to be shared with
defense counsel once you email them to let them know.
Original Message
From:
Sent: Friday, November 12, 2021 12:07 PM
To:
is
is
is
EFTA00018265

=== Page 2 ===
Cc:
(USANYS) [Contractor]
Subject: RE: Questionnaires are ready
Thanks! Team, as a reminder for planning purposes: your comments/objections to your batch of jurors will be due to
by 11 a.m. tomorrow morning. I'll work with
today to get this out to the defense and the court and get the
juror numbers assigned out to the team to review.
Original Message
From:
Sent: Friday, November 12, 2021 12:03 PM
To:
is
is
is
Cc:
(USANYS) [Contractor]
Subject: Questionnaires are ready
Well let you know when they're scanned and ready for you.
Sent from my iPhone
EFTA00018266


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020098.pdf
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=== Page 1 ===
From: Bruce Marshall
To: Callie Meier
)"
Cc:
)"
X
(USANYS)"
>, , Suzanne Pruitt
Subject: [EXTERNAL] RE: Subpoena to
Part 6 - final
Date: Mon, 11 Oct 2021 17:57:25 +0000
Attachments: N722JE - Order_44814_Part6.pdf
Inline-Images: image001.jpg
Bruce Marshall
EVP & General Counsel
Tel:
or
Fax:
f
in
From: Bruce Marshall
Sent: Monday, October 11, 2021 12:56 PM
To: 'Callie Meier'
is
)'
Cc:
)'
V.
(USANYS)'
>; ; 'Suzanne
Pruitt'
Subject: RE: Subpoena to
Part 5
Bruce Marshall
EVP & General Counsel
Tel:
or
Fax:
f
in
From: Bruce Marshall
Sent: Monday, October 11, 2021 12:55 PM
To: 'Callie Meier'
is
)'
Cc:
)'
i
(USANYS)'
>; 'Suzanne
Pruitt'
Subject: RE: Subpoena to
Part 4
EFTA00020098

=== Page 2 ===
Bruce Marshall
EVP & General Counsel
Tel:
or
Fax:
f
in
From: Bruce Marshall
Sent: Monday, October 11, 2021 12:54 PM
To: 'Callie Meier'
is
)'
Cc:
)'
>;
(USANYS)'
>; 'Suzanne
Pruitt'
Subject: RE: Subpoena to
Part 3
Bruce Marshall
EVP & General Counsel
Service
Tel:
or
Fax:
f
in
From: Bruce Marshall
Sent: Monday, October 11, 2021 12:52 PM
To: 'Callie Meier'
V.
)'
Cc:
)'
is
(USANYS)'
>; ; 'Suzanne
Pruitt'
Subject: RE: Subpoena to
Part 2
Bruce Marshall
EVP & General Counsel
Tel:
or
Fax:
f
in
From: Bruce Marshall
Sent: Monday, October 11, 2021 12:50 PM
To: 'Callie Meier'
is
)'
Cc:
)'
is
(USANYS)'
>; ; Suzanne
Pruitt
Subject: RE: Subpoena to
Part 1
EFTA00020099

=== Page 3 ===
I am sending the response in multiple files due to size.
Best Regards,
Bruce Marshall
EVP & General Counsel
Tel:
or
Fax:
f
in
From: Callie Meier
Sent: Friday, October 8, 2021 2:15 PM
To:
Cc:
is
(USANYS)
>;
Subject: RE: Subpoena to
Hi
I have completed the requested subpoena for N722JE and sent it to our general counsel for review. I should hear back
from him next week and will forward directly to you. Thank you and please contact me with any questions. Have a great
weekend.
The FAA and
will be closed Monday, 11 September in honor of Indigenous Peoples' Day.
Callie Meier
Document Specialist
f
in
Tel:
or
Fax:
Ask me about Title Insurance for your aircraft!
From:
)
Sent: Thursday, September 30, 2021 2:13 PM
To:
Cc:
is
(USANYS)
Subject: Subpoena to
Hi Callie,
Thank you again for the call this afternoon. Attached is the subpoena we discussed. Please feel free to give me a call if
you have any questions.
Thanks,
EFTA00020100

=== Page 4 ===
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00020101


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=== Page 1 ===
Please note my new office address and preferred email address:
This message and any attached documents contain information from the
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.
EFTA00019044


c1: EFTA00018839
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018839.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: PBPD
Date: Mon, 04 Oct 2021 16:01:08 +0000
Attachments: 2020-10-
07_GM_letter_to_Judge_Nathan_re_discovery_from_other_agencies_(FINAL).pdf;
Pages_from_PB_76-2.pdf
From:
Sent: Monday, October 4, 2021 11:05 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: PBPD
From:
Sent: Monday, October 4, 2021 11:01 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: PBPD
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00018839


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018100.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
)"
Cc:
(USANYS)"
Subject: Epstein
Date: Fri, 17 Jan 2020 16:41:06 +0000
Can you guys please send me our filings on bail when you can? Want to provide to Civ Div, so please let me know if
anything was filed under seal.
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00018100


c1: EFTA00019486
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019486.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: GM discovery demand letter
Date: Thu, 25 Mar 2021 13:29:07 +0000
Attachments: 2021.03.08_LAM_Letter_to_USAO_re_discovery_F).pdf_2021-03-
24_Letter_Re_Discovery_Requests_Re_FOIA.ebd.docx
Some thoughts on this in track.
From:
)
Sent: Wednesday, March 24, 2021 8:27 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
(USANYS)
Subject: GM discovery demand letter
Attached for your review is a draft of your response to Maxwell's most recent discovery demand (also attached).
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00019486


c1: EFTA00019321
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019321.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: Re: Question from HQ
Date: Fri, 16 Aug 2019 23:46:53 +0000
I'm not sure I understand the question. Does he mean Epstein's prison call(s) while detained?
Sent from my iPhone
On Aug 16, 2019, at 7:23 PM,
(USANYS)
wrote:
FYI- let us know how you'd like us to proceed.
Begin forwarded message:
From:
"
(OIG)"
Date: August 16, 2019 at 7:17:54 PM EDT
To:
(USANYS)"
i
(USANYS)"
Subject: Question from HQ
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
EFTA00019321


c1: EFTA00019825
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019825.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Subject: FW: Your Thursday morning trip with Uber
Date: Fri, 15 Nov 2019 23:46:59 +0000
Inline-Images: ap_bb88f481-b723-437f-96ff-061c4538cb83_wide.png map_bb88f481-b723-437f-96ff-
061c4538cb83.png; image001.jpg; image002.png; image003.jpg; image004.jpg;
image005.jpg; image006.jpg; image007.jpg; image008.jpg; image009.jpg; image010.jpg;
image011.jpg; image012.jpg; image013.jpg
Hi
Below is my receipt for my Uber from the LA airport to my meeting with the Epstein team for my most recent work trip.
Thanks!
From:
Sent: Thursday, November 14, 2019 9:07 PM
To:
Subject: Fwd: Your Thursday morning trip with Uber
Begin forwarded message:
From: Uber Receipts <uber.us@uber.com>
Date: November 14, 2019 at 12:10:44 PM PST
To:
Subject: Your Thursday morning trip with Uber
Total: $24.93
Thu, Nov 14, 2019
EFTA00019825

=== Page 2 ===
Thanks for riding,
We hope you enjoyed your ride
this morning.
Total
$24.93
Trip fare
$24.93
Subtotal
$24.93
8688 Switch
$24.93
A temporary hold of $24.93 was placed on your payment method 8688 at the start of the trip.
This is not a charge and has or will be removed. It should disappear from your bank statement
shortly. Learn More
You rode with Sung
EFTA00019826

=== Page 3 ===
How was your ride?
Rate Or Tip
Rate Or Tip
Has passed a
multi-step safety
screen
4.91
Rating
Sung is known
for:
Excellent
Service
When you ride with Uber, your trips are insured in case of a covered
accident. Learn more.
10
10
1
187
90
405
1
Google
Map data ©2019
UberX
11.68 mi I 27 min
11:42am
6365 Sky Way, Los Angeles,
CA
12:10pm
EFTA00019827

=== Page 4 ===
1717 4th St, Santa Monica,
CA
405
2
10
10
1
187
90
405
1
Google
1
Map data ©2019
Invite your friends and family.
Get $5 off your next ride when you refer a friend to
try Uber. Share code: cfhp6
REPORT LOST ITEM >
CONTACT SUPPORT >
MY TRIPS >
FAQ
Uber Technologies
1455 Market St
Forgot password
San Francisco, CA 94103
EFTA00019828

=== Page 5 ===
Privacy
Read about our zero
Terms
tolerance policy.
Report a zero
tolerance complaint
by visiting
help.uber.com.
EFTA00019829


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c2: DataSet 8
c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Tentative: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Start Date: 2021-11-21 19:00:00 +0000
End Date: 2021-11-21 19:30:00 +0000
Location:
Class: X-PERSONAL
Comment:
Date Created: 2021-11-20 22:13:39 +0000
Date Modified: 2021-11-20 22:13:39 +0000
Priority: 5
DTSTAMP: 2021-11-20 22:06:35 +0000
Attendee: Stoddart, Allison
@wilmerhale.com>
EFTA00019457


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c3: VOL00008
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=== Page 1 ===
From:
Subject: Re: Epstein priv review -- 1B72 released and update
Date: Tue, 03 Nov 2020 22:16:31 +0000
Inline-Images: image001.png
Terrific. Thanks so much for getting this done, much appreciated.
Sent from my iPhone
On Nov 3, 2020, at 5:05 PM,
wrote:
Per below, we released two more devices today, will release two more tonight, and the final one tomorrow.
Thanks,
From:
5:03 PM
To:
1
Subject: RE: Epstein priv review -- 1B72 released and update
I'm loading 1B72 to your shared directory now. We did not remove any potentially privileged materials. As stressed
below, do not try to open from the shared directory.
Enrique is generating NP reports for 1B69 and 1B84.
W/r/t 1B84, we are removing 169 PP emails, so there will be 1762 emails, and we are removing one PP chat (with
Darren Indyke) so there will be 243 chats.
W/r/t 1B69, we are removing 93 PP emails, so there will be 1074 emails.
l'll finish 1B71 tomorrow.
And as always, stop your review and let me know if you come across anything that you think may be privileged.
And thanks
for all the help today!!
From:
Sent: Tuesday, November 03, 2020 1:12 PM
To:
Subject: RE: Epstein priv review -- 1B83 released
Got it, thank you so much!
From:
Sent: Tuesday, November 3, 2020 1:09 PM
To:
EFTA00018089

=== Page 2 ===
Subject: Epstein priv review -- 1B83 released
We just finished 1B83. 30 emails were removed as potentially privileged. The redacted report is saved to your shared
directory below but DO NOT open it from the shared or it will shut down the office network. Save it to your D drive or
Enrique can put it on a flashdrive.
From:
Sent: Tuesday, November 03, 2020 11:09 AM
To:
Subject: RE: Help with Epstein Privilege Review
Thank you so much,
From:
Sent: Tuesday, November 3, 2020 11:08 AM
To:
Subject: RE: Help with Epstein Privilege Review
The first two phones are up on the Priv share. (71 and 72).
From:
Sent: Tuesday, November 03, 2020 10:23 AM
To:
Subject: RE: Help with Epstein Privilege Review
Thank you!
From:
Sent: Tuesday, November 3, 2020 10:19 AM
To:
Subject: RE: Help with Epstein Privilege Review
Yes. And I will produce on a rolling basis to
From:
Sent: Tuesday, November 03, 2020 10:17 AM
To:
Subject: RE: Help with Epstein Privilege Review
Great, can you do 1B72 first and if we still don't have a PRIV shared directory, email it to just me? The case team is on a
tight discovery deadline so I want to get
reviewing asap.
Thanks,
From:
Sent: Tuesday, November 03, 2020 10:13 AM
To:
EFTA00018090

=== Page 3 ===
Cc:
Subject: RE: Help with Epstein Privilege Review
Got it. This will take me a few hours to complete. I'll let you know when it's done.
From:
Sent: Tuesday, November 03, 2020 9:51 AM
To:
Subject: RE: Help with Epstein Privilege Review
Great! Can you create the following extractions from the Epstein HD? And save them to the Priv shared directory as
soon as I can create one? And then l'll hav
start reviewing them for privilege.
1B71 - Chats and SMS
1B72 - Chats
1B69 - Chats
1B84 - Chats
1B83 - Chats
From:
Sent: Tuesday, November 03, 2020 9:47 AM
To:
Subject: Re: Help with Epstein Privilege Review
Yes I'm in. Let me know what you need.
Investigative Analyst
U.S. Attorney's Office, SDNY
On Nov 3, 2020, at 9:37 AM,
wrote:
Hi
Can you help me today on this?
Thanks,
From:
Sent: Tuesday, November 03, 2020 9:33 AM
To:
Subject: RE: Help with Epstein Privilege Review
Do you guys have a shared directory? Can you send me the link? I need to set up a Privilege shared directory.
Thanks,
From:
Sent: Tuesday, November 03, 2020 9:16 AM
To:
EFTA00018091

=== Page 4 ===
Cc:
Subject: RE: Help with Epstein Privilege Review
H
or
will correct me if they have a better way but I think the best way to generate the Responsive Report
is to deselect (by removing the X in the column on the far left) all the data in the report and then go to the Tags view
and select (by putting the X back in the column on the far left) all your tags. You then go up to the top left and choose
the Report drop down and then choose Generate a New Report. Be sure to name it something that makes it clear that
it is the Responsive report and you can also choose whether to create a UFDR report or a PDF.
l'll give you an update on the other reports shortly.
Thanks
From:
Sent: Monday, November 02, 2020 9:59 PM
To:
Subject: RE: Help with Epstein Privilege Review
Hi
I've finished the responsiveness review of the four reports that Reggie generated last week. I've tagged all of the
responsive items in each report. What should my next step be to generate reports that only include the tagged items?
Now that these are done,
and I are all just waiting on the release of the remaining portions of 1B72 and
1B69, as well as any content from 1B71, 1B83, and 1B84. As soon as you can release even just some of those reports,
we will dive into the responsiveness review.
To give you a sense of timing: In order to give our paralegals enough time to prepare the responsive materials for
production in time for our 11/9 deadline, we need to finish the responsiveness review by no later than Thursday 11/5.
So the sooner we can get anything over the wall for us to review, the better.
Thanks very much,
From:
Sent: Thursday, October 29, 2020 11:11 AM
To:
Subject: RE: Help with Epstein Privilege Review
Just to be safe, please double check when you open up the reports that they correspond to the notes below, i.e., 1B72
should not have chats and 1B69 should not have chats and should only have 1074 emails. And as always please stop
your review and let me know if you come across anything else that you think may be privileged. Thanks!
1B72 - Release without chats
1B67 - Release entire report
1B68 - Release entire report
1B69 - Release without chats and without the 93 PP emails, as tagged on the attached .pas file (so only release 1074
emails)
From:
Sent: Thursday, October 29, 2020 11:08 AM
To:
Cc:
Subject: RE: Help with Epstein Privilege Review
EFTA00018092

=== Page 5 ===
You can stop by now if you'd like. I have the drive.
From:
Sent: Thursday, October 29, 2020 11:04 AM
To:
Subject: RE: Help with Epstein Privilege Review
Thank you!
please let me know when would be a good time for me to swing by.
From:
Sent: Thursday, October 29, 2020 11:03 AM
To:
Subject: Re: Help with Epstein Privilege Review
I'm not in the office today, but I left the reports copying overnight to a flash drive. See
and he can give
it to you.
Sent from my iPhone
On Oct 29, 2020, at 11:01 AM,
wrote:
Hi all,
I'm in the office today and available to pick up the released reports from these devices if they are ready.
Thanks,
From:
Sent: Wednesday, October 28, 2020 12:09 PM
To:
Subject: RE: Help with Epstein Privilege Review
Thank you all very much.
From:
Sent: Wednesday, October 28, 2020 11:36 AM
To:
Subject: RE: Help with Epstein Privilege Review
Ok
From:
Sent: Wednesday, October 28, 2020 11:36 AM
To:
Subject: RE: Help with Epstein Privilege Review
I have it on 8; I can bring it down to you shortly.
EFTA00018093

=== Page 6 ===
Thanks,
From:
Sent: Wednesday, October 28, 2020 11:32 AM
To:
Subject: RE: Help with Epstein Privilege Review
Yes I'm here. Where is the drive?
From:
Sent: Wednesday, October 28, 2020 11:30 AM
To:
Subject: RE: Help with Epstein Privilege Review
Hi
Are you either of you in the office today? And if so, do you have time to help on this? It shouldn't take a lot of time. I
need the following reports released to the pros team:
1B72 - Release without chats
1B67 - Release entire report
1B68 - Release entire report
1B69 - Release without chats and without the 93 PP emails, as tagged on the attached .pas file (so only release
1074 emails)
Thanks!
From:
Sent: Wednesday, October 28, 2020 9:31 AM
To:
Subject: RE: Help with Epstein Privilege Review
Yep!
From
Sent: Wednesday, October 28, 2020 9:30 AM
To:
Subject: RE: Help with Epstein Privilege Review
Awesome, thanks
Are you in the office today?
From:
Sent: Wednesday, October 28, 2020 9:07 AM
To:
Subject: RE: Help with Epstein Privilege Review
Yes, I still have a copy of this drive. Let me know what you need, and l'll be happy to assist.
Thanks,
From:
Sent: Tuesday, October 27, 2020 6:08 PM
To:
EFTA00018094

=== Page 7 ===
Subject: RE: Help with Epstein Privilege Review
Hi
Do you still have a copy of this drive in the office? If so, would you be able to coordinate with Lisa to help get
portions of those files ready for me to conduct a responsiveness review?
Thanks very much,
From:
Sent: Monday, August 24, 2020 11:26 AM
To:
Subject: RE: Help with Epstein Privilege Review
The drive is done being copied and is going out via FedEx to
oday. It should arrive tomorrow.
Please let me know if there is anything else I can do to be of assistance.
From:
Sent: Friday, August 21, 2020 3:44 PM
To:
Subject: RE: Help with Epstein Privilege Review
Got it, thanks.
From
Sent: Friday, August 21, 2020 3:02 PM
To:
Subject: RE: Help with Epstein Privilege Review
Just checked with IT again about the drive; they unfortunately ran into some issue when copying it and have to
restart the copy over the weekend. Hopefully, per IT's diagnosis and apology for the delay, it will be ready Monday or
Tuesday.
From:
Sent: Wednesday, August 19, 2020 5:18 PM
To:
Subject: RE: Help with Epstein Privilege Review
Thanks for staying on top of it-appreciate the update.
From
Sent: Wednesday, August 19, 2020 5:18 PM
To:
Subject: RE: Help with Epstein Privilege Review
Just FYI, the drive is still being copied- I was apparently overeager with my expectations for how long it would take. I
will let you know once it is ready and I've put it in the mail for
From:
Sent: Monday, August 17, 2020 3:30 PM
To:
EFTA00018095

=== Page 8 ===
Subject: RE: Help with Epstein Privilege Review
Thanks very much.
From:
Sent: Monday, August 17, 2020 3:28 PM
To:
Subject: RE: Help with Epstein Privilege Review
Update on this: I asked
to copy the drive this morning with the aim that it would be done in time to
mail this afternoon, but he's left for the day and did not leave me with an ETA for it being finished being copied. I'll
check back in with him in the morning and hope to have it sent to
tomorrow.
From:
Sent: Friday, August 14, 2020 8:20 PM
To:
Subject: Re: Help with Epstein Privilege Review
Perfect, thank you!
On Aug 14, 2020, at 8:16 PM,
wrote:
Hi Maurene and Lisa,
Thanks for the welcome and for your emails. I will get on this first thing Monday morning, as I had just left the
office when Maurene's email came in.
Hope you all have great weekends, and more soon.
Best,
Sunny
Sent from my iPhone
On Aug 14, 2020, at 6:55 PM, Korologos, Lisa (USANYS)
wrote:
Hi
Welcome and thanks in advance for your help!!
My address is:
55 Leamington Street
Lido Beach, NY 11561
Thanks so much,
From:
Sent: Friday, August 14, 2020 5:22 PM
To
Subject: Help with Epstein Privilege Review
Hi
First, welcome to the unit! I'm sorry we have not met yet, but I'm looking forward to meeting you when we are
both in the office one day.
EFTA00018096

=== Page 9 ===
I'm hoping you would be able to help us with some logistics for the privilege review of data extracted from
several of Jeffrey Epstein's devices.
S going to leave a drive on your desk today, which contains data from
several of Epstein's phones and ipads. Would you please copy of all of that data onto a second drive?
Once the data is copied, we then need you to please mail one of the drives to
(who is cc'd and will
reply to this email with her mailing address). Please keep the second drive in your files in the office
ill then
reach out to you if she needs any additional help coordinating the review of that data for privileged materials.
Please let me know if you have any questions, and thanks so much for your help.
NYS
>
StAndrews
>
Shared
>
USvEpstein-2018R01618
>
From Filter Team
Search F
Name
Date modified
Type
Size
1B83 NP Report 11_03_2020
11/3/2020 12:59 PM File folder
EFTA00018097


c1: EFTA00017939
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c3: VOL00008
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c0:
=== Page 1 ===
From: "Boyd, Stephen E. (OLA)"
To:
(USANYS)"
Cc: "
(USANYS)"
Subject: RE: MCC Indictment
Date: Tue, 19 Nov 2019 16:36:12 +0000
Thank you - much appreciated.
From:
(USANYS)
Sent: Tuesday, November 19, 2019 11:36 AM
To: Boyd, Stephen E. (OLA)
Cc: Strauss, Audrey (USANYS)
Subject: MCC Indictment
Stephen - Attached please find a copy of the Indictment obtained this morning charging two correctional officers at MCC
in connection with their failures to perform their duties on the night of the suicide of Jeffrey Epstein. The attached has
also now been filed with the court and is thus a public document. Please let us know if we can pass on anything else that
might be of use.
Thanks,
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00017939


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=== Page 1 ===
From:
)"
To: Christian Everdell
)"
(USANYS)"
Cc: 'Jeff Pagliuca'
>, Laura Menninger
"Bobbi Sternheim
(
(USANYS) [Contractor]"
>, "Thomas J. Powers"
Subject: RE: Discovery Issues
Date: Mon, 29 Mar 2021 22:37:35 +0000
Inline-Images: image001.jpg; image002.jpg
No problem. Our paralegal just sent the documents over. Please let us know if you have any difficulty accessing them.
Best,
From: Christian Everdell
>
Sent: Monday, March 29, 2021 6:22 PM
To:
)
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; ; Laura Menninger
>; ; Bobbi Sternheim
(
>;
(USANYS) [Contractor]
>;
Thomas J. Powers
Subject: RE: Discovery Issues
Thanks,
Please send the docs via the link below:
From:
) [mailto:
Sent: Monday, March 29, 2021 3:53 PM
To: Christian Everdell;
);
(USANYS)
Cc: 'Jeff Pagliuca'; Laura Menninger; Bobbi Sternheim
(
);
(USANYS) [Contractor]
Subject: RE: Discovery Issues
Chris,
Following up on point number 7, that gap would not come in between those two productions but would instead be
contained solely in the November 18, 2020 production. If you are missing those files, the omission was unintentional, and
we have those files available to produce immediately. If you can send a link to your ftp site, our paralegal can upload
those materials right away.
Best,
Assistant United States Attorney
EFTA00020426

=== Page 2 ===
Southern District of New York
From:
Sent: Monday, March 29, 2021 3:36 PM
To: Christian Everdell
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; Laura Menninger
>; Bobbi Sternheim
Subject: RE: Discovery Issues
Chris,
We are available for a call to discuss tomorrow between 1pm and 2pm, between 3pm and 5pm, or after 5:30pm. Please
let us know if there is a time in those windows that would work on your end. In the meantime, below are some initial
responses:
1. Our supervisors have indicated that we are not permitted to send a drive that our IT department did not load to
the MDC. As a result, we cannot provide the drive directly to the MDC. That said, I am happy to join you in asking
the MDC to accept the drive from you. If the MDC still refuses, then my office would not object to an application to
Judge Nathan for an order directing the MDC to accept the drive from you, though we would need to allow MDC
legal counsel the opportunity to note their objections to Judge Nathan.
2. The MDC recently alerted us to this issue, and our paralegal converted the excel files at issue to pdfs and sent a
new CD with those pdfs to the MDC. If you client still cannot view them, then we are happy to load them to a drive
if you would like to provide one for us.
3. I have asked our vendor to look into this issue and will get back to you when I have spoken with them.
4. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said,
similar to the note I sent in my email regarding highly confidential images on March 16, 2021, the electronic files
recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized
each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except for data
showing when a particular file was saved to a drive by the investigative team or prepared for production.
5. As indicated in our November 9, 2020 discovery letter, all images within Bates range SDNY_GM_00467566 though
SDNY_GM_00514100 were seized during the 2019 searches of Epstein residences. These are the images from the
CDs that were recovered during those searches, so they did not come from any of the electronic devices that were
the subject of extractions by CART. As a result, these images would not have CART numbers. As for the metadata, I
have asked our vendor to look into this issue and will get back to you when I have spoken with them.
6. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, I
note again that the electronic files recovered from Epstein's devices have the same metadata on the hard drive that
was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so
none is viewable. Additionally, as indicated in our November 9, 2020 discovery letter, all images within the
SDNY011 load file (Bates range SDNY_GM_00467566 though SDNY_GM_00514100) were seized during the 2019
searches of Epstein residences. These are the images from the CDs that were recovered during those searches, so
they did not come from any of the electronic devices that were the subject of extractions by CART. As a result,
these images would not have CART numbers.
EFTA00020427

=== Page 3 ===
7. I have asked our paralegals and vendor to look into the Bates gap and will get back to you when I have spoken to
them.
Best,
Assistant United States Attorney
Southern District of New York
From: Christian Everdell
Sent: Monday, March 29, 2021 2:40 PM
To:
>;
is
(USANYS)
Cc: 'Jeff Pagliuca'
; Laura Menninger
>; Bobbi Sternheim
Subject: Discovery Issues
and
-
We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a
call to discuss.
1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created
(without the highly confidential items). You had said you would check to see if you could facilitate this. We have
not heard back from you. Are you able to send Ms. Maxwell the hard drive?
2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and
must use the prison computer. But the prison computer cannot read some of the files. We can include these files
on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please
advise which way you would like to proceed.
3. A number of the emails in the discovery - over 109,000 - were produced without their attachments (see tab 1 of
the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the
missing attachments, if they exist.
4. A number of electronic documents - over 110,000 - that were extracted from one of Epstein's devices, as identified
by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or
afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with the original
metadata for these files.
5. A number of photographs - over 6500 - were produced in native format, but do not have a CART number and have
"date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please
provide the CART number for these photographs or specify which device they came from. Also, we request that
you produce a metadata overlay with the original metadata for these files.
EFTA00020428

=== Page 4 ===
6. A number of the audio/visual files - over 460 - have similar metadata issues (see tab 4 of the attached Excel file).
These fall into the following buckets:
a. SDNY_GM_SUPP: these have CART numbers, but were produced without metadata load files and have
"date created" and "date last modified" dates in September-November 2020, after the date the device was
seized. We request that you produce a metadata overlay with the original metadata for these files.
b. SDNY005 (October 20, 2020 production): these are a few videos from the SDFL or PBPD investigations that
were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that
you produce a metadata overlay with the original metadata for these files.
C. SDNY011 (November 9, 2020 production): these were produced in native form with load files, but do not
reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these
files or indicate their source. Also, we request that you produce a metadata overlay with the original
metadata for these files.
7. There is a gap between 11/18 and 12/18 production numbers (SDNY_GM_02742044 to 2742183). Was that
intentional or are we missing those documents?
Please let us know your responses as soon as possible.
Thanks,
Chris
Christian R Everdell
COHEN & GRESSER LLP
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
CG
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: MCC Discovery Response
Date: Fri, 21 Feb 2020 15:30:47 +0000
Attachments: 2020.02.xx to Defense Discovery Requests v2.docx; Michael Thomas -
Discovery_Request.pdf;_Response_to_1-24-20_letter_from_the_Government.pdf
Chiefs,
Our response (and their original requests) are attached for your review. Thanks.
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00019888


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From:
)"
To:
)"
)"
Subject: RE: draft protective order
Date: Thu, 09 Jul 2020 18:52:51 +0000
Attachments: 2020-07-03,_GM,_protective_order_for_discovery_(A.JN).docx
Paragraph three in what I sent is superfluous - it's removed in the attached, but if you're already reviewing, no problem,
just ignore that para.
From:
Sent: Thursday, July 09, 2020 14:47
To:
Subject: draft protective order
Team, apologies again for the delay on this (among other things - and you'll be entertained by this -
*!!), but draft is attached. It is as strong as I could think to make it, but very happy to take additional thoughts or
suggestions, and I anticipate we'll likely get some pushback but we can see what they say. Thoughts / comments / edits?
Thanks.
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=== Page 1 ===
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To:
Subject: Travel Authorization 10892303-1 has received final approval
Date: Mon, 23 Dec 2019 17:47:24 +0000
Importance: Normal
Dear
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Purpose: R20NYS13197 - U.S. V. Epstein - Witness Interview (California)
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=== Page 1 ===
From:
To:
Cc:
Subject: FW: FOR THE ATTENTION OF GEOFFREY BERMAN
Date: Mon, 15 Jun 2020 15:28:15 +0000
Inline-Images: image001.jpg
FYI, I am merely forwarding this email sent to me but directed to you. It isn't from a journalist, so far as I can tell, but
rather from an Epstein/Andrew/others conspiracy theorist. The gentleman is asking you to make a public statement
about Andrew and the investigation that addresses two points:
"The first would be to make an unequivocal statement to the press that the Prince IS now a target of your
investigation due to his obfuscation and blatant stonewalling."
this is the second thing I'd like to see you do, to ask your Attorney General why he has dismissed the idea of
extradition out of hand?"
From:
Sent: Monday, June 15, 2020 10:54 AM
To:
Subject: FOR THE ATTENTION OF GEOFFREY BERMAN
FOR THE ATTENTION OF GEOFFREY BERMAN
Dear
May I offer my congratulations on the way in which your office has been handling the Prince Andrew
Affair this past week?
My thinking is that it must have been rather interesting, even for a grown man, to learn just how low
and dirty and
tricky the British can sink when push comes to shove? They make Roger Stone, he who still has a
Richard Nixon
tattoo on his back, look like an amateur don't they?
Everyone it the UK has hugely welcomed the news that an MLA has been sought with the Home
Office, and most
seem to be confident that Priti Patel dare not interfere by denying your request. The consensus
seems to be that
she would instantly destroy not only her career but also her life by acting to prevent someone who is
obviously
a child-abuser and paedophile from facing justice when the entire English-speaking world has branded
him a liar
after the car-crash interview.
However I am not so certain. Looking at the tactics they have employed this past week, of
trying to blame you
for all of Prince Andrew's ills when you are in the middle of trying to conduct a professional
investigation into
EFTA00019112

=== Page 2 ===
something as serious as child sex slavery; my thinking is that they are willing to use every
dirty trick in the book
to keep the pervert Prince out of the FBI's clutches. The UK Tory Party has always been
an instrument designed
primarily to maintain the status quo in this country, with priority always given to
perpetuation of the monarchy.
It would not be beyond the Eton/Westminster old boys to find some way of using Priti Patel
without her even
being aware of it. ( she's not all that bright Mark my words, this is what I expect will
happen next; and I am
a man who told the world that Jeffrey Epstein would never make it to trial barely 48 hours
before his life was ended.
So there are two things I am now hopeful you might do. The first would be to make an
unequivocal statement to
the press that the Prince IS now a target of your investigation due to his obfuscation and
blatant stonewalling.
Many are they on your side of the pond who have said, quite rightly, that an innocent man
does not deflect or hide.
And it is for this reason that everyone in Britain now feels that Prince Andrew really should
be extradited. The reaction
to the latest headline from the Sun newspaper has made this abundantly clear. Everyone
is saying that if he were
a Plumber or a Bus Driver he would be in handcuffs on a flight bound for New York right
now. So don't you think it
is high time, and this is the second thing I'd like to see you do, to ask your Attorney General
why he has dismissed the idea of extradition out of hand? Is it not a slap in the face of
Democracy to accord Prince Andrew special privileges
simply because of his royal status?
What does General William Barr want the world to think? That perhaps there may be
people in high places in
America who are guilty along with Prince Andrew? And this after Donald Trump himself
was filmed next to their
close mutual friend Jeffrey Epstein yelling "oh yeah, she looks hot!".
Journalists all over the globe have been saying the whole world has been watching this
affair unfold as if they had
telescopic eyeballs. If the United States law system does not interrogate this wicked man
under oath very soon the
world will have to conclude that the American ruling class is controlled by Paedophiles in
exactly the same way as the
British ruling class. And that the kind of corruption we have seen in Hollywood which led to
the death of children like Heather O'Rourke is endemic throughout the higher echelons of
the entire Anglo/American establishment.
EFTA00019113

=== Page 3 ===
Is this what you want the world to think? Does your Attorney General want the world to
think that he must be
a child abuser as well?
You are now aware that the British Royal family are nothing but gangsters, every bit as
willing as were the Chicago
mob of the 1930's to silence anyone who becomes inconvenient. So please think about
this very carefully
Supposing during the course of your investigation you uncover the inconvenient truth that
both Donald Trump and
your Attorney General ARE involved with the international paedophile network? and that
your own country truly is
being run by gangsters?
What then?
kind regards
Virus-free. www.avg.com
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=== Page 1 ===
From:
To:
)"
)"
Cc:
)"
Subject: RE: Follow Up Call
Date: Mon, 19 Aug 2019 15:26:53 +0000
That works for us. You can call my office number, which is
Thanks,
From:
Sent: Monday, August 19. 2019 8:34 AM
To:
Cc:
Subject: RE: Follow Up Call
and I are both available today at 1:30 MT/ 3:30 ET if that still works for you. Just let us know what number to call.
Thanks
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York NV 10007
From
Sent: Saturday, August 17, 2019 3:49 PM
To:
Cc:
is
Subject: Re: Follow Up Call
Thanks for the response and good luck in your trial.
Let me know if any of the below proposed days and times work for you:
Monday - 1:30 MT/ 3:30 ET
EFTA00019664

=== Page 2 ===
Tuesday - 9:30 MT / 11:30 ET
Wednesday - 9:30 MT /11:30 ET or 1:30 MT / 3:30 ET
Best,
Holland
Sent from my iPhone
On Aug 17, 2019, at 12:46 PM,
wrote:
We certainly can be in touch. I'm copying my colleagues on the case
because I have a trial starting
August 26 so I'll be mostly unavailable next week, but it should be possible to find a time for one or both of them to
chat. If you send a couple possible times for next week we can figure it out.
thanks,
From:
Sent: Friday, August 16, 2019 14:01
To:
Subject: Follow Up Call
Would you have a couple of minutes to chat with me and one of my colleagues about some NM-related Epstein matters
this afternoon or early next week? If today works for you, I am available any time after 1:30 MT/ 3:30 ET today. It is
nothing urgent.
EFTA00019665


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=== Page 1 ===
From
USANYS) [Contractor]"
To:
(USANYS)"
)"
)"
Cc:
(USANYS) [Contractor]"
Subject: RE: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Date: Mon, 04 Oct 2021 15:45:28 +0000
Attachments: 2021.10.04 MDC - Maxwell_MAIN.docx; 2021.10.04_MDC_
_Maxwell_PASSWORD.docx
The production has been shared with them on USAfx and the disc is ready to get sent out to MDC. Can you please confirm
the attached cover letters are good to go?
From:
(USANYS)
Sent: Monday, October 4, 2021 11:33 AM
To: Christian Everdell
Mark S. Cohen
Bobbi Sternheim
; Laura Menninger
;
Jeff Pagliuca
Cc:
is
(USANYS) [Contractor]
>;
(USANYS) [Contractor]
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Counsel,
We have an additional discovery production ready to send to you today. Attached please find the accompanying cover
letter. The production will be made via USAfx.
We will send a CD with the new production to the MDC for Ms. Maxwell. If you would prefer that she receive the
production on a drive, we can either request that the MDC send us one of the drives back to load with the production, or
we can load a new drive if you would like to provide us with one.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
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=== Page 1 ===
From:
(USANYS)"
To: "Berman, Geoffrey (USANYS)"
Subject: https://www.washingtonexaminer.com/news/epstein-accuser-angry-about-financiers-death-and-
wants-his-accomplices-and-enablers-prosecuted
Date: Sat, 10 Aug 2019 16:12:48 +0000
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I Mobile:
(
I
Press Office:
EFTA00018968


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 10893150(1) prepared by a travel arranger is pending your review
Date: Wed, 18 Dec 2019 23:38:21 +0000
Importance: Normal
Dear
Final voucher 10893150(1) has been prepared by your travel arranger and is ready for your review. Please log
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=== Page 1 ===
From:
)"
To:
)"
Subject:
Date: Mon, 30 Dec 2019 02:05:33 +0000
https://atlantajevishtimes.timesofisrael.com/jeffrey-epstein-consulted-atlanta-attorney-days-before-death/
Sent from my iPhone
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=== Page 1 ===
From:
)"
To:
Subject: RE: FW: Ghislaine Maxwell (02879-509)
Date: Thu, 05 Nov 2020 17:31:15 +0000
Just tried you but got no answer. I'm at my desk when you have a minute
Thanks,
From:
Sent: Thursday, November 5, 2020 12:28 PM
To:
)
Subject: Re: FW: Ghislaine Maxwell (02879-509)
yes, I am at Brooklyn today. Available until 2:30.
>>>
)" <
> 11/5/2020 12:27 PM >>>
Hi Nicole,
Do you have time today or tomorrow for a call to discuss?
Thanks,
From: BOBBI C STERNHEIM <bcsternheim@mac.com>
Sent: Thursday, November 5, 2020 10:58 AM
To:
)
Cc: BRO/Exec Assistant~ <BRO/ExecAssistant^@bop.gov> Nicole McFarland
Subject: Ghislaine Maxwell (02879-509)
Good morning-
As a result of my email to you on Sunday and your intervention with the MDC, Ms. Maxwell is permitted use of
a mug for water and possession of commissary snacks in her isolation cell.
However, the information provided to you regarding moisture and temperature conflicts with our information. I
am told that moisture in her cell has degraded envelopes and paperwork and the temperature check was
conducted outside her cell.
I request that Ms. Maxwell be moved to an interior cell. This relocation would eliminate exposure to moisture
and cold air seeping through exterior concrete walls. Further, it would assist in safeguarding Ms. Maxwell from
impending cold temperatures and the detrimental effect of wind, rain and snow.
Your continued assistance is needed and greatly appreciated.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
EFTA00019115

=== Page 2 ===
Main: 212-243-1100
Cell: 917-912-9698
Fax:
888-587-4737
bcsternheim@mac.com
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
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=== Page 1 ===
From: "postmaster@usdoj.gov" <postmaster@usdoj.gov>
To:
Subject: Notice of Message Failure; Encryption Required
Date: Fri, 16 Aug 2019 17:13:46 +0000
In accordance with the Department Memorandum "Safeguarding Personally Identifiable Information", dated
April 16, 2015, the preceding message has been identified as containing possible sensitive Personally
Identifiable Information (PII) and cannot be delivered unless properly encrypted.
When electronically sending PII to external users outside of Department email systems, the communication
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To compose a secure message open Microsoft Outlook email application and compose the message as normal.
When ready to send - select the "Send Securely" button. Alternately, if you are using another email client (OWA,
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If you did not intend to send PII within the message, please check the message contents and resend the message
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Message Details:
From:
To:
Date : 2019-08-16 17:13:46 GMT
Subject: RE: Subpoenas Re
For any questions, please contact your local IT Helpdesk.
EFTA00019663


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: CBP Question
Date: Fri, 30 Jul 2021 01:46:46 +0000
Attachments:
bcrossing_exported.xlsx
Hey
As discussed, I reviewed all the travel records you sent. Unfortunately, the outbound travel records were not recorded in
CBP database during that time (between 1990-2000) as they are today. In short, the TECS travel records you have for
Maxwell and Epstein are all we have in CBP holdings so there's nothing further I can provide for that date range. However,
if you want travel records beyond 2000 I can certainly provide that just let me know if you have a specific date range you
looking for.
Since
as two different name variations (with and without the space in her surname) you were
provided two separate TECS travel records. After reviewing both records, they are accurate and include all her travel
crossings recorded in CBP holdings. Attached is an excel spreadsheet that includes her full travel crossings in chronological
order for you to cross reference with the TECS records provided. Hopefully it will make it easier to review her travel rather
than going back and forth between the two PDFs.
If you need any additional info (visa/passport applications, travel records, etc.) or have any questions please don't hesitate
to reach out!
Respectfully,
U.S. Customs and Border Protection
Task Force Officer - SDNY
US Attorney's Office
Southern District of New York
Mobile:
Desk:
Raymond.Sanicola@usdoj.gov
(LES/FOUO) LAW ENFORCEMENT SENSITIVE - FOR OFFICIAL USE ONLY
WARNING:
The information contained in this email is considered confidential and sensitive in nature as well as sensitive but
unclassified and/or legally privileged information. It is not to be released to the media, the general public, or to non-law
enforcement personnel who do not have a "need-to-know". This information is not to be posted on the Internet, or
disseminated through unsecured channels, and is intended for law enforcement personnel only. It is solely for the use of
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released to the public or media.
From:
Sent: Thursday, July 29, 2021 6:17 PM
To:
EFTA00018023

=== Page 2 ===
Cc:
Subject: RE: CBP Question
Thanks again for helping; we really appreciate it. Attached are the records. Please let us know if you have any questions.
Thanks,
From:
Sent: Thursday, July 29, 2021 5:31 PM
To:
Cc:
Subject: Re: CBP Question
Hey
Sorry I was on the road but I spoke with
he filled me in on what your looking for. I'm also available for a call to
further discuss.
Respectfully,
U.S. Customs and Border Protection
Task Force Officer - SDNY
US Attorney's Office
Southern District of New York
(LES/FOUO) LAW ENFORCEMENT SENSITIVE - FOR OFFICIAL USE ONLY
WARNING:
The information contained in this email is considered confidential and sensitive in nature as well as sensitive but
unclassified and/or legally privileged information. It is not to be released to the media, the general public, or to non-law
enforcement personnel who do not have a "need-to-know". This information is not to be posted on the Internet, or
disseminated through unsecured channels, and is intended for law enforcement personnel only. It is solely for the use of
the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable
laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender
and destroy all copies of the communication.
DISSEMINATION INSTRUCTIONS: This document is marked Law Enforcement Sensitive/For Official Use Only and may be
disseminated, with proper attribution, to Law Enforcement, DOD, or U.S. Intelligence Agencies. Further disclosure to
unauthorized entities could jeopardize ongoing investigations, operations, and personal safety. This product shall not be
released to the public or media.
From:
Sent: Thursday, July 29, 2021 3:56:15 PM
To:
EFTA00018024

=== Page 3 ===
Cc:
Subject: CBP Question
CAUTION: This email originated from outside of DHS. DO NOT click links or open attachments unless you recognize and/or trust the
sender. If you feel this is a suspicious-looking email, please report by using the Report Phish button option.
Hi
I hope you are well!
passed along your info to us. We were hoping to connect with you by phone about a
question in one of our cases. Do you have time to talk today or tomorrow morning?
Thanks so much!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
EFTA00018025


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=== Page 1 ===
From:
To:
Cc
Bcc: "USAHUB-USAJournal111"
Subject: Re: Sixth Production
Date: Mon, 09 Nov 2020 22:37:59 +0000
Embedded: Re:_Sixth_Production.msg
Sender:
Subject: Re: Sixth Production
Message-Id: <7294EFAA-BCB3-4552-A39D-9855C0078379@usa.doj.gov>
To:
Cc:
Cc:
Cc:
Cc:
EFTA00019202


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=== Page 1 ===
From:
Cc:
Subject: "Epstein Murder Evidence"
Date: Mon, 19 Oct 2020 16:37:35 +0000
sent me a CD he received, which is called "Epstein Murder Evidence." I saved the contents here:
\\usa.doj.gov\cloud\nys\StAndrews\Shared\InReEpsteinDeath-2019R01059\CD sent by mail
It appears to us to be materials from a crazy person and, as such, does not need to be produced. That said, there's likely
no harm in producing it to the defense. We are inclined to not produce it, but we wanted to run it by you first. Thoughts?
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00017942


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=== Page 1 ===
From:
To:
Cc: Brad Edwards
Subject: RE: Epstein Client Meetings
Date: Fri, 11 Oct 2019 20:23:25 +0000
Inline-Images: image001.png
Thanks Brittany. Yes, we will be meeting at our office at 1 St. Andrews Plaza, NY, NY.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Friday, October 11, 2019 3:15 PM
To:
is
is
Cc: Brad Edwards
is
>;
Subject: RE: Epstein Client Meetings
That schedule works for us. I will let the clients know. Will we be meeting in your office?
Thanks,
EDWARDS
POTTINGER LLC
Brittany N. Henderson
Trial Attorney
I
www.epllc.com
EFTA00019747

=== Page 2 ===
From:
)
Sent: Thursday, October 10, 2019 3:36 PM
To:
is
>;
Cc: Brad Edwards
is
>;
Subject: RE: Epstein Client Meetings
Hi Brittany,
Thanks very much for reaching out. I would propose the following dates and times for interviews:
10/23 at 1 pm -
10/23 at 3 pm -
10/24 at 10 am -
10/24 at 12 pm -
Would those work on your end?
Thanks again,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Thursday, October 10, 2019 2:08 PM
To:
is
>;
Cc: Brad Edwards
Subject: Epstein Client Meetings
&
We have been coordinating with
to schedule the following victim interviews for October 23 & 24:
If possible, the morning on October 24 works best for
would prefer the 23 to minimize her travel into
the City.
and
are available either day.
Let us know what works best for you.
EFTA00019748

=== Page 3 ===
ГД
EDWARDS
LI
POTTINGER LLC
Brittany Henderson
Trial Attorney
www.epllc.com
EFTA00019749


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
Subject: RE: OPR Matter
Date: Thu, 06 Aug 2020 21:23:55 +0000
I would like to.
would not allow me to share it with the team unless and until you blessed me doing so. I see no
reason why they should not be allowed to review it, and, to the contrary, view them as best positioned to review it.
Assuming you're okay with that, I will send it to them now and ask for their comments.
Thanks,
From:
(USANYS)
Sent: Thursday, August 6, 2020 5:20 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: FW: OPR Matter
Are you asking Maxwell team to review and comment?
From:
(OPR) <Laura.Ingersoll@opr.usdoj.gov>
Sent: Thursday, August 6, 2020 2:49 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: OPR Matter
Acting United States Attorney
for the Southern District of New York
New York, New York
Dear
Please find attached a letter from OPR Director
regarding OPR's draft report regarding the handling of the
Jeffrey Epstein matter by the U.S. Attorney's Office for the Southern District of Florida in 2006-2008. A copy of the draft
report, for your review, is also attached.
With regards,
Counsel
Office of Professional Responsibility
U.S. Department of Justice
950 Pennsylvania Avenue, N.W. - Room 3266
Washington, D.C. 20530
EFTA00018566

=== Page 2 ===
CC:
AUSA
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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein Assistance Request
Date: Mon, 19 Aug 2019 19:59:00 +0000
Can anyone advise as to the full names and possibly dates of birth for the following BOP employees?:
?
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
EFTA00019326


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=== Page 1 ===
From:
To:
Subject: RE: status memo draft
Date: Wed, 06 Mar 2019 15:17:11 +0000
Importance: Normal
Attachments: 2019-03-06_JE_status_memo_to_ODAG.docx
Redline attached- let me know if you want to discuss. Thanks!
From:
Sent: Tuesday, March 5, 2019 9:22 PM
To:
Subject: status memo draft
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!
EFTA00019481


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=== Page 1 ===
Subject: Proposed redactions to voir dire
Date: Sat, 20 Nov 2021 00:13:23 +0000
Counsel,
Attached are our proposed redactions to the voir dire transcripts.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00019450


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=== Page 1 ===
From:
To: Brian Burns
)"
>, Patrick Smith
Cc:
Subject: RE: [EXTERNAL EMAIL] Rule 17(c) subpoena
Date: Wed, 17 Nov 2021 01:38:17 +0000
Attachments: 2021.11.14_Proposed_Subpoena.pdf
Hey Brian,
Here's an unsigned version of the subpoena. We understand from the defense that they are going to serve you later
tonight, but if you don't get it by tomorrow morning, let us know and we'll raise it with the Court.
Thanks,
From: Brian Burns
Sent: Tuesday, November 16, 2021 7:14 PM
To:
is
>; ; Patrick
Smith
is
Cc:
Subject: [EXTERNAL] RE: [EXTERNAL EMAIL] Rule 17(c) subpoena
Thanks
If you have a minute to talk by phone, please let me know.
Brian T. Burns
Smith Villazor LLP
From:
Sent: Tuesday, November 16, 2021 7:09 PM
To: Brian Burns
is
)
>; Patrick
Smith
is
)
Cc:
Subject: RE: [EXTERNAL EMAIL] Rule 17(c) subpoena
Brian,
We don't have specific information about when you'll get the subpoena, but we and the defense were in Court today for
voir dire, so that may have delayed things on their end.
Thanks,
From: Brian Burns
Sent: Tuesday, November 16, 2021 7:02 PM
To:
>; ; Patrick Smith
is
EFTA00018210

=== Page 2 ===
Cc:
is
Subject: [EXTERNAL] RE: [EXTERNAL EMAIL] Rule 17(c) subpoena
Checking in again to see whether you have any additional info about the status of the subpoena. Thanks.
Brian T. Burns
Smith Villazor LLP
From: Brian Burns
Sent: Tuesday, November 16, 2021 11:34 AM
To:
)'
>; Patrick Smith
is
)'
Cc:
is
)'
Subject: RE: [EXTERNAL EMAIL] Rule 17(c) subpoena
- We haven't yet been sent or served a copy of the subpoena. Checking to see if you have any
additional knowledge as to whether the Court authorized it yet. Thanks.
Brian T. Burns
Smith Villazor LLP
From: Brian Burns
Sent: Monday, November 15, 2021 1:26 PM
To:
>; ; Patrick Smith
>;
Cc:
is
Subject: RE: [EXTERNAL EMAIL] Rule 17(c) subpoena
Confirmed for 2:30. Thank you.
Brian T. Burns
Smith Villazor LLP
From:
)
Sent: Monday, November 15, 2021 1:22 PM
To: Patrick Smith
is
)
Cc:
is
>; Brian Burns
Subject: RE: [EXTERNAL EMAIL] Rule 17(c) subpoena
2:30 works for our team, thanks very much. We can use the below dial-in:
EFTA00018211

=== Page 3 ===
Dial-in:
Code:
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From: Patrick Smith
Sent: Monday, November 15, 2021 12:35 PM
To:
Cc:
is
)
;
>; Brian Burns
Subject: [EXTERNAL] Re: [EXTERNAL EMAIL] Rule 17(c) subpoena
Yes. How is 230 pm?
Patrick J. Smith
Smith Villazor LLP
New York, New York 10019
From:
)"
Sent: Monday, November 15, 2021 12:27
To: Patrick Smith
Cc:
);
);
Subject: RE: [EXTERNAL EMAIL] Rule 17(c) subpoena
Hi Pat,
Are you available for a call this afternoon?
Thanks,
EFTA00018212

=== Page 4 ===
From: Jordy Feldman
Sent: Monday, November 15, 2021 11:39 AM
To:
Cc:
is
>; Patrick Smith
Subject: [EXTERNAL] RE: Rule 17(c) subpoena
Thanks for reaching out. Pat Smith of Smith Villazor, LLP serves as our outside counsel for these matters. I have added
him to the email chain so you can contact him directly.
Regards,
Jordy
CONFIDENTIALITY NOTICE - This message and all attachments are a private communication, and may contain information that is confidential
and/or protected by privilege. If you are 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, disclosure, copying, or any use of the information contained in or attached to this message is
strictly prohibited. If you have received this message in error please notify the sender immediately and delete any and all copies of this message,
including any attachments from your computer. The receipt in error of this message and any attachment is not a waiver of the confidentiality and/or
privilege attached to this communication.
From:
Sent: Monday, November 15, 2021 11:02 AM
To: Jordy Feldman
Cc:
is
>;
Subject: Rule 17(c) subpoena
Jordy,
We're reaching out about a Rule 17(c) subpoena that defense counsel intends to serve in United States V. Maxwell, 20 Cr.
330 (AJN). We understand you may be represented by counsel in connection with issues like this. Could you please put us
in touch with your attorney?
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint
Plaza
New York, NY 10007
EFTA00018213


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: Read: Call with PAE re Epstein
Date: Thu, 25 Mar 2021 19:43:21 +0000
EFTA00019031


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=== Page 1 ===
From:
To:
(USANYS)"
Cc:
)"
(NY) (FBI)"
Subject: Re: Epstein
Date: Mon, 10 Dec 2018 18:54:43 +0000
Attachments: E-Justice_SOMU_profile.pdf
See attached SOMU records.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
From:
(USANYS)
Sent: Monday, December 10, 2018 12:47:40 PM
To:
Cc:
);
(NY) (FBI);
Subject: Re: Epstein
Can we chat after 2? Otherwise go ahead without me and
will catch me up.
you are going to have to change your
name!
Sent from my iPhone
On Dec 10, 2018, at 12:46 PM,
<mailto:
,
wrote:
We are available now if you would like to call but I am on the road so you will have to conference us in separately.
On Dec 10, 2018, at 12:12,
)
<mailto:
wrote:
and
Any chance you're free for a brief call this afternoon? We wanted to touch base about a few items. I'm sure you're both
very busy in preparation for Wednesday, so we promise to keep it short.
Thanks,
Assistant United States Attorney
Southern District of New York
<mailto:
EFTA00019508


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=== Page 1 ===
Event: Epstein/Maxwell FOIA
Start Date: 2021-03-10 22:00:00 +0000
End Date: 2021-03-10 22:30:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Date Created: 2021-03-10 22:45:42 +0000
Date Modified: 2021-03-10 22:45:42 +0000
Priority: 5
DTSTAMP: 2021-03-10 20:13:35 +0000
Attendee:
Alarm: Display the following message 15m before start
I
Reminder
-- Do not delete or change any of the following text. --
When it's time, join your Webex meeting here.
Join meeting
More ways to join:
Join from the meeting link
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EFTA00018729

=== Page 2 ===
Join by meeting number
Meeting number (access code): 199 962 1511
Meeting password: PMxMsPua532
Tap to join from a mobile device (attendees only)
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EFTA00018730


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=== Page 1 ===
From:
"
To:
Subject: Fw: PRIVATE & CONFIDENTIAL
Date: Fri, 11 Jun 2010 15:16:05 +0000
Importance: Normal
From:
To:
Sent: Mon Jun 07 11:09:02 2010
Subject: FW: PRIVATE & CONFIDENTIAL
Yours???
Special Agent
Federal Bureau of Investigation
450 Golden Gate Ave., 13th floor
San Francisco, CA 94102
From:
Sent: Friday, June 04, 2010 10:18 AM
To:
E.
Subject: PRIVATE & CONFIDENTIAL
Hello Agent
,
IMPORTANT. I am writing a book and producing a documentary on a significant child trafficking case and understand you
have been assigned to this particular case.
Jeffrey Epstein will most likely leave the country (right after he completes house arrest on 7/21/10), for good. He does not
have to remain in the US since he does not NEED TO EVER work, or represent clients. He knows he CANNOT and has no
interest in soliciting new clients. He has made enough money ($2 billion assets according to last income tax return), to
personally manage his wealth and thereby save the 2% fee usually paid to an investment banker who manages large
portfolios.
Epstein will be free in 2 months and continue to damage vulnerable and underage girls in other countries.
He doesn't ever NEED to work.
Question: Why hasn't the FBI not contacted attorney Robert Josefsberg in Miami in order to speak with victim
in Australia? THIS IS STEP 1 if the FBI is truly interested in arresting him on child sex trafficking charges.
is Jane Doe 102 in case # 09-80656. She was trafficked and prostituted and now lives with her husband and
baby in Australia. He settled last year with her for pennies (in comparison to what he's worth), and she now has a gag order.
is key witness since she was on his plane many times being paid to perform sexual activities with heads of state,
leading businessmen, royalty, politicians and celebrities.
Thank you for your prompt attention to this matter and if you have any questions you may reach me via email or telephone
EFTA00019169

=== Page 2 ===
Sincerely,
The message and any attachment may be confidential or privileged and is
intended only for the individual or entity identified above as the
addressee. If you are not the addressee, or if this message has been
addressed to you in error, you are not authorized to read, copy or
distribute this message or any attachments and we ask that you please delete
this message and any attachments and notify the sender by return email.
Delivery of this message and any attachments to any person (s) is not
intended in any way to waive confidentially or a privilege.
EFTA00019170


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=== Page 1 ===
From:
To:
Subject: Re: United States V. Ghislaine Maxwell
Date: Sun, 28 Nov 2021 15:09:02 +0000
Great email!
Sent from my iPhone
On Nov 28, 2021, at 9:59 AM,
wrote:
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:
To:
Cc:
Subject: Expert Testimony
Date: Thu, 29 Oct 2020 19:47:55 +0000
Dr. Hughes,
Together with colleagues
I'm one of the federal prosecutors handling the case of
United States V. Ghislaine Maxwell, which is scheduled to go to trial on July 12, 2021 in the Southern District of New York.
We would be interested in speaking with you about your availability to testify as an expert witness at trial. Are you
available for a call tomorrow or next week to discuss?
Thanks very much,
EFTA00018259


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From:
To:
Subject: RE: Language to include
Date: Thu, 02 Jul 2020 13:55:59 +0000
Great, thanks.
From:
>
Sent: Thursday, July 2, 2020 9:55 AM
To:
is
Subject: RE: Language to include
is cross-referencing the FBI list against hers right now and will call me when she's done with any issues
From:
)
Sent: Wednesday, July 01, 2020 22:27
To:
is
Subject: FW: Language to include
could you please take on this project of making sure the victim info in the database is accurate for the letter that will
go out? I can't tell if this email is just meant to supplement the data we already have, or if they're sending this as the
proposed list (which would be strange, since it has our statutory victims on it). Thanks.
From:
>
Sent: Wednesday, July 1, 2020 9:37 PM
To:
is
is
>;
Cc:
Subject: Re: Language to include
Good Evening,
SA
has identified each of these names on the attached spreadsheet as victims in the original case
against Jeffrey Epstein. Included in the attached document is victim contact information as well as attorney
information regarding representation and contact information. This is a comprehensive list.
Lastly, would you be able to send your draft language for the VNS notifications?
Thank you,
Program Manager
FBI Victim Services Division
EFTA00020362

=== Page 2 ===
From:
Sent: Monday, June 29, 2020 9:05 AM
To:
Cc:
Subject: Language to include
Good Morning,
I hope each of you had a good weekend. Please find language below that has been approved by FBI NY, VSD
executive management and our OGC rep. I'm more than happy to have a call if you would like to discuss.
The FBI's Victim Services Division (VSD) is committed to providing services and support to victims of crimes
committed by Jeffrey Epstein. Though this particular indictment is focused on specific individuals, you are still
entitled to your rights, resources, and referrals as a federal victim independent of this indictment. An overview
of these services is available at www.fbi.gov/resources/victim-services If you would like to speak with a Victim
Specialist, or if you have any questions regarding your rights to victim services and referrals, please email
victimservices@fbi.gov.
Thank you,
Program Manager
FBI Victim Services Division
EFTA00020363


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From:
To:
Subject: Perjury draft v9 (to redact) (002).docx
Date: Fri, 26 Feb 2021 00:26:58 +0000
Attachments: Perjury_draft_v9_(to_redact)_002).docx
EFTA00018288


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=== Page 1 ===
From:
To:
Subject: FW: Necheles Submission
Date: Wed, 22 Jul 2020 15:57:34 +0000
Attachments:
plea_submission,_with_attachments.pdf
Please print
From:
Sent: Monday, July 20, 2020 12:09 PM
To:
Subject: Necheles Submission
Attached
Counsel to the Acting U.S. Attorney
United States Attorney's Office
Southern District of New York
EFTA00019237


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=== Page 1 ===
From: "Biase, Nicholas (USANYS)"
To:
)"
Cc:
)"
(USANYS)"
,
"Margolin, James (USANYS) [Contractor]"
Subject: Re: Ghislaine Maxwell update
Date: Tue, 20 Jul 2021 20:42:59 +0000
Appreciate it, thanks.
Sent from my iPhone
On Jul 20, 2021, at 4:38 PM,
)
wrote:
No comment on #6, thanks very much.
From: Biase, Nicholas (USANYS)
Sent: Tuesday, July 20, 2021 3:24 PM
To:
is
V.
(USANYS)
Cc: Margolin, James (USANYS) [Contractor]
Subject: Fwd: Ghislaine Maxwell update
I know all of the answers except #6. Defer to you on how to handle that one, unless you think that's a better question
for
Thanks.
Sent from my iPhone
Begin forwarded message:
From: "Gadher, Dipesh"
Date: July 20, 2021 at 3:17:20 PM EDT
To: "Biase, Nicholas (USANYS)"
Subject: Ghislaine Maxwell update
Dear Nick
I hope this email finds you well. Since we last spoke,
I wanted to check a few things with you if I may on the Ghislaine Maxwell case:
1) Is it correct to say that there will now be TWO trials - the first on the child sex trafficking charges (covering the
period 1994-2004) and the second on the 2016 perjury charges?
2) Is the main trial still scheduled to start in November?
3) Is there any date set aside for the perjury trial?
4) What does this mean for the maximum sentence that Maxwell can now receive? I think we previously talked settled
on up to 80 years behind bars.
5) Is the investigation into Maxwell and Epstein's network still ongoing?
EFTA00019656

=== Page 2 ===
6) If so, does Prince Andrew remain a person of interest? Have US prosecutors managed to get a statement from him
yet or are there any arrangements in the pipeline to do so?
I'd be grateful if you could drop me line with some responses within the next 48 hours if at possible please. Many
thanks
All the best
Dipesh
The Sunday Times
1 London Bridge Street
London SE1 9GF
Tel:
Mob:
"Please consider the environment before printing this e-mail"
This e-mail and any attachments are confidential, may be
legally privileged and are the property of News Corp UK & Ireland
Limited on whose systems they were generated. News Corp UK
& Ireland Limited is the holding company for the News UK group,
is registered in England & Wales under number 81701, has its
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is registered with VAT number GB 243 8054 69. If you have received
this e-mail in error, please notify the sender immediately and do not
use, distribute, store or copy it in any way. Statements or opinions in
this e-mail or any attachment are those of the author and are not
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or any member of its group. News Corp UK & Ireland Limited may
monitor outgoing or incoming emails as permitted by law. It accepts
no liability for viruses introduced by this e-mail or attachments.
News Corp UK & Ireland Limited and its titles are committed to abiding by
IPSO's regulations and the Editors' Code of Practice that IPSO enforces.
EFTA00019657


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 92 Filed 12/08/20 Page 1 of 2
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 12/8/20
SOUTHERN DISTRICT OF NEW YORK
United States of America,
-V-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
On December 4, 2020, the Court received a letter from MDC legal counsel responding to
the concerns that the Defendant raised in her November 24, 2020 letter. See Dkt. Nos. 75, 88;
see also Dkt. No. 78. The Defendant responded to the MDC legal counsel's letter on December
7, 2020, reiterating her request that the Court summon Warden Heriberto Tellez to personally
respond to questions from the Court regarding the Defendant's conditions of confinement. See
Dkt. No. 91. Having carefully reviewed the parties' submissions, along with the MDC legal
counsel's December 4, 2020 letter, the Court DENIES the Defendant's request to summon the
Warden to personally appear and respond to questions. This resolves Dkt. No. 75.
Notwithstanding this, as originally provided in Dkt. No. 49, the Government shall
continue to submit written status updates detailing any material changes to the conditions of Ms.
Maxwell's confinement, with particular emphasis on her access to legal materials, including
legal mail and email, and her ability to communicate with defense counsel. The updates shall
also include information on the frequency of searches of the Defendant.
The Court hereby ORDERS the Government to submit these written updates every 60
days. Furthermore, the Government shall take all necessary steps to ensure that the Defendant
1
EFTA00018016

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 92 Filed 12/08/20 Page 2 of 2
continues to receive adequate access to her legal materials and her ability to communicate with
defense counsel.
so ORDERED.
Alim D.Netto
Dated: December 8, 2020
New York, New York
ALISON J. NATHAN
United States District Judge
2
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=== Page 1 ===
From:
To:
Subject: RE: United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Date: Thu, 31 Oct 2019 16:10:26 +0000
You know sometimes it's hard to decide whether to read entirely through a lunatic email but in this case the signature
block was quite the twist
From
Sent: Thursday, October 31, 2019 11:04
To:
Cc:
Subject: FW: United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
From: Kelley Lynch
Sent: Thursday, October 31, 2019 2:34 AM
To:
Subject: Re: United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Correction:
For the record, I think Epstein's a criminal but he's DEAD so there's nothing LEFT to be said about his alleged
crimes.
On Wed, Oct 30, 2019 at 11:31 PM Kelley Lynch
wrote:
I didn't notice any email address for taxpayer inquiries so as yours is listed, I am contacting you.
I, of course, heard Dr. Baden's conclusions today. I have the utmost respect for Dr. Baden. Will your office
address why the medical examiner is refusing to take a second look at this case and refuses to hand over DNA
that is clearly material and critical? With the death of Epstein, the case itself no longer interests me and I have
problems with the women involved - being a mother. However, I am interested in the horrendous conditions at
MCC, a probable murder of a man your office refused to grant bail, and how you intend to handle the murder
investigation.
For the record, I think Epstein's a criminal but he's death so there's nothing let to be said about his alleged
crimes.
Thank you.
Kelley Lynch
EFTA00019687

=== Page 2 ===
Q: What's brown and looks really good on a lawyer?
A: A Doberman.
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From: BOBBI C STERNHEIM
To:
Cc:
Christian Everdell
Subject: Ghislaine Maxwell 02879-509
Date: Thu, 17 Jun 2021 18:20:49 +0000
Good afternoon-
Earlier this week, around 1:00 am
guards purposely awoke Ms. Maxwell because they observed her body shaking
and were concerned that she was having a seizure.
They determined she was shivering from the extremely cold temperature in her cell.
At approximately 3:00 am the following day, the guards again disrupted Ms. Maxwell's sleep
because her body was shaking. Again, they determined that she was
shivering and gave her a blanket.
The guards have now removed two of her blankets, claiming the blankets
are not authorized. Today, Ms. Maxwell awoke cold and headachy
with a sore throat. When medical staff came by she was too exhausted
to address her physical discomfort.
Please explain why guards purposely disrupt Ms. Maxwell's
sleep, determine she is shivering, and then remove blankets-
her only source of warmth. This makes no sense, is detrimental
her health, and is utterly insensitive.
In addition, VTC viewing is less blurry on counsel's end but the image repeatedlybecomes broken
and then completely blacks out.
This is disrupting attorney-client communication, the ability to prepare for trial, and is negatively impacting
counsel's vision and concentration.
Please address and remedy this problems immediately.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Main:
Cell:
Fax:
**Covid-19 Notice: The
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
EFTA00019933

=== Page 2 ===
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
On Jun 16, 2021, at 1:46 PM, BOBBI C STERNHEIM
wrote:
Good afternoon-
Despite being subjected to the most unique, restrictive, and invasive conditions
of pretrial confinement, Ms. Maxwell has and continues to be a compliant detainee.
She obeys all orders and commands - often muffled by masks,
uttered behind prison doors, and/or combined with the din of background noise -
as soon as they are audibly discernible.
Erratic enforcement of inconsistent rules and regulations imposed by
revolving teams of guards who exert varying degrees of officiousness
and contempt toward Ms. Maxwell is the fault of the MDC/BOP,
not Ms. Maxwell.
Regards,
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Main:
Cell:
Fax:
*Covid-19 Notice: The
office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
On Jun 16, 2021, at 11:25 AM,
wrote:
Hi Bobbi-
I apologize for the delay in response. I have been out of office sick.
We are looking into the concerns you have brought to our attention
EFTA00019934

=== Page 3 ===
regarding the VTC units. All of the VTC units throughout the
institution are now being stored in this manner as it is a protective
barrier for the equipment. With that said, we will be doing test runs
to investigate concerns you have mentioned.
Furthermore, Ms. Maxwell must oblige by the orders of the Officers. We
offer Ms. Maxwell medical care on a daily basis, which she has
declined.
Additionally, can you please provide me with a photo of the ear buds
you are requesting to bring into the institution?
Best,
BOBBI C STERNHEIM
6/16/2021 10:23 AM
Good morning-
As reported yesterday, the modifications made in the VTC room
are negatively impacting attorney-client communication.
The video is blurry; the audio includes distorting noises.
I am requesting that these problems be remedied immediately.
Also, I am bringing to your attention the inappropriate behavior of the
guards presently on Ms. Maxwell's detail: threatening discipline if
Ms. Maxwell is "off camera" while leaning against a wall to soothe her
aching
back; barking orders regarding the noise emanating from the washing
machine
and the pace of her gait when walking; laughing amongst themselves as
if any of this is funny.
The manner in which some of the guards responded to me on Sunday gives
me reason to be concerned
about how they treat Ms. Maxwell when out of public view.
The courtesy of a response is requested.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Main:
Cell:
Fax:
**Covid-19 Notice: The
office is currently closed
but we continue to work remotely.
EFTA00019935

=== Page 4 ===
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.
EFTA00019936


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=== Page 1 ===
From:
To:
Subject: RE: can you make sure the Maxwell case is a victim case 20 Cr 330
Date: Tue, 07 Jul 2020 15:06:53 +0000
Thanks
From:
Sent: Tuesday, July 07, 2020 10:53 AM
To:
Subject: RE: can you make sure the Maxwell case is a victim case 20 Cr 330
No problem - it's under the Epstein investigation USAO, which is 2018R01618
And all good with me so far, thanks, and hope the same for you!
From:
Sent: Tuesday, July 07, 2020 10:51
To:
Subject: FW: can you make sure the Maxwell case is a victim case 20 Cr 330
Hello
Hope all is well.
Do you have USAO# for this case?
Thanks,
From:
Sent: Monday, July 06, 2020 11:19 AM
To:
Subject: can you make sure the Maxwell case is a victim case 20 Cr 330
Victim Witness Coordinator
United States Attorney's Office
Southern District of New York
1 St. Andrews Plaza
New York, New York 10007
Tel.
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From:
)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
i
)"
Subject: FW: Follow Up Call
Date: Thu, 05 Sep 2019 19:20:24 +0000
From
Sent: Thursday, September 5, 2019 2:11 PM
To
Cc:
)
is
Subject: RE: Follow Up Call
FYI: state authorities in New Mexico are moving forward with their own plans with respect to the Epstein property.
Yesterday the state land commissioner revoked leases held by Cypress Inc.
https://www.abgjournal.com/1362185/land-commissioner-voids-epsteins-nm-grazing-leases.html
The linked news coverage quotes the New Mexico Attorney General as saying that he is conducting a criminal
investigation at the state level "in coordination with" the SDNY. Here are a few sentences from late in the article:
The [State] Attorney General's Office is investigating whether crimes took place on Zorro Ranch. [State Land
Commissioner Stephanie] Garcia Richard said Wednesday her office had notified [State] Attorney General
Hector Balderas to provide notice if any criminal activity was found to have occurred on the trust land leased by
EFTA00018553

=== Page 2 ===
Epstein "because we were looking for a reason to cancel these leases and criminal activity would have given us
the perfect reason."
Balderas did issue a statement saying he was pleased Garcia Richard was "taking back lands that should be
managed to best serve the State and for the benefit of New Mexico school children." Public schools are one
beneficiary of state trust land revenue. Balderas added: "We continue to investigate this matter at the state level
in coordination with U.S. Attorney's Office for the Southern District of New York."
Fraud and Public Corruption Section
U.S. Attorney's Office - District of New Mexico
From:
Sent: Wednesday, September 4, 2019 4:12 PM
To:
Cc:
Subject: RE: Follow Up Call
Thank you for the speedy response. Next week works for us. Can you all do the call next Thursday, September 12th at
1:30 MT / 3:30 ET?
From:
Sent: Wednesday, September 04, 2019 3:41 PM
To:
Cc:
;
Subject: RE: Follow Up Call
Hope you're doing well. This week is a bit tough for us. Are there dates next week that would work for you? We are
traveling Monday through Wednesday, but could talk Thursday or Friday.
Thanks,
EFTA00018554

=== Page 3 ===
From:
Sent: Wednesday, September 4, 2019 4:28 PM
To:
Cc:
>;
is
Subject: RE: Follow Up Call
and I were hoping to schedule a follow up call with you concerning Epstein's New Mexico conduct and property
sometime this week. We are both available tomorrow morning (9-12 MT / 11-2 ET) or Friday any time after 12pm MT /
2pm ET. Do you all have availability for a follow up call on either of these days?
Thanks,
From:
Sent: Saturday, August 17, 2019 12:46 PM
To:
Cc:
is
Subject: RE: Follow Up Call
We certainly can be in touch. I'm copying my colleagues on the case,
because I have a trial starting
August 26 so l'll be mostly unavailable next week, but it should be possible to find a time for one or both of them to chat.
If you send a couple possible times for next week we can figure it out.
thanks
From:
Sent: Friday, August 16, 2019 14:01
To:
Subject: Follow Up Call
Would you have a couple of minutes to chat with me and one of my colleagues about some NM-related Epstein matters
this afternoon or early next week? If today works for you, I am available any time after 1:30 MT/ 3:30 ET today. It is
nothing urgent.
Thanks,
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=== Page 1 ===
From:
Cc:
Bec: "USAHUB-USAJournal111"
Subject: RE: Virgin Islands action
Date: Mon, 21 Dec 2020 20:03:47 +0000
Embedded: RE:_Virgin_Islands_action.msg
Sender:
Subject: RE: Virgin Islands action
Message-Id:
<BN3P110MB0386AD28F5D7929054B880AB89C00@BN3P110MB0386.NAMP110.PROD.OUTLOOK.CO
M>
To:
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=== Page 1 ===
From:
To:
Cc:
Subject: Hammad Memo - Epstein Death Investigation
Date: Wed, 14 Aug 2019 22:49:41 +0000
Hammad Memos under NY Rule of Professional Conduct 4.2 are approved seriatim by the Unit Chief (criminal) or Deputy Chief (civil); Civil or
Criminal Professional Responsibility Officer; and Division Chief.
Requesting AUSA: Donaleski/ Roos
USAONo: 2019R01059
Investigation/Complaint/Arrest/Indictment Investigation
Covert or Overt Contact: Overt
Ongoing, Additional, Different Crime (Yes/No):Yes
Any Special Precautions (discuss below) (Yes/No): Yes
Bar(s) of Admission: New York
Discussion:
We are currently investigating the circumstances surrounding the August 10, 2019 apparent suicide of Jeffrey Epstein
while in the custody of the Bureau of Prisons ("BOP") at the Metropolitan Correctional Center ("MCC"). In particular, we
are investigating MCC staff's (i) decision not to reassign a cellmate to Epstein on August 9, 2019, contrary to regular BOP
practice and direct orders from the Warden; (ii) the failure of correctional officers assigned to the Special Housing Unit
("SHU") at which Epstein was housed the night of August 9, 2019, to perform the required overnight counts and 30-
minute checks; and (iii) the falsification of records related to those count slips and 30-minute checks, in violation of Title
18, United States Code, Section 1519. We would like to have agents interview three inmates who were housed in the
same area of the SHU with Epstein on August 9 and 10, 2019, in order to discuss what they saw and heard that night,
including whether officers performed any overnight checks, or said or did anything upon discovering Epstein in his cell.
While we anticipate interviewing other cooperating witnesses who were in the SHU that night, no cooperating witness
was housed in the same area of the SHU as Epstein. Thus, these three inmates would be the most likely to have overheard
or seen something of relevance. While ten other inmates were housed in the same area as Epstein and these three
inmates, we have conferred with the AUSAs assigned to those matters and do not believe that those inmates would be
appropriate individuals to approach, given their pending charges.
Each of the three inmates is considered a potential witness in our investigation, and each is also currently being
prosecuted by our Office in connection with other crimes. Investigating agents will seek to interview the inmates at MCC,
will advise them of their Miranda rights prior to speaking with them, and will direct them not to discuss their ongoing
criminal case. None of the investigating agents have had any involvement in the investigations of the conduct for which
these individuals have already been charged, and they will make that clear to the inmates before trying to interview them.
Nor do we intend to ask any of the inmates about why they are in the SHU or about facts which may implicate them in
misconduct while housed at the MCC. Instead, our questioning will be narrowly focused on the general behavior of the
guards while the inmates have been housed in the SHU (including whether checks are or are not regularly done) and,
more specifically, the events on the night of August 9-10. We believe that the inmates may be more likely to cooperate
and be forthcoming in this setting, rather than going through their attorneys. An overview of each of the inmates is set
forth below.
is currently charged by Indictment in
) with
counts of
in violation of Title
). These charges relate to
A trial date has not yet been set. We have conferred with
AUSA
to whom the case is assigned, and he has no objection to us proceeding in this manner.
is currently charged by Indictment in
)
with one count of
in
violation of Title
), in connection with an incident in which he
We have conferred with AUSA
to whom the case is
,
assigned, and he has no objection to us proceeding in this manner.
EFTA00018132

=== Page 2 ===
pled guilty to
in violation of
). His guidelines are
months' imprisonment. His sentencing is
scheduled for
We have conferred with AUSAs
and
, to
whom the case is assigned, and they have no objection to us proceeding in this manner.
The proposed contact is permissible under Hammad because the inmates are not represented in connection with their
status as potential witnesses to the events of August 9 and 10, 2019. Moreover, agents will be instructed to advise the
inmates of their Miranda rights, make clear they are not part of the investigation that gave rise to the inmates' pending
charges, not ask any questions about their open criminal cases, and direct the inmates not to speak about their open
criminal cases. Additionally, while there is no question that the Sixth Amendment, including its right to counsel, ordinarily
applies at the point of indictment, none of these defendants have been indicted for the conduct about which we propose
to question them. Nor, as noted, do we intend to question them about anything that might require them to implicate
themselves in misconduct while being housed as a result of the crimes for which they have previously been charged.
Accordingly, we believe the proposed contact is permissible.
Assistant United States Attorney
Southern District of New York
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From:
To:
Cc:
Subject: FW: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Wed, 03 Nov 2021 18:08:03 +0000
Attachments: Disclosure_of_Juror_Names_to_Counsel_Only_upon_completion_of_Questionnaire.pdf
FYI
From: BOBBI C STERNHEIM
Sent: Wednesday, November 3, 2021 12:49 PM
To:
Cc: Christian Everdell
; Laura Menninger
Jeff Pagliuca
Subject: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Courtesy copy of today's ECF filing.
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be
confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
EFTA00018879


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c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
)"
)"
Subject: RE: Diary, boots, photos
Date: Mon, 03 May 2021 00:59:01 +0000
Attachments: 2021.05.XX_Letter_to_AJN_re_Requests_9-11_v2_(MC)_(LP).docx
Thank you so much
Here are some suggestions on top of
comments. Hope you all had a nice
weekend!
From:
Sent: Sunday, May 2, 2021 8:53 PM
To:
(USANYS)
Cc:
is
Subject: Re: Diary, boots, photos
I've read through and looks great- will do another pass first thing and add any stuff on top of
On May 2, 2021, at 7:48 PM,
(USANYS)
wrote:
I will circulate some additional suggestions in a bit. Thank you both!
From:
Sent: Sunday, May 2, 2021 6:11 PM
To:
)
is
)
in
(USANYS)
Subject: RE: Diary, boots, photos
Forgot to attach. Here you go.
From:
Sent: Sunday, May 2, 2021 6:11 PM
To:
is
is
(USANYS)
Subject: RE: Diary, boots, photos
Thanks so much,
My proposed edits and responses to your questions in track.
/
do you want to
review before this goes to the chiefs?
From:
Sent: Friday, April 30, 2021 1:26 PM
To:
is
(USANYS)
is
Subject: Diary, boots, photos
Hi all,
EFTA00020246

=== Page 2 ===
Attached is a draft response to Judge Nathan's order on Rule 17 subpoenas. I've also attached her order and the three
briefs by BSF/GM, in case they are helpful.
This is due Tuesday, but I'm trying to get this to the chiefs early in case they have strong (and different) views about this.
Happy to discuss, too!
Thanks,
EFTA00020247


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=== Page 1 ===
BAT
ADVISE
AND
CONSENT
ALLEN DRUSY
$
&
effrey
rocking
lowre of bes
ks my for world the
THE
FRANKLIN
CIBRARY


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=== Page 1 ===
From:
To:
Cc:
Subject: Confirming FBI numbers for Epstein devices
Date: Sun, 25 Oct 2020 20:43:39 +0000
Attachments: 2020-06-26,_search_warrant,_20_mag_6719.pdf;
Spreadsheet_of_Epstein_Electronic_Devices_in_SWs.xlsx
Attached is a spreadsheet of all the devices we have listed in a warrant for the Epstein/Maxwell cases. Based on
information from both of you and from
I've compiled the FBI 1B number, barcode number, and CART
number for each device. For your reference, I'm also attaching the June 2020 warrant, which includes 62 of these
devices. The other three devices are contained in the draft warrant I sent on Friday. Would you please confirm that all of
the numbers in this spreadsheet are accurate?
Once you have confirmed the accuracy of this chart, we plan to provide a version of the chart to Maxwell's attorneys.
Please feel free to give me a call if you would like to discuss.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00018585


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=== Page 1 ===
From:
To:
Subject: Accepted: Call on Epstein
Date: Tue, 04 Feb 2020 15:41:09 +0000
Importance: Normal
Attachments: unnamed
EFTA00018222


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: following up
Date: Tue, 22 Dec 2020 16:26:58 +0000
2pm works for us. Speak with you then.
Sent from my iPhone
On Dec 22, 2020, at 9:24 AM,
wrote:
We are flexible this afternoon. How about 2pm?
We can use the below dial-in:
Dial-in:
Code:
Thanks,
On Dec 21, 2020, at 10:40 PM,
wrote:
I was busy and just saw this. What time would be good?
Sent from my iPhone
On Dec 21, 2020, at 2:52 PM,
wrote:
Hi all,
Would you be available for a call tomorrow?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
EFTA00019314

=== Page 2 ===
New York, NY 10007
From:
Sent: Wednesday, December 16, 2020 3:57 PM
To:
Cc:
Subject: RE: following up
Trying again
From:
Sent: Wednesday, December 16, 2020 3:55 PM
To:
Cc:
Subject: Re: following up
Thanks! We are on the line when you're ready.
Sent from my iPhone
On Dec 16, 2020, at 3:52 PM,
wrote:
No problem! Will call in right now
Sent from my iPhone
On Dec 16, 2020, at 3:51 PM,
wrote:
Would it be possible to jump on the same line we used earlier today? I'm having tech issues merging the lines.
Thanks!
Sent from my iPhone
On Dec 16, 2020, at 3:43 PM,
wrote:
Why don't you call me at your convenience?
From:
Sent: Wednesday, December 16, 2020 2:05 PM
To:
Cc:
Subject: Re: following up
Hi
We'd be happy to talk that through- - we are available from 3 p.m. onwards today for a call.
Sent from my iPhone
On Dec 16, 2020, at 1:23 PM,
> wrote:
Can you let us know how you calculated the guidelines?
Thanks,
Sent from my iPhone
EFTA00019315

=== Page 3 ===
On Dec 16, 2020, at 11:34 AM,
wrote:
That's fine, thanks:
From:
Sent: Wednesday, December 16, 2020 11:20 AM
To:
Cc:
Subject: RE: following up
Should we use the same call-in number as last time?
From:
Sent: Tuesday, December 15, 2020 12:10 PM
To:
Cc:
Subject: Re: following up
Noon tomorrow works for us, thanks.
Sent from my iPhone
On Dec 15, 2020, at 11:55 AM,
wrote:
Can we move our call to tomorrow? How about noon tomorrow? If that doesn't work let us know a
different time that works tomorrow.
Thanks,
From:
Sent: Monday, December 14, 2020 10:32 PM
To:
Cc:
Subject: Re: following up
3 tomorrow works, thanks.
Sent from my iPhone
On Dec 14, 2020, at 4:57 PM,
wrote:
We can't do earlier unfortunately but could speak at 3 or 4.
From:
Sent: Monday, December 14, 2020 3:35 PM
To:
Cc:
Subject: RE: following up
Hi
would be happy to speak tomorrow morning. Would it be possible to speak
sometime before 11 a.m.? We unfortunately have a conflict at 11, but could speak any time before then.
EFTA00019316

=== Page 4 ===
If not, we can find a time in the afternoon that works.
Thanks,
From:
Sent: Monday, December 14, 2020 3:23 PM
To:
Cc:
Subject: RE: following up
Hi
Would you all be able to speak tomorrow at 11am?
Thanks,
From:
Sent: Sunday, December 13, 2020 6:37 PM
To:
Cc:
Subject: following up
All,
Thanks for speaking with us yesterday. Below is the most current version of the statement of facts we
have discussed. We want to emphasize that this is not a plea offer or a proposal, but we are passing this
along since you've asked us to send you a draft that reflects our must recent discussions. This is not final
from our perspective, and this may change following our conversations with victims during the conferral
process.
We recognize and respect that you will need to speak with your client this week. However, we do not
want to delay notifying the victims, and, as we've discussed, we plan to issue a letter to the victims
notifying them that we are in plea negotiations. That letter will need to go out this week. From our
conversation, it sounds like you plan to meet with your client in the next few days, so let's plan to talk
mid-week.
Thanks,
Between approximately 2001 and 2013,
worked for Jeffrey Epstein as a personal assistant.
has been evaluated by an expert psychologist who specializes in victims of sexual trauma, who
completed a report dated April 21, 2020 regarding
experiences before, during, and after her
employment with Epstein. The parties agree that the contents of the expert's report may be considered
at sentencing, and the Government does not dispute that
was herself a victim of sexual abuse by
Epstein, as discussed in the expert report.
During the period of her employment between approximately 2002 and 2005, as part of her duties to
schedule appointments at the direction of Epstein and Maxwell,
scheduled hundreds of
appointments for women and girls, including dozens of minors, to massage Epstein. Over the course of
that several year period, Epstein received approximately two to three massages per day, and during
those massage appointments, Epstein sexually abused dozens of minor victims. The vast majority of the
massage appointments that
scheduled took place at Epstein's residence in Palm Beach, Florida,
though some victims recall that
arranged massages which took place at Epstein's residence in New
York, New York.
has reported that she has no recollection of scheduling massages for anyone in
New York.
did occasionally schedule massages to take place in Florida by phone while she was in
New York City. When
was first hired, she used a directory provided to her by Epstein's previous
personal assistant and Ghislaine Maxwell to contact women and girls to massage Epstein. Over the
ensuing years,
would add new names to the directory when directed to do so by Epstein or
Maxwell.
EFTA00019317

=== Page 5 ===
Through the process of arranging and facilitating massage appointments for Epstein,
met dozens
of underage victims, who ranged in age from 14 to 17 years old. For example, when minor victims arrived
for the appointments at Palm Beach,
sometimes met them, walked them up to the massage room,
and set up the massage table for the appointment. After some of the appointments,
paid minor
victims in cash. Epstein encouraged minor victims to bring other girls to massage him, which led to an
increasing number of victims coming to massage Epstein at his residences.
None of those victims told
that they were underage.
did know that some of those victims
did not have their own cars, and
arranged for a driver to pick them up and take them to their
appointments with Epstein. Additionally, some of those victims told
they could not attend certain
appointment times because they were attending school. Epstein also told
that at least one of
those victims was studying for the SATs.
During some of the massage appointments with minor girls that
scheduled, Epstein sexually
abused the minor girls by, among other things,
In addition, the Government would be prepared to prove that
witnessed some of the
sexual abuse that occurred. In particular, one victim ("Victim-1") has informed law enforcement that
was present for and participated in one massage when Victim-1 was a minor, during which Epstein
touched Victim-1's
Another victim ("Victim-2") has informed law enforcement that
walked in on one instance in which Victim-2, a minor, was
Epstein. Another victim
("Victim-3") has informed law enforcement that
walked in when Victim-3 was a minor and was
in Epstein's massage room.
has informed the U.S. Attorney's Office that she denies
participating in any of the incidents described by Victim-1, Victim-2, and Victim-3.
In or about 2005,
learned that law enforcement was investigating Epstein for sex crimes involving
minors, arising from the massage appointments, some of which
had scheduled. After learning
about the investigation into Epstein, at Epstein's direction,
called multiple minor victims and
encouraged them to "help" Epstein and conveyed that Epstein would help them if they helped him.
encouraged them to talk to Epstein's investigator, offered that Epstein would pay for an attorney
for them, and, in one or two cases,
offered financial incentives to victims.
understood that
by asking her to make these calls, Epstein intended to dissuade the victims from speaking to law
enforcement, and by agreeing to make the calls and take these steps, she was aiding him in this
objective. Beginning in approximately 2006, multiple minor victims were interviewed by federal law
enforcement officers who were conducting a criminal investigation of Epstein and his associates for sex
trafficking of minors, among other federal offenses. During those interviews, minor victims reported to
federal agents that Epstein paid them for sexualized massages while they were underage girls, including
during massages that
scheduled.
EFTA00019318


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=== Page 1 ===
1 of 1.
OFFICIAL RECORD
FD-302 (Rev. 5-8-10)
FEDERAL BUREAU OF INVESTIGATION
Date of entry
08/28/2019
On August 16, 2019, at the Metropolitan Correctional Center (MCC) 150
Park Row, New York, NY, Special Agent (SA)
, SA
, TFO
,
OIG Investigator
and MCC Lt.
interviewed
,
MCC Inmate
- After
being advised of the identities of the agents and the purpose of the
interview,
provided the following information:
On Friday (August 09, 2019),
was housed in Cell
on
of the Special Housing Unit within MCC. He received a visit from his
girlfriend,
,
that day. He was suspected of receiving
contraband at the visit and was placed in the dry room for approximately 25
hours.
was then moved to
tier Cell
.
last day being housed in
was Friday (August 9, 2019)
prior to his visit.
remembers that JEFFREY EPSTEIN would be in legal from
approximately 9am to 9pm and he was housed in cell 220 in L Tier.
FERNANEZ had no information regarding the death of EPSTEIN.
Investigation on 08/16/2019 at New York, New York, United States (In Person)
File #
Date drafted 08/19/2019
by
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not
to be distributed outside your agency.
EFTA00018135


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=== Page 1 ===
From: Jenna Dabbs
@kaplanhecker.com>
To:
)"
Cc:
@kaplanhecker.com>
Subject: Epstein
Date: Sat, 10 Aug 2019 13:50:11 +0000
We were certainly saddened to see the news this morning, as I know all of you were. I appreciate that you have more
pressing issues to deal with at the moment, but we are interested in whether you expect any aspect of the SDNY's
investigation/case to continue, potentially a separate civil forfeiture proceeding, or possible criminal prosecutions against
other defendants. We also understand that you may not be in a position to tell us anything at the moment, which is fine.
Just anticipating and preparing for questions we expect to be asked. Separately, having had the experience of a defendant
in a case I charged commit suicide, I wanted to add that it can be a complicated feeling, and to the extent it is helpful, I
think you brought a really important case and conducted yourselves in a professional, compassionate and impressive way.
So despite sad news, and frustrating news after putting so much work into filing a case and preparing to see it through,
heads should be held high.
Best,
Jenna
Jenna Dabbs Kaplan Hecker & Fink LLP
350 Fifth Avenue Suite 7110
New York, New York 10118
(W)
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00019948


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=== Page 1 ===
From: "Weinstein, Marc A."
To:
Cc: Andrew Tomback
Subject: Epstein estate
Date: Wed, 08 Jul 2020 14:44:29 +0000
Would you have time for a relatively quick call today around 1:00?
Thanks,
Marc
Marc A. Weinstein | Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
New York, NY 10004-1482
Office
Cell
I Fax
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
EFTA00020365


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: FW: Letter regarding discovery attached.
Date: Wed, 12 Aug 2020 16:35:36 +0000
Attachments: letter_to_USA_re_protective_order_(002)_(002)final.pdf; 2020-08-
12_GM_letter_to_defense_counsel_re_discovery_v2.docx
Inline-Images: image001.jpg
Chiefs,
Attached is a draft response to Jeff's letter regarding the unsealing materials. Happy to discuss or incorporate any edits.
Thanks,
From:
Sent: Monday, August 10, 2020 6:35 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: FW: Letter regarding discovery attached.
FYI - we'll circle up on this when
is back tomorrow.
From: Jeff Pagliuca <jpagliuca@hmflaw.com>
Sent: Sunday, August 09, 2020 18:56
To:
)
>;
)
>;
)
Cc: Laura Menninger <Imenninger@hmflaw.com>; Christian Everdell <CEverdell@CohenGresser.com>; Mark S. Cohen
<mcohen@CohenGresser.com>; Nicole Simmons <nsimmons@hmflaw.com>
Subject: Letter regarding discovery attached.
Dear Counsel,
Please see attached conferral letter.
Jeff
Jeffrey S. Pagliuca
Haddon, Morgan and Foreman, P.C.
TKI
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
jpagliuca@hmflaw.com
www.hmflaw.com
EFTA00017828

=== Page 2 ===
mation that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to
the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing,
distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have
received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its
attachments without reading or saving it in any manner. Thank you
EFTA00017829


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=== Page 1 ===
Event: Accepted: Epstein Meeting (Please hold the time)
Start Date: 2020-01-16 19:00:00 +0000
End Date: 2020-01-16 20:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-01-15 23:42:09 +0000
Date Modified: 2020-01-15 23:42:09 +0000
Priority: 5
DTSTAMP: 2020-01-15 23:17:37 +0000
Attendee:
EFTA00019230


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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:
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
AUDREY STRAUSS
United States Attorney for the
UNITED STATES DISTRICT COURT ILLINOIS
Southern District of New York
Assistant United States Attorney
OUTRICT FOR THE YORK
One St. Andrew's Plaza
New York, New York 10007
Email:
Telephone:
rev. 02.01.12
EFTA00019651


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Subject: RE: Epstein Estate update
Date: Mon, 09 Nov 2020 15:22:13 +0000
I'm tied up from 11:45 to 12:30 and 2 to 3, but otherwise happy to dial-in to the call.
From:
Sent: Monday, November 09, 2020 10:10 AM
To:
Cc:
(USANYS)
Subject: Re: Epstein Estate update
Thanks, I can join a call this afternoon, as long as you're ok taking the lead. I'll be continuing to review images at a snail's
pace during all of my calls today.
On Nov 9, 2020, at 9:55 AM,
)
wrote:
Given that today is the deadline, I would be fine pushing this call to tomorrow to make more time today. Or if you'd
prefer I can just deal with this call alone this afternoon.
Sent from my iPhone
Begin forwarded message:
From: "Weinstein, Marc A."
Date: November 9, 2020 at 9:49:47 AM EST
To:
)"
i
)"
Cc: Andrew Tomback
Subject: Epstein Estate update
and
Would you have time for a call this afternoon to give you an update on a new development?
Thanks,
Marc
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
EFTA00019127

=== Page 2 ===
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this
e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of
this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
EFTA00019128


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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 18:34:54 +0000
Inline-Images: image001.png
Hey thank you!! And hope you and your family are doing alright these days!
From:
Sent: Thursday, July 02, 2020 14:30
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congrats!!
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,
EFTA00019546

=== 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.
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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.
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[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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