# docs_fts_content

c1: EFTA00023497
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023497.pdf
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=== Page 1 ===
From:
To:
)"
Cc:
)"
(USANYS)"
Bec: "USAHUB-USAJournal111"
Subject: RE: Question re SDFL Epstein file
Date: Thu, 18 Feb 2021 00:49:57 +0000
Embedded: RE:_Question_re_SDFL_Epstein_file.msg
Sender:
Subject: RE: Question re SDFL Epstein file
Message-Id:
<DM3P110MB0345A3F0848B6D393B19061A84859@DM3P110MB0345.NAMP110.PROD.OUTLOOK.CO
M>
To:
Cc:
Cc:
EFTA00023497


c1: EFTA00020629
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020629.pdf
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=== Page 1 ===
THE SHIPPING ON4 FEEDER and PRISONS SEQUITUR OF DEPARTUTION
BUREAU OF
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey #76318-054
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 - -1:45 AM
EFTA00020629

=== Page 2 ===
OF SE RETURN SHIPPING ORd FEDERAL no SEQUITUR PRISONS* OF DEPARTMENTS
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey #76318-054
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:45 AM
Adoos
EFTA00020630

=== Page 3 ===
OF JUSTICE * SNOSINA our FEDERAL PRO SOMINE VILLING
BUREAU OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey #76318-054
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:45 AM
COPY
EFTA00020631

=== Page 4 ===
RETURN OH4 FEDEBALL ano SEQUITUR PRISONS * DISTRICT OF DEPARTMENT
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey #76318-054
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:45 AM
COPY
bLEZ-L
EFTA00020632

=== Page 5 ===
WHING OH# mo SEQUITUR PRISONS* OF DISTRIBU DEPARTMENT
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey #76318-054
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:45 AM
COPY
7-23-19
EFTA00020633

=== Page 6 ===
ENE OM4 FEEDER INO PRISONS* SEQUITUR OF INSURED DEPARTMENT
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey #76318-054
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:45 AM
COPY
7-23-19
EFTA00020634

=== Page 7 ===
WORKING 084 FEDERAL FEDER no SEQUITUR PRISONS* DISTRICT OF DEPARTUTION
BUREAU OF
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey #76318-054
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:45 AM
COPY
$1-22-C
EFTA00020635

=== Page 8 ===
OF STATES ORA no SEQUITUR PRISONS* OF REPUBLICATE
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey #76318-054
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:45 AM
COPY
7-23-19
EFTA00020636

=== Page 9 ===
OF JUSTITOR WHING ONE no SEQUITUR PRISONS* SUSTE OF
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt(Cellmate)
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Tartaglione, Nicholas #78514-054
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
,
Date and Time of Photo
07/23/19 -2:25 AM
COPY
1-23-19
EFTA00020637

=== Page 10 ===
THE SHIPPING PAID ano SEQUITUR PRISONS* APPLICA OF
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt(Cellmate)
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Tartaglione, Nicholas #78514-054
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -2:25 AM
COPY
7-23-19
EFTA00020638

=== Page 11 ===
ORA no SEQUITUR PRISONS * OF
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt(Cellmate)
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Tartaglione, Nicholas #78514-054
Location of Incident
Special Housing Unit
Photograph(s) by
2, Lieutenant
Date and Time of Photo
07/23/19 -2:25 AM
COPY
EFTA00020639

=== Page 12 ===
OF JUSTICE
JUSTITOR SHIPPING OM4 FEDDER no SEQUITOR PRISONS*
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt(Cellmate)
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Tartaglione, Nicholas #78514-054
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -2:25 AM
1234
COPY
EFTA00020640

=== Page 13 ===
OF MUSTING SHIPHING 084 FEDERAL ano SEQUITUR PRISONS* INSURED OF DEPARTMENTO
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt(Cellmate)
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Tartaglione, Nicholas #78514-054
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -2:25 AM
12379
COPY
EFTA00020641

=== Page 14 ===
FEDERAL AL ONE OF DOMINA JUSTITIA OF F JUSTICE SECURITA
BUREAU
OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt(Cellmate)
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Tartaglione, Nicholas #78514-054
Location of Incident
Special Housing Unit
Photograph(s) by
, Lieutenant
Date and Time of Photo
07/23/19 -2:25 AM
COPY
EFTA00020642

=== Page 15 ===
BUREAU OF THE 084 and SEQUITUR PRISONS* PUSTA OF
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey #76318-054
Location of Incident
Special Housing Unit
Photograph(s) by
Lieutenant
Date and Time of Photo
07/23/19 -1:55 AM
72319
COPY
0
EFTA00020643

=== Page 16 ===
OF ENE ORd no SEQUITUR PRISONS * OF DISTRICT REPARTMENT
BUREAU
Lieutenant's Office
Metropolitan Correctional Center New York, N.Y.
Photo Sheet
Special Investigative Section
Type of Incident
Possible Suicide Attempt
Date and Time of Incident
07/23/19 - 1:27 AM
Inmate Name/Register Number
Epstein, Jeffrey #76318-054
Location of Incident
Special Housing Unit
Photograph(s) by
7,
Lieutenant
Date and Time of Photo
07/23/19 -1:55 AM
COPY
EFTA00020644


c1: EFTA00021069
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c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021069.pdf
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=== Page 1 ===
From: UberConference <noreply@uberconference.com>
To:
Subject: Conference Invite from The Bloom Firm: Call re Epstein on Thursday January 23, 2020
@ 12:00 pm (PST)
Date: Wed, 22 Jan 2020 21:44:54 +0000
Attachments: invite.ics
The Bloom Firm has invited you to a conference call.
Your UberConference Will Begin At:
January 23, 2020 at 12:00PM (PST
-
US/Pacific)
Call re Epstein
6 Participants
JOIN THE CALL
Other ways to join
URL - https://www.uberconference.com/thebloomfirm
EFTA00021069

=== Page 2 ===
Conference Number - 818-405-0476
No PIN needed
Joining from outside the US? - International access numbers
Add to my calendar: Google I Outlook I iCal I Yahoo
6 Participants
teri@thebloomfirm.com
teri@thebloomfirm.com
colleen@thebloomfirm.com
colleen@thebloomfirm.com
The Bloom Firm
marcelino@thebloomfirm.com
F
T
L
witt
ink
EFTA00021070

=== Page 3 ===
UberConference by Dialpad
100 California Street
San Francisco, CA 94111
You are receiving this email because you signed up for UberConference
If you'd like to stop getting emails from UberConference, click here
EFTA00021071


c1: EFTA00021131
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021131.pdf
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=== Page 1 ===
From:
)"
To:
Subject: RE: Epstein search materials for upload and privilege review
Date: Fri, 14 Feb 2020 19:45:15 +0000
just tried calling but didn't catch you - wanted to follow up on this since a week ago it sounded like the vendor
expected to be finished early the very next (business) day, but we're now at a week later and they're still not completed -
do you know what the issue is?
From:
Sent: Wednesday, February 12, 2020 13:17
To:
Cc:
is
)
is
)
Subject: RE: Epstein search materials for upload and privilege review
The data is almost done. I should have it to you by the end of the week.
Thank you.
From:
Sent: Wednesday, February 12, 2020 1:04 PM
To:
Cc:
is
)
i
)
Subject: RE: Epstein search materials for upload and privilege review
wanted to follow up on this - is the data fully uploaded, or did it get delayed? Thanks.
From:
Sent: Friday, February 07, 2020 11:25
To:
Cc:
i
)
i
)
Subject: RE: Epstein search materials for upload and privilege review
Great, thank you!
From:
Sent: Friday, February 07, 2020 09:34
To:
Cc:
is
)
i
)
Subject: RE: Epstein search materials for upload and privilege review
The data should be ready by Monday morning.
EFTA00021131

=== Page 2 ===
From:
Sent: Tuesday, February 4, 2020 6:58 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
Wanted to quickly check the status of the below - it's only been a couple weeks, so totally understand it may not be
complete, but hopefully we're getting close? If you could please check with the vendor and let us know, we'd be grateful
- and we'll plan to get it to
asap once we have access.
thanks,
From:
Sent: Tuesday, January 21, 2020 18:50
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
We've received a hard drive from FBI CART, which they've processed from devices seized and searched in connection with
the Epstein case. Can we please get those materials uploaded to Relativity, for privilege review by
(copied here)? I've
left the hard drive with the materials on your chair. (And if we could please get that hard drive back once the materials
are uploaded, the FBI has another batch they want to transmit to us for the same process, so that will also be coming
shortly.)
And then
these will be subject to just the exact same privilege review you previously ran in connection with Epstein
search warrant returns.
Please let us know if any questions or issues at all? And thanks very much as always.
EFTA00021132


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=== Page 1 ===
Court Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Lockheed Martin
6801 Rockledge Drive
Bethesda, MD 20817
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the United States District Court for the Southern District of New York, 40 Foley Square, in the
Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the
following date, time and place:
Appearance Date:
November 29, 2021
Appearance Time: 9:00 a.m.
Appearance Place:
40 Foley Square, Courtroom 906
to testify and give evidence in the following matter:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
Records of any transactions by Lockheed Martin or Sikorsky with the following entities:
Jeffrey Epstein
Ghislaine Maxwell
Air Ghislaine Inc., a/k/a Shititka Air Inc., a/k/a Freedom Air International Inc.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
June 21, 2021
AUDREY STRAUSS
United States Attorney for the
UNITED STATES DISTRICT COURT
Southern District of New York
THE
RICT
YORK
Assistant United States Attorney
Rev. 02.01.12
EFTA00022024

=== Page 2 ===
EFTA00022025


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=== Page 1 ===
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100
Main
33 West 19th Street - 4th Floor
917-306-6666
Cell
New York, New York 10011
888-587-4737
Fax
bc@sternheimlaw.com
February 1, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re. United States V. Ghislaine Maxwell
20 Cr. 330 (AJN)
Dear Judge Nathan:
By letter to the Court, dated January 25, 2021 (Dkt. 117 at 2-3), the MDC raised objection
to the Court's order, unopposed by the government, directing the MDC to permit Ms. Maxwell to
use on a laptop computer on weekends and holidays. (Dkt. 116 at 2). The MDC has failed to
state a valid or compelling reason for opposing the Court's directive.
The MDC does not identify any valid reason why Ms. Maxwell cannot have access to the
laptop computer on weekends and holidays. The MDC does not argue, for example, that access
to the laptop cannot be provided because of issues related to safety or security, staffing, or (to
quote the government) the need to "manag[e] its inmate population." Instead, in opposition to
the Court's order, the MDC repeats its stock response: Ms. Maxwell has received significant
amount of time to review her discovery and has more contact with counsel than any other MDC
inmate is allotted. The MDC's fixation on the relative time Ms. Maxwell has been given to
review discovery is totally misguided. The government has produced millions of pages of
discovery. Ms. Maxwell has the right to review all of them in order to prepare her defense for
trial. To do that, she needs access to the laptop for as much time as possible, including the
weekends and holidays because the prison computers are incapable of reading the millions of
discovery documents. Ms. Maxwell loses 10 or more hours per week due to delay in receiving
the laptop, problems caused by the MDC computer, and inability to access the computer during
morning and afternoon counts on the weekends. Comparing Ms. Maxwell to other inmates does
not justify restricting her use of the laptop to review discovery.
The MDC's proposed solution-that Ms. Maxwell can simply use the prison computer on
the weekends and holidays to review discovery-is utterly inadequate. As Ms. Maxwell has
pointed out on many occasions, the prison computer is incapable of reading a significant portion
of the discovery, including but not limited to native files, Excel files, some video and audio files,
and anything requiring Cellebrite software. The MDC concedes this fact in their letter-Ms.
Maxwell cannot review all of her discovery on the prison computer. And using it causes a
colossal waste of time. For example, if Ms. Maxwell locates a document on the prison computer
EFTA00021015

=== Page 2 ===
LAW OFFICES OF BOBBI C. STERNHEIM
for which she needs to review the native image, many of which are embedded in other files, she
must write down the Bates number for that document and then wait until Monday to find the
same document using the laptop computer so that she can review the full document. Moreover,
the MDC computer shuts down every two hours, requiring Ms. Maxwell to reboot the computer
and find her place in the documents to resume her review. This process can take 20-30 minutes,
all of which is lost time. In addition, the power of central processing unit of the MDC computer
is very slow. Uploading videos can take up to a half hour, time that cannot be used to review
other documents. When the computer automatically shuts down, videos need to be re-opened,
requiring Ms. Maxwell to locate the portion of the video she was viewing when the computer
shut down. In sum, using the prison computer is a problem, not a solution.
Ms. Maxwell's review of discovery is challenging enough on the laptop computer that
was provided. Even with the laptop, Ms. Maxwell is unable to search, unable to print, and
unable to tag or highlight documents for later review. She must review millions of pages of
unwieldy documents produced in various formats (native, image, text) one page at a time-with
no filtering or organizing-and record millions of Bates numbers and notes of her review by
hand on the limited amount of paper she is provided. And she is not permitted to have any
supplies to organize the voluminous legal papers. Hard drives provided by the government have
been mishandled by MDC staff (dropped on the floor and slammed on a cart) causing them to
become degraded and unstable and to randomly shut down. While the laptop does not solve all of
these issues, it performs far better than the MDC computers. The time, resources and funds
expended on problems caused by the electronic discovery and the computers is unnecessary,
wasteful, and frustrating. The MDC is in no position - and is neither qualified nor experienced -
to challenge Ms. Maxwell's and her counsel's claim that she needs access to the laptop on the
weekends and holidays to even hope to finish reviewing the millions of pages of documents
produced in discovery.
The MDC's assertion that Ms. Maxwell's access to her attorneys is a reason to deny her
access to the laptop computer on weekend and holidays is non-sensical. One has absolutely
nothing to do with the other. And it ignores the fact that, aside from time to review discovery or
communicate with counsel, Ms. Maxwell is far more restricted than all other MDC inmates.
Other inmates have unlimited time to communicate with other inmates. With exception of
inmates detained in the SHU for disciplinary reasons, all other MDC inmates have unlimited
time to interact with other inmates. Other than calls with family or communication with counsel,
Ms. Maxwell has no human contact except with guards who wield power over her, overmanage
her, and have psychologically and physically abused her. And complaints regarding
mistreatment by guards have led to reprisals against Ms. Maxwell.
Rather than state a valid reason for opposing the Court's directive, the MDC's opposition
shines a klieg light on the deficiencies of its electronics and the limitations imposed on all
inmates, most especially those detained pretrial. The restrictions placed on pretrial detainees goes
beyond deprivation of liberty. Their ability to prepare for trial is compromised, their access to
counsel is restricted, and their right to effective assistance of counsel is jeopardized. The
pandemic has made the situation even more dire. Requiring pretrial detainees, including Ms.
Maxwell, to review terabytes of electronic discovery on inadequate computers further tips an
already unlevel playing field to the detriment of criminal defendants.
2
EFTA00021016

=== Page 3 ===
LAW OFFICES OF BOBBI C. STERNHEIM
There are no reasonable conditions to assure that as a pretrial detainee Ms. Maxwell will
be as prepared for trial as a defendant on bail. Permitting Ms. Maxwell to use the laptop on
weekends and holidays is a reasonable and minimum accommodation for the difficulties entailed
in reviewing enormous amounts of electronic discovery, and one that imposes no burden on the
BOP nor any security issues. The Court's order directing the MDC to permit Ms. Maxwell
access to the computer on weekends and holidays should remain in effect.
Very truly yours,
Bobbi C. Sternbeim
BOBBI C. STERNHEIM
cc: Sophia Papapetru, MDC counsel
Government Counsel
3
EFTA00021017


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=== Page 1 ===
Event: Accepted: Re: [EXTERNAL] RE: Touhy Request in United States V.
Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Start Date: 2021-10-29 13:30:00 +0000
End Date: 2021-10-29 14:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2021-10-29 13:23:34 +0000
Date Modified: 2021-10-29 13:23:34 +0000
Priority: 5
DTSTAMP: 2021-10-29 13:18:46 +0000
Attendee:
EFTA00023457


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: FW: draft search warrant
Date: Sun, 07 Jul 2019 03:27:31 +0000
Importance: Normal
Attachments: Second_New_York_Residence_SW.v3.docx
FYI, went to FBI about ten minutes ago, so we're hoping to hear back from them shortly.
From:
Sent: Saturday, July 06, 2019 23:14
To:
Cc:
Subject: draft search warrant
S having some computer issues so I'm sending - please see attached.
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00021302


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=== Page 1 ===
From:
To:
Subject: RE: [EXTERNAL] Ghislaine Maxwell- 02879-509
Date: Tue, 12 Oct 2021 14:50:28 +0000
Thanks.
From:
Sent: Tuesday, October 12, 2021 10:49 AM
To:
Subject: FW: [EXTERNAL] Ghislaine Maxwell- 02879-509
FYI
From: BOBBI C STERNHEIM
Sent: Tuesday, October 12, 2021 10:25 AM
To:
Subject: [EXTERNAL] Ghislaine Maxwell- 02879-509
Good morning-
The government has sent a hard drive to the MDC via Federal Express for Ms. Maxwell.
Upon arrival, it must IMMEDIATELY be given to Ms. Maxwell.
Time is of the essence.
Please inform me when it arrives.
Thank you-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Main:
Cell:
Fax:
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.
EFTA00023036


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=== Page 1 ===
From:
To:
)"
Subject: RE: New documents:
V. Maxwell (Doc# 1078, S.D.N.Y. 1:15-cv-07433-LAP)
Date: Wed, 29 Jul 2020 19:28:54 +0000
Inline-Images: image001.jpg
Received, thank you.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Wednesday, July 29, 2020 2:35 PM
To:
)
is
>;
Subject: FW: New documents:
V. Maxwell (Doc# 1078, S.D.N.Y. 1:15-cv-07433-LAP)
I wanted to alert you that Maxwell's counsel just filed the attached public filing in the
V. Maxwell case.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
From: ECFdocuments@pacerpro.com [mailto:ECFdocuments@pacerpro.com]
Sent: Wednesday. July 29. 2020 2:07 PM
To:
Subject: New documents:
V. Maxwell (Doc# 1078, S.D.N.Y. 1:15-cv-07433-LAP)
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
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V. Maxwell
Docket entry number: 1078
LETTER addressed to Judge Loretta A. Preska from Ty Gee dated July 29, 2020 re:
Reconsideration of the Courts July 23 Ruling. Document filed by Ghislaine Maxwell.
(Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5)
Exhibit E). (Gee, Ty) (Entered: 07/29/2020)
Date entered: 2020-07-29
VIEW CASE
https://app.pacerpro.com/cases/1833757
Sent from PacerPro, the fastest and most insightful way to access federal court records.
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The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
EFTA00021764


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=== Page 1 ===
THEN RED
DRAFT
U.S. Department of Justice
Southern District of New York
One St. Andrews Plaza
PUSTITIA
New York, NY 10007
Phone: (212) 637-1028
Fax: (212) 637-0421
August 14, 2019
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd. Suite 1500
Los Angeles, CA 90048
Re: Case Number 2018R01618 and Court Docket Number 19-CR-00490
Dear Gloria Allred:
The enclosed information is provided by the United States Department of Justice Victim Notification System
(VNS). As a victim witness professional, my role is to assist you with information and services during the
prosecution of this case. You have been designated to receive notifications on behalf of the following victim(s)
(or potential victims) identified by law enforcement during the investigation of the case:
On August 10, 2019, Jeffrey Epstein died while in custody at the Manhattan Correctional Center. Where a
defendant dies prior to conviction, this Department of Justice will, in the ordinary course, seek dismissal of the
pending indictment. However, as the U.S. Attorney has publicly stated, the investigation of the conduct charged
in the Indictment remains ongoing and we continue to urge anyone who feels they may be a victim or have
information related to the conduct in this case to please contact 1-800-CALL-FBI.
Sincerely,
Geoffrey Berman
United States Attorney
wendy alsen
Wendy Olsen
Victim Witness Coordinator
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=== Page 1 ===
ED
EDWARDS
POTTINGER LLC
Florida Office
425 North Andrews Avenue
New York Office
Suite 2
J. Stanley Pottinger #
Bradley J. Edwards *01
Fort Lauderdale, FL 33301
Seth M. Lehrman *+
t Admitted in California
Telephone (954)524-2820
0 Admitted in District of Columbia
Brittany N. Henderson *0
- Admitted in Florida
Matthew D. Weissing *I
Fax (954)524-2822
# Admitted in New York
I I Board Certified Civil Trial Lawyer
October 15, 2020
VIA E-MAIL AND FEDEX
The Honorable Geoffrey S. Berman
United States Attorney for the
Southern District of New York
c/o
Assistant United States Attorney
86 Chambers Street, Third Floor
New York, New York 10007
Re:
Request for Tangible and Documentary Evidence (Touhy Request)
V. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07625
Dear
:
In follow up to our previous communications, please accept this as our formal written request for
documentary and tangible evidence currently in the in the possession, custody, and control of the
Department of Justice by way of the Southern District of New York relating to the sexual abuse of
one of Jeffrey Epstein's many victims,
1 See United States ex rel. Touhy V. Ragen, 340 U.S.
462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R.
$ 16.21 et seq. Should you find there to be any deficiencies within this request, please notify us
and we will do what is necessary to correct any such shortcomings.
was sexually assaulted by prolific pedophile, Jeffrey Epstein, on two occasions in 2000, when
she was only 15 years old, record of which we believe is currently in the Government's possession
as a result of the investigation that was conducted into Epstein's criminal activity relating to the
sexual abuse of minor children. Given the highly relevant nature of this tangible evidence to
currently pending litigation, we request production of documentary evidence relating to
in
order to enable her to prove her claims from both a liability and damages standpoint.
1 To protect her anonymity, our client has elected to proceed as a
As such, we have referred to her
herein using the pseudonym under which she has filed her lawsuit. To the extent that her identity is not
already known by the prosecutors in the Southern District of New York, please contact us at your earliest
convenience to discuss her true identity.
EFTA00023326

=== Page 2 ===
Page 2
We specifically seek copies of the following documents that we believe are currently in the
possession of the Government:
1) Photographs of
2) Videos of
;
3) Any and all correspondence between Jeffrey Epstein, his agents, or his employees, and
;
4) Any and all documents including
true name;
5) Any and all lists including
true name; and
6) Any and all other documentary materials relating in any way to
Pursuant to the Touhy regulations set forth by the Department of Justice, the Deputy or Associate
Attorney General assesses the following considerations in determining whether disclosure is
warranted:
(a)(1) Whether such disclosure is appropriate under the rules of procedure
governing the case or mater in which the demand arose;
(a)(2) Whether disclosure is appropriate under the relevant substantive law of
privilege. This request satisfies both of these considerations. As explained
previously, the requested non-privileged documentary evidence directly concerns
the allegations in Doe's civil case.
Due to the establishment of the Epstein Victim Compensation Program that is currently underway,
seeks this information on an expedited basis in order to properly and completely present her
claim for consideration, and if necessary, to continue to proceed by way of formal litigation. The
requested information is within the scope of ordinary practice and does not seek disclosure of
information prohibited by statute or regulation. Furthermore, this request does not seek
information that is classified or that would reveal the source or identity of any informant. To that
effect,
specifically does not request any investigatory records compiled for law enforcement
purposes that would interfere with ongoing law enforcement proceedings.
simply requests
information in the Government's possession that will assist in the prosecution of her claims and
ultimately, aid in her ability to finally obtain the justice that she deserves. To the extent that the
requested materials can be made available to
on an expedited basis, it would be greatly
appreciated.
Please contact us at your earliest convenience to discuss the identity of
in more detail, at which
time we are fully prepared to answer any questions that you may have.
Very truly yours,
EDWARDS POTTINGER LLC
BEE
Bradley Edwards
Brittany Henderson
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=== Page 1 ===
From: BOBBI C STERNHEIM <bcsternheim@mac.com>
To:
Cc:
, Christian Everdell <CEverdell@cohengresser.com>,
Subject: Re: [EXTERNAL] Re: Ghislaine Maxwell 02879-509
Date: Wed, 27 Oct 2021 12:39:39 +0000
Thank you.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
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 Oct 27, 2021, at 8:21 AM,
wrote:
Good morning Bobbi-
I apologize for the delay in response, however, I will inquire with the
appropriate staff regarding both of your concerns.
Best,
BOBBI C STERNHEIM <bcsternheim@mac.com> 10/26/2021 9:14 PM
Good evening-
I am still awaiting a reply to yesterday's email regarding Ms.
Maxwell's legal mail.
There are items that need to be picked up by the MDC.
I have provided the tracking information.
Please provide a response by 10:00 am tomorrow Wednesday.
Thank you-
EFTA00023481

=== Page 2 ===
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
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 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 Oct 25, 2021, at 8:33 PM, BOBBI C STERNHEIM <bcsternheim@mac.com>
wrote:
Good evening -
During my in-person visit yesterday with Ms. Maxwell, the HEPA
filters were not operating in the visiting room that I have been
required
to use, even when more than one attorney is present. The officers
told me to use the larger, corner room.
Previous requests to use this more ample corner room have been denied
because the officers' claim
the camera cannot be positioned. Yesterday, the officers simply and
easily positioned the camera focused on the corner room.
I am requesting that future in-person visits be conducted in the
EFTA00023482

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larger corner room.
The previous reason for denying that request appears invalid.
Also, legal mail sent to the MDC has not been picked up by the
facility. See tracking information below.
Please promptly provide an explanation and inform me when Ms. Maxwell
will receive these deliveries.
Thank you-
Bobbi
<Screen Shot 2021-10-25 at 7.10.13 PM.png>
<Screen Shot 2021-10-25 at 7.07.56 PM.png>
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Main: 212-243-1100
Cell: 917-912-9698
Fax: 888-587-4737
<mailto:bcsternheim@mac.com>
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,
EFTA00023483

=== Page 4 ===
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.
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=== Page 1 ===
From: Martin Weinberg
To:
)"
"Martin
Weinberg"
, Reid Weingarten
Subject: Re: US V Epstein - - Preservation Requests
Date: Thu, 01 Aug 2019 21:05:38 +0000
Attachments: 8.1.19_Supplemental_Discovery_Letter_Epstein_(1).pdf
, see attached. If you would like, I can forward to
My only time sensitive
request is whether it is your intention (and if no decision has yet been reached until you return let me
know and we will wait) whether I will need to ask eg AUSA
or AUSA
to preserve
documents or whether I can expect that this request will be forwarded to appropriate persons by you
and your team.
Thanks
Marty
Martin G. Weinberg, Esq.
20 Park Plaza
Suite 1000
Boston, MA 02116
- Office
- 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.
On Thursday, August 1, 2019, 03:35:47 PM EDT,
>
wrote:
Marty,
I think it would be useful for you to send that follow-up letter today or tomorrow, and we should be able to incorporate it
into our response. Apologies again for the delay but it is in progress.
thanks,
From: Martin Weinberg
Sent: Thursday, August 01, 2019 15:31
To:
)
>; ; Martin Weinberg
Subject: Re: US V Epstein - Preservation Requests
EFTA00020937

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Hi
hopefully your travels are for personal pleasure and not business but I won't inquire. I have a followup
letter than focuses on AUSA
(SD Fla) and whether you would send a request to her to preserve
potentially relevant documents. I can either email it to you today so you can consider it in concert with the other
requests or hold it and we can discuss further when you return
Thanks
Marty
Martin G. Weinberg, Esq.
20 Park Plaza
Suite 1000
Boston, MA 02116
- Office
- 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.
On Thursday, August 1, 2019, 02:59:25 PM EDT,
A
wrote:
Marty,
I'm unfortunately traveling this afternoon and tomorrow through the weekend - we had hoped to get you a responsive letter
very shortly but it may be next week instead. Apologies for the delay, but we could speak Monday or Tuesday and in any
event will get you the full response in the coming days as well.
thanks,
From: Martin Weinberg
Sent: Thursday, August 01, 2019 14:00
To:
>; ; Martin Weinberg
Subject: US V Epstein - Preservation Requests
Hi
Can we have a short call regarding what I can reasonably expect in the way of my earlier letter seeking your notifying other relevant
districts, DOJ of my preservation request.
Thanks
Marty
Martin G. Weinberg, Esq.
20 Park Plaza
Suite 1000
Boston, MA 02116
EFTA00020938

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- Office
- 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.
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=== Page 1 ===
From:
Subject: 1.19.21
interview - draft
Date: Wed, 20 Jan 2021 20:09:48 +0000
Attachments:
1.19.21.docx
Attached is a draft copy of the interview from yesterday.
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
New York, New York 10007
March 14, 2020
BY EMAIL
Jason E. Foy
Foy & Seplowitz LLC
Hackensack, NJ 07601
Montell Figgins, Esq.
Law Offices of Montell Figgins
Newark, NJ 07102
Re:
United States V. Tova Noel and Michael Thomas, No. 19 Cr. 830
Dear Counsel:
We write in response to your discovery request letters, dated January 29, 2020. This letter
and the content herein is designated as "Protected Materials" pursuant to the Protective Order
entered in this matter.
Thomas Request. The Government refers to its prior response to this request, as stated at
the November 25, 2019 pretrial conference.
Noel Requests No. 1-10, 12-13. We note, at the outset, that many of these requests are
extremely broad and pertain to information that does not appear to be relevant to the case. To the
extent material called for by these requests is within the Government's possession and subject to
disclosure at this time, the Government has already disclosed such information to you, including
by letter dated January 24, 2020. To the extent these requests call for information that is not
currently in the Government's possession or which is not subject to disclosure, you identify no
legal basis or authority for these requests, and we are not aware of any authority requiring us to
obtain and/or disclose this information.
Noel Request No. 11. The name of the MCC technician referenced in the Government's
previous letter is
Noel Request No. 16. The Government has already produced the available video
surveillance in its possession for July 23, 2019 for the Special Housing Unit. The Government
attaches hereto two public filings in United States V. Tartaglione, 16 Cr. 832 (KMK), which
reference these issues.
06.20.2018
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=== Page 2 ===
Page 2
Noel Requests No. 14-5, 17-23. These requests, in general terms, call for information about
where particular evidence may be located within the discovery produced to date. As you note, you
seek this information to "assist in expediting the ability of the defense to be ready for trial."
Accordingly, with respect to Noel Requests No. 14-15, 17-23, at your request and solely as a
courtesy to aid you in your review of discovery, the Government is providing the information that
follows. The Government's response to your requests should not be used for any other purpose,
nor should it be construed as a representation that only these files or portions of the surveillance
video are potentially relevant to the Government's case or any potential defense, or as a
representation that the identified portions are the only portions of surveillance video that would be
responsive to your requests. The Government expressly reserves the right to identify and/or offer
at trial additional material as probative of any of the issues identified in these requests.
Noel Request No. 14. With respect to August 9, 2019, we direct your attention to the
following video files: CH0080_20190809195956; CH0080_20190809205956,
CH0080_20190809215956; CH0080_20190809225956. With respect to August 10, 2019, the
following video files contain this activity: CH0080_20190809235959;
CH0080_20190810005959;
CH0080_20190810025959;
CH0080_20190810035959;
CH0080_20190810045959; and CH0080_20190810055959.
Noel Request No. 15. While the Government has not conducted a review of every time
Jeffrey Epstein was captured on MCC surveillance during the more than 30 days he was housed
there prior to his death and does not purport to provide such an exhaustive response, as a courtesy
and to aid in your review of the discovery, we direct your attention to the following: on August 9,
2019 Epstein was captured leaving his cell to make a phone call at approximately 18:53:54 -
18:54:46 (CH0080_20190809175956). Epstein was escorted back to his cell at approximately
19:49:25 - 19:49:39 (CH0080_20190809185956).
Noel Request No. 17. We direct your attention to files CH0080_20190809145956 and
CH0080_20190809155956, during approximately 15:45:00 - 16:15:00 on August 9, 2019.
Noel Request No. 18. We direct your attention to files CH0080_20190809205956 and
CH0080_20190809215956, during approximately 19:45:00 - 20:15:00 on August 9, 2019.
Noel Request No. 19. We direct your attention to file CH0080_20190809215956, during
approximately 22:29:00 - 22:34:00.
Noel Request No. 20. We direct your attention to files CH0080_20190809225956
CH0080_20190809235959, during approximately 23:45:00 (August 9) - 00:15:00 (August 10).
Noel Request No. 21. The Government does not presently believe this interaction was
captured by surveillance video.
Noel Request No. 22. The Government refers you to the forensic examination of the
computers used by defendants Noel and Thomas during August 9 to 10, 2019, which were
previously produced in discovery (SDNY_00000021 - SDNY_00000075). The Government also
06.20.2018
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=== Page 3 ===
Page 3
refers you to the following files during the following times, which show the defendants at the desk
during the periods of time in which they were using computers, as shown by the forensic
examination referenced above: files CH0080_20190809225956, CH0080_20190809235959
CH0080_20190810005959,
CH0080_20190810025959,
CH0080_20190810035959,
CH0080_20190810045959, and CH0080_20190810055959, during approximately (8/9) 23:39:00
- (8/10) 00:15:00, (8/10) 03:54:00 - 03:57:00, (8/10) 04:29:00 - 05:04:00, and (8/10) 05:10:00 -
06:20:00 as to defendant Noel, and approximately (8/10) 00:35:00 - 01:15:00 and (8/10) 06:00:00
- 06:20:00 as to defendant Thomas.
Noel Request No. 23. The Government refers you to files CH0080_20190810005959,
CH0080_20190810015959, and CH0080_20190810025959 during approximately 00:01:00 -
03:15:00 on August 10, 2019.
We are available at your convenience to discuss any further.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
By:
/s/
Assistant United States Attorneys
06.20.2018
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=== Page 1 ===
From:
To:
Subject: FW: PBSO
Date: Fri, 02 Aug 2019 19:27:25 +0000
I just checked with
and he told me no one from your office has called him back or contacted him on the
Epstein issue. Is there an issue I can address?
From:
Sent: Friday, July 26, 2019 3:35 PM
To:
Subject: Re: PBSO
here you go. Below is the PBSO contact. My cell is
if you have questions. I would appreciate it if
someone could reach out to him today. Have a great weekend.
Palm Beach County Sheriff's Office
Violent Crimes Division / Homicide
Sent from my iPhone
On Jul 26, 2019, at 3:26 PM,
wrote:
- Please send along contact information for the point of contact, and I will pass along to the appropriate folks on this
end.
Thanks,
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
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From:
)"
To: Sigrid McCawley
Cc:
)"
Subject: RE:
follow-up request
Date: Fri, 08 May 2020 19:54:55 +0000
Sigrid,
Tomorrow morning would actually be fine - we'll send you a calendar invite for 11:00 a.m. Eastern time, including a
conference line number, and we'll plan to talk with you then. And just as a heads up, not that I particularly expect this will
be necessary, but similar to how we always tell witnesses that if they want to talk with their counsel privately during an in-
person meeting, we'll let her know that the same thing holds true for over the phone as well, that you two can always
have a side call at any point! And otherwise I think it will be the usual awkwardness of phone but hopefully not too bad.
thanks again,
From: Sigrid McCawley
Sent: Friday, May 08, 2020 14:46
To:
Cc:
Subject: RE:
follow-up request
If that does not work she also said she could do it this Monday morning - 10:00 Eastern (9:00 Texas) if that is better for
your team.
Just let me know.
Thanks
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, May 8, 2020 1:59 PM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize
the sender.
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=== Page 2 ===
Sigrid,
Thanks for getting back to us so quickly. Goes without saying that we of course would be happy for you to be on the call
as well-I should have mentioned that in my initial email. On timing, let us just check with the agents on the case to see if
that works for them, and we hope to be able to confirm with you in the next couple hours.
thanks,
From: Sigrid McCawley
Sent: Friday, May 08, 2020 13:27
To:
Cc:
Subject: RE:
follow-up request
Hello
-
said she has time tomorrow if that would work for you team. She is in Texas so an hour behind us.
I
would like to be on the call as well. Would it work to do something tomorrow at 11:00 EST? Let me know. If that does not
work I can try to get other times.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Friday, May 8, 2020 11:02 AM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize
the sender.
I unfortunately was on trial during the previous interview, but I think somewhat less time than how long it went last time.
Ordinarily we try not to go longer than about 90 minutes in any event, so I think if she is able to block out that amount of
time, that would be great - and we'll try to be as efficient as possible and hopefully take less than that. If that sounds
alright?
thanks,
From: Sigrid McCawley
Sent: Thursday, May 07, 2020 18:57
To:
EFTA00023170

=== Page 3 ===
Cc:
Subject: RE:
follow-up request
Hello
I am sure
will be happy to help in any way she can. Let me find out what her patient schedule is like for next week
and find a time that works. How much time do you think she should allot for the interview - just so she can plan?
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Thursday, May 7, 2020 6:41 PM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
Hi Sigrid,
We wanted to follow up in connection with
- our supervisors have asked us to do an additional interview with her,
both to follow up on some specific aspects of her recollection but also do basically go through her experiences again. As
I'm sure you know, we have no doubts whatsoever, at all, about her candor and truthfulness in our previous interview,
which also was broadly consistent with what she has said in other interviews, but we are nevertheless hoping she might
be willing to speak with us sometime in the next week or two? Obviously due to the current situation we would plan to
do it via phone, and we would be happy to chat about logistics with you if that would be helpful, or to answer any
questions at all. And if
is willing to speak with us again, we're happy to work around her schedule, including talking
during an evening or weekend if that's easier for her than during the day-whatever you and she would prefer.
Please let us know if any questions, or if it would be useful to chat, and thanks very much.
From:
Sent: Thursday, January 16, 2020 14:35
To: Sigrid McCawley
Cc:
V.
Subject: RE:
follow-up request
EFTA00023171

=== Page 4 ===
Got it, thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 2:29 PM
To:
)
>
Cc:
is
)
Subject: RE:
follow-up request
I checked back with
and she said that the last entry in her journal is in late February and she
went to New Mexico in April.
Thanks
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
Sent by Boxer
On January 16, 2020 at 1:05:54 PM EST,
)
wrote:
Thank you very much, Sigrid.
Just to confirm, does
have any journal entries regarding the time when she traveled to New Mexico? I
believe she told us during our interview that she does not have any entries from that time, but I just wanted to
make sure.
Thanks again,
EFTA00023172

=== Page 5 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 12:31 PM
To:
Cc:
)
;
)
Subject: RE:
follow-up request
Hello - attached are the pages
sent me to provide to you. Here is a bit of an explanation and I also
asked her to take a copy of the front and back of the journal book which she did. Hope this helps. Please let
me know if you need anything else:
"The shortest page and the one that is the hardest to read is the first entry from 12/95. It is written in colored
pencil and is fading. There are then two pages from 01/07/1996 where I talk about the highlights of my NY
trip and going to Epstein's house and then the next entry from 01/25/1996 is where I talk about going to the
movies with him."
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 4:01 PM
To: Sigrid McCawley
Cc:
)
i
)
Subject: RE:
follow-up request
Thanks very much, Sigrid. Yes, we received the photographs from
which we very much appreciate.
Anything else she is willing to share, including her journal entries, would be very helpful.
Best,
EFTA00023173

=== Page 6 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Friday, January 10, 2020 3:59 PM
To:
Cc:
)
Subject: RE:
follow-up request
Hello
,
Let me follow up with
about her journal. I know she shared some pictures with you from around the
time period when she was with Epstein/Maxwell. I will ask her about the journal ASAP and will get back to
you and will check with her to see if she has anything else that might be helpful to the investigation.
All my best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 3:30 PM
To: Sigrid McCawley
Cc:
)
Subject:
follow-up request
Hi Sigrid,
Hope you had a wonderful holiday season and very happy New Year. We wanted to follow up on a request we
made after interviewing
a few months ago. During her interview,
referred to several
entries in her journal that had helped refresh her recollection of the events involving Epstein and Maxwell. As
we mentioned at the end of the interview, it would be very helpful to our investigation if we could review
those journal entries, as well as any other records or documents
may have that relate to her experiences
with Epstein and Maxwell.
EFTA00023174

=== Page 7 ===
Would
be willing to share with us any relevant journal entries (or any other relevant documents she may
have) to assist in our investigation?
Happy to have a call to discuss if that would be helpful.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information
that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of
this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication
in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1
08201831BSF
EFTA00023175


c1: EFTA00022399
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022399.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UBS Financial Services Inc.
UBS
299 Park Avenue
25th Floor
Resource Management Account
New York NY 10171-0002
April 2016
CNP7005675137 0416 Y1 0
GHISLAINE MAXWELL
116 E 65TH STREET
NEW YORK NY 10065-7007
Account name: GHISLAINE MAXWELL
Friendly account name: Ind:Cash/Saving
Account number:
Your Financial Advisor:
SCOTT STACKMAN/LYLE CASRIEL
Phone: 212-821-7000/800-308-3140
Questions about your statement?
Call your Financial Advisor or the
Value of your account
RMA ResourceLine at 800-RMA-1000,
on March 31 ($)
on April 29 ($)
account 029023575.
Your assets
4,815,922.95
18,955,082.77
Visit our website:
Your liabilities
0.00
0.00
www.ubs.com/financialservices
Value of your account
$4,815,922.95
$18,955,082.77
Sources of your account growth
Tracking the value of your account
during 2016
Value of your account
$ Millions
at year end 2015
$6,144,731.58
Net deposits and
19.0
withdrawals
$12,794,446.43
Your investment return:
Dividend and
interest income
$12,397.40
6.1
4.2
4.8
Change in
market value
$3,507.36
Value of your account
Dec 2014
Dec 2015
Mar 2016
Apr 2016
on Apr 29, 2016
$18,955,082.77
Member SIPC
CNP70008005675137 NP7000191098 00005 0416 030575004 Y123575550 000000
Page 1 of 8
EFTA00022399

=== Page 2 ===
UBS
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
April 2016
Friendly account name;Ind:Cash/Saving
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Your account balance sheet
Summary of your assets
Value on
Percentage of
April 29 ($)
your account
A
Cash and money balances
0.00
0.00%
Your current asset allocation
B
Cash alternatives
15,438,248.43
81.45%
C
Equities
0.00
0.00%
D
D
Fixed income
3,516,834.34
18.55%
E
Non-traditional
0.00
0.00%
F
Commodities
0.00
0.00%
G
Other
0.00
0.00%
Total assets
$18,955,082.77
100.00%
B
Value of your account
$18,955,082.77
Eye on the markets
Percentage change
Index
April 2016
Year to date
S&P 500
0.39%
1.74%
Russell 3000
0.62%
1.59%
MSCI - Europe, Australia & Far East
3.00%
0.04%
Barclays Capital U.S. Aggregate Bond Index
0.38%
3.43%
Interest rates on April 29, 2016
3-month Treasury bills: 0.20%
One-month LIBOR: 0.44%
CNP70008005675138 NP7000191098 00005 0416 030575004 Y123575550 000000
Page 2 of 8
EFTA00022400

=== Page 3 ===
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
UBS
Friendly account name: Cash/Saving
April 2016
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Change in the value of your account
Summary of gains and losses
April 2016 ($)
Year to date ($)
Values reported below exclude products for which gains and losses are not classified
Opening account value
$4,815,922.95
$6,144,731.58
Realized gains and losses
Unrealized
April 2016 ($)
Year to date ($)
Deposits, including investments
gains and losses ($)
transferred in
14,261,795.27
14,545,566.37
Short term
0.00
0.00
14.29
Withdrawals and fees,
including investments transferred
out
-129,982.64
-1,751,119.94
Cash activity summary
Dividend and interest income
3,844.37
12,397.40
See Account activity this month for details. Balances in your Sweep Options are included in the opening and
closing balances value. FDIC insurance applies only to deposits at UBS Bank USA, not to deposits at UBS AG,
Change in market value
3,502.82
3,507.36
Stamford Branch or bank deposits placed through the UBS International Deposit Account program. SIPC
protection applies to money market sweep fund holdings but not bank deposits. See Important information
Closing account value
$18,955,082.77
about your statement on the last two pages of this document for details.
$18,955,082.77
April 2016 ($)
Year to date ($)
Dividend and interest income earned
Opening balances
$0.00
$2,010,294.62
Additions
For purposes of this statement, taxability of interest and dividend income has been determined from a US
Deposits and other funds credited
14,261,795.27
14,545,566.37
tax reporting perspective Based upon the residence of the account holder, account type, or product type,
some interest and/or dividend payments may not be subject to United States (US) and/or Puerto Rico (PR)
Dividend and interest income
3,844.37
12,397.40
income taxes. The client monthly statement is not intended to be used and cannot be relied upon for tax
purposes. Clients should refer to the applicable tax reporting forms they receive from UBS annually, such as
Proceeds from investment transactions
129,988.89
1,704,128.54
the Forms 1099 and the Forms 480, for tax reporting information It is the practice of UBS to file the
applicable tax reporting forms with the US Internal Revenue Service and PR Treasury Department, and in
Total additions
$14,395,628.53
such forms accurately classify dividends and/or interest as tax exempt or taxable income. Please consult your
$16,262,092.31
individual tax preparer.
Subtractions
April 2016 ($)
Year to date ($)
Other funds debited
-129,982.64
-1,751,119.94
Taxable dividends
3,844.26
10,202.44
Funds withdrawn for investments
bought
-14,265,645.89
-16,521,266.99
Taxable interest
0.11
21.23
Total subtractions
-$14,395,628.53
-$18,272,386.93
Total current year
$3,844.37
$10,223.67
Net cash flow
$0.00
-$2,010,294.62
Prior year adjustment
0.00
2,173.73
Total dividend & interest
$3,844.37
$12,397.40
Closing balances
$0.00
$0.00
CNP70008005675139 NP7000191098 00005 0416 030575004 Y123575550 000000
Page 3 of 8
EFTA00022401

=== Page 4 ===
UBS
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
Friendly account name: Cash/Saving
April 2016
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
UBS Bank USA Deposit Account APY
Interest period Mar 7 - Apr 6
Opening UBS Bank USA Deposit balance Mar 7
$13,399.64
Closing UBS Bank USA Deposit balance Apr 6
$0.11
Number of days in interest period
31
Average daily balance
$5,006.70
Interest earned
$0.11
Annual percentage yield earned
0.03%
Your investment objectives:
You have identified the following investment objectives for this account If you have questions
about these objectives, disagree with them, or wish to change them, please contact your
Financial Advisor or Branch Manager. You can find a full description of the alternative
investment objectives in Important information about your statement at the end of this
document
Your return objective:
Current income & capital appreciation
Your risk profile:
Primary Moderate
Investment eligibility consideration - None selected
Your account instructions
Your account cost basis default closing method is FIFO, First In, First Out.
CNP70008005675140 NP7000191098 00005 0416 030575004 Y123575550 000000
Page 4 of 8
EFTA00022402

=== Page 5 ===
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
UBS
Friendly account name: Ind:Cash/Saving
April 2016
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Your assets
Some prices, income and current values shown may be approximate. As a result, gains and losses may not
be accurately reflected See Important information about your statement at the end of this document for
more information
Cash alternatives
Money market funds
Money market funds are neither insured nor guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although money market funds seek to preserve the value of your investment at $1.00 per
share, it is possible to lose money by investing in these funds.
Total reinvested is the total of all reinvested dividends. It does not include any cash dividends. It is not a tax
Unrealized (tax) gain or loss is the difference between the current value and the cost basis and would
lot for the purposes of determining holding periods or cost basis. The shares you receive each time you
reinvest dividends become a separate tax lot.
generally be your taxable gain or loss if the security was sold on this date. The unrealized (tax) gain or loss may
need to be adjusted for return of capital payments in order to determine the realized gain or loss for tax
Cost basis is the total purchase cost of the security, including reinvested dividends. The cost basis may
reporting purposes.
need to be adjusted for return of capital payments in order to determine the adjusted cost basis for tax
Investment return is the current value minus the amount you invested. It does not include shares that are not
reporting purposes.
reflected on your statement, including shares that have been realized as either a gain or a loss. It also does
not include cash dividends that were not reinvested
Purchase price/
Number
Average price
Client
Cost
Price per share
Value on
Unrealized
Holding
of shares
Investment Holding
per share ($)
investment ($)
basis ($)
on Apr 29 ($)
Apr 29 ($)
gain or loss ($)
return ($) period
UBS SELECT PRIME
INSTITUTIONAL FUND
15,438,248.430
1.000
15,438,248.43
15,438,248.43
1.000
15,438,248.43
EAI: $58,665 Current yield: 0.38%
Fixed income
Mutual funds
Total reinvested is the total of all reinvested dividends It does not include any cash dividends. It is not a
Unrealized (tax) gain or loss is the difference between the current value and the cost basis and would
tax lot for the purposes of determining holding periods or cost basis. The shares you receive each time you
reinvest dividends become a separate tax lot.
generally be your taxable gain or loss if the security was sold on this date. The unrealized (tax) gain or loss may
need to be adjusted for return of capital payments in order to determine the realized gain or loss for tax
Cost basis is the total purchase cost of the security, including reinvested dividends. The cost basis may
reporting purposes.
need to be adjusted for return of capital payments in order to determine the adjusted cost basis for tax
Investment return is the current value minus the amount you invested. It does not include shares that are not
reporting purposes.
reflected on your statement, including shares that have been realized as either a gain or a loss. It also does not
include cash dividends that were not reinvested
Purchase price/
Number
Average price
Client
Cost
Price per share
Value on
Unrealized (tax)
Holding
of shares
Investment Holding
per share ($)
investment ($)
basis ($)
on Apr 29 ($)
Apr 29 ($)
gain or loss ($)
return ($) period
PUTNAM SHORT DURATION
INCOME FUND Y
continued next page
CNP70008005675141 NP7000191098 00005 0416 030575004 Y123575550 000000
Page 5 of 8
EFTA00022403

=== Page 6 ===
UBS
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
April 2016
Friendly account name: Ind:
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Your assets
Fixed income
Mutual funds (continued)
Purchase price/
Number
Average price
Client
Cost
Holding
Price per share
Value on
of shares
Unrealized (tax)
per share ($)
investment ($)
basis ($)
Investment Holding
on Apr 29 ($)
Apr 29 ($)
gain or loss ($)
return ($)
period
Symbol: PSDYX
Trade date: Jul 20, 15
348,605.578
10.040
3,500,005.25
3,500,005.25
10.040
3,500,000.00
-5.25
ST
Total reinvested
1,676.727
10.028
16,814.80
10.040
16,834.34
19.54
EAI: $22,068 Current yield: 0.63%
Security total
350,282.305
10.040
3,500,005.25
3,516,820.05
3,516,834.34
14.29
16,829.09
Your total assets
Percentage of
Cost
Estimated
Unrealized
Value on Apr 29 ($)
your account
basis ($)
annual income ($)
gain or loss ($)
Cash alternatives
Money market funds
15,438,248.43
81.45%
15,438,248.43
58,665.00
Fixed income
Mutual funds
3,516,834.34
18.55%
3,516,820.05
22,068.00
14.29
Total
$18,955,082.77
100.00%
$18,955,068.48
$80,733.00
$14.29
Account activity this month
Date
Activity
Description
Amount ($)
Deposits and other funds credited
Apr 1
Transfer
JOURNAL FROM Y1 23574 GHISLAINE MAXWELL
436.07
Apr 1
Transfer
JOURNAL FROM Y1 23572 GHISLAINE MAXWELL
1,396.83
Apr 1
Transfer
JOURNAL FROM Y1 23568 GHISLAINE MAXWELL
2,072.89
Apr 12
Transfer
JOURNAL FROM Y1 28776 GHISLAINE MAXWELL
0.88
Apr 20
Transfer
JOURNAL FROM Y1 23692 116 EAST 65TH STREET LLC
14,194,596.49
Apr 27
Transfer
JOURNAL FROM Y1 23568 GHISLAINE MAXWELL
809.14
Apr 27
Transfer
JOURNAL FROM Y1 23574 GHISLAINE MAXWELL
1,276.61
Apr 27
Transfer
JOURNAL FROM Y1 23572 GHISLAINE MAXWELL
61,206.36
Total deposits and other funds credited
$14,261,795.27
Date
Activity
Description
Amount ($)
Dividend and interest income
Taxable dividends
Apr 1
Dividend
PUTNAM SHORT DURATION INCOME FUND Y AS OF 03/31/16
2,562.85
Apr 29 Dividend
UBS SELECT PRIME INSTITUTIONAL FUND
1,281.41
Total taxable dividends
$3,844.26
Taxable interest
Apr 7 Interest
UBS BANK USA DEPOSIT ACCOUNT AS OF 04/06/16
0.11
continued next page
CNP70008005675142 NP7000191098 00005 0416 030575004 Y123575550 000000
Page 6 of 8
EFTA00022404

=== Page 7 ===
Resource Management Account
Account name:
GHISLAINE MAXWELL
UBS
Your Financial Advisor:
April 2016
Friendly account name: Ind:Cash/Saving
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Account activity this month (continued)
Date
Activity
Description
Amount ($)
Dividend and interest income (continued)
Taxable interest (continued)
Total taxable interest
$0.11
Total dividend and interest income
$3,844.37
Date
Activity
Description
Amount ($)
Other funds debited
Apr 1
Transfer
JOURNAL TO Y1 23692 116 EAST 65TH STREET LLC
-5,368.21
Apr 1
Transfer
JOURNAL TO Y1 23692 116 EAST 65TH STREET LLC
-30,000.00
Apr 12
Transfer
JOURNAL TO Y1 23576 GHISLAINE MAXWELL
-718.75
Apr 18
Transfer
JOURNAL TO Y1 23576 GHISLAINE MAXWELL
-95.68
Apr 19
Transfer
JOURNAL TO Y1 23679 POT & KETTLE, LLC
-70,000.00
Apr 20 Transfer
TO Y1 23568 7100
-1,510.00
Apr 20 Transfer
TO Y1 23574 1100
-2,290.00
Apr 28 Transfer
JOURNAL TO Y1 23576 GHISLAINE MAXWELL
-20,000.00
Total other funds debited
-$129,982.64
Investment transactions
For more information about the price/value shown for restricted securities, see Important information about
your statement at the end of this document
Proceeds from
Funds
Date
Activity
Description
investment
withdrawn for
Accrued
Quantity
Value ($)
Price ($)
transactions ($)
investments bought ($)
interest ($)
Apr 1
Sold
UBS SELECT PRIME INSTITUTIONAL FUND
-5,368.210
5,368.21
Apr 1
Reinvestment
PUTNAM SHORT DURATION INCOME FUND Y
255.518
DIVIDEND REINVESTED AT 10.03 NAV ON
-2,562.85
03/31/16 AS OF 03/31/16
Apr 1
Sold
UBS SELECT PRIME INSTITUTIONAL FUND
-30,000.000
30,000.00
Apr 6
Bought
UBS SELECT PRIME INSTITUTIONAL FUND
3,905.790
-3,905.79
Apr 12
Bought
UBS SELECT PRIME INSTITUTIONAL FUND
0.110
-0.11
Apr 12
Sold
UBS SELECT PRIME INSTITUTIONAL FUND
-725.000
725.00
Apr 14
Bought
UBS SELECT PRIME INSTITUTIONAL FUND
7.130
-7.13
Apr 18
Sold
UBS SELECT PRIME INSTITUTIONAL FUND
-95.680
95.68
Apr 19
Sold
UBS SELECT PRIME INSTITUTIONAL FUND
-70,000.000
70,000.00
Apr 20
Sold
UBS SELECT PRIME INSTITUTIONAL FUND
-3,800.000
3,800.00
Apr 25
Bought
UBS SELECT PRIME INSTITUTIONAL FUND
14,194,596.490
-14,194,596.49
continued next page
CNP70008005675143 NP7000191098 00005 0416 030575004 Y123575550 000000
Page 7 of 8
EFTA00022405

=== Page 8 ===
UBS
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
Friendly account name: nd:Cash/Saving
April 2016
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Account activity this month (continued)
Investment transactions (continued)
Proceeds from
Funds
investment
withdrawn for
Date
Accrued
Activity
Description
Quantity
Value ($)
Price ($)
transactions ($)
investments bought ($)
interest ($)
Apr 27
Bought
UBS SELECT PRIME INSTITUTIONAL FUND
63,292.110
-63,292.11
Apr 28
Sold
UBS SELECT PRIME INSTITUTIONAL FUND
-20,000.000
20,000.00
Apr 29
Reinvestment
UBS SELECT PRIME INSTITUTIONAL FUND
1,281.410
-1,281.41
DIVIDEND REINVESTED AT 1.00 NAV ON
04/29/16
Total
$129,988.89
-$14,265,645.89
Date
Activity
Description
Amount ($)
Money balance activities
Mar 31
Balance forward
$0.00
Apr 4
Deposit
UBS BANK USA DEPOSIT ACCOUNT
3,905.79
Apr 7
Withdrawal
UBS BANK USA DEPOSIT ACCOUNT AS OF 04/06/16
-3,905.79
Apr 7
Deposit
UBS BANK USA DEPOSIT ACCOUNT AS OF 04/06/16
0.11
Apr 13
Deposit
UBS BANK USA DEPOSIT ACCOUNT
7.02
Apr 15
Withdrawal
UBS BANK USA DEPOSIT ACCOUNT AS OF 04/14/16
-7.13
Apr 21
Deposit
UBS BANK USA DEPOSIT ACCOUNT
250,000.00
Apr 26
Withdrawal
UBS BANK USA DEPOSIT ACCOUNT AS OF 04/25/16
-250,000.00
Apr 29
Closing UBS Bank USA Deposit Account
$0.00
The UBS Bank USA Deposit Account is your primary sweep option.
Mar 31
Balance forward
$0.00
Apr 21
Deposit
UBS AG DEPOSIT ACCOUNT
13,944,596.49
Apr 26
Withdrawal
UBS AG DEPOSIT ACCOUNT AS OF 04/25/16
-13,944,596.49
Apr 29
Closing UBS AG Deposit Account
$0.00
The UBS AG Deposit Account is your secondary sweep option.
CNP70008005675144 NP7000191098 00005 0416 030575004 Y123575550 000000
Page 8 of 8
End of statement for account number Y1 23575 S5
EFTA00022406


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020539.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "NYSReportServer@usa.doj.gov" <NYSReportServer@usa.doj.gov>
To:
Subject: Child Exploitation & Porn Update Report III
Date: Mon, 05 Apr 2021 20:55:38 +0000
Attachments: Child_Exploitation_&_Porn_Update_Report_II.pdf
Attached is the Child Exploitation & Porn Update Report III for Project Safe Childhood.
Chiefs and Project Safe Childhood Coordinator, please remind the assigned AUSA to make updates in their
cases. Thanks!
EFTA00020539


c1: EFTA00021640
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021640.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE:
Date: Fri, 19 Jul 2019 16:16:57 +0000
l'll add summaries for
Sorry for the delay.
From:
Sent: Thursday, July 18, 2019 7:56 PM
To:
Subject: RE:
I added
which I think is the only one for me - thanks for doing!
From:
Sent: Thursday, July 18, 2019 10:49
To:
Subject: RE: RE:
Guys, I filled in summaries for the interviews I attended. Would you please fill in the ones that you guys attended/know
the details of, so we can send to
Since Epstein's arrest, our team has conducted the following interviews:
as interviewed
In 2001, when Ms
was approximately 14
years old, another young woman, identity unknown (the "Woman"), befriended her outside her school
After they became friends, the Woman invited her to Epstein's house. In subsequent meetings,
over approximately a year, Ms
as enticed to provide nude massages, and was paid $300 in cash each
time. In fall 2002, while Ms.
was massaging Epstein, he asked her to
and intends to continue to cooperate with the investigation.
was interviewed
In 2002, when Ms
was 14 years old, her friend
recruited her to give Epstein a massage at his Palm Beach house, during which Epstein touched
Ms
recruited one other minor girl to give Epstein a massage.
vas interviewed
In the early 2000s, when Ms
was either 16
or 17 years old, her friend recruited her to give Epstein massages at his Palm Beach house. She provided him with
at least two massages and was
during both. During the first, Epstein
The second involved
was interviewed on
was interviewed on
In or around 2004, when Ms.
was in her early 20s,
she met Epstein through
Around December 2004, Epstein offered Ms.
a job
working as an assistant. Around early 2005, Ms.
began working as an assistant for Epstein, and she remained
his employee until early 2006. Her responsibilities included running errands and scheduling appointments. As a
EFTA00021640

=== Page 2 ===
result, Ms.
cheduled numerous massages for Epstein. According to Ms
Epstein expected to have two
massages every day: one in the morning and one in the afternoon. Ms.
nd
were responsible
for ensuring that these massages were confirmed when Epstein was in
as responsible
for scheduling the massages in
At some point, Epstein and Ms
egan having sexual encounters.
M:
was very distressed when discussing these incidents and was not prepared to describe them in detail
during our first meeting.
At least some of these encounters involved Ms.
oviding Epstein with his massages when
they were in the Virgin Islands. As a result, Ms.
vas aware that his massages were sexual. Ms.
described how Epstein had two groups of girls who provided massages in his homes: one group was of
professional masseuses who gave actual massages to Epstein's friends, and the second group consisted of young
girls who were not professional masseuses and who only gave massages to Epstein. Ms.
ecalled certain
details that signaled that girls in this second group were minors. For example, she was asked to help find SAT prep
courses for one girl, and she recalled girls mentioning school and their parents.
was interviewed on
was interviewed on
was interviewed on
Ms.
knew and interacted with Epstein
between in or around 2007 and in or around 2017. She first met Epstein through her
who had been
previously introduced to Epstein by a mutual friend, in 2007 when she was 17 years old. Epstein specifically asked
her age and told her, in substance, that they could not interact until she turned 18. After her 18th
birthday, Epstein began having
give him massages,
A short time later, Epstein took Ms.
on a trip to his private island in the Virgin Islands.
During that trip, Epstein
during a massage. Between 2007
and 2009, Epstein had
with Ms.
n multiple occasions. Ms.
escribed the first few of
these instances as
When Epstein was serving
his jail sentence, M
visited him at his office on at least one occasions and engaged in sexual conduct with
him. After Epstein completed his sentence, Ms.
di not have any other sexual encounters with him, but
she continued to occasionally work for him by running errands or cleaning his house. In or around 2013, Epstein
paid Ms.
10,000
Ms.
ceased all communication with Epstein after the
divorce in 2017.
In addition, numerous other potential victims and witnesses have contacted the team either directly or through their
attorneys. We are continuing to schedule interviews.
From:
Sent: Tuesday, July 16, 2019 9:21 PM
To:
Cc:
Subject: Re: RE:
Does not need to be very detailed - if you could by Thursday, would be great.
Sent from my iPhone
On Jul 16, 2019, at 8:33 PM,
wrote:
Sure, by when do you need this? We don't have 302s back from the agent yet, and we didn't take a separate set of
notes for ourselves, so if you need this quickly, we can't be particularly detailed.
EFTA00021641

=== Page 3 ===
From
Sent: Tuesday, July 16, 2019 8:30 PM
To:
Subject:
Sorry to ask, but can you guys put together brief (few sentence, maybe more for
summaries of the interviews you
did last week? In addition, can you provide any information on other victims who have reached out and we expect to
interview soon? Putting together an overall summary for brass. Thank you!
EFTA00021642


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc:
Christian Everdell
Laura Menninger
,
Jeff Pagliuca
Subject: Re: US V. Maxwell, 20 Cr. 330 (AJN) - MDC Conditions Update
Date: Tue, 15 Jun 2021 17:45:10 +0000
Attachments: Proposed_redactions_2021-06-07_GM_letter_update_re_MDC_conditions_final.pdf;
ATT00001.htm
Good afternoon-
Attached is the conditions letter with requested redaction highlighted.
EFTA00022023


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=== Page 1 ===
From:
To: "Weinstein, Marc A."
Cc:
Subject: RE: [EXTERNAL] Re: following up
Date: Sun, 24 Oct 2021 21:54:43 +0000
Attachments: 2021.10.24_Subpoena_to_Estate.pdf
Hi Marc,
Please see the attached subpoena. Thanks.
From: Weinstein, Marc A. <
Sent: Sunday, October 24, 2021 1:46 PM
To:
Cc:
is
ATomback@mclaughlinstern.com
Subject: RE: [EXTERNAL] Re: following up
Yes, c/o the two Co-Executors.
Thanks!
Marc A. Weinstein | Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Sunday, October 24, 2021 1:43 PM
To: Weinstein, Marc A.
Cc:
is
is
Subject: Re: [EXTERNAL] Re: following up
CAUTION: This email was sent by someone outside of the Firm.
Thanks very much. I can send a subpoena. Should it be addressed to the estate?
EFTA00023202

=== Page 2 ===
On Oct 24, 2021, at 1:34 PM, Weinstein, Marc A. <marc.weinstein@hugheshubbard.com> wrote:
I believe it's ready to go. Can you send us a subpoena for those records?
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
On Oct 24, 2021, at 11:00 AM,
wrote:
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
Thanks so much, and apologies for pestering while you're on trial. Were you able to process these materials?
Thanks,
From: Weinstein, Marc A.
Sent: Thursday, October 21, 2021 4:26 PM
To:
Cc:
is
is
Subject: Re: [EXTERNAL] Re: following up
my apologies as I'm on trial and the paralegal who would prepare the production is also the paralegal at the trial.
We have a day off tomorrow so let me see if she can get it processed tomorrow.
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
On Oct 21, 2021, at 3:12 PM,
wrote:
EFTA00023203

=== Page 3 ===
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
Just checking in on this - do you have a sense of timing? We very much appreciate your efforts to obtain these
documents, but we're mindful of the approaching trial date.
Thanks,
From:
Sent: Thursday, October 14, 2021 10:08 AM
To: 'Weinstein, Marc A.'
Cc:
is
Subject: RE: [EXTERNAL] Re: following up
Hi Marc,
Thanks. We'd very much appreciate receiving this as soon as possible. We are scheduled to begin trial next month, and
we would like to produce these materials to defense counsel in discovery immediately upon receipt.
Thanks,
From: Weinstein, Marc A. <r
Sent: Wednesday, October 13, 2021 9:56 PM
To:
Cc:
y.
Subject: RE: [EXTERNAL] Re: following up
We should be able to produce that next week.
Marc A. Weinstein I Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
marc.weinstein@hugheshubbard.com
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.
From:
Sent: Wednesday, October 13, 2021 9:05 PM
To: Weinstein, Marc A.
<
EFTA00023204

=== Page 4 ===
Cc:
is
is
Subject: Re: [EXTERNAL] Re: following up
CAUTION: This email was sent by someone outside of the Firm.
Marc,
Thanks very much. Do you have a timeframe for when you expect the production to be available?
Thanks,
On Oct 13, 2021, at 5:42 PM, Weinstein, Marc A. <marc.weinstein@hugheshubbard.com> wrote:
We've gathered the flight logs and will prepare them for production. Sorry for the delay.
Best regards,
Marc
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
marc.weinstein@hugheshubbard.com
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.
On Oct 7, 2021, at 5:16 PM,
wrote:
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
Checking in on this. Would it be helpful to have a call to discus the status of this request?
Thanks very much,
EFTA00023205

=== Page 5 ===
From:
Sent: Friday, September 24, 2021 11:25 AM
To: Weinstein, Marc A.
Cc:
Subject: RE: following up
Hi Marc,
Following up on this, can you let us know the status of this?
Thanks,
From: Weinstein, Marc A.
Sent: Friday, August 27, 2021 4:06 PM
To:
Cc:
is
is
Subject: Re: following up
Allison,
Sorry for the delay, as I'm away this week. I should have something for you next week.
Regards,
Marc
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this
e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of
this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
On Aug 23, 2021, at 9:24 AM,
wrote:
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
Following up on this, could you please let us know the status of our request for flight manifests? Thanks very much for
looking into this.
Best,
EFTA00023206

=== Page 6 ===
From: Weinstein, Marc A.
Sent: Thursday, April 22, 2021 6:50 AM
To:
is
Cc:
Subject: RE: following up
The investigator did not see anything of interest in the Florida home. I am checking to confirm on New Mexico.
Regards,
Marc
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this
e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of
this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Wednesday, April 21, 2021 6:28 PM
To: Weinstein, Marc A. <r
>;
Cc:
Subject: RE: following up
CAUTION: This email was sent by someone outside of the Firm.
Hi Marc,
I hope all is well. Following up on the below.
Thanks very much,
From: Weinstein, Marc A.
Sent: Monday, April 12, 2021 5:57 PM
To:
is
is
EFTA00023207

=== Page 7 ===
Cc:
Subject: RE: following up
We can confirm that we are not aware of any historical surveillance video. We will be back to you later this week on
the other materials.
Best regards,
Marc
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this
e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of
this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Monday, April 12, 2021 2:15 PM
To:
>; Weinstein, Marc A.
Cc:
Subject: RE: following up
CAUTION: This email was sent by someone outside of the Firm.
Marc and Andy,
Thanks for your time last week. We wanted to follow up on with you on our conversation last week. When can we
expect to get the materials discussed?
Thanks again,
From:
Sent: Wednesday, March 31, 2021 1:59 PM
To: Weinstein, Marc A.
Cc:
is
Subject: RE: following up
Thanks, talk to you then. We can use this conference line:
From: Weinstein, Marc A.
Sent: Wednesday, March 31, 2021 1:52 PM
To:
is
EFTA00023208

=== Page 8 ===
Cc:
is
Subject: RE: following up
3:30 works for us.
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this
e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of
this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
From:
Sent: Wednesday, March 31, 2021 1:35 PM
To: Weinstein, Marc A.
Cc:
is
Subject: RE: following up
CAUTION: This email was sent by someone outside of the Firm.
Thanks very much- would it be possible to speak slightly later on Monday, perhaps at 3:30 or later? Alternatively,
we're available between 10:30 and 2 p.m. on Monday.
From: Weinstein, Marc A. <
Sent: Wednesday, March 31, 2021 10:58 AM
To:
is
Cc:
is
Subject: RE: following up
how about Monday at 2:30pm?
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this
e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of
this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
EFTA00023209

=== Page 9 ===
From:
Sent: Wednesday, March 31, 2021 9:33 AM
To:
Weinstein, Marc A. <r
Cc:
is
Subject: following up
CAUTION: This email was sent by someone outside of the Firm.
Marc and Andy,
Hope you're both doing well. Are you available for a call early next week? We wanted to follow up with you on an
aspect of our previous document requests.
Thanks very much,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00023210


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
(USANYS)"
Bcc:
Subject: GM 16(d) reply letter
Date: Sun, 18 Oct 2020 16:55:57 +0000
Embedded: GM_16(d)_reply_letter.msg
Sender:
Subject: GM 16(d) reply letter
Message-Id:
<SN5P110MB05425734CD0AF40FAB89023292010@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
Cc:
Cc:
EFTA00023328


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=== Page 1 ===
From:
To:
Cc:
Subject: FW:
Birth Certificate
Date: Tue, 03 Aug 2021 21:47:22 +0000
Attachments:
Certificate_1.pdf;
Birth_Certificate_Identified_and_obtained.pdf
This is what
had asked
to save and put in the next production.
From:
Sent: Wednesday, July 28, 2021 6:06 PM
To:
Cc:
is
Subject: FW:
Birth Certificate
Hi
Could you please save these in the subpoena returns folder and also in a folder for the next discovery production? Thanks.
From:
Sent: Wednesday, July 28, 2021 6:02 PM
To:
is
is
Cc:
Subject:
Birth Certificate
See attached.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
EFTA00022346


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=== Page 1 ===
From:
To:
Subject: RE: Fourth Production - Scene2Go
Date: Tue, 29 Sep 2020 14:58:14 +0000
Attachments:2020.09.29_Maxwell_Discovery_Letter.docx 2020.09.29_MDC - Maxwell_MAIN.docx
Attached are both cover letters. I also overlooked the most recent JPMorgan production that we received:
Luckily, it's much smaller than the previous productions we've received and can thus be re-stamped manually. Let me
know if you'd like me to do so for this production.
From:
Sent: Monday, September 28, 2020 9:00 PM
To:
Subject: RE: Fourth Production - Scene2Go
Thanks, would you send me a cover letter for each, please?
From:
Sent: Monday, September 28, 2020 3:36 PM
To:
Subject: RE: Fourth Production - Scene2Go
Those are ready as well.
From:
Sent: Monday, September 28, 2020 3:34 PM
To:
Subject: RE: Fourth Production - Scene2Go
Thank you both so much! Would you please send me a draft cover letter?
Once you get the
straightened out, please let me know.
Also, how are the replacement files for Maxwell's MDC drive coming?
From:
Sent: Monday, September 28, 2020 3:31 PM
To:
Subject: RE: Fourth Production - Scene2Go
EFTA00020861

=== Page 2 ===
Hi all,
All the materials have been stamped and are ready to go. A big shout out to
for a great job on her first stamping
project. We went ahead and stamped the two
productions that are not password locked. The other two
we still have to figure out how to open. I've been in contact with
who has one of the productions that we
need. The first files he sent over were corrupted; I'm hoping that the second time is the charm.
From:
Sent: Friday, September 25, 2020 2:05 PM
To:
Subject: RE: Fourth Production - Scene2Go
Ah got it, sorry I was confused. That plan for marking is fine with me, thanks.
From:
Sent: Friday, September 25, 2020 2:04 PM
To:
Subject: RE: Fourth Production - Scene2Go
Hey
I believe what
meant was that we would still be producing everything in the folder but would only stamp select
files; in doing so we'd be avoiding the filler and supporting files which don't contain any viewable data.. My thinking is
that we stamp only the folders and leave the files as they are since the structure and contents of the folder are already
confusing as is. On something like this, defense will be leaning entirely on the manual that is included for viewing. I fear
that if we were to alter file names it would greatly complicate the process of figuring out how to work the files.
Thanks,
From:
Sent: Friday, September 25, 2020 1:51 PM
To:
Subject: RE: Fourth Production - Scene2Go
Hi
Thanks very much for working through this. My preference is to produce everything where possible. Is it possible to
produce the entirety of the files and app related to LSJ Scene2Go? We are trying to produce everything we can.
Thanks,
From:
Sent: Friday, September 25, 2020 11:15 AM
To:
EFTA00020862

=== Page 3 ===
Subject: Fourth Production - Scene2Go
Hi all,
I'm bates stamping files within the Fourth Production folder, and one of the items we're going to produce is called "LSJ
Scene2Go." From what I gather, this is an application for viewing 3D maps - in this case, there's a 3D view of the grotto
and the main structure. When not viewed in the Scene2Go app itself, you can view screenshots of the 3D maps, and I'm
assuming these images are what we want to produce.
For your reference, here are the files pertaining to the grotto
and those pertaining to the main structure
(
In each location,
the "map" and "scans" folders contain the viewable files. Within the map folder is an aerial view, and within the scans
folder are essentially screenshots of the 3D view of the landscapes. Each view is saved 7 different times, each increasing in
size. For the sake of easy review, I think that only the largest (and highest quality) images should be stamped, instead of
stamping every duplicate.
This looks similar to the issues we faced with the Second Production, as the vast majority of files within the larger
Scene2Go folder are system- or application-generated files that simply accompany the files (in this case, scans and maps
of the grotto and the main structure) that are actually viewable and of interest. I'm thinking it would be best to just stamp
these viewable files, along with the Scene2Go user manual (for context), but of course I wanted to run this by you all first.
l'll defer to your better judgement!
I'm happy to talk this over further as well - thank you so much!
EFTA00020863


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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: U.S. V Thomas, No. 19 Cr 830 - Discovery Production 6
Date: Wed, 14 Oct 2020 21:17:40 +0000
Embedded: :U.S._v_Thomas,_No._19_Cr_830__Discovery_Production_6.nsg
Sender:
Subject: U.S. V Thomas, No. 19 Cr 830 - Discovery Production 6
Message-Id:
<BN3P110MB0529420A5F085CAC57486CF5F5050@BN3P110MB0529.NAMP110.PROD.OUTLOOK.COM
>
Cc:
Cc:
EFTA00021986


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=== Page 1 ===
From:
To:
Subject: RE: Hello
Date: Tue, 09 Jul 2019 13:11:25 +0000
Importance: Normal
Thanks very much,
Kind of you to reach out. Excited to see that you're in EDVA-hope all is well.
From:
Sent: Monday, July 8, 2019 11:53 AM
To
Subject: Hello
Hi
I read you are working on the Epstein case. It seems like an excellent and very important case! I'm glad (and unsurprised)
to see you are doing so well up there.
Best regards,
Special Assistant United States Attorney
Eastern District of Virginia
EFTA00021195


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=== Page 1 ===
From:
To:
Cc:
Subject: 5th Production cover letters
Date: Mon, 19 Oct 2020 20:05:39 +0000
Attachments: 2020.10.19 Maxwell_Discovery_Letter.docx; 2020.10.19_MDC - Maxwell_MAIN.docx;
2020.10.19_MDC - Maxwell_PASSWORD.docx
Hi, all!
I'm preparing the 5th Production to go out today, and I've attached the cover letter for defense counsel and two cover
letters for Maxwell (one main cover letter to be included with the drive sent to MDC, and one letter containing the
password to be sent in a separate envelope to MDC). Please review at your convenience; once you approve, I'll have both
drives sent out.
Thank you very much!
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
a
EFTA00022051


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Case 1:19-cr-00830-AT Document 56 Filed
5
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 5/25/2021
SOUTHERN DISTRICT OF NEW YORK
United States of America
Deferred Prosecution Agreement
V.
19 Cr. 830 (AT)
Michael Thomas,
Defendant.
TO:
MICHAEL THOMAS
On November 19, 2019, a grand jury sitting in this District returned a six-count indictment
(the "Indictment"), which charged Michael Thomas ("you") with committing offenses against the
United States, to wit, conspiring to knowingly defraud the United States and to knowingly make
and use a false writing or document, in violation of 18 U.S.C. § 371, and three counts of knowingly
making and using a false writing or document, in violation of 18 U.S.C. $ 1001. However, after a
thorough investigation, and based on the facts of this case and your personal circumstances, the
U.S. Attorney's Office for the Southern District of New York ("USAO-SDNY") has determined
that the interests of justice will best be served by deferring prosecution in this District. Upon your
acceptance of responsibility for your behavior and by your signature on this deferred prosecution
agreement (the "Agreement"), prosecution will be deferred during the term of your behavior and
satisfactory compliance with the terms of this Agreement for the period of six months from the
date of this Agreement.
The terms and conditions constituting your good behavior and satisfactory compliance are
as follows:
(1)
You shall refrain from violating any federal, state, or local law. You shall immediately
contact your U.S. Pretrial Services Officer if arrested or questioned by a law-
enforcement officer.
(2)
You shall associate only with law-abiding persons.
(3)
You shall work regularly at a lawful occupation, regularly attend school, and/or support
or care for your legal dependents, if any, to the best of your ability, as approved by your
U.S. Pretrial Services Officer. You shall notify your supervising U.S. Pretrial Services
Officer prior to any work or school changes.
(4)
You shall not leave the contiguous United States without permission of your
supervising U.S. Pretrial Services Officer. In accordance with this condition, the U.S.
Pretrial Services Office shall return your passport upon the Court's entering this
Agreement, and shall do so indefinitely unless this Agreement is violated.
- 1
EFTA00023092

=== Page 2 ===
Case 1:19-cr-00830-AT Document 56 Filed 05/25/21 Page 2 of 5
(5)
You shall notify your supervising U.S. Pretrial Services Officer immediately of any
change in your place of residence.
(6)
You shall follow your supervising U.S. Pretrial Services Officer's instructions and
advice.
(7)
You shall report to your supervising U.S. Pretrial Services Officer as directed.
As a further condition you hereby consent to disclosure, by any federal, state, or local
government agency, or by any medical or substance abuse treatment provider, to the U.S. Pretrial
Services Officer supervising your case, of such medical and treatment records as may be requested
by the Pretrial Services Officer to evaluate deferral of prosecution in this case. You further agree
that you will execute any additional consent forms that any such agency or provider may require
to release such information.
Special conditions are as follows:
You shall truthfully and completely disclose all information with respect to the activities
of yourself and others related to your employment by the Bureau of Prisons ("BOP"), which
information can be used for any purpose. You shall agree to meet with and be interviewed by the
USAO-SDNY, the Federal Bureau of Investigation, the Department of Justice, Office of the
Inspector General ("DOJ-OIG"), and any other law enforcement agency designated by this Office.
You shall complete 100 documented hours of community service, preferably related to the
criminal justice system, including working with recently released inmates. The specific type of
community service to be performed must be approved by your Pretrial Services Officer.
The USAO-SDNY may at any time revoke or modify any condition of this provisional
release or change the period of such supervision, which shall in no case exceed six months. The
USAO-SDNY may discharge you from supervision at any time. The USAO-SDNY may at any
time proceed with the prosecution for this offense should the USAO-SDNY, in its sole discretion,
deem such action advisable.
If upon completion of your supervision a written report from your supervising U.S. Pretrial
Services Officer is received to the effect that you have complied with all the rules, regulations and
conditions and special conditions applicable to your deferred prosecution, no further prosecution
will be instituted in this District for the above offenses.
Nothing in this Agreement shall be interpreted to preclude the BOP or the DOJ-OIG from
taking any administrative action against you, including suspension or termination of employment,
based on the facts alleged in the Indictment, the facts identified in the course of the investigation
that led to the Indictment, or your own statements to the DOJ-OIG or any other law enforcement
entity. Nothing in this Agreement shall be interpreted to require the BOP or the DOJ-OIG to delay
- 2
EFTA00023093

=== Page 3 ===
Case 1:19-cr-00830-AT Document 56 Filed 05/25/21 Page 3 of 5
any administrative action until after the expiration of the period of deferment contemplated by this
Agreement. You agree that a copy of this Agreement, including your admission and acceptance
of responsibility, shall be provided to the BOP.
*
*
*
If you successfully complete the term of supervision and fulfills all the terms and
conditions of this Agreement, the Government will move the Court to dismiss the Indictment as to
the defendant.
It is further understood that this Agreement and the terms and conditions set forth herein
are limited to the facts and circumstances of this case and lack precedential value.
Dated: New York, New York
May 20, 2021
United States Attorney for the
Southern District of New York
By: Jusica Lonergan
Assistant United States Attorneys
Tel.:
- 3 -
EFTA00023094

=== Page 4 ===
Case 1:19-cr-00830-AT Document 56 Filed 05/25/21 Page 4 of 5
The undersigned hereby consents to the foregoing. The undersigned hereby further admits
that he willfully and knowingly completed materially false count and round slips regarding
required counts and rounds in the Special Housing Unit of the Metropolitan Correctional Center
("MCC") on August 9, 2019 and August 10, 2019. The undersigned expressly waives any and all
rights to a speedy trial pursuant to the Sixth Amendment to the United States Constitution, the
Speedy Trial Act, §§ 3161 et seq., and any other pertinent provisions, and consents to the
adjournment of all pending proceedings in this case. The undersigned further waives the
applicable statute of limitations with respect to any prosecution that is not time-barred on the date
that this agreement is signed. It is the intent of this provision to toll the applicable statute of
limitations during the pendency of the deferred prosecution.
The undersigned understands that pursuant to Title 18, United States Code, Section
3161(h)(2), this Agreement is subject to approval by the Court. Should the Court refuse to
approve, and thereby reject, this Agreement, neither party shall be bound to any term of this
Agreement, and no admissions in this Agreement may be used against the undersigned.
Finally, the undersigned acknowledges that he has read this Agreement and has carefully
reviewed each provision with his attorney. The undersigned and his attorney acknowledge that no
threats, promises, or representations have been made, nor agreements reached, other than those set
forth in this Agreement. The undersigned further acknowledges that he understands and
voluntarily accepts each and every term and condition of this Agreement.
Dated: New York, New York
May 20 , 2021
Montell Figgins
Montell Figgins (May 20, 2021 15:49 EDT)
Michael MothaP theme Thomas (May 20, 2021 16:04 EDT)
Montell Figgins, Esq.
Michael Thomas
Attorney for Defendant
Defendant
- 4
EFTA00023095

=== Page 5 ===
Case 1:19-cr-00830-AT Document 56 Filed 05/25/21 Page 5 of 5
Pursuant to 18 U.S.C. §3161(h)(2), exclusion under the Speedy Trial Act of the period of
time during which the prosecution of the defendant is deferred pursuant to this Agreement is
hereby approved.
Dated: New York, New York
May 25, 2021
Honorable Analisa Torres
United States District Judge
The undersigned hereby consents to the foregoing and will accept supervision of the
above-named defendant on the conditions set forth herein.
Dated: New York, New York
May , 2021
Francesca
Digitally signed by
Francesca Piperato
Piperato
Date: 2021.05.24 10:32:36
-04'00'
United States Pretrial Services Officer
- 5 -
EFTA00023096


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Date: Wed, 05 Aug 2020 23:13:47 +0000
That's extremely helpful, thanks so much. We'll plan to put the drive in the mail tomorrow, and of course please let us
know if any issues arise.
thanks again,
From:
Sent: Wednesday, August 05, 2020 19:05
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Hard drives should be mailed to the facility to the attention of the legal department. We need to etch the drive with a
number and provide an authorization memo so she can retain it. Then it will be provided to her. It can be password
protected so long as you include a cover letter that contains the password for her.
Hope this helps,
>>>
8/5/2020 4:34 PM>>>
We have a hard drive with loaded discovery that we need to deliver to Ghislaine Maxwell,
at MDC. Could you
please let us know what the current protocol is for that? Also, it's our understanding that hard drives with discovery
materials for inmates needs to be non-encrypted (and not have a password for access), is that also correct?
We're hoping to get these materials to her tomorrow if at all possible, so we greatly appreciate your help. And I'm
reachable any time at
f it would be helpful to discuss.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00021873


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=== Page 1 ===
From:
To: Gloria Allred
Subject: Automatic reply: E-TICKET RECEIPT -
- Travel Date: 26AUG19 -
Ref: XHKCBU
Date: Mon, 26 Aug 2019 16:11:00 +0000
I am currently on trial before the Honorable Ronnie Abrams. I will be checking email at the end of each trial day. If you need immediate
assistance in connection with United States V. Epstein, 19 Cr. 490 (RMB), please contact AUSA
For all other matters,
please contact AUSA
Thank you.
EFTA00020994


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=== Page 1 ===
From:
To:
Subject: RE: 2021-11-12 GM letter re CC statements v2.docx
Date: Fri, 12 Nov 2021 22:41:38 +0000
Yep. I think because
turned 18 in 2004 or 2005, and at the time we didn't have
saying it kept going
into 2005
From:
Sent: Friday, November 12, 2021 1:45 PM
To:
Subject: 2021-11-12 GM letter re CC statements v2.docx
This looks good to me - one small comment in a bubble. And this certainly underscores your point/joke about
superseding. Why did we cut off the conspiracy in 2004?
EFTA00023354


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 260 Filed 04/30/21 Page 1 of 2
CG
800 Third Avenue
COHEN & GRESSER LLP
New York, NY 10022
+1 212 957 7600 phone
USDC SDNY
www.cohengresser.com
DOCUMENT
Christian R. Everdell
ELECTRONICALLY FILED
DOC #:
DATE FILED: 5/3/21
April 30, 2021
BY ECF
The Honorable Alison J. Nathan
Counsel for the MDC may
United States District Court
5/3/21
submit any objection to
Southern District of New York
Alim D. Netto
the Defendant's request by
United States Courthouse
May 4, 2021.
so ORDERED.
SO ORDERED.
ALISON NATHAN U.S.D.J.
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write to respectfully request the Court to issue an order to the MDC directing it to
accept two hard drives from defense counsel that contain the non-Highly Confidential discovery in
this case for Ms. Maxwell's use at the MDC.
In an effort to facilitate Ms. Maxwell's review of the discovery, defense counsel have
created a master set of two hard drives that contain a complete set of the discovery produced by
the government so far, excluding the materials marked Highly Confidential, which Ms. Maxwell is
not permitted to possess in the MDC pursuant to the terms of the Protective Order. The master
drives are easier to use than her existing hard drives because they collect all of the material in one
place and organize the documents in a more user-friendly format. For example, the November 18,
2020 production containing roughly 2.2 million pages was produced in load file format, which
contains images of individual pages of documents in native file format, image file format, and
other formats. The hard drives organize these files by document, as opposed to by page, and
eliminate duplicative file formats so that Ms. Maxwell will not have to add countless hours to her
review.
Defense counsel would like to send these hard drives to Ms. Maxwell for her to use in the
MDC. We were informed by the MDC Legal Department that they are only permitted to accept
hard drives that are loaded and certified by the U.S. Attorney's Office. We have conferred with
the government, which has advised that it does not object to the defense making an application to
the Court to issue an order directing the MDC to accept the hard drives. The government
requested, however, that the Court allow MDC legal counsel the opportunity to note their
objections to the Court.
EFTA00022514

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 260 Filed 04/30/21 Page 2 of 2
The Honorable Alison J. Nathan
April 30, 2021
Page 2
Accordingly, we respectfully request that the Court issue an order directing the MDC to
accept the master hard drives either from defense counsel or from the government. We will send a
copy of this letter to the MDC Legal Department so that they can note any objections they may
have.
Thank you for your attention to this matter.
Sincerely,
/s/ Christian Everdell
COHEN & GRESSER LLP
cc:
All Counsel of Record (By ECF)
MDC Legal Department
EFTA00022515


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=== Page 1 ===
Prage110622
USDC SDNY
DOCUMENT
UNITED STATES DISTRICT COURT
ELECTRONICALLY FILED
SOUTHERN DISTRICT OF NEW YORK
DOC #:
DATE FILED: 11/18/21
X
:
:
UNITED STATES OF AMERICA
:
[PROPOSED] ORDER
:
- V. -
:
S2 20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
:
:
Defendant.
:
:
X
ALISON J. NATHAN, United States District Judge:
WHEREAS the Court has ordered that certain witnesses
will be permitted to testify either using pseudonyms or only using
first names (the "Protected Witnesses"). See 11/01/21
Tr.
at
11:13-17) ;
WHEREAS to effectuate that order, it is necessary to
prohibit courtroom sketch artists from drawing exact likenesses of
the Protected Witnesses;
IT HEREBY IS ORDERED:
1. That courtroom sketch artists - whether in the
courtroom or overflow rooms - may not draw exact likenesses of the
Protected Witnesses; and
1
EFTA00023385

=== Page 2 ===
Caase11200ecr0033B0AAJN Prage220622
2. For avoidance of doubt, courtroom sketch artists
may confer with the Court or counsel for either party to determine
whether a witness is a Protected Witness.
SO ORDERED:
Dated:
New York, New York
November 18, 2021
Alim D.Netto
HONORABLE ALISON J. NATHAN
United States District Judge
2
EFTA00023386


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=== Page 1 ===
From:
"
To:
Subject: Accepted: Epstein scheduling conference
Date: Thu, 18 Jul 2019 16:18:27 +0000
Importance: Normal
Attachments: unnamed
EFTA00020945


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=== Page 1 ===
From:
To:
Subject: FW: Motions to Suppress
Date: Mon, 22 Feb 2021 18:59:12 +0000
Attachments: Motion_to_Suppress_Opp_v6.docx
I can start looking at this.
From:
Sent: Monday, February 22, 2021 1:44 PM
To:
Cc:
Subject: RE: Motions to Suppress
Thanks very much. Attached is a revised draft for your review. Should I plan to send this to
after I get back your next
edits? I gave him a heads up that I was hoping to send it to him later today. Separately, I have been thinking a bit more
about the documents that we are planning to attach as exhibits, and I was hoping that we could discuss as a team with
you both. I was hoping to do that before I reach out to
to let her know our plan. I'm available for a call
whenever is best for others today.
Thanks,
From:
Sent: Saturday, February 20, 2021 6:02 PM
To:
is
Cc:
is
is
Subject: RE: Motions to Suppress
Really nice work on this. Some combined comments in track. Would love to see again after you've had a chance to
review/clean up and, of course, happy to discuss in the interim.
From:
Sent: Thursday, February 18, 2021 4:44 PM
To:
is
Cc:
is
is
Subject: Motions to Suppress
Attached is a draft of the opposition to the defense's suppression motions (motions 3 and 11), which are attached here for
reference. I wrote this as one section with several subheadings since I think the issues are entangled (and that helps
explain the length of this), but happy to discuss further.
edits are incorporated in this draft.
Thanks,
EFTA00021377


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
(USANYS)
[Contractor]"
Cc:
(USANYS) [Contractor]"
)"
)"
)"
Subject: RE: GM FedEx Project
Date: Wed, 21 Jul 2021 19:32:20 +0000
Attachments: 2021.07.21_Maxwell_Discovery_Letter.docx
Hey
Sounds good on those names. We will get this done after pushing out the 3500.
In looking at the FedEx documents we are pretty confident that they were never produced in discovery. I've downloaded
and stamped them, and drafted a cover letter (attached). Should these materials be stamped with the same text that
sent previously ("SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17")? If so, I'll add it to each
of them.
There are also a number of additional materials that are saved in a pending production folder here:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Discovery\GM\27Eighteenth Production (2021-07-
xx)
Are these materials good to be stamped as well or should we just produce the FedEx materials and wait on the rest?
Thanks,
From:
(USANYS)
Sent: Wednesday, July 21, 2021 2:40 PM
To:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
is
)
is
Subject: RE: GM FedEx Project
Thanks so much for helping out with this project. As discussed, here are the names to look for:
As always, let us know if you have any questions.
Thanks,
EFTA00023043

=== Page 2 ===
From:
(USANYS) [Contractor]
Sent: Monday, July 19, 2021 10:31 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS)
is
is
is
)
Subject: Re: GM FedEx Project
Hi everyone! I'm free any time on Wednesday, but I'm out on Thursday. Thanks!
Sent from my iPhone
On Jul 19, 2021, at 8:08 PM,
(USANYS) [Contractor]
wrote:
I'm also free the same times on Wednesday and all day on Thursday.
On Jul 19, 2021, at 8:03 PM,
(USANYS) [Contractor]
wrote:
Wednesday I'm available before 12:30 and after 2:30, and Thursday I'm available anytime in the afternoon (essentially
anytime after we're done with defense's review of the stuff for
).
Sent from my iPhone
On Jul 19, 2021, at 7:55 PM,
(USANYS)
> wrote:
Hi paralegals extraordinaire,
Do you have a few minutes to speak about a project we were hoping you could work on for Maxwell? I'm pretty
flexible Wednesday and Thursday if you guys want to confer and let me know some times that work for you for a call.
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
Tel:
EFTA00023044


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=== Page 1 ===
From: "Biase, Nicholas (USANYS)"
To:
Subject: https://deadline.com/2021/01/eleventh-hour-films-options-ghislaine-maxwel-podcast-
1234672637/
Date: Wed, 13 Jan 2021 20:06:37 +0000
Nicholas Biase
Spokesman
United States Department of Justice
U.S. Attorney's Office | Southern District of New York
EFTA00021716


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=== Page 1 ===
Good morning Sir
Last night a source extended dates on bike path. Epstein riding with young girl to Feb 21.
2 sightings between Feb 13-21, 2019.
One just below Royal Poinciana Bridge
Second just below Sailfish Club Palm Beach
Also apparently young girl wad not tall, brunette, wearing a ponytail and looked 18 give or take a f
ew years? Could not say for certain.
JE was wearing a baseball cap.
It seems they were walking on bike path.
In December a different source had spotted JE and what seemed a very young girl.
I told
Former PB chief of police.
He explained cameras only keep video for 3 months. That first incident happened sometime in Nov. I W
as told January.
Nothing was done to follow up.
This is a different source and now another sighting.
Thank you
Good day
EFTA00020778


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: Epstein
Date: Thu, 25 Jul 2019 19:28:22 +0000
Attachments: EPphotos.pdf; ATT00001.htm; EP.staffmemos.pdf; ATT00002.htm
As discussed, these have not yet been reviewed by anyone. If you could have a walled off AUSA review and report back to
me, I'd appreciate it. Thanks
From:
)
Sent: Thursday, July 25, 2019 3:24 PM
To:
(USANYS)
Subject: Fwd: Epstein
,
As discussed, I have not opened the attachments to the below email.
Begin forwarded message:
From:
To:
)"
Cc:
(USANYS)"
Subject: Re: Epstein
,
Thank you. Attached please find the staff memos and photos that were taken. Please advise if you need to
share this with Main Justice so that I can make appropriate notifications on BOP's end.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
New York, New York 10007
p:
f:
"
)"
7/25/2019 2:08 PM
Thanks
Please consider this email my request for any and all documents and other materials, including
photographs, related to the investigation regarding the incident involving Jeffrey Epstein earlier this week.
EFTA00020627

=== Page 2 ===
On Jul 25, 2019, at 1:49 PM,
wrote:
Hi
,
I left you a voicemail, but wanted to follow up via email as well.
Our Regional Office reminded me that we need a written request from your office to produce the documents
you seek. It does not have to be a subpoena. An email from you requesting the investigation documentation
will suffice.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
New York, New York 10007
p:
f:
EFTA00020628


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=== Page 1 ===
From:
"
(
)"
To:
)"
)"
Subject: RE: Epstein
Date: Mon, 09 Dec 2019 22:26:34 +0000
Let's do 12:30.
Original Message
From:
)
Sent: Monday, December 9, 2019 4:39 PM
To:
(
)
i
;
(
Subject: RE: Epstein
Yes. Either one is fine.
Original Message
From:
(
)
Sent: Monday, December 9, 2019 4:30 PM
To:
)
i
(
)
Subject: RE: Epstein
Sure. We just met with the team.
Would 12:30 or 1 work?
Original Message
From:
)
Sent: Monday, December 9, 2019 4:13 PM
To:
(
)
i
(
)
Subject: Epstein
Can we talk Epstein tomorrow?
Sent from my iPhone
EFTA00022172


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=== Page 1 ===
From:
To:
Subject: Automatic reply: Epstein
Date: Mon, 26 Aug 2019 16:40:51 +0000
I am currently on trial before the Honorable Ronnie Abrams. I will be checking email at the end of each trial day. If you need immediate
assistance in connection with United States V. Epstein, 19 Cr. 490 (RMB), please contact AUSA
at
For all other matters,
please contact AUSA
-
at
Thank you.
EFTA00020993


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=== Page 1 ===
From
To
Subject: FW: SDNY Homepage
Date: Tue, 16 Jul 2019 18:35:28 +0000
Importance: Normal
Attachments: Epstein_Homepage.png
Inline-Images: image001.png
I think this is a good idea, but defer to you two.
From
Sent: Tuesday, July 16, 2019 2:33 PM
To:
Cc:
Subject: SDNY Homepage
How would you guys feel about linking the victim/witness page to the attached image? It would replace the one pictured below.
Search
THE UNITED STATES ATTORNEY'S OFFICE
SOUTHERN DISTRICT of NEW YORK
SEARCH
HOME
ABOUT
DIVISIONS
RESOURCES
NEWS
PROGRAMS
EMPLOYMENT
CONTACT
SOCIAL MEDIA
f
Tweets by @SDNYnews
US Attorney SDNY
OF
@SDNYnews
Iranian national extradited and
charged, along with 2 others, with
exporting carbon fiber from the US
the
to Iran go.usa.gov/xym5n
VEO
CRITED
JUSTITIA
Manhattan U....
STATES
justice.gov
DEPARTMENT
musal
Public Service Announcement
on Sexual Assault in Public
24m
Housing
1
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US Attorney SDNY
@SDNYnews
JUSTICE 101
Welcome to the U.S. Attorney's Office for the Southern District of
USA Berman Polluters will be held
New York, which encompasses the boroughs of Manhattan and the
to account, even in bankruptcy, for
Bronx in New York City, along with Dutchess, Orange, Putnam,
contaminating the environment
Rockland, Sullivan, and Westchester counties. The Office prosecutes
cases involving violations of federal laws, and represents the interests
20h
of the United States government and its agencies in criminal and civil
matters. The Office investigates and prosecutes a broad array of
criminal conduct of every conceivable magnitude, even when the
NEWS
Community Outreach
conduct arises in distant places. Today, the Office is at the forefront of
many important areas of criminal law enforcement, including
July 16, 2019
Giving back to the community
terrorism, white collar and cyber crime, mortgage fraud, public
Manhattan U.S. Attorney
through a variety of venues &
corruption. gang violence. organized crime. international narcotics
Announces Extradition Of
initiatives.
Public Affairs
United States Department of Justice
U.S. Attorney's Office [Southern District of New York
EFTA00021406


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From:
"
(USANYS) [Contractor]"
To:
)"
,
)"
Cc:
)"
Subject: RE:
Date: Wed, 05 Aug 2020 19:58:27 +0000
Attachments: Discovery.zip
Here is a zip!
From:
Sent: Wednesday, August 5, 2020 3:55 PM
To:
Cc:
is
(USANYS) [Contractor]
Subject: FW:
thanks very much for jumping on this.
per my email a moment ago. It may be easiest to zip these and send that way, or otherwise to send in two emails
since the total file size is large.
Please anyone let me know if any issues? And thanks again to all for the quick fix.
From:
(USANYS) [Contractor]
Sent: Wednesday, August 05, 2020 15:50
To:
Subject:
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
EFTA00021874


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From:
To:
Subject: Memorandum endorsement in 20-cr-330, US V Maxwell
Date: Mon, 03 May 2021 14:44:52 +0000
Attachments:20cr330_Memo_Endorsement_5.3.21.pdf
Counsel,
Please find attached a memorandum endorsement signed by Judge Nathan, which has been filed on the public
docket.
Respectfully,
The Chambers of the Hon. Alison J. Nathan
EFTA00022513


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From:
To:
Subject: RE: GX-52G
Date: Fri, 12 Nov 2021 18:39:53 +0000
Attachments: GX-52-G.pdf; 7._Motion_to_Exclude_Government_Exhibit_52.pdf;
!2021.10.27_Maxwell_Reply_ISO_Motns_In_Limine.pdf;
72_obstruction_case_302s_Part1.pdf
Attached. Also attaching the defense motions in case that's helpful. Also attaching some of the 302s from the 2009
obstruction case (which we produced to the defense a long time ago), in case that's helpful.
From:
Sent: Friday, November 12, 2021 1:29 PM
To:
Subject: GX-52G
Will you send a copy?
Deputy Chief, Public Corruption Unit
Southern District of New York
Office:
Cell:
Email:
EFTA00023353


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From:
To:
Subject: Ho bail appeal response
Date: Tue, 23 Jul 2019 17:24:17 +0000
Embedded: RE: Breaking News: A federal judge denied Jeffrey Epstein bail, rejecting_his_request_t
o_stay_in_his_mansion_under_guard_until_his_sex-trafficking_trial.msg
Attached, and I think the Boustani papers also will be very helpful. This doc also saved in the share.
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From:
To:
Subject: 19-2221 United States of America V. Epstein "Attorney ADDED"
Date: Tue, 06 Aug 2019 12:46:01 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 08/06/2019
Case Name:
United States of America V. Epstein
Case Number: 19-2221
Docket Text:
ATTORNEY,
for United States of America, in case 19-2221 , [16], ADDED.[2624733] [19-
2221]
Notice will be electronically mailed to:
Martin G. Weinberg, -:
Reid Weingarten, -:
,
Notice will be stored in the notice cart for:
Quality Control 1
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From:
To:
Cc:
Subject: RE: Request re Ghisliane Maxwell
Date: Fri, 08 Jan 2021 17:01:41 +0000
Np!!
1/8/2021 12:00
PM
Thanks very much and sorry I missed your response.
Original Message
From:
Sent: Friday, January 8, 2021 12:00 PM
To
4
Co
Subject: RE: Request re Ghisliane Maxwell
I responded earlier today. No, unfortunately not. It would have to
come from your office.
1/8/2021 11:58
AM
Good morning,
Following up on this email, would it be acceptable for someone from the
defense to deliver this new drive from our office to the MDC today,
please?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York NY 10007
<mailto:
From:
Sent: Thursday, January 7, 2021 4:35 PM
T
C
Subject: Request re Ghisliane Maxwell
EFTA00021711

=== Page 2 ===
Good afternoon,
At the request of defense counsel, our office is preparing a new drive
with a copy of discovery material that was previously produced to
Ghislaine Maxwell on a CD, but which she has been unable to view. The
drive will be ready tomorrow. Today, defense counsel asked that Maxwell
be able to review those materials over this coming weekend, but no one
from our office is available to hand deliver the drive tomorrow, and we
understand that Maxwell would not receive a FedEx package sent out
tomorrow until next week. Defense counsel has offered to pick the drive
up from our office and hand deliver it to the MDC themselves tomorrow.
Would that be permissible?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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From:
To:
Cc:
Subject: Urgent - Epstein
Date: Tue, 23 Jul 2019 21:22:59 +0000
Are either of you able to call my cell
regarding Epstein as soon as possible, please?
Thanks,
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=== Page 1 ===
Case 1:19-cv-10475-LGS-DCF Document 118 Filed 02/10/21 Page 1 of 6
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
:
:
Plaintiff,
:
19 Civ. 10475 (LGS)
:
-against-
:
OPINION AND
:
ORDER
DARREN K. INDYKE, in his capacity as executor
:
of the Estate of Jeffrey Edward Epstein, et al.,
:
:
Defendants.
:
X
LORNA G. SCHOFIELD, District Judge:
On January 21, 2021, Plaintiff
filed
motion to dismiss this action with
prejudice, pursuant to Federal Rule of Civil Procedure 41()(2). In connection with her motion,
Plaintiff filed
proposed order of dismissal imposing certain conditions (the "Proposed Order").
Defendant Ghislaine Maxwell opposed the motion. For the following reasons, subject to
Plaintiff's consent, dismissal is granted pursuant to the terms of the Proposed Order modified as
described below.
I.
BACKGROUND
On November 12, 2019, Plaintiff filed
Complaint against Ms. Maxwell and Defendants
Darren K. Indyke and Richard D. Kahn in their official capacities as appointed executors of the
Estate of Jeffrey E. Epstein (the "Estate") (Indyke and Kahn together, the "Co-Executors"). The
Complaint alleges claims of battery, false imprisonment and intentional infliction of emotional
distress under New York law. These claims stem from and/or arise in connection with Mr.
EFTA00023488

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Case 1:19-cv-10475-LGS-DCF Document 118 Filed 02/10/21 Page 2 of 6
Epstein's and Ms. Maxwell's alleged sexual abuse of Plaintiff. Defendants did not file
counterclaims.
On June 2, 2020, the Superior Court of the United States Virgin Islands granted the Co-
Executors' motion to establish the Epstein Victims' Compensation Program,
voluntary
independent program designed to compensate and resolve the claims of victims of sexual abuse
by Jeffrey Epstein (the "Program"). On June 22, 2020, based on an understanding that Plaintiff
wished to participate in the Program and that participation could result in the resolution of
Plaintiff's claims, Judge Freeman stayed this case. The case remains stayed.
On June 26, 2020, Plaintiff submitted
claim to the Program. Before submitting her
claim, Plaintiff was ensured that compensation offers and information submitted to the Program
would be confidential. Plaintiff's participation in the Program resulted in her receipt and
acceptance of an offer of compensation on October 5, 2020. In exchange for the offer of
compensation, Plaintiff executed
release, releasing the Estate, Mr. Epstein and other related
entities and individuals, including Ms. Maxwell, from any and all claims (the "General
Release"). To receive her compensation, Plaintiff must dismiss with prejudice any existing
lawsuits against the Estate and related entities and individuals -- including this lawsuit.
To conclude her participation in the Program, Plaintiff now moves for Rule 41
)(2)
dismissal of all claims with prejudice. In connection with her motion, Plaintiff filed the
Proposed Order, to which the Co-Executors do not object. The Proposed Order states that
dismissal is "with prejudice," and that each party shall "bear its own attorneys' fees and costs."
It also states that "Plaintiff shall provide Ms. Maxwell with
copy of the General Release, with
the compensation amount redacted" and that "[t]he parties shall not dispute the authenticity of
this copy of the General Release in any future proceedings." In addition, the Proposed Order
2
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Case 1:19-cv-10475-LGS-DCF Document 118 Filed 02/10/21 Page 3 of 6
includes language that preserves Defendants' rights and legal positions with respect to
indemnity.
Ms. Maxwell objects to dismissal pursuant to the Proposed Order on the grounds that she
will be unduly prejudiced if (1) Plaintiff is not required to provide an unredacted copy of the
General Release, showing Plaintiff's compensation, and (2) each party is required to bear its own
attorneys' fees and costs. Ms. Maxwell accordingly requests that the Court impose the following
conditions on dismissal: (1) Plaintiff must provide copy of the unredacted General Release and
(2) Ms. Maxwell is entitled to costs and may seek attorneys' fees in another action and at another
time.
II.
STANDARD
Rule 41()(2) states as relevant here, "Except as provided in Rule 41()(1) [which
describes voluntary dismissals made either before the defendant files
responsive pleading or on
consent], an action may be dismissed at the plaintiff's request only by court order, on terms that
the court considers proper." Fed. R. Civ. P. 41()(2). district court may exercise its "sound
discretion" in deciding
Rule 41()(2) motion. Catanzano V. Wing, 277 F.3d 99, 109 (2d Cir.
2001); accord Stinson V. City Univ. of New York, No. 18 Civ. 5963, 2020 WL 2133368, at *2
(S.D.N.Y. May 4, 2020).
Although "[v]oluntary dismissal without prejudice is
not
matter of right" and is
subject to substantial scrutiny, Zagano V. Fordham Univ., 900 F.2d 12, 14 (2d Cir. 1990)
(emphasis added); accord Stone V. Fisher, No. 20 Civ. 1818, 2020 WL 2765107, at *2 (S.D.N.Y.
May 28, 2020), motion for voluntary dismissal with prejudice is generally subject "to far less
scrutiny," HOV Servs., Inc. V. ASG Techs. Grp., Inc., No. 18 Civ. 9780, 2021 WL 355670 at *2
(S.D.N.Y. Feb. 2, 2021) (collecting cases). On motion for voluntary dismissal with prejudice,
3
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Case 1:19-cv-10475-LGS-DCF Document 118 Filed 02/10/21 Page 4 of 6
the essential inquiry is "whether the voluntary dismissal 'will be unduly prejudicial to the
defendants." Nix V. Office of Comm'r of Baseball, No. 17 Civ. 1241, 2017 WL 2889503, at *2
(S.D.N.Y. July 6, 2017) (citing Lan V. Time Warner, Inc., No. 11 Civ. 2870, 2016 WL 6778180,
at *6 (S.D.N.Y. Oct. 18, 2016), report and recommendation adopted, 2016 WL 6779526
(S.D.N.Y. Nov. 15, 2016)). To avoid undue prejudice, courts have the authority to impose
conditions of dismissal, so long as plaintiff has an opportunity to withdraw her motion if she
"feels that the conditions are too burdensome." Paysys Int 'l, Inc. V. ATOS IT Servs. Ltd., 901
F.3d 105, 109 (2d Cir. 2018) (internal citation omitted).
III.
DISCUSSION
Ms. Maxwell will not be unduly prejudiced by dismissal. In this case, all the claims
against Ms. Maxwell will be dismissed, she did not file any counterclaims and dismissal is with
prejudice so that the claims cannot be brought against her again. She has not shown any
prejudice from the dismissal or its consequences. Nevertheless, Ms. Maxwell seeks to impose
two conditions on dismissal. These conditions are unnecessary to prevent prejudice that would
otherwise result from the dismissal because she has shown no such prejudice. As explained
below, the Court rejects one condition, and subject to Plaintiff's consent, would grant the other
requested condition.
First, Ms. Maxwell asks that the amount of Plaintiff's compensation from the Estate be
disclosed to her as
condition of dismissal. She argues that she needs the information (1) "to
make public" that plaintiff wanted money and not justice and (2) to cross-examine Plaintiff in
Ms. Maxwell's criminal trial. In effect, she is arguing that dismissal will deprive her of the
vehicle to obtain information she would use in other settings. This is not the type of prejudice
the rule was intended to prevent, and she cites no case to suggest that it is. The argument is
4
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Case 1:19-cv-10475-LGS-DCF Document 118 Filed 02/10/21 Page 5 of 6
flawed because she is entitled to information in this case only to defend against the claims in this
case. See Fed. R. Civ. P. 26(b)(1) (permitting discovery "relevant to any party's claim or
defense"). If there are no claims in this case as
result of dismissal, she is not entitled to
information in this case to defend against them. If she wants information to use in the court of
public opinion she must get it elsewhere. Similarly, if she wants information to use in her
defense in the criminal case, then she should try to obtain the information using the procedures
available in that case.
Ms. Maxwell asks as
second condition to strike the language in the Proposed Order that
"each party [is] to bear its own attorneys' fees and costs." Subject to Plaintiff's consent, the
Court would grant that application, not because the dismissal is otherwise prejudicial to
Defendant, but because adjudication of fees and costs is unnecessary to dismiss the case.
Ms. Maxwell states that she is not seeking attorneys' fees from Plaintiff at this time in
this action but does not wish to be precluded from doing so in
different action. The issue of
fees, therefore, is not ripe, and the parties can litigate it when and if Ms. Maxwell raises it.
The issue of costs similarly does not need to be resolved in order to grant dismissal. Ms.
Maxwell apparently intends to seek costs in this case, but she has not yet done so and the parties
have not fully briefed the issue.
prevailing party, including one in Ms. Maxwell's position, is
typically entitled to recover its costs. See Fed. R. Civ. P. 54(d)(1) ("Unless
federal statute, [the
federal] rules, or
court order provides otherwise, costs -- other than attorney's fees -- should be
allowed to the prevailing party."); see Carter V. Inc. Vill. of Ocean Beach, 759 F.3d 159, 165 (2d
Cir. 2014) ("
voluntary dismissal of an action with prejudice works
material alteration of the
legal relationship of the parties], because it constitutes an adjudication on the merits for purposes
of res judicata ") (internal citations and quotation marks omitted); accord K "oyitl ots 'ina, Ltd.
5
EFTA00023492

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Case 1:19-cv-10475-LGS-DCF Document 118 Filed 02/10/21 Page 6 of 6
V. Gottschalk, No. 19 Civ. 11309, 2020 WL 6690640, at *3 (S.D.N.Y. Nov. 12, 2020) (treating
defendant as the "prevailing party," after dismissal with prejudice and awarding costs).
However, "whether to award costs ultimately lies within the sound discretion of the district
court." Marx V. Gen. Revenue Corp., 568 U.S. 371, 377 (2013). It remains to be seen whether
Ms. Maxwell will move to recover her costs and in what amount, whether Plaintiff will oppose
the application, and if so, whether Plaintiff could overcome the presumption that Ms. Maxwell is
entitled to her costs.
Because the issues of attorneys' fees and costs need not be resolved in order to dismiss
this action, the Court is prepared to enter the Proposed Order, modified by striking the language
"with each party to bear its own attorneys' fees and costs." Plaintiff shall file letter no later
than February 12, 2021, stating whether she consents to this modification or wishes to withdraw
her motion for voluntary dismissal, in which case the Court will restore this matter to its active
calendar. See Paysys Int 'l. Inc., 901 F.3d at 109 (2d Cir. 2018) (holding that the plaintiff may
accept the court's conditions of dismissal or withdraw its dismissal motion and proceed with the
case).
IV. CONCLUSION
Plaintiff shall file
letter no later than February 12, 2021, stating whether she consents to
the Court's entry of the Proposed Order modified by striking the language "with each party to
bear its own attorneys' fees and costs," or wishes to withdraw her motion for voluntary
dismissal. The Clerk of Court is respectfully directed to close the motion at Docket No. 97.
Dated: February 10, 2021
New York, New York
LORNA G. SCHOFIELD
UNITED STATES DISTRICT JUDGE
6
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From:
To:
newyork
, "washington field"
Subject: JEFFREY EPSTEIN
Date: Tue, 23 Jul 2019 21:49:57 +0000
Dear Sirs
A 2019 documentary, currently being shown on Netflix Canada, entitled The Disappearance of
Madeleine McCann, is about the four year old English girl who disappeared from Portugal in 2007
while on holiday with her parents and siblings. She has never been found.
In Series 1, episode 3, Portuguese journalists refer to a scandal that took place years earlier regarding
child abuse in a Portuguese orphanage. It is referred to as the Pact of Silence. In connection with the
orphanage, Casa Pia, a journalist states that it is a known fact that American millionaires were
flying into Portugal on private jets for the purpose of sexually abusing these children.
This might be a line of enquiry that you may wish to follow up.
Yours truly,
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From:
To:
Subject: PC Unit -- Short Form Update.12.6.18.docx
Date: Fri, 07 Dec 2018 14:58:16 +0000
Importance: Normal
Attachments:PC_Unit_-Short_Form_Update.12.6.18.docx
Also saved in shared.
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From:
"
)"
To:
(USANYS)"
Subject: Accepted: Epstein-related Touhy request
Date: Fri, 15 May 2020 22:47:30 +0000
Importance: Normal
Attachments: unnamed
EFTA00023160


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: US V Epstein
Date: Fri, 19 Jul 2019 20:50:48 +0000
Agree, and I can do anytime on Tuesday.
Original Message
From:
Sent: Friday, July 19, 2019 16:45
To:
)
;
)
Subject: FW: US V Epstein
I would propose we just schedule a call for Tuesday, which will give us time to sort out a few things.
Original Message
From: Martin Weinberg
Sent: Friday, July 19, 2019 4:42 PM
To:
Cc: Martin Weinber
Subject: US V Epstein
Should we talk about any case management issues? Protective Order? Discovery rollout?
Thanks
Marty
Sent from my iPhone
EFTA00021635


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=== Page 1 ===
Case 9:08-cv-80736-KAM Document 290-3 Entered on FLSD Docket 01/20/2015 Page 1 of 8
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff,
VS.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually,
and L.M., individually,
Defendants.
/
NOTICE OF FILING
COMES NOW the Defendant/CounterClaimant, BRADLEY EDWARDS, by and
through his undersigned counsel, and hereby files the attached transcript of the telephone
interview of
to supplement the proffer made in support of Counter-Claimant's
Motion for Leave to Amend to Assert Punitive Damages.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
U.S. Mail to all Counsel on the attached list on this 17 day of May 2011.
Jack 9 Scarola
Florida Bar No.: 169440
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax: (561) 383-9451
Attorney for Defendant/CounterClaimant
Edwards
Government Exhibit C
Case No. 08-80736-CIV-MARRA
EFTA00020703

=== Page 2 ===
Case 9:08-cv-80736-KAM Document 290-3 Entered on FLSD Docket 01/20/2015 Page 2 of 8
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Notice of Filing Supplement
COUNSEL LIST
Jack A. Goldberger, Esquire
Martin Weinberg, Esquire
jgoldberger@agwpa.com;
Martin Weinberg, P.C.
smahoney@agwpa.com
20 Park Plaza, Suite 1000
Atterbury, Goldberger & Weiss, P.A.
Suffolk, MA 02116
250 Australian Avenue South, Suite 1400
Attorneys for Jeffrey Epstein
West Palm Beach, FL 33401
Phone: (561)-659-8300
Fax: (561)-835-8691
Attorneys for Jeffrey Epstein
Farmer, Jaffe, Weissing, Edwards, Fistos &
Lehrman, PL
425 N. Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
Phone: (954)-524-2820
Fax: (954)-524-2822
Attorneys for Jeffrey Epstein
Joseph L. Ackerman, Jr., Esquire
jla@fowler-white.com
Fowler White Burnett, P.A.
901 Phillips Point West
777 S Flagler Drive
West Palm Beach, FL 33401-6170
Phone: (561)-802-9044
Fax: (561)-802-9976
Attorneys for Jeffrey Epstein
Marc S. Nurik
marc@nuriklaw.com
Law Offices of Marc S. Nurik
One E Broward Blvd., Suite 700
Fort Lauderdale, FL 33301
Phone: (954)-745-5849
Fax: (954)-745-3556
Attorneys for Scott Rothstein
2
Government Exhibit C
Case No. 08-80736-CIV-MARRA
EFTA00020704

=== Page 3 ===
Case 9:08-cv-80736-KAM Document 290-3 Entered on FLSD Docket 01/20/2015 Page 3 of 8
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Notice of Filing Supplement
3
Government Exhibit C
Case No. 08-80736-CIV-MARRA
EFTA00020705

=== Page 4 ===
Case 9:08-cv-80736-KAM Document 290-3 Entered on FLSD Docket 01/20/2015 Page 4 of 8
PRIVILEGED PURSUANT TO FS 766.205(4) and/or WORK PRODUCT
TELECON
PARTICIPANTS: JACK SCAROLA
BRAD EDWARDS
RE:
Edwards adv. Epstein
291874
DATE:
April 07, 2011
JS:
Jack Scarola and Brad Edwards
BE:
Hi
Hi Jack! Hi Brad! How you guys doing?
JS:
We're doing fine, thank you. I'm sorry for all of the trouble and before we go any
further, let me tell you, if I have your permission, I have started a tape recorder and I
want to be able to tape this conversation from the very beginning. Is that alright with
you?
Sure, that's fine, Jack. No problem
JS:
Ok, good, thank you. I appreciate that. Let me start off by introducing myself. I know
that Brad has spoken to you about me but I am Brad's lawyer, and I assume that you can
confirm that you and I have never had any communication before. Is that right?
That's correct.
JS:
Alright. I have, however, gotten some information from Brad about conversations that
you have had with him, and that will enable me, hopefully, to make this a little bit more
efficient and take up a minimum amount of your time while still getting the information
that we think is going to be helpful to us and to any jury that might ultimately have to
hear these facts.
So, let me begin by asking you first to tell us what your full name is.
That's my maiden name. My married name is
*
Government Exhibit C
Case No. 08-80736-CIV-MARRA
EFTA00020706

=== Page 5 ===
Case 9:08-cv-80736-KAM Document 290-3 Entered on FLSD Docket 01/20/2015 Page 5 of 8
Edwards adv. Epstein
Telephone interview with
Page 17 of 23
Yes, he did. He did all the time. The worst one that I heard from his own mouth was this
pretty 12 year old girls he had flown in for his birthday. It was a surprise birthday gift
from one of his friends and they were from France. I did see them, I did meet them.
Jeffrey bragged afterwards after he met them that they were 12 year olds and flown over
from France because they're really poor over there, and their parents needed the money
or whatever the case is and they were absolutely free to stay and flew out. Those were
the worst ones. He was constantly bragging about girls' ages or where he got them from
or their past and how terrible their past was and good he is making it for them.
JS:
Where were the 12 year old girls flown to from France? Where did they come to?
Palm Beach.
JS:
And were they flown in on Jeff's private plane or did they get transported?
No. They were transported by somebody else.
JS:
Ok. Was the sexual activity that went on on the airplane conducted in such a way so that
any of the crew was aware of what was going on?
They were told to knock if they had to come out, if the crew had to come out. They were
told, you know, to come out as little as possible, so they weren't out there hanging out
watching everything, no, but it doesn't take an idiot to put two and two together to say
well there's a whole bunch of half dressed teenagers on board with this old man who is
constantly being massaged by them and he wants me to keep the door shut for what
reason? I mean, only they could put that together, but yeah, they knew.
JS:
Did Mr. Epstein ever talk to you about people of power and influence owing him favors?
He would laugh about it, you know, I never really knew what to take serious from Jeffrey
because he was such a funny character at times. You never knew if what he was saying
was true or not. Yeah, lots of people owed him favors from what he told me. He's got
everybody in his pocket, and he would laugh about he helps people for the sole purpose
in the end they owe him something. That's why I believe he does so many favors in the
first place.
JS:
When and how did you first become aware that Mr. Epstein was in trouble with the law?
I was first informed by, I think someone from the FBI called me first and started to ask
me questions, and I started to answer the questions but then fear took over, and I just said
look, I don't know what's going on, I've got a young family that I don't want to risk, you
know, please don't bother me about this again, and it was real short simple conversation,
and within a week or 2, I had gotten a call from Jeffrey's attorney, and then a week later,
Jeffrey himself.
Government Exhibit C
Case No. 08-80736-CIV-MARRA
EFTA00020707

=== Page 6 ===
Case 9:08-cv-80736-KAM Document 290-3 Entered on FLSD Docket 01/20/2015 Page 6 of 8
Edwards adv. Epstein
Telephone interview with
Page 18 of 23
JS:
Ok, well let's back up before we get to those conversations and tell me approximately
when it was that you were contacted by the person who you believe was with the FBI.
Ok. It's hard for me to pinpoint, if I had to pinpoint it, it would be in 2007 sometime.
JS:
Alright. And you were living in
at that time, correct?
Correct.
JS:
You were contacted by telephone?
That's correct, by my cell phone.
JS:
Ok and do you have any idea how your name came up leading to that contact.
No idea. No idea whatsoever. When I did ask, I was told that some girls had revealed
my name, I guess, and that's how everybody, the FBI knew to contact me.
JS:
OK.
But I don't know offhand or sorry, I just walked into the wrong room.
JS:
Ok.
Sorry go on.
JS:
Yes & I'll never tell her you said that.
how long was it after that phone call
from the FBI person were you contacted by Mr. Epstein's lawyers.
Like a week. It was back to back to each other. I remember being so scared after talking
to the FBI thinking what's happening, what's going on. It's been like 6 years, 7 years at
that stage, how did they find me & what do I have to do with this? So yeah, I do
remember that very well, and it was only about a week later I was called by his attorney.
JS:
Who was it that contacted you, do you remember?
I want to say Bill Riley, but he might have been from the FBI. No, it was Bill Riley. Bill
Riley. Not sure if that's his correct name, but that's what is coming to mind
JS:
What do you remember about that conversation?
I remember a Mr. Goldberger as well, I remember, there might have been two of them.
JS:
Alright.
Government Exhibit C
Case No. 08-80736-CIV-MARRA
EFTA00020708

=== Page 7 ===
Case 9:08-cv-80736-KAM Document 290-3 Entered on FLSD Docket 01/20/2015 Page 7 of 8
Edwards adv. Epstein
Telephone interview with
Page 19 of 23
I can't remember which one it was. I want to say Bill Riley is the good one.
JS:
Alright, so either Bill Riley or a Mr. Goldberger or both of them contacted you, and what
do you remember about that?
I don't know if it was the same guy who contacted me that week later who put me in
touch with Jeffrey. I think he was on the phone and he put speakerphone on with Jeffrey.
So he connected me with Jeffrey. I don't know if it was the same guy or different, but I
definitely know that Bill Riley was the first guy to contact me. I'm pretty sure about that.
JS:
Ok. Tell me about that conversation.
He asked me what I knew about what's going on with Jeffrey and apparently, there was
an investigation being held about some of the girls who had come out and said that
Jeffrey had sexual contact with them under the age of a minor and that he was
discrediting lot of these girls and making them out to be drug addicts and prostitutes and
what have you so they wouldn't be looked upon as worthy in the court's eyes so to speak.
And you know, he told me in the first five minutes that, you know, if I stay quiet, that
"I'll be looked after" And that was the exact way it was said. It wasn't like you know,
I'm gonna pay you a zillion dollars or anything if you be quiet, but if I stay quiet, I would
"looked after". And I remember saying I don't want any part to do with this. You know,
this is not something I want to be a part of, I've got a young family. I wish the best for
everybody in this, you know, take care kind of thing. A week later, I was called after the
hearing by one of Jeffrey's lawyers. I can't tell you exactly which one it was but he had
Jeffrey on the other line and he connected Jeffrey and I, and Jeffrey tried to make some
simple conversation, "How are you? How have things been?" You know what I mean,
catching up.
JS:
Do you know if the lawyer, did the lawyer stay on the line while Jeffrey was speaking to
you?
I'm pretty sure he did. That's why I think Jeffrey was on speaker phone because it
sounded a lot different, and I was never taken off the line to begin with or connected to
another line, so I was pretty sure Jeffrey was on speaker phone and the lawyer was
making the call. After the simple conversation, it led to what was going on again and you
know, Jeffrey couldn't believe it. You know, he thought he helped all these girls out. He
didn't think he was wrong in any circumstance here at all. A lot of these girls were drug
addicts and just after drug money. You know, he was really putting down these women
or these girls I should say, not giving them the credit they deserved, and then he exactly
repeated what the lawyer said the week before is that he would look after me if I stayed
quiet, and if I need any help, you know, his lawyers would represent me and he would get
legal help for me, whatever I need, he would do, and I told him exactly, I said, "Jeffrey,
I'm the mother of two children at that stage. I'm away from everything there, I don't
want to be a part of it. I'm not going to speak to anybody and I don't want to speak to
anybody, I don't want to be involved." That was the last time I heard from him. And the
Government Exhibit C
Case No. 08-80736-CIV-MARRA
EFTA00020709

=== Page 8 ===
Case 9:08-cv-80736-KAM Document 290-3 Entered on FLSD Docket 01/20/2015 Page 8 of 8
Edwards adv. Epstein
Telephone interview with
Page 20 of 23
next thing I knew, I was sent my victim's letter, my notification of being a victim through
the US Attorney's Office and that's when I knew it was well out there enough not to have
Jeffrey's lawyers come back on me and discredit me in the same way he had done to all
the other girls. So, I called up Joseph Bird who was the recommended lawyers on my
paperwork that they had given me and started going from there.
JS:
So you contact Mr. Joseph Bergs' office and then you were dealing with his office from
that point forward.
That's correct.
JS:
Tell me about the ending of your relationship with Jeffrey. That is, at what point in time
did your full time employment end and how did that happen?
Ok. So, it hadn't really ended. I walked away from it all. Jeffrey sent me to Thailand
where I met my husband and escaped to Australia, never to return back to the states.
About 6 months prior to that, he came up with a proposition that I thought was really
disgustingly sick. And it really showed me for the first time in 4 years I had been with
him that nothing was going to change and I was always just going to be used by him(?)
which I did not like. He offered me a mansion and some of his money every month, I
forget what he called it, a monthly income of what he made to bear one of his children.
The proposition was that if anything ever happened between Jeffrey and I, that I would
have to sign my child over to him basically and that the child would be his and
Ghislaine's, and I would be looking after it as long as nothing happened between Jeffrey
and I. So, I was kind of freaked out by all of that. I pushed Jeffrey more to please get me
some more training, you know, and I was getting older and not of as much interest to
Jeffrey anyways. I was 19 now, and he likes a female a lot younger. So he sent me to
Thailand, in September 2002_. I was first supposed to meet a girl there and bring her
back with me, but I never met up with her. I proceeded get a short course in Thai massage
so that was to shut me up about my training so I went there, and one of my friends from
school invited me to watch a fight, like a muay thai fight, which is like a form
kickboxing. So I went and watched it, and I saw this guy that was a really good fighter,
and a girl's word, looked really hot, so I asked my friend who knew him to introduce me.
We got introduced and fell in love immediately, 3 days later
proposed and 7 days
later I was being married in a buddist temple. I called Jeffrey and told him I'm sorry, I'm
never coming back. I've gotten married, I've fallen in love. I thought he'd wish the best
for me but he was kind of rude and he just said "have a good life" and hung up the phone,
and that was the last time I'd talked to him ever until all this started again.
JS:
Ok.
is there anything else that you would like to add to what you have told us
up to this point in time?
I'd like to know that this time around something's going to be done about it and that
Jeffrey and a lot of his colleagues, no matter how rich they are, will know that there is
Government Exhibit C
Case No. 08-80736-CIV-MARRA
EFTA00020710


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Subject: Response to Rule 16/Brady Letter
Date: Mon, 19 Oct 2020 22:49:39 +0000
Attachments:2020.10.13_Letter_to_Government_re_Rule_16_and_Brady_Requests.PDF_2020-10-
19_Discovery_Letter_Draft_v1.docx
Hi team,
Attached is a draft letter in response to Chris's October 13, 2020 letter (his letter is attached here for your convenience).
Since you are both much closer to the discovery and the investigation, please feel free to edit as much as you would like.
Thanks,
Lara
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00022056


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=== Page 1 ===
G20
U.S. 2016-395-373
FD-597 (Rev. 4-13-2015)
Page
/ of /
UNITED STATES DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF INVESTIGATION
Receipt for Property
Case ID:
On (date)
7/18/19
item (s) listed below were:
Collected/Seized
Received From
Returned To
Released To
(Name)
Marc Fernich
(Street Address)
(City)
Description of Item (s):
Florida Drivers License #
Lumi Not Swiss made Series 3050/3950 watch
us Passport Red Case
Wallet (amex Card, us Customs + Boarder Protection Card
2 Medicare Health card, United health Care Card, $500
Kellow Post it)
Receipt from Dept Homeland Scourity
Received
By: N (Signature)
Received From:
Printed Name/Title: MARC FERNICH
Printed Name/Title:
EFTA00021522


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: MCC Visit Thursday
Date: Tue, 13 Aug 2019 20:13:21 +0000
Will do. We will meet you in the lobby of MCC at 10 on Thursday.
From
Sent: Tuesday, August 13, 2019 4:03 PM
To:
Cc:
Subject: RE: MCC Visit Thursday
If it is not too much of an imposition, we ask that all visitors come to our front lobby for screening before admission.
Thanks!
>>>
>
8/13/2019 3:58 PM >>>
Yes, thank you. Where should we go?
From:
Sent: Tuesday, August 13, 2019 3:38 PM
To:
Cc:
Subject: Re: MCC Visit Thursday
Hi
It should not be a problem. Does 10 am work for Mr. Berman and the rest of his staff?
Thank you
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York New York 10007
> 8/13/2019 2:05 PM >>>
The list of visitors from our office is below:
EFTA00022631

=== Page 2 ===
As discussed, we would like to see the 2nd floor pscyh observation and suicide watch area; the 9th floor SHU, and Epstein's
cell, which we understand to still be cordoned off. As discussed, we would appreciate if only MCC legal would escort us,
and we will not speak to any of the guards present given the ongoing investigations. Please give me a call with any
questions, and let us know what time and where we should go, and if it would be easier for us to enter via the 3rd floor
bridge.
Thanks,
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00022632


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=== Page 1 ===
From:
To:
Cc:
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Letter to Pseudonym Conferral
Date: Wed, 01 Dec 2021 02:55:45 +0000
Attachments: 2021-11-30_GM_pseudonym_order_letter_[final]pdf
Chambers,
Please see the attached letter regarding the Court's pseudonym order. The Government respectfully submits this letter
under seal.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
EFTA00022196


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: URGENT-Ghislaine Maxwell 02879-509 - COURT ORDER
Date: Sat, 16 Jan 2021 04:16:23 +0000
Embedded: RE:_Mailing_and_Laptop.msg
I apologize for the confusion. I did not know that the defense planned to file their letter in advance, and they did
not ask us for input before filing. Judge Nathan endorsed the order within less than 24 hours without allowing
time for any response. To be very clear, my office has never filed any response to the defense motion. The
defense represented in their letter what I have said repeatedly to them and you, which is that my office has no
objection to Maxwell accessing the laptop on weekends.
I am sorry that Judge Nathan ruled before you had the opportunity to inform us that you wished to respond to the
defense letter. Given that you did not tell me that you wanted to respond when I sent you the defense letter, I did
not realize that you intended to object. (I have attached the only response I received from you after I sent you
the defense letter, which makes no indication of any intent to file an objection.) Had I realized, I would have
notified the Court.
We will, of course, file whatever letter you wish to submit with Judge Nathan, and we are always happy to
discuss if that would be useful. We remain very grateful for all of your assistance.
Best,
On Jan 15, 2021, at 10:35 PM,
wrote:
We were informed after our afternoon meeting of the order. While we will be complying with the order this
weekend, we will be filing a letter requesting the order be vacated. Judge Nathan's order states "the
unobserved to order." I explicitly stated that MDC was objection and denying this however you failed to
represent that to the court it seems. While I understand you do not work at the institution, and you may not
understand the hardships this may cause, ii do expect that you would understand it is setting precedent that
causes many serious concerns and hardships for the institution, myself, and all the other staff.
EFTA00021724

=== Page 2 ===
Sent from my Verizon, Samsung Galaxy smartphone
Hi
I just received the below from Maxwell's attorney. Would you please confirm that the MDC intends to comply with
Judge Nathan's order?
Thanks,
From: BOBBI C STERNHEIM
Sent: Friday, January 15, 2021 5:58 PM
To:
Cc:
Subject: Fwd: URGENT-Ghislaine Maxwell 02879-509 - COURT ORDER
Good evening,
In disregard of the Court's order, the team leader of Ms. Maxwell's security detail
informed Ms. Maxwell that she will not have access to the laptop on Saturday.
(See email below.)
I will be notifying Judge Nathan of MDC's blatant disregard of the Court's order.
Perhaps this will move the Court to direct Warden
to appear and face questions
concerning the mistreatment of Ms. Maxwell and misconduct by his staff.
Any assistance you can provide to effect compliance with the order so that Ms. Maxwell
has access to the laptop over this long holiday weekend is greatly appreciated.
Thank you. Enjoy the long weekend.
Bobbi
EFTA00021725

=== Page 3 ===
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
Begin forwarded message:
From: BOBBI C STERNHEIM
Subject: URGENT-Ghislaine Maxwell 02879-509 - COURT ORDER
Date: January 15, 2021 at 5:41:09 PM EST
To: BRO/Exec Assistant~
Earlier today I forwarded a copy of the court order directing MDC to
provide Ms. Maxwell with access to her laptop on weekends and holidays.
(See email and Order below).
At 3:40 pm, Officer
told Ms. Maxwell
she 'will not be getting the laptop on Saturday.'
Ms. Maxwell informed Officer
that access to the laptop has been court ordered,
to which Officer Regan replied "I don't care."
Be advised: Judge Nathan will be informed of the explicit violation of the Court's order.
I urge the MDC to immediately comply with the order or face contempt of court.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
EFTA00021726

=== Page 4 ===
**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.
Begin forwarded message:
From: BOBBI C STERNHEIM
Date: January 15, 2021 at 3:05:18 PM EST
To: BRO-ExecAssistant-S BRO-ExecAssistant-S
Subject: URGENT-Ghislaine Maxwell 02879-509 COURT ORDER
By Order of the Court (attached)
You are directed to give Ms.Maxwell access to her laptop on weekends and holidays. Please comply
immediately.
Thank you-
Bobbi C. Sternheim, Esq.
Docket Text:
MEMO ENDORSEMENT as to Ghislaine Maxwell on [115] LETTER by Ghislaine Maxwell
addressed to Judge Alison J. Nathan from Christian R. Everdell dated January 14, 2021 re:
Laptop Access. ENDORSEMENT: The unobjected-to request is GRANTED. The Bureau of
Prisons is ORDERED to give the Defendant access to the laptop computer on weekends
and holidays during the hours that she is permitted to review discovery. so ORDERED.
(Signed by Judge Alison J. Nathan on 1/15/2021) (Inl)
https://ecf.nysd.uscourts.gov/doc1/127128346956?
caseid=539612&de_seq_num=371&magic_num=56905676
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
EFTA00021727

=== Page 5 ===
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.
EFTA00021728


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=== Page 1 ===
From:
To:
Cc:
(USANYS) [Contractor]"
Subject: RE: Jes Staley and his relationship with Epstein
Date: Wed, 26 Feb 2020 19:34:22 +0000
Thanks. Just copying/pasting, here goes:
I just called your desk, but no answer/full mailbox! Quickly, I'm reaching out because my colleagues are working on a story
-- following up on this story. from the other week -- about how UK law enforcement is involved in an investigation into
Barclays PLC CEO Jes Staley and his relationship with Jeffrey Epstein. We understand that the FCA (the UK's financial
watchdog) and the Bank of England's financial stability organization (the very Britishly-named Prudential Regulation
Authority) is investigating disclosures made the other week by Barclay's board regarding Epstein and Staley's relationship.
I believe they have now officially confirmed the investigation.
I think we will want to include a line in the story about how -- I THINK -- SDNY's investigation into Epstein's sex-trafficking
organization is continuing. It's been reported that banks have provided some information to SDNY. My questions are as
follows:
1. Is it accurate to say that SDNY continues to investigate Epstein's enterprise?
2. Is SDNY working with the UK authorities on the Staley matter?
I think that's basically it. Happy to discuss on the phone. I think they plan to publish a story today or tomorrow first thing.
From:
Sent: Wednesday, February 26, 2020 2:33 PM
To:
Cc:
(USANYS) [Contractor]
Subject: RE: Jes Staley and his relationship with Epstein
Us
From:
Sent: Wednesday, February 26, 2020 2:30 PM
To:
)
i
Cc:
(USANYS) [Contractor]
Subject: Jes Staley and his relationship with Epstein
Would this be an inquiry for you guys or MLTCHE?
Public Affairs
United States Department of Justice
U.S. Attorney's Office Southern District of New York
I Mobile:
I
Press Office:
EFTA00023410


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: proposed schedule.
Date: Tue, 24 Sep 2019 12:55:16 +0000
Good morning,
We are still working internally on a proposed schedule. Can we circle back to you on a week or two? We should
still have plenty of time to meet and hopefully agree on dates before our next status conference.
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country road
Garden City, NY 11530
Barket Epstein.com
On Sep 21, 2019, at 9:33 AM,
wrote:
We are free Thursday afternoon except from 2:45 - 4.
Assistant U.S. Attorney
On Sep 21, 2019, at 07:22
wrote:
Any day next week works for me. Also in my role as Learned Counsel, and in full compliance with the ABA Guidelines, I
will be submitting a proposed schedule for penalty phase pleadings over the weekend.
Thanks
Tonyricco
Original Message
Sent: Fri, Sep 20, 2019 9:15 pm
Subject: Re: proposed schedule.
We are free next Friday afternoon if that works for you all.
EFTA00021345

=== Page 2 ===
Assistant U.S. Attorney
On Sep 20, 2019, at 12:16, Bruce Barket
wrote:
I think we will be ready to propose a schedule sometime early next week. Is there a day and time when you
can meet to discuss? We will send you a proposed briefing schedule ahead of the meeting. I hope to have
ours finalized no later than Tuesday.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it
is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error;
any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have
received this communication in error, please notify us immediately by telephone or email and immediately delete this
message and all its attachments
EFTA00021346


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=== Page 1 ===
OFFICIAL RECORD
Intake (Rev. 5-23-17)
signed
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Intake
Date: 09/08/2020
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Drafted By:
Date/Time Received: 09/08/2020 10:29 PM EDT
Details:
On 09/08/2020, at 10:29 p.m. Eastern Time,
/
date of birth
telephone number
/
home address
,
New York, NY 10027, called the FBI National Threat Operations Center
(NTOC) to report information regarding Ghislaine Maxwell.
provided the following information:
In 2013,
at Behavior Health in West Palm
Beach, Florida. During a break he notice Maxwell speaking with two young
ladies, identifiers unknown.
also saw Jeffrey Epstein at the
facility sitting in car three or four times. He remembers the ladies
getting into the car with Epstein and them leaving. The ladies were back
at the facility within an hour of leaving.
is still in contact with a counselor, identifiers not provided,
at the facility.
UNCLASSIFIED
EFTA00020505


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=== Page 1 ===
From: Christian Everdell <CEverdell@CohenGresser.com>
To:
)"
(USANYS)"
Cc: "Mark S. Cohen" <mcohen@CohenGresser.com>, Bobbi Sternheim <bcsternheim@mac.com>,
Jeff Pagliuca <jpagliuca@hmflaw.com>, "Laura Menninger" <lmenninger@hmflaw.com>
Bcc: "USAHUB-USAJournal111"
Subject: RE: Discovery Requests
Date: Mon, 01 Feb 2021 03:41:38 +0000
Embedded: RE:_Discovery_Requests.msg
Sender: CEverdell@CohenGresser.com
Subject: RE: Discovery Requests
Message-Id: <41abd1c04da54126a02a42b3ea002b32@CohenGresser.com>
Recipient:
EFTA00020977


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=== Page 1 ===
From:
)
[Contractor]"
To:
)"
Cc:
)"
)"
Subject: RE: Epstein discovery
Date: Mon, 29 Jul 2019 19:11:11 +0000
Yes, I will start on it now. Everything looks straightforward, but I will let you know if I have any questions.
From:
)
Sent: Monday, July 29, 2019 1:26 PM
To:
) [Contractor]
Cc:
is
Subject: Epstein discovery
The discovery is ready to be prepped. I've saved everything here:
H
FIRST PRODUCITON - TO BE PRODUCED
Only thing we're still waiting on is the arrest 302, which will be added to the folder entitled "Epstein Arrest" when we get
it later today. Can you start prepping this afternoon, please?
Thanks,
EFTA00021394


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=== Page 1 ===
Event: Accepted: Epstein scheduling conference
Start Date: 2019-07-31 15:00:00 +0000
End Date: 2019-07-31 16:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-07-18 17:41:53 +0000
Date Modified: 2019-07-18 17:41:53 +0000
Priority: 5
DTSTAMP: 2019-07-18 16:24:19 +0000
Attendee:
EFTA00022526


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=== Page 1 ===
From:
To:
Subject: [EXTERNAL] Elizabeth Loftus
Date: Mon, 22 Nov 2021 19:19:58 +0000
Why would this woman have a seat at "the table" when she clearly knew Epstein and his ilk? She was on the
board of EDGE. She knew Epstein https://www.edge.org/memberbio/elizabeth_loftus
Sent from my iPhone
EFTA00023366


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=== Page 1 ===
From:
(USANYS)"
To: USAEO-Foreign Travel
Cc:
)"
(USANYS)"
Subject: FW: ECC package - AUSA
ECC ackage
Date: Fri, 24 Jan 2020 19:30:52 +0000
Importance: High
Attachments:
-_ECC_package_2.3.20.pdf
Hi RMP,
Please see the attached ECC request package for
If required, please inform the traveler how to determine who the POC is for this trip.
Hi
Please let EOUSA know if you have checked to see if a visa is required for your destination.
View the state dept. link for the country you are traveling to visa link for the country you are traveling to.
Visa policies may be found on the Department of State's website or on the website hosted by each country 's embassy.
https://travel.state.gov/content/passports/en/country.html
Traveler, Consult EOUSA usaeo.foreign.travel@usdoj.gov mailbox to obtain a visa for you.
To provide sufficient time for the State Dept. to issue the authorization letter and for the foreign government to process the visa
request, it is recommended that visa request package be submitted to EOUSA's RMP Travel.
Staff 15 business days prior to the proposed date of departure.
Thank you
Original Message
From:
Sent: Friday, January 24, 2020 1:41 PM
To:
(USANYS)
is
(USANYS)
Subject: FW: ITINERARY ONLY -
R - Travel Date: 03FEB20 - Ref: HEZZTD
Finally have a correct itinerary! This is for both the passport application and the request for approval of the travel.
Thanks so much for your help.
From:
Sent: Friday, January 24, 2020 10:39 AM
To:
(USANYS)
is
)
Cc:
(USANYS)
Subject: RE: Sorry One more thing - EOUSA also needs your OIA approval email. Thanks
We have reached out to OIA and are awaiting their approval. We'll send it as soon as we have it.
From:
(USANYS)
Sent: Friday, January 24, 2020 10:39 AM
To:
is
Cc:
(USANYS)
Subject: Sorry One more thing - EOUSA also needs your OIA approval email. Thanks
EFTA00021052

=== Page 2 ===
Sorry, One more thing - EOUSA also needs your OIA approval email. Thanks
From:
)
Sent: Friday, January 24, 2020 10:33 AM
To:
(USANYS)
is
Subject: RE: Questionnaire - Hi We also need this one ASAP. Thanks
Attached is my questionairre
Original Message
From:
(USANYS)
Sent: Thursday, January 23, 2020 2:28 PM
To: USAEO-Foreign Travel
Cc:
(USANYS)
is
Subject: FW: ITINERARY ONLY -
R - Travel Date: 04FEB20 - Ref: HEZZTD
Hi
-
Attached is AUSA
flight itinerary for her upcoming foreign travel. I know you needed this for the passport. We
will be routing a travel authorization for her trip soon.
Thank you!
Original Message
From:
Sent: Thursday, January 23, 2020 2:26 PM
To:
(USANYS)
is
(USANYS)
Subject: FW: ITINERARY ONLY -
R - Travel Date: 04FEB20 - Ref: HEZZTD
Hi,
Attached is my itinerary with the revised dates (2/4/20 through 2/6/20) for the trip to Sweden. Should have the draft
travel memo ready to send shortly.
Thanks,
EFTA00021053


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=== Page 1 ===
From:
To:
Cc:
)"
,
)"
Subject: FW:
interview notes
Date: Mon 27 Iul 2020 23:46:13 +0000
Attachments:
interview_notes180754.pdf
Hi Will,
Would you please save these on the Epstein share drive and note them in the tracker?
Thanks
From:
Sent: Monday, July 27, 2020 6:38 PM
To:
is
)
>;
Cc:
Subject
interview notes
Attached are the interview notes from
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
C:
EFTA00021758


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=== Page 1 ===
From:
To: Christian Everdell
>, BOBBI C STERNHEIM
, Laura Menninger
, Jeff Pagliuca
Cc:
Subject: US V. Maxwell, 20 Cr. 330 (AJN)
Date: Sat, 06 Nov 2021 17:30:59 +0000
Attachments: 2021.11.06_Maxwell_Cover_Letter.pdf; 2021.11.06_U.S._v_Ghislaine_Maxwell_Non-
Testifying_Witness_Material_(Defense).pdf;
2021.11.06_U.S._v_Ghislaine_Maxwell_3500_Index_(Defense).pdf
Counsel,
We have a supplemental production of testifying witness and non-testifying witness material ready to send to you.
Attached please find the accompanying cover letter and indices. The production will be made via USAfx. We will load and
send the hard drive you provided to the MDC for Ms. Maxwell.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00021965


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=== Page 1 ===
From:
To:
"
)"
Cc:
)"
)"I
Subject: RE: Epstein - Scheduling Call
Date: Mon, 29 Jul 2019 22:29:04 +0000
Confirmed for 9 AM Wed, thanks. Hope all are well.
From:
[mailto
Sent: Monday, July 29, 2019 5:41 PM
To:
Cc:
Subject: RE: Epstein - Scheduling Call
that works for us, thanks. Also, separately, regarding the return of property, you should feel free to contact Special
Agent
directly, her number is
or alternatively I expect
be in court on Wednesday so you
could speak with
directly then.
thank you,
From:
Sent: Monday, July 29, 2019 16:59
To:
Cc:
Subject: Epstein - Scheduling Call
Dear all - -
Can we plan on a call regarding Epstein scheduling issues for Wed morning at 9 am using the following dial in:
EFTA00021517

=== Page 2 ===
EFTA00021518


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: the safe on Epstein's private island
Date: Fri, 12 Jul 2019 17:46:47 +0000
Importance: Normal
Not sure if
sent this to you or not, but just in case
From:
(BLOOMBERG/ NEWSROOM:
Sent: Friday, July 12, 2019 1:09 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: the safe on Epstein's private island
,
Just wanted to make sure your team saw this reference in today's story to a
super-secret safe in Epstein's island getaway:
https://www.bloomberg.com/news/articles/2019-07-12/jeffrey-epstein-s-
private-island-in-the-caribbean-has-gone-quiet?srnd=premium
"The level of secrecy around a steel safe in Epstein's office, in
particular, suggested it contained much more than just money, he said.
Outside of an occasional visit by a housekeeper, no one was allowed in
those rooms. "
Bloomberg News
EFTA00023242


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=== Page 1 ===
From:
To:
Cc:
Subject: Maxwell
Date: Tue, 21 Sep 2021 14:36:42 +0000
Thanks for chatting yesterday. As discussed, here is a list of potential testifying witnesses for you to check for in your
files/emails. Please let us know if you have any questions.
Thanks!
Lara
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
2
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00021176


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=== Page 1 ===
From:
)"
To:
)"
,
(USANYS)"
Subject: Today's redaction projects
Date: Mon, 22 Nov 2021 16:06:10 +0000
Attachments: 2021.11.18_Mot_to_quash_[final].pdf; 2021-11-20_GM_reply_re_GX-
52_final_[proposed_redactions].pdf;
2021.11.15_JSP_Ltr_re_EX._52_[proposed_redactions],pdf; 2021-11-
22_GM_letter_re_redactions.docx
Hi team,
Today we need to docket our proposed redactions to our Motion to Quash (see Dkt. No. 473), we and the defense are
required to docket our letters on the birth certificates issue (see Dkt. No. 474), and we and the defense need to docket
our letters on GX 52 (see Dkt. No. 476).
We already redacted the birth certificates letters. I've attached:
Our motion to quash, which I don't think needs any redactions
The remaining GX-52 letters, for which I've proposed redactions
A draft letter to the Court
Would one of you three quickly take a look, and then I'll coordinate with the defense?
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York. New York 10007
EFTA00021029


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=== Page 1 ===
From:
To:
Cc:
Subject: this coming week
Date: Sat, 29 Jun 2019 15:51:12 +0000
Importance: Normal
Inline-Images: image001.gif
We have a fairly quiet week ahead, presumably because of the holiday. Depending on what we learn at Monday's
briefing, we may have some work to do to deal with this drone exercise (although if Eric's information is correct, it really
should be an inconvenience but not something that requires radical adjustments.)
Trials Continuing:
Ahuja
(SCFU). Securities mismarking at Premum Point Investments. Judge Failla.
Monday, July 1
-
First Day for AUSAs
Swearing -in ceremony - 12 p.m.
-
Matos verdict report - 2 p.m.
-
Sarcone briefing re: drones - 3 p.m.
-
-
-
Tuesday, July 2
-
AUSA interviews
-
Geragos meeting - 2 p.m.
-
Epstein indictment (PC)
-
Ernesto Lopez sentencing (Narc). Dr. Lopez was convicted after trial of illegally dispensing oxycodone and
fentanyl. Judge Cote.
-
Wednesday, July 3
-
VOC pipeline meeting - 10 a.m.
Narcotics pipeline meeting - 12 p.m.
-
Thursday, July 4
EFTA00021266

=== Page 2 ===
Friday, July 5
Other
I am contemplating who should take
place in organizing the trial training program (with Karl)
that all new AUSAs do, and welcome any thoughts in that regard. This is not time sensitive, but better to think
about it ahead of time.
Chief, Criminal Division
United States Attorney's Office, SDNY
EFTA00021267


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=== Page 1 ===
From:
To:
Subject: RE: Epstein OIG/FBI--Document Preservation
Date: Wed, 14 Aug 2019 20:38:13 +0000
PS that's all I need.
From:
Sent: Tuesday, August 13, 2019 12:12 PM
To:
Subject: RE: Epstein OIG/FBI--Document Preservation
Attached please find my completed form. The USAO number for the portion of the case that I worked on is 2018R01618.
Throughout my participation in this case, I have, as a practice, saved all Epstein-related emails that I received in my email
archive in a folder entitled "Epstein". Any emails that I sent regarding the case would be in the sent items folder in my
email. I have not sent or received any substantive text messages regarding the case (any texts with other team members
are purely logistical-e.g., setting up a time to meet or for a call).
Please let me know if you need anything else.
Thanks,
From:
Sent: Monday, August 12, 2019 5:13 PM
Subject: RE: Epstein OIG/FBI--Document Preservation
Dear all,
As
explained, we are instituting a formal litigation hold in connection with Mr. Epstein's death at MCC. You have
been identified as having done work on or supervised the Epstein matter, and thus as possibly having responsive records.
Please note and preserve whatever you have about Mr. Epstein, not limited to his death and to the earlier reported
incident in which he suffered physical injuries. In addition, to the extent possible, please avoid altering any relevant
records. If you need to use existing documents, please save what you're working off of as a new document so that the
version that now exists remains preserved and available.
EFTA00022636

=== Page 2 ===
I attach a formal litigation hold notice, which as required is on an EOUSA-provided form. Please review the notice, fill out
the form to indicate whether and where you have responsive records, and sign and return it to me. In particular, be sure
to let me know by USAO number if possible what records and share directories we have that are likely to include relevant
information.
I prefer scanned and emailed return of the forms, but you can also use interoffice mail if you prefer.
Please let me know if you think other USAO personnel may have relevant documents or evidence.
And please let me know if you have questions or want to discuss.
Finally, I am copying
to inform him of the new litigation hold, and to ask him to ensure that all responsive
information on our electronic record systems is preserved, including by suspending the routine maintenance email
deletions for recipients of this email.
Many thanks,
Deputy Chief, Civil Division, and Litigation Hold Coordinator
U.S. Attorney's Office, S.D.N.Y.
New York, NY 10007
From:
Sent: Monday, August 12, 2019 4:46 PM
Subject: RE: Epstein OIG/FBI--Document Preservation
FYI, as a result of a preservation request Epstein's lawyers have made on behalf of the family, which indicates a
potential wrongful death case, you will shortly be receiving a formal litigation hold request from
our litigation hold coordinator.
From:
Sent: Monday, August 12, 2019 11:43 AM
EFTA00022637

=== Page 3 ===
Subject: FW: Epstein OIG/FBI--Document Preservation
All - Please see below and follow
instructions. Additionally, if you believe there are others at SDNY to whom this
email should be sent, please let me know immediately.
Thanks,
From:
Sent: Monday, August 12, 2019 11:35 AM
Subject: Epstein OIG/FBI--Document Preservation
Please forward this to everyone who might have any documents relating to the Epstein suicide, and cc me:
Please make sure to preserve any documents you may have relating to Epstein's conditions of confinement.
Your emails will be adequately preserved, for present purposes, by the regular three-year backup. But let
me know if you have any or not.
If you have any hard-copy notes, please scan them and send them to me. If you have none, let me know
that too.
Most particularly, please check to see if you have texted anything pertinent. If so let me know, one way
or the other. If you do have anything, we'll figure out how to preserve that.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
New York, NY 10007
EFTA00022638


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=== Page 1 ===
From:
To
Subject: OOP
Date: Wed, 17 Nov 2021 03:41:28 +0000
Attachments: Maxwell_Order_of_Proof_v12.docx
Revised draft attached.
please let us know once you've decided what you'd like to do about the order around
EFTA00023417


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=== Page 1 ===
From:
To:
Subject: Subpoena requests
Date: Fri, 06 Dec 2019 00:05:56 +0000
Hey all,
Could we get some subpoenas for the below agencies for Ghislaine Maxwell, DOB 12/25/1961
Uber
Uber Technologies, Inc.
1455 Market Street, 4th Floor
San Francisco, CA 94103
Lyft
185 Berry Street Suite 5000
San Francisco, CA 94107
Thanks!
EFTA00020970


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
)"
)"
Subject: RE: Epstein investigation
Date: Mon, 15 Jul 2019 17:56:41 +0000
Importance: Normal
Works for me if that's okay for agent(s) -- just FYI for
, not sure if you guys have attended
reverse proffers before? You're totally welcome to be in on it, but it will just be her lawyer, no witness statements
or anything, and we basically will pitch why she would be better off coming in to talk to us rather than us maybe
just arresting her down the line. Sorry if you already talked about this with
just wanted to make
clear it's definitely an invite but not an obligation if you don't want!
Original Message
From:
)
Sent: Monday, July 15, 2019 13:54
To:
(NY) (FBI)
Subject: RE: Epstein investigation
Sorry, forgot about both of those things. Let's say tomorrow at 3:30?
Original Message
From:
)
Sent: Monday, July 15, 2019 1:53 PM
To:
(NY) (FBI)
Subject: RE: Epstein investigation
/
I'm going to be in Florida for a witness interview on Wednesday. But tomorrow works.
Original Message
From:
)
Sent: Monday, July 15, 2019 1:51 PM
To:
(NY) (FBI)
Subject: RE: Epstein investigation
I have a doctor's appointment Wednesday at 10:30 so if it's possible to do tomorrow at 11:00 or 3:30, Wednesday
at 3:30, or Thursday after 4, I could do any of those times. Or if it ends up being Wednesday at 11:00, I'll get the
notes after.
Original Message
From:
)
EFTA00021434

=== Page 2 ===
Sent: Monday, July 15, 2019 13:49
To
(NY) (FBI)
Subject: FW: Epstein investigation
Wednesday at 11 work for everyone?
Original Message
From: Michael Bachner
Sent: Monday, July 15, 2019 1:42 PM
To:
Cc:
Subject: RE: Epstein investigation
Hi
Tomorrow or Wednesday at 11 or 3:30. Thursday any time after 11:30 to 4.
https://www.actl.com/
Michael Bachner, Esq.
Bachner & Associates, PC
39 Broadway, Suite 1610
New York, NY 10006
www.bhlawfirm.com
CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic
Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally privileged. If you
are not the intended recipient, you are hereby notified that any retention, dissemination, distribution, or copying
of this communication is strictly prohibited. Please reply to the sender that you have received the message in
error and then delete it. Thank you.
Original Message
From:
) [mailto:
Sent: Monday, July 15, 2019 12:50 PM
To: Michael Bachner
Cc:
)
)
Subject: Re: Epstein investigation
Hi Michael,
Apologies for the delay. Would you please let us know what times would work for you and
in the next
two or three days? We'll then figure out a time when we can all meet.
EFTA00021435

=== Page 3 ===
Thank you,
On Jul 11, 2019, at 10:43 PM, Michael Bachner
wrote:
Hello
6 o'clock is somewhat late. The client lives in
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
[X]
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information,
which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or
the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any
dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this
communication by error, please immediately notify the sender by e-mail and delete this email from your system.
Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 11, 2019, at 9:01 PM,
)
<mailto:
wrote:
Michael,
Would 7/16 at around 6pm work for the reverse proffer in our office at 1 St. Andrews?
Thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
<mailto:
From: Michael Bachner
Sent: Thursday, July 11, 2019 12:26 PM
To:
<mailto:
Cc:
)
<mailto:
)
EFTA00021436

=== Page 4 ===
<mailto:
Subject: Re: Epstein investigation /
Regarding the reverse proffer, We are available next week from the 15-18. I have a 2 o'clock meeting in my
office on the 16th and 17th that should last an hour. So I can meet with you on those days at 11 or 1030 in the
morning if that works. Please let me know
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information,
which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or
the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any
dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this
communication by error, please immediately notify the sender by e-mail and delete this email from your system.
Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 10, 2019, at 11:20 AM, Michael Bachner
wrote:
Sure.
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York. NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information,
which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or
the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any
dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this
communication by error, please immediately notify the sender by e-mail and delete this email from your system.
Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 10, 2019, at 11:08 AM,
<mailto:
wrote:
EFTA00021437

=== Page 5 ===
Mike,
I think it would be useful to get a better understanding of your position-it would be helpful for us to know, for
example, how much time you propose to take to evaluate matters, and whether we can provide any additional
information that might be useful for that process of evaluation. That likely will affect our determination
regarding the grand jury appearance, at which we would expect, were we to call
to ask her a number
of questions we would expect to argue to the court do not implicate a fifth amendment privilege-i.e., that she
couldn't simply blanket invoke. Would it be useful to discuss via phone?
thanks,
From: Michael Bachner
Sent: Wednesday, July 10, 2019 10:25
To:
)
<mailto:
Cc:
)
<mailto:
<mailto:
Subject: Re: Epstein investigation /
Dear Counsel:
I met with
and I need time to evaluate matters. Regarding the subpoena to testify before the Grand
Jury on
we hereby notify you that if called as a witness
would invoke her Fifth Amendment
privilege against compelled self-incrimination. Please let me know if you will require her to invoke in person or
whether this communication suffices and no appertaining will be required.
Yours truly,
Michael Bachner
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD026.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential information,
which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or
the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any
dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this
communication by error, please immediately notify the sender by e-mail and delete this email from your system.
Nothing in this email should be construed as a legal opinion or tax advice.
On Jul 9, 2019, at 11:43 AM,
<mailto:
wrote:
EFTA00021438

=== Page 6 ===
Mr. Bachner,
Following up on our conversation earlier this morning, we wanted to provide you with the additional information
and materials we discussed. In the first instance, so that you have full contact info for the team, please feel free to
reach out to any of us at any time; we're all available via email or at the following phone numbers:
Additionally, attached are the non-prosecution agreement, previously publicly filed in civil proceedings in
Florida, and a blank version of our standard proffer agreement, both as discussed.
As we mentioned, please don't hesitate to reach out with any questions, and we look forward to setting a time to
speak again after you're able to confer with
thank you,
Assistant U.S. Attorney
Southern District of New York
<blank proffer agreement.pdf>
<Epstein NPA, dated 2007-09-24.pdf>
EFTA00021439


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=== Page 1 ===
From:
To:
Subject: Epstein & Leon Black
Date: Wed, 17 Jul 2019 17:14:20 +0000
Read NYPost -
interesting
EFTA00022521


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=== Page 1 ===
From: "Weinstein, Marc A."
To:
(USANYS)"
Cc: "Tomback, Andrew"
,
(USANYS)"
(USANYS)"
Subject: RE: Grand jury subpoena response
Date: Mon, 27 Jan 2020 17:01:28 +0000
Thanks
Marc A. Weinstein | Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor New York NY 10004-1482
Office
I Cell
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.
From:
(USANYS)
Sent: Monday, January 27, 2020 11:36 AM
To: Weinstein, Marc A.
Cc: Tomback, Andrew
(USANYS)
(USANYS)
Subject: RE: Grand jury subpoena response
CAUTION: This email was sent by someone outside of the Firm.
There is not, not relating to our case. We've been advised by our supervisors that Geoff is speaking in connection with
the state law allowing for look-back civil suits.
From: Weinstein, Marc A.
Sent: Monday, January 27, 2020 11:25
To:
(USANYS)
Cc: Tomback, Andrew
;
(USANYS)
>;
(USANYS)
Subject: RE: Grand jury subpoena response
is there some type of announcement happening today?
Marc A. Weinstein | Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor I New York, NY 10004-1482
Office
I Cell
Fax
EFTA00021055

=== 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.
From: Weinstein, Marc A.
Sent: Saturday, January 25, 2020 3:55 PM
To:
(USANYS)'
Cc: Tomback, Andrew
V.
(USANYS)
is
(USANYS)
Subject: RE: Grand jury subpoena response
Attached.
From:
(USANYS)
Sent: Saturday, January 25, 2020 3:07 PM
To: Weinstein, Marc A.
Cc: Tomback, Andrew
(USANYS)
(USANYS)
Subject: Re: Grand jury subpoena response
CAUTION: This email was sent by someone outside of the Firm.
We have not seen it, if you could please send it that would be helpful. Thank you.
Sent from my iPhone
On Jan 25, 2020, at 15:04, Weinstein, Marc A.
wrote:
Have you seen the USVI Attorney General's motion to intervene in the estate administration and opposition to the
proposed claims program? If not we can send you a copy.
Regards,
Marc
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor | New York NY 10004-1482
Office
I Cell
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.
On Jan 24, 2020, at 8:23 PM,
(USANYS)
wrote:
EFTA00021056

=== Page 3 ===
CAUTION: This email was sent by someone outside of the Firm.
Marc,
We received all three emails, containing documents marked as GJ_000198 through GJ_000459. Thank you, and have a
good weekend.
From: Weinstein, Marc A.
Sent: Friday, January 24, 2020 16:02
To:
(USANYS)
is
(USANYS)
(USANYS)
Cc: Tomback, Andrew
Subject: Grand jury subpoena response
and
:
In response to your request for any prior trusts referenced in the prior wills of Jeffrey Epstein produced on January 16,
2020, which further request we understand is made pursuant to the October 18, 2019 grand jury subpoenas to the
executors of the estate of Jeffrey Epstein, attached please find documents bearing Bates numbers GJ_000406 through
GJ_000459.
Regards,
Marc
Marc A. Weinstein | Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor | New York, NY 10004-1482
Office
I Cell
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.
EFTA00021057


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=== Page 1 ===
From:
To:
Subject: FW: Epstein financials
Date: Tue, 08 Oct 2019 15:31:19 +0000
FYI
From: Goldstein, Matthew <matthew.goldstein@nytimes.com>
Sent: Tuesday, October 08, 2019 10:15
To:
Subject: Epstein financials
ICYM missed our story from last week I am sending it to you as we will continue report out the mystery of
Epstein's financial operation on the Virgin Islands which benefited from a incredibly lucrative tax break afforded
by US and Virgin Islands law.
The biggest question remains the $200 million that Epstein's Southern Trust took in as revenue and made in
profits -- in the years after his Florida conviction. We remain committed to getting to the bottom of this puzzling
influx of cash. Is there any guidance the office can provide that there is interest in the financial issues raised by
the Epstein affair, even after his death.
Finally we have been told that the offices of Southern Trust were searched on Aug. 12-- the same day authorities
search Epstein's island residence. Can you confirm?
We also have been told by an eyewitness that two weeks before Epstein's arrest, there were several large garbage
bags with shredded documents seen outside the office door to Southern Trust. Do you know anything about this?
If nothing else, I hope we can engage some discussion on these issues. As much as we are committed to solving
the many mysteries of Epstein's financial business, we want to separate fact from fiction and fact from Internet
conspiracies
best
matt
https://www.nytimes.com/2019/10/03/business/jeffrey-epstein-southern-trust.html
Matthew Goldstein
The New York Times
(w) 212-556-1665
(c) 347-843-9938
@mattgoldstein26
EFTA00023239


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=== Page 1 ===
From:
(OCME)"
To:
(USANYS)"
Subject: RE: Epstein Autopsy Report
Date: Wed, 30 Jun 2021 14:58:56 +0000
I left you voicemail earlier this morning; please call back when you get a chance.
Thanks.
General Counsel
Office of Chief Medical Examiner
New York, NY 10016
Tel:
Mobile:
The information contained in this e-mail communication may be confidential and/or legally privileged and is for the use of the intended
recipient only. If you are not the intended recipient, or an authorized employee or an agent responsible for delivering it to the intended
recipient, the dissemination, distribution or reproduction of this communication or its contents (including any attachments) is prohibited.
If you have received this communication in error, please notify us immediately by telephone or reply e-mail and permanently delete it and
any copies from your system files.
From:
(USANYS)
Sent: Tuesday, June 29, 2021 8:19 AM
To:
(OCME)
Subject: Re: Epstein Autopsy Report
Great, speak to you then.
On Jun 29, 2021, at 8:14 AM,
(OCME)
wrote:
I'm actually teleworking today, so please call my cell; thanks.
Talk to you then.
General Counsel
Office of Chief Medical Examiner
New York, NY 10016
Tel:
Mobile:
The information contained in this e-mail communication may be confidential and/or legally privileged and is for the use of the intended
recipient only. If you are not the intended recipient, or an authorized employee or an agent responsible for delivering it to the intended
recipient, the dissemination, distribution or reproduction of this communication or its contents (including any attachments) is
prohibited. If you have received this communication in error, please notify us immediately by telephone or reply e-mail and
permanently delete it and any copies from your system files.
From:
(USANYS)
Sent: Tuesday, June 29, 2021 8:13 AM
EFTA00022018

=== Page 2 ===
To:
(OCME)
Subject: Re: Epstein Autopsy Report
Let's do 3:30 today. Should I call your desk? Thanks.
On Jun 29, 2021, at 7:58 AM,
(OCME)
wrote:
Let me know if any of the following times work for you;
Today at 3:30
Tomorrow (Wed) between 9:30-12 or 3-4:30
Thanks.
General Counsel
Office of Chief Medical Examiner
New York, NY 10016
Tel:
Mobile:
The information contained in this e-mail communication may be confidential and/or legally privileged and is for the use of the
intended recipient only. If you are not the intended recipient, or an authorized employee or an agent responsible for delivering it to
the intended recipient, the dissemination, distribution or reproduction of this communication or its contents (including any
attachments) is prohibited. If you have received this communication in error, please notify us immediately by telephone or reply e-
mail and permanently delete it and any copies from your system files.
From:
(OCME)
Sent: Monday, June 28, 2021 8:17 PM
To:
(USANYS)
Subject: Re: Epstein Autopsy Report
Sure. Tomorrow morning is booked but I can definitely find time.
Thanks.
General Counsel
Office of Chief Medical Examiner
On Jun 28, 2021, at 17:14,
(USANYS)
> wrote:
Hi
I hope this finds you well. Do you have a few minutes for a call tomorrow or Wednesday? I wanted to give you a
head's up about what will be made public in connection with an ongoing FOIA case against the BOP on Friday.
EFTA00022019

=== Page 3 ===
Thanks,
Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
Desk
Cell
EFTA00022020


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=== Page 1 ===
From: Bruce Barket
To:
Cc: "tonyricco
"Michael Bachrach
Subject: proposed schedule.
Date: Fri, 20 Sep 2019 16:14:56 +0000
I think we will be ready to propose a schedule sometime early next week. Is there a day and time when you can meet to
discuss? We will send you a proposed briefing schedule ahead of the meeting. I hope to have ours finalized no later than
Tuesday.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments
EFTA00021330


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=== Page 1 ===
From:
To:
)"
Subject: Automatic reply: Epstein SW database
Date: Mon, 25 Jan 2021 16:03:34 +0000
I will be out of the office on January 25, 2021. I will be back in the office on January 26, 2021
If there are any questions please contact either
Thank you.
EFTA00020902


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: RAY Q/A
Date: Fri, 07 Feb 2020 15:39:37 +0000
Attachments: Larry_Ray_Q_&_A_2.7.2020.docx
Thx.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I
Mobile:
I
Press Office:
EFTA00020570


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=== Page 1 ===
From:
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:46:22 +0000
Attachments: U.S._v._Ghislaine_Maxwell_Indictment.pdf, Ghislaine_Maxwell_Indictment_PR.pdf
Inline-Images: image001.png
Awesome work.
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO ENITED DEPARTMENT VILLING
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
EFTA00021834

=== Page 2 ===
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.
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
EFTA00021835

=== Page 3 ===
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00021836


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=== Page 1 ===
The Beverly Hilton
9876 Wilshire Boulevard
A
Beverly Hills, CA 90210
Hilton
United States of America
TELEPHONE 310-274-7777
FAX 310-285-1313
HOTELS & RESORTS
Reservations
www.hilton.com or 1 800 HILTONS
Room No:
6230/D2H
Arrival Date:
2/26/2020 11:37:00 AM
Departure Date:
2/28/2020 11:40:00 AM
Adult/Child:
1/0
Cashier ID:
Room Rate:
181.00
AL:
HH #
VAT #
Folio No/Che
Confirmation Number
The Beverly Hilton 2/28/2020 11:39:00 AM
DATE
DESCRIPTION
ID
REF NO
CHARGES
CREDIT
BALANCE
2/26/2020
GUEST ROOM EXEMPT
TMEEK
11988159
$181.00
2/27/2020
GUEST ROOM EXEMPT
TMEEK
11989830
$181.00
2/28/2020
11991671
($362.00)
REF=0001552702-03271498 CHIP
05
Application Label: CREDIT
TC: 01595B3E25F0C04C
TVR: 0000008000
AID: 0000008000
**BALANCE**
$0.00
CREDIT CARD DETAIL
APPR CODE
052131
MERCHANT ID
500356170 BANK# 2454
CARD NUMBER
EXP DATE
12/23
TRANSACTION ID
11991671
TRANS TYPE
Sale
Page:1
XXXXXXXXX,
EFTA00023313


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=== Page 1 ===
From:
)"
To:
(USANYN)"
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Fri, 03 Jul 2020 14:41:23 +0000
Thanks!
From:
(USANYN)
Sent: Friday, July 3, 2020 6:59 AM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Awesome!
Assistant United States Attorney
Public Information Officer for the Albany/Plattsburgh Offices
Northern District of New York
James T. Foley U.S. Courthouse
Albany, NY 12207
Phone:
Fax:
From: USDOJ-Office of Public Affairs
Sent: Thursday, July 2, 2020 3:53 PM
To:
(USANYN)
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
seal - centered header for gov delivery
The United States Department of Justice
EFTA00021780

=== Page 2 ===
Audrey Strauss
Acting United States Attorney
Southern District of New York
FOR IMMEDIATE RELEASE
THURSDAY, JULY 2, 2020
WWW.JUSTICE.GOV/USAO-SDNY
CONTACT: JIM MARGOLIN
PHONE:
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
NEW YORK CITY - Audrey Strauss, the Acting U.S. Attorney for the Southern
District of New York, William F. Sweeney Jr., the Assistant Director in Charge of
the New York Field Office of the Federal Bureau of Investigation (FBI), and
Dermot Shea, Commissioner of the New York City Police Department (NYPD),
announced that Ghislane Maxwell was arrested this morning and charged with
enticing a minor to travel to engage in criminal sexual activity, transporting a
minor with the intent to engage in criminal sexual activity, conspiracy to commit
both of those offenses, and perjury in connection with a sworn deposition.
The indictment unsealed today alleges that between at least in or about 1994
through 1997, Maxwell and co-conspirator Jeffrey Epstein exploited girls as young
as 14, including by enticing them to travel and transporting them for the purpose
of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference
for young girls, Maxwell played a critical role in the grooming and abuse of minor
victims that took place in locations including New York, Florida, and New
Mexico. In addition, as alleged, Maxwell made several false statements in sworn
depositions in 2016. Maxwell is expected to be presented this afternoon in 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
EFTA00021781

=== Page 3 ===
youth into behavior they should never have been exposed to, creating the
potential for lasting harm. We know the quest for justice has been met with great
disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered
against the rich and connected, and they did so without a badge, a gun, or a
subpoena - and they stood together. I have no doubt the bravery exhibited by the
women involved here has empowered others to speak up about the crimes of
which they've been subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges
allege are, and always will be abhorrent for the lasting trauma they inflict on
victims. I commend our investigators, and law enforcement partners, for their
continuing commitment to bringing justice to the survivors of sexual assault,
everywhere."
If you believe you are a victim of the sexual abuse perpetrated by
Jeffrey Epstein, please contact the FBI at 1-800-CALL FBI, and
reference this case.
According to the indictment[1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, Ghislane 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
EFTA00021782

=== Page 4 ===
well as group sexualized massages of Epstein involving a minor victim where
Maxwell was present.
As alleged, minor victims were subjected to sexual abuse that included, among
other things, the touching of a victim's breasts or genitals, placing a sex toy such a
vibrator on a victim's genitals, directing a victim to touch Epstein while he
masturbated, and directing a victim to touch Epstein's genitals. Maxwell and
Epstein's victims were groomed or abused at Epstein's residences in New York,
Florida, and New Mexico, as well as Maxwell's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, Maxwell
repeatedly made false statements, including about certain specific acts and events
alleged in the indictment.
*
*
*
Ghislaine Maxwell, 58, is charged with one count of enticing a minor to travel to
engage in illegal sex acts, which carries a maximum sentence of five years in
prison, one count of conspiracy to entice a minor to travel to engage in illegal sex
acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which
carries a maximum sentence of 10 years in prison, one count of conspiracy to
transport a minor with the intent to engage in criminal sexual activity, which
carries a maximum sentence of five years in prison, and two counts of perjury,
each of which carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided
here for informational purposes only, as any sentencing of the defendant would be
determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S.
Attorneys
,
, and
are in charge of the
prosecution.
The charges contained in the Indictment are merely accusations. The defendant
is presumed innocent unless and until proven guilty.
[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.
# # #
Do not reply to this message. If you have questions, please use the contacts in the
message or call the Office of Public Affairs at
.
EFTA00021783

=== Page 5 ===
Follow us:
T Fa Yo In
This email was sent to
using GovDelivery, on behalf of U.S. Department of Justice Office of Public Affairs I 950 Pennsylvania
Ave., NW - Washington, DC 20530
TTY
GovDelivery may not use your subscription information for any other purposes.
Click here to unsubscribe.
Department of Justice Privacy Policy I GovDelivery Privacy Policy
EFTA00021784


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: RE: FOIA Request for Ghislaine Maxwell's Mugshot
Date: Wed, 22 Jul 2020 20:55:12 +0000
Got it, I'll forward, thanks.
From:
Sent: Wednesday, July 22, 2020 16:55
To:
Cc:
Subject: Re: FOIA Request for Ghislaine Maxwell's Mugshot
It's correct that SDNY doesn't have it. I don't know who the FOIA request is directed to - whether it's just to our office or
to FBI or DOJ as a whole. I think the office's practice on this case is to forward all FOIA inquiries to
who is
handling them as the main point of contact.
Sent from my iPhone
On Jul 22, 2020, at 4:46 PM,
wrote:
Isn't the answer just that we don't even have it?
Related, I just put in an intake form request (apologies if someone already did), for discovery production
From:
(USAEO)
Sent: Wednesday, July 22, 2020 16:08
To:
is
)
is
Cc:
(USANYS)
Subject: FOIA Request for Ghislaine Maxwell's Mugshot
, and
:
Good afternoon. I'm with the FOIA/PA Staff here in D.C., and I just received a FOIA request from someone for Ghislaine
Maxwell's "mugshot." Though I tasked this FOIA request to
I'm checking with you directly to see if the
photo exists and if it is releasable. I sense it's not being circulated on the internet for a reason and wanted to get the
backstory in order to respond to the request. Please feel free to let me know if this is something that should be
discussed over the phone. Thanks.
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=== Page 1 ===
From:
"
(USANYS) [Contractor]"
To: "Berman, Geoffrey (USANYS)"
Subject: Epstein accusers
Date: Thu, 05 Dec 2019 17:07:28 +0000
Attachments: Epstein_Accusers.docx
EFTA00022132


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=== Page 1 ===
From:
To: "Berman, Geoffrey (USANYS)"
Subject: Accepted: Epstein Press Meeting
Date: Mon, 01 Jul 2019 02:57:06 +0000
Importance: Normal
Attachments: unnamed
EFTA00021268


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=== Page 1 ===
Page 1 of 5
OGC Electronic Freedom of Information - NYT FOIA request - -- BOP #1, filed 8/13/19
From:
"Ivory, Danielle"
To:
Date:
8/13/2019 4:58 PM
Subject: NYT FOIA request - -- BOP #1, filed 8/13/19
Hi, I am enclosing a FOIA request, below. Please let me know if I can be of any help in explaining this
or narrowing it.
Many thanks,
Danielle
Danielle Ivory
Reporter
The New York Times
620 Eighth Avenue
New York, NY 10018
Office phone:
Mobile phone:
Email:
Aug. 13, 2019
Bureau of Prisons
FREEDOM OF INFORMATION ACT REQUEST
Dear FOIA Officer:
Requested records
"Records" means information of any kind, including writings (handwritten, typed, electronic or otherwise
produced, reproduced or stored), letters, memoranda, correspondence, notes, applications, completed
forms, studies, reports, reviews, telephone conversations, faxes, emails, documents, photographs,
EFTA00023419

=== Page 2 ===
Page 2 of 5
minutes of meetings, records of meetings in any form, and any other compilation of data from which
information can be obtained. All of the foregoing are included in this request if they are in the
possession of or otherwise under the New York Times requests for Records of the following type in the
possession, custody, or control of OSHA.
Pursuant to the Freedom of Information Act, 5 U.S.C. Section 552 et seq ("FOIA"), I request copies of
(or access to) documents about Jeffrey Epstein who died at the Metropolitan Correctional Center
(MCC) on Aug. 10, 2019, specifically (hereafter described as "the records"):
(1) The signed log in the Special Housing Unit at MCC that shows when prison staff did rounds on July
22 and 23, and Aug. 9 and 10.
(2) All quarter entries (showing which cells he was housed in) for Jeffrey Epstein at MCC.
(3) The CIM Clearance and Separatee data sheet for Jeffrey Epstein at MCC.
(4) The chronological disciplinary records for Jeffrey Epstein at MCC.
(5) The intake screening form for Jeffrey Epstein at MCC.
(6) The security designation records for Jeffrey Epstein at MCC.
(7) The inmate profile for Jeffrey Epstein at MCC.
(8) All incident reports related to Jeffrey Epstein at MCC.
(9) All medical reports related to Jeffrey Epstein at MCC.
(10) The signed visitor log for Jeffrey Epstein at MCC.
(11) Documents showing when MCC staff held meetings regarding Jeffrey Epstein, and who attended.
(12) All records generated from the meeting at MCC during which it was decided that Jeffrey Epstein
would be taken off suicide watch.
(13) The Post-Watch report compiled in order to take Jeffrey Epstein off suicide watch.
(14) The overtime sign-up sheets for the Special Housing Unit (9 South) at MCC for Aug. 9 and 10, and
on July 22 and 23.
(15) Documents showing which staff were augmented at MCC and what positions they worked in on
Aug. 9 and 10, and on July 22 and 23.
EFTA00023420

=== Page 3 ===
Page 3 of 5
The Bureau of Prisons web-based inmate locator shows that only one Jeffrey Epstein is listed in the
BOP system, so identifying the correct Jeffrey Epstein should not be a problem for the bureau.
I am a reporter for The New York Times, an accredited and recognized newsgathering organization. I
request the Records to inform the public about matters of public concern.
ONGOING LAW ENFORCEMENT PROCEEDINGS/INVESTIGATIONS
As to any records located in the investigative files of pending investigations, you may not assert
Exemption 7(A) without conducting a document-by-document review to determine whether release of
the records would interfere with ongoing law enforcement proceedings.
The United States District Court of the District of Columbia recently "remind[ed] the FBI of its obligation
to conduct record-level reviews at the administrative level before refusing to produce records contained
in its investigative files." Tipograph V. Dep't of Justice, 83 F. Supp. 2d 234 (D.D.C. Mar. 18, 2015)
In addition, the FOIA Improvement Act of 2016 added a provision instructing federal agencies to
withhold records only when their release would work some foreseeable or is prohibited by law, not just
because they may technically be exempt.
Even if the records might otherwise be exempt, an agency may withhold them only if their disclosure
would actually harm the interest protected by the exemption, or if it is prohibited by some other law. 5
U.S.C 552(a)(8). The agency does need to identify what reasonably foreseeable harm would flow from
release of the information being withheld, consider partial disclosure of the information, take reasonable
steps to segregate and release nonexempt information.
RESPONSE TIME
FOIA requires that your agency respond to this request within 20 business days. This request is
segregable, and your agency may not withhold entire records because of one section that you believe
is exempt from disclosure. Under federal law, if you choose to withhold any such parts of the records
from disclosure, you must specify in a written response the factual and legal basis for withholding any
part of the Records.
EFTA00023421

=== Page 4 ===
Page 4 of 5
ESTIMATED DATE OF COMPLETION
I respectfully request that you provide me with a reasonably estimated date of completion. See 5 U.S.C.
$ 552(a)(7)(B)(ii). If the estimated date of completion is being significantly delayed because of a portion
of the request needs to be processed by another agency, please inform me which agency that is and
whether it has provided you with an estimated date of completion.
FORMAT OF REQUESTED RECORDS
I am further requesting that the Records be provided to me on computer files in the same format as
they are currently maintained at the agency, pursuant to Burka V. Dept. of Health & Human Svcs., 87
F.3d 508 (D.C. Cir. 1996). As you know, providing documents electronically is cheaper than mailing
hard copies.
FEE WAIVER
I respectfully request that you waive all fees in connection with this request as provided by 5 U.S.C. $
552(a)(4)(A)(iii). FOIA was designed to provide citizens a broad right to access government records.
FOIA's basic purpose is to "open agency action to the light of public scrutiny," with a focus on the
public's "right to be informed about what their government is up to." U.S. Dep't of Justice V. Reporters
Comm. For Freedom of Press, 489 U.S. 749, 773-74 (1989) (internal quotation and citations omitted).
In order to provide public access to this information, FOIA's fee waiver provision requires "[d]ocuments
shall be furnished without any charge or at a [reduced] charge disclosure of the information is in
the
public interest because it is likely to contribute significantly to public understanding of the operations or
activities of the government and is not primarily in the commercial interest of the requester." 5 U.S.C. $
552(a)(4)(A)(iii).
EXPEDITED PROCESSING
There is extreme public interest in records concerning the prison stay and death of Jeffrey Epstein, who
was accused of sexually abusing scores of women and underage girls. Not only has a person died in
federal custody, but the death has generated multiple conspiracy theories implicating government
works at the highest levels and taxpayer money. Disclosure of the records request is in the public
interest because disclosure is likely to contribute significantly to the understanding of the operations or
activities of the government. In addition, as one of the largest circulation newspapers in the United
States, The New York Times plays an important role in sharing information with the public and helping
the public understand how the federal government works. Disclosure of the records is not primarily in
the commercial interest of myself or The New York Times but is intended to facilitate reporting on the
EFTA00023422

=== Page 5 ===
Page 5 of 5
operations of government.
Please contact me if I may assist in your office's response to this request.
Yours,
Danielle Ivory
Danielle Ivory
The New York Times
Office:
Cell:
Fax:
Signal encrypted chat:
EFTA00023423


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From:
)"
To:
Subject: Automatic reply: CACI document scanning 15JA5421F00000068 US V. Maxwell Epstein Scanning
Date: Thu, 24 Jun 2021 09:47:38 +0000
I will be traveling for work from June 22nd through June 24th. Although I will have access to email during this time, my responses may be
delayed. For urgent VOC matters, please contact
at
or
For any matter regarding a specific
case, please contact the other AUSA(s) on the case.
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From:
To:
Subject: Govt Reply v2 JME.docx
Date: Wed, 27 Oct 2021 19:09:36 +0000
Attachments: Govt_Reply_v2_JME.docx
With a few minor clarifying comments.
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From:
"
(USANYS)"
To: "
(USANYS)"
Subject: RE: Chief of Staff
Date: Tue, 12 Mar 2019 17:33:36 +0000
Importance: Normal
From:
(USANYS)
Sent: Tuesday, March 12, 2019 1:14 PM
To:
(USANYS)
Subject: Chief of Staff
Hi
- can you remind me of his name, so I can put on Epstein memo?
Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
t.
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From:
"
)"
To:
)"
Cc:
)"
)"
Subject: RE: FAA Question
Date: Wed, 29 Sep 2021 15:10:50 +0000
Importance: Normal
Thanks,
and thanks for your assistance with this. Congratulations on your retirement.
From:
Sent: Wednesday, September 29, 2021 11:08 AM
To:
Cc:
is
(
)
is
Subject: [EXTERNAL] RE: FAA Question
I recommend you contact the appropriate title company for the title/escrow file.
They accept summons and subpoenas, most of them accept them via fax.
I hope this helps.
I'm retiring on September 30 and if you need additional assistance please contact my Supervisor;
Best regards,
Special Agent
Federal Aviation Administration
Law Enforcement Assistance Program
Atlanta, GA
From:
Sent: Wednesday, September 29, 2021 10:47 AM
To:
Cc:
is
(
)
is
Subject: RE: FAA Question
Hi
EFTA00021675

=== Page 2 ===
I hope all's well. We've had a chance to review the records, and we'd like to learn more about one aircraft in particular.
(I've pasted your notes on it below.)
From our conversation, it sounds like the best next step is to contact the title companies involved. Do you have contacts
at Insured Aircraft Title Service Inc. and Aero Records and Title Co.? If not, I'll just give them a call.
Thanks,
On December 30, 2008, Sikosrksy Aircraft helicopter, S-76C-2, serial number 760750, tail number N750A was sold to;
Air Ghislaine Inc
Wilmington, Delaware 19803
The registrant was Larry VISOSKI, he signed as Director of Aviation
On February 11, 2010, Air Ghislaine Inc changed their name to Shmitka Air Inc.
In March 2010, Air Ghislaine Inc changed the tail number from N750A to N722JE. On the 8050-64 the signature is not
legibile but it looks
similar to the signature of Lawrence VISOSKI. He signed as Director of Operations for Shmitka Air Inc., f/k/a Air Ghislaine
Inc.
On August 25, 2010, N722JE was registered to Freedom Air International Inc.,
Wilmington,
Delaware 19803
The registrant was Darren K. INDYKE, he signed as Vice President
According to a bill of sale dated July 26, 2011, Freedom Air International (Darren K. INDYKE) sold N722JE to ASI Wings LLC,
Hartford, CT
-
On June 13, 2019, ASI Wings LLC sold N722JE to Hyperion Air LLC,
St. Thomas, U.S. Virgin
Islands
The registrant was Lawrence P. VISOSKI Jr., he signed as Manager
Per a bill of sale dated May 13, 2021, Hyperion Air LLC (Larry VISOSKI) sold N722JE to Industrial Integrity Solutions Inc.,
Ontario, CA
signed as CFO.
From:
Sent: Tuesday, August 24, 2021 8:21 AM
To:
Cc:
(
is
Subject: RE: FAA Question
2007 Gulfstream GV-SP (G550), serial number 5173 was assigned tail number N415LM in March 2017 and was registered
to
Chevron USA Inc., Oakland, CA. Per a bill of sale dated March 29, 2017, Chevron USA Inc sold Gulfstream N415LM to;
Plan D LLC
EFTA00021676

=== Page 3 ===
St. Thomas, U.S. Virgins Islands
The registrant was Lawrence VISOSKI, he signed as Manager
I believe he is Lawrence Paul VISOSKI Jr.
he is a pilot
I don't see EPSTEIN's name on any of the FAA paperwork.
There is open source reporting that VISOSKI was a pilot for EPSTEIN.
It looks like Insured Aircraft Title Service in Oklahoma handled the transaction.
https://insuredaircraft.com/
Per the Plan D LLC, statement in support of registering aircraft that was submitted to the FAA, Jeffrey E. EPSTEIN was a
member
and VISOSKI was the manager. Further, Plan D LLC was established in 2012 in the U.S. Virgin Islands.
Per a request to the FAA dated August 07, 2017 from VISOSKI, they requested to change the tail number from N415LM to
N212JE.
In January 2018 they changed the tail number to N212JE. VISOSKI provided phone number
and e-mail:
On August 14, 2019 I was told that N212JE was owned by Jeffrey Epstein and was in a hangar at the Cobb County airport
(KRYY) in Kennesaw, Georgia.
Flight plans indicated N212JE operated on July 07, 2019 from Paris, France to Teterboro, NJ then on July 11, 2019 it
operated from
Teterboro, NJ to Brunswick, GA (KBQK).
Per a bill of sale dated December 22, 2020, Lawrence VISOSKI on behalf of Plan D LLC "sold" N212JE to Six G Aviation LLC
who "sold" it the same day
to N550GP LLC in Ontario, CA. N212JE was registered on February 24, 2021 to N550GP and James PREVITI signed as
manager of Frontier JV LLC, its member.
in March 2021, they changed the tail number to N550GP and it's still registered as N550GP to N550GP LLC.
It looks like Insured Aircraft Title Service in Oklahoma handled this transaction also.
https://insuredaircraft.com/
I attached a picture of N212JE.
1969 Boeing 727, serial number 20115, N505LS was sold on January 19, 2001 by Real Estate Exchange Inc., Portland, OR
to JEGE Inc.
New York, NY 10022. The signature on the aircraft registration application is
not legible
but they listed their title as President. They changed the tail number to N908JE in April 2001. On the 2013 re-registration
application for N908JE,
Darren K. INDYKE, Vice President signed as Vice President of JEGE Inc.
They were the registered owner of N908JE from 2001 until October 05, 2019 when the registration was cancelled.
The aircraft was on the Part 125 certificate of JEGE Inc. and the CEO was Jeffrey EPSTEIN,
West Palm Beach, FL 33406 Phone
N908JE was certificated for passenger operations only (not cargo).
N908JE has a business configuration with a kitchen and bedroom and has approximately 25 seats in the aircraft and they
aren't economy seats.
It was used for private business not charter flights.
https://www.aircraft.com/aircraft/1237885/n908je-boeing-727-100
EFTA00021677

=== Page 4 ===
N908JE might be in Brunswick, Georgia (BQK). If you need confirmation of its location please advise.
I think Insured Aircraft Title Service in Oklahoma handled the transaction.
https://insuredaircraft.com/
In 1994, a 1974 Gulfstream G-1159B, serial number 151, N979GA was sold by Gulfstream to
Hyperion Air Inc., Wilmington, Delaware. David RODGERS signed as the Chief Pilot and Jeffrey EPSTEIN signed as
President.
The signature of EPSTEIN looks similar to the signature on the N505JS that became N909JE documents.
In May 1994 they changed the tail number to N909JE. In 1999 and 2013 we see Darren K. INDYKE name on documents on
behalf of
Hyperion Air Inc. In November 2013 they sold N909JE to Starbridge Landing Inc., Dover, Delaware
).
The aircraft was deregistered on December 02, 2014 for export to Venezuela.
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxx
In March 2012, a 2001 Bell 430 helicopter, serial number 49078, N901RL was registered to Hyperion Air Inc.,
Wilmington, Delaware. Darren INDYKE signed the registration application as Corporate Secretary. In June 2012 they
changed the
tail number to N331JE. In August 2013 they transferred N331JE to Hyperion Air LLC,
St.
Thomas, U.S. Virgin Islands.
The same players in the Inc and LLC are on the FAA registration paperwork - Darren INDYKE and Lawrence VISOSKI.
In November 2019 they provide phone number
In May 2020 they sold helicopter N331JE to CMG Aircraft Leasing Inc., Miami, FL (broker), who sold it the same day to QIR
Air Resources LLC,
Salt Lake City, Utah. In July 2020 they changed the tail number to N430D.
No other aircraft registered to or indexed to Hyperion Inc or LLC, and none to Ossa Properties Inc.
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
On May 30, 2013, 1988 Gulfstream G-IV, serial number 1085, tail number N423TT was registered to;
JEGE, LLC
St. Thomas, U.S. Virgin Islands 00802
The registrant was Lawrence VISOSKI, he signed as Manager
In July 2013 they (Lawrence VISOSKI) changed the tail number to N212JE. In August 2017, they (Lawrence VISOSKI)
changed the tail number to N120JE.
According to the JEGE LLC, statement in support of registering aircraft submitted to the FAA in 2013, JEGE LLC was
established in St. Thomas, U.S. Virgin Islands
on October 19, 2012 and the members were Jeffrey EPSTEIN and Lawrence VISOSKI.
In June 2019, an Aircraft Security Agreement for $2,800,000.00 on N120JE was filed with the FAA reflecting JEGE Inc.,
Powder Springs, GA 30127
as assignor and
New Bern, NC 28562 as secured party.
According to the JEGE LLC, statement in support of registering aircraft submitted to the FAA in 2019, JEGE LLC was
established in St. Thomas, U.S. Virgin Islands
on October 19, 2012 and the members were Aviation Development Group LLC and the manager was Thomas H. Huff.
He is Thomas Harrison HUFF
Ika/Powder Springs, GA
He's a pilot and has been involved in aviation at the Cobb County airport (RYY), in Kennesaw, GA for many years.
EFTA00021678

=== Page 5 ===
He is of interest to DEA S/A
in Atlanta, GA
The aircraft is still registered to JEGE LLC, St. Thomas, U.S. Virgin Islands.
I suspect HUFF bought JEGE LLC which included the aircraft.
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxx
On December 30, 2008, Sikosrksy Aircraft helicopter, S-76C-2, serial number 760750, tail number N750A was sold to;
Air Ghislaine Inc
Wilmington, Delaware 19803
The registrant was Larry VISOSKI, he signed as Director of Aviation
On February 11, 2010, Air Ghislaine Inc changed their name to Shmitka Air Inc.
In March 2010, Air Ghislaine Inc changed the tail number from N750A to N722JE. On the 8050-64 the signature is not
legibile but it looks
similar to the signature of Lawrence VISOSKI. He signed as Director of Operations for Shmitka Air Inc., f/k/a Air Ghislaine
Inc.
On August 25, 2010, N722JE was registered to Freedom Air International Inc.,
Wilmington,
Delaware 19803
The registrant was Darren K. INDYKE, he signed as Vice President
According to a bill of sale dated July 26, 2011, Freedom Air International (Darren K. INDYKE) sold N722JE to ASI Wings LLC,
Hartford, CT
).
On June 13, 2019, ASI Wings LLC sold N722JE to Hyperion Air LLC,
St. Thomas, U.S. Virgin
Islands
The registrant was Lawrence P. VISOSKI Jr., he signed as Manager
Per a bill of sale dated May 13, 2021, Hyperion Air LLC (Larry VISOSKI) sold N722JE to Industrial Integrity Solutions Inc.,
Ontario, CA
signed as CFO.
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
On January 29, 2000, Air Ghislaine Inc, Wichita, KS purchased 6.25% in a Beech 400A jet, serial number RK-260, tail
number N787TA.
On May 01, 2009, Air Ghislaine Inc., sold their 6.25% to Flight Options LLC in Richmond Heights, Ohio.
signed the bill of sale as
Executive Vice President of Flight Options LLC, acting as attorney-in-fact for Air Ghislaine Inc.
(this aircraft is currently assigned tail number N727KB)
Flight Options provides fractional jet ownership.
To identify the persons behind Air Ghislaine Inc., contact Flight Options LLC in Ohio.
http://www.flightoptions.com/
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
On May 01, 2009, Air Ghislaine Inc., Richmond Heights, Ohio purchased 6.25% in a Beech 400A jet, serial number RK-244,
tail number N439LX.
EFTA00021679

=== Page 6 ===
On February 11, 2010, Air Ghislaine Inc. changed their name to Shmitka Air Inc. and on July 06, 2010 Shmitka Air Inc.
changed their name to
Freedom Air International Inc.
On June 02, 2011, Freedom Air International Inc sold their 6.25% share in N439LX to Flight Options LLC in Cleveland, Ohio.
signed the bill of sale as Director of Sales Administration of Flight Options LLC, acting as attorney-in-fact
for
Freedom Air International Inc.
(this aircraft is currently assigned tail number N188TH)
Flight Options provides fractional jet ownership.
To identify the persons behind Shmitka Air Inc and Freedom Air International Inc., contact Flight Options LLC in Ohio.
http://www.flightoptions.com/
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Bell 407, serial number 53375, G-IORB was deregistered by the United Kingdom civil aviation authority on November 04,
2002 for
export to the United States. G-IORB was sold on October 30, 2002 to;
Air Ghislaine Inc
New York, NY 10022
It was registered as N491GM on November 13, 2002 to;
Air Ghislaine Inc
Wilmington, Delaware
The signature of the registrant is illegible but looks like that of VISOSKI.
Based on a name change from Air Ghislaine Inc to Shmitka Air Inc, the aircraft was registered on February 23, 2010 to
Shmitka Air Inc
Wilmington, DE
The registrant was Darren K. INDYKE, he signed as Vice President
Based on a name change from Shmitka Air Inc to Freedom Air International Inc, the aircraft was registered on August 25,
2010 to
Freedom Air International Inc
Wilmington, DE
The registrant was Darren K. INDYKE, he signed as Vice President
On April 30, 2012, Freedom Air International Inc (Darren K. INDYKE) sold N491GM to Eagle Copters Ltd in Calgary, Canada.
The aircraft was registered in a trust and subsequently deregistered on May 07, 2012 for export to Canada.
It was later re-registered in the U.S. with tail number N405PJ.
Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
1997 Sikorsky S-76C helicopter, serial number 760472, N162AE was sold on July 26, 2021 by ASI Wings Inc
(
) to
Freedom Air International Inc.
EFTA00021680

=== Page 7 ===
Sikorsky S-76C helicopter N162AE was registered on August 2011 to;
Freedom Air International Inc
Wilmington, Delaware
The registrant was Darren K. INDYKE, he signed as Vice President.
They changed the tail number in August 2011 to N162AD. Lawrence VISOSKI signed the 8050-64 as Director of
Maintenance of
Freedom Air International Inc to change the tail number from N162AE to N162AD.
Per a bill of sale dated February 09, 2012, Freedom Air International Inc. (Darren K. INDYKE) sold N162AD to
Greenwich Aerogroup Inc Brazil Leasing Inc
Middletown, Delaware
N162AD was deregistered on April 10, 2013 for export to Brazil.
I ordered Blue Ribbon (certified) copies of the aircraft registration records of the ten aircraft and they will be sent via
regular mail from the FAA in Oklahoma.
In the next few hours you will receive an email with links to working copies of these aircraft registration files.
No other aircraft registered to or indexed to Hyperion Inc/LLC, Plan D LLC, Ossa Properties Inc. or
Jeffrey Epstein
Ghislaine Maxwell
Thomas World Air LLC
Freedom Air Petroleum LLC
NES LLC
Maple, Inc.
Nautilus Inc.
No FAA certificates issued to Darren INDYKE.
I hope this helps,
Special Agent
Federal Aviation Administration
Law Enforcement Assistance Program
Atlanta, GA
From:
Sent: Wednesday, August 18, 2021 1:08 PM
To:
Cc:
is
Subject: RE: FAA Question
Thanks,
EFTA00021681

=== Page 8 ===
From:
Sent: Wednesday, August 18, 2021 1:07 PM
To:
Cc:
is
Subject: RE: FAA Question
In 2015/2016, DEA S/A
was interested in EPSTEIN and his aircraft;
Special Agent
Saint Thomas Resident Office
Drug Enforcement Administration
Saint Thomas, Virgin Islands 00802
In August 2019, the FBI in Atlanta, GA was interested in aircraft linked to EPSTEIN.
More will follow.
Special Agent
Federal Aviation Administration
Law Enforcement Assistance Program
Atlanta, GA
From:
Sent: Wednesday, August 18, 2021 12:41 PM
To:
Cc:
is
(
)
i
Subject: RE: FAA Question
Hi
Thanks again for the helpful call this morning. Here is the list of entities we'd like you to use as search terms:
Jeffrey Epstein
Ghislaine Maxwell
Air Ghislaine
EFTA00021682

=== Page 9 ===
Thomas World Air LLC
Hyperion Air LLC
Freedom Air Petroleum LLC
NES LLC
Maple, Inc.
Nautilus Inc.
Thanks,
From:
Sent: Tuesday, August 17, 2021 3:56 PM
To:
Cc:
is
i
Subject: Re: FAA Question
Anytime after 0930 is preferable.
Special Agent
Federal Aviation Administration
Atlanta, GA
From:
Sent: Tuesday, August 17, 2021 3:53:43 PM
To:
Cc:
is
)
V.
Subject: RE: FAA Question
Thanks,
We'll plan to give you a call tomorrow morning, assuming you're free to talk then.
Thanks,
From:
Sent: Tuesday, August 17, 2021 3:30 PM
To:
Cc:
is
(
i
Subject: RE: FAA Question
Hi!
Feel free to call my cell at your convenience.
Happy to help,
EFTA00021683

=== Page 10 ===
Special Agent
Federal Aviation Administration
Law Enforcement Assistance Program
Atlanta, GA
From:
Sent: Tuesday, August 17, 2021 3:25 PM
To:
Cc:
in
(
)
is
Subject: FAA Question
Hi
I hope all's well. I got your email from
at the FBI. We are working on a case and could use some assistance
from the FAA. Do you have a few minutes to talk sometime this week?
Thanks,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00021684


c1: EFTA00020454
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020454.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
US V Epstein
Search Terms Report
Report Name: Search Terms . OPR Materials
Searchable Set: STR - Search Terms - OPR
Materials
300,000
288,431
280,000
260,000
240,000
220,000
200,000
180,000
160,000
140,000
120,000
100,000
80,000
60,000
40,000
20,000
11,692
5,462
0
Total documents with
Total documents with
Total documents without
hits
hits, including Family
hits
Results Summary
Documents in
Total documents with
Total documents with
Total documents
searchable set
hits
hits, including Family
without hits
300,123
5,462
11,692
288,431
Report Generated: 12/8/2020 8:17:22 AM
Page 1 of 3
EFTA00020454

=== Page 2 ===
US V Epstein
Search Terms Report
Report Name: Search Terms - OPR Materials
Searchable Set: STR - Search Terms - OPR
Materials
39
56
2,059
0
2
114
4
33
963
7
629
4
167
0
4
1,225
438
0
329
63
36
Report Generated: 12/8/2020 8:17:22 AM
Page 2 of 3
EFTA00020455

=== Page 3 ===
US V Epstein
Search Terms Report
Report Name: Search Terms - OPR Materials
Searchable Set: STR - Search Terms - - OPR
Materials
0
200
400
600
800
1000
1200
1400
1600
1800
2000
2200
Terms Summary
Term
Documents with hits
Documents with hits,
Unique hits
including Family
39
148
7
56
308
37
2,059
3,191
1,955
0
0
0
2
3
2
114
254
95
4
8
0
33
128
30
963
2,488
810
7
20
3
629
1,976
544
4
6
3
167
484
5
0
0
0
4
6
0
1,225
3,242
886
438
1,156
295
0
0
0
329
1,033
267
63
575
54
36
125
9
Report Generated: 12/8/2020 8:17:22 AM
Page 3 of 3
EFTA00020456


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=== Page 1 ===
From:
To:
Subject: Accepted: Brass Meeting on Epstein
Date: Sat, 07 Dec 2019 00:12:48 +0000
Importance: Normal
Attachments: unnamed
EFTA00022149


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: draft letter to Netburn
Date: Wed, 22 Jul 2020 18:12:05 +0000
Attachments: 2020-07-22,_GM,_letter_to_Judge_Nathan_re_Local_Rule_23.1.docx
Sorry guys, I'm having bad tech issues today. Attached is the draft letter re 23.1, which is far rougher than I'd hoped to get
it. I should free back up in an hour or so, at which point I can turn back to this if there's still more to do on it.
From:
Sent: Wednesday, July 22, 2020 1:57 PM
To:
is
Subject: RE: draft letter to Netburn
Looking at this now.
From:
Sent: Wednesday, July 22, 2020 1:55 PM
To:
Cc:
Subject: RE: draft letter to Netburn
No problem, totally understand.
From:
Sent: Wednesday, July 22, 2020 13:55
To:
Cc:
Subject: Re: draft letter to Netburn
Sorry guys I can't. I keep getting kicked off the vpn, and I'm fighting with my computer, so I haven't been able to do nearly
as much work as I had planned this afternoon.
On Jul 22, 2020, at 1:52 PM,
wrote:
So I obviously had to do this pretty quickly today, and it doesn't help that Westlaw has been down all afternoon, but one
way or the other we gotta get something filed. Does either of you have a moment to take a look at this in the next hour
or so?
I'm sorry, I know you have something at 2:00! If the answer is no, totally understand, I can just pass it
up to
and
Thanks either way and talk soon.
<2020-07-22, JE, letter to Netburn re order on unsealing.docx>
EFTA00021917


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=== Page 1 ===
Troutman Sanders LLP
875 Third Avenue
troutman
New York, New York 10022
sanders
troutman.com
Bennet J. Moskowitz
December 3, 2019
E-MAIL
Sigrid S. McCawley, Esq.
Boies Schiller Flexner LLP
401 East Las Olas Boulevard
Suite 1200
Fort Lauderdale, FL 33301
Re:
Estate of Jeffrey E. Epstein
Dear Ms. McCawley:
We write in response to your letter dated November 22, 2019, posing two inquiries
concerning the proposed Epstein Victims' Compensation Program (the "Program") presented by
the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate") on November 14, 2019 to the
Superior Court of the United States Virgin Islands (the "USVI Court") for approval. Our
response does not constitute the Co-Executors' position regarding discovery (e.g., whether
discovery is appropriate at this time or the information you requested is discoverable in the
actions pending in the Southern District of New York); rather, we respond in order to further the
parties' discussions concerning the Program.
Accordingly, we repeat your inquiries below and address them to the best of our ability
based on currently available information.
1. "What is the total value of Epstein's Estate?"
The total assets held by the Estate are a matter of public record: the Co-Executors'
Petition for Probate and for Letters Testamentary, filed on August 19, 2019 in the United States
Virgin Islands, valued the Estate's assets in excess of $577 million.
However, the Estate is subject to substantial potential liabilities in an undetermined
amount, which makes it impossible to accurately calculate the total value of the Estate. Among
other things, (i) the Estate is subject to estate taxes in at least two jurisdictions, the United
States and France; (ii) the United States Department of Justice has indicated that it may seek
civil forfeiture of properties held by the Estate; and (iii) your clients and other claimants have
lodged 17 separate lawsuits in New York state and federal courts, seeking multi-million-dollar
damages awards. Moreover, the number and size of future claims is unknown: one plaintiffs'
EFTA00023230

=== Page 2 ===
December 3, 2019
Page 2
troutman
sanders
counsel recently predicted that "[p]otentially dozens" more additional lawsuits will be filed,
without specifying exact numbers of such cases or the damages that may be sought.¹
For these reasons, it is simply not possible at present for the Co-Executors to state the
total value of the Estate. However, if you and other plaintiffs' counsel provide us with a
complete report on how many additional claims your clients intend to assert - as well as a
realistic assessment of damages to be sought in those claims - the Co-Executors can gain a
better understanding of the Estate's potential liabilities.
2. "How much of Epstein's Estate will be set aside for compensating victims
through the proposed claims resolution program?"
The Co-Executors await approval of the Program by the USVI Court. In the interim,
Program Administrator Jordana Feldman and Program Designers Kenneth Feinberg and
Camille Biros are proceeding with preparation of a detailed Program protocol to establish a fair,
independent claims resolution process as a voluntary alternative to protracted civil litigation. As
we understand it, the Program Administrator intends to reach out to your firm and other
plaintiffs' counsel for input on the content of that protocol.
Once the Program protocol is finalized, the Co-Executors will submit it to the USVI Court
for approval and seek an order to formally commence claims resolution proceedings under the
Program. It remains to be seen how many claimants - your clients included — will decide to
participate in the Program. When the number of participating claimants become clearer, the Co-
Executors anticipate being better able to estimate how much money will ultimately be required
to adequately fund the Program. It is the Co-Executors' intent that the Program be "open-
ended" regarding amounts awarded - i.e., the Estate will not impose any absolute numerical
cap on the Program's aggregate compensation payments.
*
*
For any other questions you or your clients may have about the proposed Program, we
urge you to contact Ms. Feldman and her team as soon as possible. It is also in all parties'
interests for you to begin a constructive dialogue with Ms. Feldman and her team. We
appreciate any assistance your firm and other plaintiffs' counsel can provide in enabling the
Program to serve its desired function as a preferred, confidential, non-adversarial alternative to
litigation, both for your clients and any other individuals seeking to resolve sexual abuse claims
against Mr. Epstein or the Estate.
1 See November 21, 2019 transcript of proceedings held in Doe V. Epstein, et al., 19-CV-07675 (GBD)
(S.D.N.Y.) and VE V. Nine East 71st Street, et al., 19-CV-07625 (AJN) (S.D.N.Y.), at 38:7-14.
EFTA00023231

=== Page 3 ===
December 3, 2019
Page 3
troutman
sanders
Sincerely,
/s/ Bennet J. Moskowitz
Bennet J. Moskowitz
CC:
David Brodie, Esq. (via Email)
Andrew Buzin, Esq. (via Email)
Kate Doniger, Esq. (via Email)
Brad Edwards, Esq. (via Email)
Julie Fink, Esq. (via Email)
Arick Fudali, Esq. (via Email)
Alan Goldfarb, Esq. (via Email)
Brittany Henderson, Esq. (via Email)
Daniel J. Kaiser, Esq. (via Email)
Roberta Kaplan, Esq. (via Email)
Jordan Merson, Esq. (via Email)
Josh Schiller, Esq. (via Email)
Laura Starr, Esq. (via Email)
Mariann Wang, Esq. (via Email)
EFTA00023232


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 20-3061 United States of America V. Maxwell "Defective Document CURED"
Date: Wed, 23 Sep 2020 19:06:25 +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 09/23/2020
Case Name:
United States of America V. Maxwell
Case Number: 20-3061
Docket Text:
CURED DEFECTIVE DOCUMENT: [53], SUPPLEMENTARY PAPERS TO MOTION, [54], on behalf of
Appellant Ghislaine Maxwell, FILED. [2937096] [20-3061]
Notice will be electronically mailed to:
Ty Gee, -:
Laura Menninger, -:
Adam Mueller, -
Gerard Whidbee, Deputy Clerk:
Notice will be stored in the notice cart for:
Gerard Whidbee, Deputy Clerk
Quality Control 1
EFTA00023127


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=== Page 1 ===
From: Christian Everdell
To:
⑉
)"
>, Jeff Pagliuca
>, "Mark S. Cohen"
>, "Laura
Menninger"
, "Bobbi Sternheim
(
)"
Cc:
)"
i
(USANYS)"
Subject: RE: US V. Maxwell - Request for Extension of Discovery Deadline
Date: Thu, 05 Nov 2020 22:58:30 +0000
Inline-Images: image001.jpg
Thanks,
I will speak to you then.
From:
)
[mailto:
Sent: Thursday, November 05, 2020 5:20 PM
To: Christian Everdell; Jeff Pagliuca; Mark S. Cohen; Laura Menninger; Bobbi Sternheim
(
)
Cc:
);
(USANYS)
Subject: RE: US V. Maxwell - Request for Extension of Discovery Deadline
Chris,
Yes, we are available for a call at 9am tomorrow morning to discuss. We can use the below dial-in:
Dial-in:
Code: 707522
Thanks,
Assistant United States Attorney
Southern District of New York
From: Christian Everdell
Sent: Thursday, November 5, 2020 4:53 PM
To:
>; Jeff Pagliuca
>; ; Mark S. Cohen
>; Laura Menninger
>; Bobbi Sternheim
Cc:
is
(USANYS)
Subject: RE: US V. Maxwell - Request for Extension of Discovery Deadline
-
Can we have a call tomorrow morning to discuss? I am free before 9:30am.
EFTA00020821

=== Page 2 ===
Thanks,
Chris
From:
) [mailto:
Sent: Thursday, November 05, 2020 1:57 PM
To: Jeff Pagliuca; Christian Everdell; Mark S. Cohen; Laura Menninger; Bobbi Sternheim
(
)
Cc:
);
(USANYS)
Subject: RE: US V. Maxwell - Request for Extension of Discovery Deadline
Good afternoon,
Thank you for your response. The outside vendor is PAE, which maintains our office's Relativity database. The production
at issue consists of documents extracted from numerous electronic devices seized from Jeffrey Epstein's residences in
New York and the Virgin Islands, which were loaded onto Relativity for privilege and responsiveness review. On October
7, 2020, our office's filter team completed its privilege review of those documents. On October 21, 2020, the case team
completed the responsiveness review and identified approximately 1.2 million documents as responsive. That same
night, the case team asked PAE to prepare those approximately 1.2 million documents for production by imaging, bates
stamping, and downloading the documents. We have repeatedly told PAE of the November 9th discovery deadline.
Yesterday, PAE informed us that it had finished imaging the production but would not be technologically able to finish
bates stamping and downloading the production by November 9th. PAE has indicated that it expects to complete the
production by November 19th, though it is making every effort to move as quickly as possible.
Best,
Assistant United States Attorney
Southern District of New York
From: Jeff Pagliuca
Sent: Thursday, November 5, 2020 1:42 PM
To:
>; Christian Everdell
>; ; Mark S.
Cohen
>; Laura Menninger
>; Bobbi Sternheim
(
Cc:
is
(USANYS)
Subject: RE: US V. Maxwell - Request for Extension of Discovery Deadline
Dear Ms.
Because of ongoing difficulty with client calls and visitation we have not been able to adequately discuss the request. Also,
it would be helpful for us to know the reason for the anticipated delay and the identity of the vendor.
Once we have had the opportunity to fully consider the request we will let you know our position.
EFTA00020822

=== Page 3 ===
Best regards,
Jeff Pagliuca
Jeffrey S. Pagliuca
Haddon, Morgan and Foreman, P.C.
.832.2628
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
From:
Sent: Thursday, November 5, 2020 10:30 AM
To: Christian Everdell
>; Mark S. Cohen
>; Jeff Pagliuca
>; Laura Menninger
>; Bobbi Sternheim
Cc:
is
(USANYS)
Subject: RE: US V. Maxwell - Request for Extension of Discovery Deadline
Good afternoon,
Following up on the below request, would you please let us know your position? I am available any time this afternoon if
you would like to have a call to discuss. We are planning to file our request with the Court today.
Thank you,
Assistant United States Attorney
Southern District of New York
From:
Sent: Wednesday, November 4, 2020 5:10 PM
To: Christian Everdell
>; Mark S. Cohen
>; 'Jeff Pagliuca'
>; Laura Menninger
>; Bobbi Sternheim
EFTA00020823

=== Page 4 ===
Cc:
is
(USANYS)
Subject: US V. Maxwell - Request for Extension of Discovery Deadline
Counsel,
Today our outside vendor informed us that it will not be technologically possible for the vendor to finish processing the
Government's final discovery production in this case by the November 9, 2020 deadline. The vendor has indicated that it
expects to finish processing the production by November 19, 2020, at which point it will send the production to 1 St.
Andrew's Plaza for us to conduct a spot check before providing it to you. Accordingly, we intend to ask the Court to
extend the final discovery deadline, solely for the production of materials being processed by the vendor, by two weeks to
November 23, 2020. We still expect to make a separate discovery production to you on November 9, 2020, and the only
material that will be the subject of this extension request is that being processed by the vendor.
Would you please let us know your position on this extension request? We are also happy to have a phone call to discuss.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00020824


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=== Page 1 ===
From:
To:
Bcc: "USAHUB-USAJournal111"
Subject: FW: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Transmission of Notice of Appeal
and Docket Sheet to USCA
Date: Tue, 12 Jan 2021 13:38:17 +0000
Embedded: FW:_Activity_in_Case_1:20-cr-00330-
AJN_USA_v_Maxwell_Transmission_of_Notice_of_Appeal_and_Docket_Sheet_to_USCA.m
sg
Sender
Subject: FW: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Transmission of Notice of Appeal and
Docket Sheet to USCA
Message-Id: <2f80772c0cbd47f89762ec0002984d7d@CY1P110MB0198.NAMP110.PROD.OUTLOOK.COM>
EFTA00020453


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=== Page 1 ===
From:
)"
To:
)"
Subject: Fwd: Attending the Upcoming Maxwell Trial
Date: Fri, 08 Oct 2021 20:49:10 +0000
Inline-Images: Outlook-NCVBA.png
Having some struggles with email on my phone still, but looks like I also forwarded his second email, in May.
Those two that I sent along are the only communications I have from him.
Sent from my iPhone
Begin forwarded message:
From:
)" </O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE
GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=D0812B3F0D874F78AF13D43961863FE4-
Date: May 10, 2021 at 13:34:00 PDT
Subject: FW: Attending the Upcoming Maxwell Trial
Hey team, similar email as what I got from him on April 20, just FYI.
From: Robert Y. Lewis
Sent: Monday, May 10, 2021 16:27
To:
Subject: Attending the Upcoming Maxwell Trial
Dear
I represent
one of the victims of Jeffrey Epstein and his lieutenant Ghislaine Maxwell.
would like to attend the upcoming trial of Ms. Maxwell. She will be coming from England,
where she lives.
is not asking the government to pay for any travel expenses, but would like to be given priority
(along with other victims of course) in getting into the trial as a spectator. Given the keen public interest in
the case, she is afraid that without priority she will not be able to get into the courtroom. Would you let us
know what your office is doing to ensure that victims like
can attend the trial?
Thank you for all your hard work in bringing Ms. Maxwell to justice.
Robert Y. Lewis
The Marsh Law Firm PLLC
EFTA00022643

=== Page 2 ===
THE NATIONAL
CRIME VICTIM
BAR ASSOCIATION
CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is confidential and may be
subject to the attorney-client privilege, or otherwise protected from disclosure by applicable law. Any disclosure, distribution,
copying, or use of the information contained in this message or any attachment by anyone other than the intended recipient,
regardless of address or routing, is strictly prohibited. If you are not the intended recipient, please telephone or email the
sender and delete this message and any attachment from your system.
CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is confidential and
may be subject to the attorney-client privilege, or otherwise protected from disclosure by applicable law. Any
disclosure, distribution, copying, or use of the information contained in this message or any attachment by
anyone other than the intended recipient, regardless of address or routing, is strictly prohibited. If you are not
the intended recipient, please telephone or email the sender and delete this message and any attachment from
your system.
IF YOU ARE NOT A CLIENT: This material is general information of an educational nature and is not legal
advice. This communication does not establish or constitute the retention of Marsh Law Firm PLLC for the
provision of legal services, unless explicitly so stated herein. Any attached items, including the content of this e-
mail, are offered "as is" with no guarantee as to their accuracy, timeliness, or completeness.
EFTA00022644


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=== Page 1 ===
From:
To: Christian Everdell <CEverdell@CohenGresser.com>,
>, BOBBI C
STERNHEIM <bcsternheim@mac.com>, Laura Menninger <lmenninger@hmflaw.com>,
Jeff Pagliuca <jpagliuca@hmflaw.com>
Cc:
Subject: RE: Redactions: Government motion in limine
Date: Sat, 30 Oct 2021 00:11:41 +0000
Attachments: 2021-10-29_Govt_letter_re_Proposed_Redactions_to_MILs_v1.docx
Thanks, Chris. I know you're in the process of filing, but in the meantime, here's a draft joint letter.
Thanks,
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Friday, October 29, 2021 7:55 PM
To:
is
>; BOBBI C
STERNHEIM <bcsternheim@mac.com>; Laura Menninger <lmenninger@hmflaw.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>
Cc:
is
Subject: [EXTERNAL] RE: Redactions: Government motion in limine
All -
I have confirmed that the government has incorporated all of the defense's proposed redactions within the government's
proposed redactions. We do not have any more to add. For the record, we oppose the government redactions that are
additional to the defense's redactions.
We will now file the defense's motions and exhibits, as redacted/sealed, and then wait for you to file the government's
response. It may take a little time to get them all filed, so bear with me.
Thanks,
Chris
From:
Sent: Friday, October 29, 2021 6:45 PM
To:
>; Christian Everdell <CEverdell@CohenGresser.com>; BOBBI C
STERNHEIM <bcsternheim@mac.com>; Laura Menninger <Imenninger@hmflaw.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>
Cc:
is
Subject: RE: Redactions: Government motion in limine
All,
For filing purposes, attached are redacted versions of the defendant's motions and exhibits, the government's omnibus
opposition, and the defendant's omnibus reply. Below are our notes on which exhibits should be sealed. Please let us
know if you would like to add any redactions or if you have any questions.
EFTA00023462

=== Page 2 ===
Defense Motions
Sealed
The following exhibits should be sealed
Exhibit A to Motion 4 (grand jury testimony)
Exhibit B to Motion 4 (grand jury testimony)
Exhibit 1 to Motion 7 (contact book)
Exhibit 2 to Motion 7 (deposition)
Exhibit A to Motion 8 (inventory)
Exhibit A to Motion 9 (photobook)
Exhibit to Motion 13 (various exhibits)
Redactions (attached)
Motion 1 and Exhibit 1 to Motion 1
Motion 2 and Exhibit A to Motion 2
Motion 3 and Exhibit 2 to Motion 3
Motion 4
Motion 7
Motion 8
Motion 9
Motion 10
Motion 13
No redactions
We are not seeking redactions to defense opening briefs for defense motions 5, 6, 11, and 12.
We are not seeking redactions to Exhibit 1 to Motion 3 (Government expert notice)
Government Opposition
We are not seeking to redact Government exhibits A and B (articles)
Defense Reply
Sealed
The following exhibits should be sealed
Exhibit A (tax documents)
Exhibit B (302)
Exhibit C (medical report)
Exhibit D (transcript)
No redactions
We are not seeking redactions to defense Exhibit E (English indictment)
From:
Sent: Friday, October 29, 2021 6:21 PM
To: Christian Everdell <CEverdell@CohenGresser.com>;
>; BOBBI C
STERNHEIM <bcsternheim@mac.com>; Laura Menninger <Imenninger@hmflaw.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>
Cc:
is
Subject: RE: Redactions: Government motion in limine
Happy to jump on a call. We're almost finished with the materials we'll be sending you in a second wave, so why don't we
get the first wave filed, and we'll send you the second set, and then we can get on the phone. Does that work?
EFTA00023463

=== Page 3 ===
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Friday, October 29, 2021 6:19 PM
To:
is
>; BOBBI c
STERNHEIM <bcsternheim@mac.com>; Laura Menninger <Imenninger@hmflaw.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>
Cc:
is
Subject: [EXTERNAL] RE: Redactions: Government motion in limine
Got it. We are filing the response now.
I was thinking through the joint cover letter and I think there are a few more logistics we have to discuss. Can you jump
on a quick call?
From:
Sent: Friday, October 29, 2021 6:16 PM
To: Christian Everdell <CEverdell@CohenGresser.com>;
>; BOBBI C
STERNHEIM <bcsternheim@mac.com>; Laura Menninger <Imenninger@hmflaw.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>
Cc:
>;
Subject: RE: Redactions: Government motion in limine
Thanks for asking - yes, that's correct.
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Friday, October 29, 2021 6:06 PM
To:
is
>; BOBBI C
STERNHEIM <bcsternheim@mac.com>; Laura Menninger <Imenninger@hmflaw.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>
Cc:
is
Subject: [EXTERNAL] RE: Redactions: Government motion in limine
Just so I am clear on sequencing, you are now waiting for us to file the redacted version of our response brief, correct?
From:
Sent: Friday, October 29, 2021 5:49 PM
To: Christian Everdell <CEverdell@CohenGresser.com>;
>; BOBBI C
STERNHEIM <bcsternheim@mac.com>; Laura Menninger <Imenninger@hmflaw.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>
Cc:
is
Subject: RE: Redactions: Government motion in limine
Thanks, Chris. We'll get this first group filed and then send you the next batch.
From: Christian Everdell <CEverdell@CohenGresser.com
Sent: Friday, October 29, 2021 5:42 PM
To:
>; BOBBI C STERNHEIM <bcsternheim@mac.com>; Laura
Menninger <Imenninger@hmflaw.com>; Jeff Pagliuca <jpagliuca@hmflaw.com>
Cc:
is
is
;
EFTA00023464

=== Page 4 ===
Subject: [EXTERNAL] RE: Redactions: Government motion in limine
The redactions are consistent with what the government had proposed before. We do not have any redactions to add to
these documents. But for the record, we object to all of the government's proposed redactions.
Please send me the next batch when you have them ready.
Thanks,
Chris
From:
Sent: Friday, October 29, 2021 4:55 PM
To: Christian Everdell <CEverdell@CohenGresser.com>; BOBBI c STERNHEIM <bcsternheim@mac.com>; Laura Menninger
<Imenninger@hmflaw.com>; Jeff Pagliuca <jpagliuca@hmflaw.com>
Cc:
is
Subject: Redactions: Government motion in limine
All,
Thanks for the call this afternoon, it was helpful to work through the mechanics of filing redactions this afternoon. As we
discussed, we're sending you versions of the following documents, with redactions applied: (1) the Government's motion
in limine, (2) the defendant's opposition, and (3) the Government's reply.
Please let us know if you would like us to add any redactions to these versions, and we'll get them filed. With respect to
Exhibits:
We are attaching a proposed redacted version of Government exhibit A.
Only defense exhibits E and G can be filed publicly without redactions.
All other defense exhibits to the defense opposition should be filed under seal.
Best,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00023465


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=== Page 1 ===
2010-Mar-01 04:13 PM JPMorganChase 212-464-0318
3/15
J.P. Morgan Entity Account Application
J.P.Morgan
A. Entity Information
Type of Business INVESTMENTS
Date of Incorporation/Organizatio 11/06/1998
Country of Incorporation/Organization VIRGIN ISLANDS (U.S.)
Primary Authorized Contact Person DARREN INDYKE
Phone 340-775-2525
Mailing Address 6100 RED HOOK, QUARTERS B-3
City ST THOMAS
Country VIRGIN ISLANDS - 00802
The following fields are required for Brokerage and IM Accounts:
Gross Annual
Liquid Net Worth
Revenue ($) Mm
+
Total Assets ($) locat
*
(Investable assets) ($) 100mg
Total Net Worth ($) 100mm
B. Account Information
Title of account/Name of business: FINANCIAL TRUST COMPANY INC, C/O AMERICAN YACHT HARBOR
M
Corporation
Partnership
PIC/PHC
Sole Proprietorship
Check If applicable
Foundation
Limited Liability Company
Limited Liability Partnership
Not for profit
1 have applied to open the following accounts:
Checking Account
Money Market Deposit Account/Savings
Investment Menagement/Third Party Manager (discrettonary)
K
Asset/Brokerage
Asset/Custody
I hereby apply for 8 Line of Credit linked to my Asset Account
Yes
X
No (If Yes, a U-1 form will be required)
Each account 1 open is subject to the security Interest provisions in the Agreement (defined below) and is pledged as Collateral for all
my Obligations.
c. Ownership Information
is this 8 grivetely held operating company in which any one person or entity has 25% or more of the ownership interest?
Yes (complete owner Information below)
No
*
Controlling
Owner (Primary)
Jeffrey Epstein Ownership
% of
100%
Controling
% of
Owner
Ownership 0
Date of Birth:
Date of Birth:
.
-
y Y y
m m - 0 0 - y y y y
Passport Number
Passport Number
Controlling
% of
Controlling
% of
Owner
Ownership
0
Owner
Ownership 0
Date of Birth:
-
.
Date of Birth:
-
-
m m - d d - y y y y
m m - of d - y y y y
Passport Number
Passport Number
D. Authorized Persons for Information Access
The following Individuals are authorized to Inquire about and receive all information about my accounts and transactions, including
access to account Information made available on J.P. Morgan websites:
Name RICH KAHN, HARRY BELLER
Name
E. Brokerage Information (required for Brokerage accounts only)
By checking the box below I consent to the electronic delivery of all information including, but not limited to, communications,
prospectuses, and marketing and sales documents relating to my securities activity for all investment products Including both
registered and unregistered offerings.
*
1 may be notified by e-mail regarding the above
G-Mail
Address:
My objective for this account (check one):
Cepital Preservation
Income Generation
M
Capital Appreciation
Speculative or aggressive Investments that may generate higher returns but may be riskler than other Investments because I may
lose all or part of my Investment (check one):
K
Are permitted in this account
Are not permitted in this account
Primary source of income:
X
Investments
Operating income
Other
Please Indicate the number of years of personal trading experience for the authorized party(s) on this account:
Foreign
Emerging
Stocks 20 Bonds 20 Commodities 20 Exchange 20 Markets
20
Options 20
I currently have brokerage accounts with the following firms:
J.P. Morgan Use Only
FINANCIAL TRUST COMPANY INC Title
2811138 SPN
9707980808CAS
1 of 2
Casey Mary C Banker/Investor
01/10 1060
GOVERNMENT
EXHIBIT
Confidential Treatment Requested by
503
JPM-SDNY-00001937
JPMorgan Chase
S2 20 Cr. 330 (AJN)
EFTA00020577


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=== Page 1 ===
From:
)"
To:
Subject: Automatic reply: US V. Epstein
Date: Tue, 12 Nov 2019 19:48:01 +0000
I will be out of the office until November 15th. Although I will have email access during this time, my responses may be delayed. For urgent
matters, please contact the other AUSA(s) on the case.
EFTA00020905


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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: Forfeiture question
Date: Tue, 15 Oct 2019 18:33:55 +0000
Sorry, was in a meeting. How'd it go?
From:
Sent: Tuesday, October 15, 2019 2:06 PM
To:
Subject: FW: Forfeiture question
On the phone with him now-you're welcome to swing by, but it seems like this will be super short, so no worries.
From: Matthew L. Schwartz
Sent: Tuesday, October 15, 2019 1:56 PM
To:
Cc:
>;
Subject: RE: Forfeiture question
I just freed up and can call you in a few minutes if that works.
Matthew L. Schwartz
(o)
(m)
On October 15, 2019 at 1:39:21 PM EDT,
)
wrote:
Matt,
With apologies: I now need to meet with a witness starting at 4 today, so unfortunately 4:30 no longer works.
Happy to talk between now and 4, or later this evening, if either works. Alternatively, I'm free at 9:30
tomorrow morning, or between 11 a.m. and 1 p.m. tomorrow.
Thanks,
From: Matthew L. Schwartz
Sent: Monday, October 14, 2019 9:10 PM
To:
)
Cc:
i
Subject: Re: Forfeiture question
4:30 is perfect. Where should I call?
EFTA00021337

=== Page 2 ===
Matthew L. Schwartz
(o)
(m)
On October 14, 2019 at 6:40:46 PM EDT,
)
wrote:
Hi Matt,
I'm available for a call tomorrow either at 1 p.m. or anytime from 4:30 onwards, if either of those windows
works for you.
Best,
Sent from my iPhone
On Oct 13, 2019, at 8:23 PM, Matthew L. Schwartz
wrote:
Thanks
If any of you have a moment for a forfeiture-related question in the next few days, please let
me know. FYI, this has nothing to do with my firm's representation of certain victims. Thanks.
-mls
Matthew L. Schwartz
(o)
(m)
On October 13, 2019 at 7:44:17 PM EDT,
wrote:
Hi Matt,
The Epstein case team are AUSAs
and
all cc'd on this
email. They're the right people to talk to about anything Epstein-related.
Sent from my iPhone
On Oct 13, 2019, at 2:59 PM, Matthew L. Schwartz
wrote:
Do either of you guys or the appropriate other person have 2 minutes to discuss a somewhat time-
sensitive, but by no means urgent, Epstein-related forfeiture question in the next few days?
Matthew L. Schwartz
(o)
(m)
The information contained in this electronic message is confidential information intended only
for the use of the named recipient(s) and may contain information that, among other
protections, is the subject of attorney-client privilege, attorney work product or exempt from
disclosure under applicable law. If the reader of this electronic message is not the named
recipient, or the employee or agent responsible to deliver it to the named recipient, you are
hereby notified that any dissemination, distribution, copying or other use of this
communication is strictly prohibited and no privilege is waived. If you have received this
EFTA00021338

=== Page 3 ===
communication in error, please immediately notify the sender by replying to this electronic
message and then deleting this electronic message from your computer. [v.1 08201831BSF]
EFTA00021339


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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: RE: Briefing in Florida regarding whether the Florida NPA extends to New York
Date: Thu, 25 Jul 2019 17:01:20 +0000
Attachments: VICTIMS_Reply_to_Epstein_Filed_Pacer.pdf;1 EPSTEIN_Motion_for_Sur_Reply.pdf
Hi
I wanted to make you aware of a recent filing (on Tuesday) by Jane Doe 1 and 2 in the Florida CVRA case. See attached.
You may find interesting our argument at pp. 3-6, in which we explain why Judge Marra must craft remedies in the case
that relate solely to Florida crimes and Florida victims because the NPA only covers Florida.
We filed our reply brief on remedies on Tuesday - and that should have brought all briefing on remedies for the CVRA
violation to a close. But yesterday Epstein's lawyer (Marty Weinberg) filed a motion for a sur-reply. See attached. In
point (a) on page 2, he argues that he should have an opportunity to file a sur-reply discussing, among other things, the
scope of the NPA. On Monday, we will be filing an opposition to Weinberg extending the briefing further. It appears that
Judge Marra is poised to rule rapidly on the motion for a sur-reply, as he asked for us to respond quickly.
I wanted to make you aware of these developments. My clients were told back in 2013 that the NPA did not extend to
New York or other jurisdictions - and that is the point we are making to Judge Marra.
for Jane Doe 1 and 2
You can access my publications on
CONFIDENTIAL: This electronic message along with any/all attachments - is confidential. This message is intended only for the use of the
addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this
message in error, please immediately notify the sender by reply electronic mail and delete the original message.
is admitted to the
Utah State Bar, but not the bars of other states. Any views he expresses in this email are his own.
EFTA00021441


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=== Page 1 ===
From:
To:
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509) (Out Of Office)
Date: Mon, 06 Jul 2020 23:48:44 +0000
I will be out of the office until Tuesday, July 7, 2020, with limited access to email.
If this is an urgent matter, please call the institution at
and ask for the relevant department.
You may also email
with any urgent legal matters.
Thank you!
EFTA00021833


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=== Page 1 ===
CWT
SatoTravel
Your Itinerary
Trip on Feb 26, 2020
Locator:
Date: Feb 21, 2020
Traveler
ATTN:
DO1E2
US
USA
ALL MCO#S MUST BE MAILED TO.
THIS IS YOUR OFFICIAL RECEIPT FOR TRAVEL
PLEASE RETAIN FOR VOUCHERING OR
REIMBURSEMENT PURPOSES.
Customer Number
643SR7F
Agent
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FEES TOTALING 9.35PP CHARGED IN ADDITION TO TKT PRICE
FEE-USD9.35PP-AIR DOMESTIC ONLINE
Wednesday, February 26, 2020
Confirmation
Flight JETBLUE AIRWAYS 123
DEPARTURE
ARRIVAL
NEW YORK JFK, NY
LOS ANGELES,CA
6:59 AM, Feb 26, 2020
10:27 AM, Feb 26, 2020
Status
Confirmed
Class
Coach Class - Z
Duration
06:28 (Non-stop)
Equipment
32S
Meal Service
Snack
Reserved Seats
12C (Aisle)
Frequent Flyer
Notes
DEP-TERMINAL 5
ARR-TERMINAL 5
CABIN-ECONOMY
Wednesday, February 26, 2020
Confirmation
Hotel THE BEVERLY HILTON
LOCATION
CONTACT
9876 WILSHIRE BLVD
Tel 1-310-274-7777
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Fax 1-310-285-1313
Reserved For
Status
Confirmed
Check-In
Feb 26, 2020
Check-Out
Feb 28, 2020
Number of Rooms
1
Rate
USD 181.00/night
Cancellation Policy
Cancel 2 days prior
Directions
LOS ANGELES INTL AIRPORT
Monday, March 02, 2020
Confirmation
EFTA00023314

=== Page 2 ===
Flight JETBLUE AIRWAYS 624
DEPARTURE
ARRIVAL
LOS ANGELES,CA
NEW YORK JFK, NY
2:35 PM, Mar 02, 2020
10:58 PM, Mar 02, 2020
Status
Confirmed
Class
Coach Class - Y
Duration
05:23 (Non-stop)
Equipment
32S
Meal Service
Snack
Reserved Seats
21C (Aisle)
Frequent Flyer
Notes
DEP-TERMINAL 5
ARR-TERMINAL 5
CABIN-ECONOMY
Name
Invoice / Ticket / Date
Base
Tax 1
Tax 2
Tax 3
Total
9.35
9.35
386.98
57.82
444.80
Total Amount
454.15
GENERAL INFORMATION
TO BOOK RESERVATIONS ONLINE PLEASE VISIT
CWTSATOTRAVEL.COM
FOR AIRPORT SECURITY INFORMATION SEE WWW.TSA.GOV
UNUSED PAPER TICKETS MUST BE RETURNED TO CWTSATOTRAVEL
CONTACT CWTSATOTRAVEL TO REFUND ELECTRONIC TICKETS
FARES ARE NOT GUARANTEED UNTIL TICKETED
CONTRACT CARRIER CITY PAIR FARES DO NOT REQUIRE
ADVANCE PURCHASE. ALL OTHER FARES MAY REQUIRE ADVANCE
PURCHASE AND ARE NOT GUARANTEED UNTIL TICKETED
TRANSACTION FEES ARE NONREFUNDABLE
UNUSED PAPER TICKETS MUST BE RETURNED TO SATOTRAVEL
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FOR ALLOWANCE IF TRAVELING ON CODE SHARE FLIGHT.
***DID YOU KNOW WE CAN ALSO BOOK YOUR HOTELS AND RENTAL CARS**
EFTA00023315


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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: Sun, 05 Jul 2020 21:21:56 +0000
Inline-Images: image001.png
Thanks very much,
From:
Sent: Saturday, July 4, 2020 4:55 PM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
A few days late to the party, but huge congrats guys. Such a worthy case. (Or, as my mom texted, "yay SDNY! Ghislaine
Maxwell wasn't allowed to 'slither away'!")
From:
Sent: Thursday, July 02, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO TOTAL UNITED
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
STATES
OF
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
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
,
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
EFTA00021787

=== Page 2 ===
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney
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
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
EFTA00021788

=== Page 3 ===
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
*
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms.
praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
EFTA00021789

=== Page 4 ===
unless and until proven guilty.
EFTA00021790


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=== Page 1 ===
From:
)"
To:
)
[Contractor]"
Subject: Fwd: Arrest 302
Date: Mon, 29 Jul 2019 20:23:56 +0000
Attachments: Arrest_of_JEFFREY_EPSTEIN.PDF; ATT00001.htm; 2019_JE_advice_of_rights.pdf;
ATT00002.htm; 2019_JE_arrest _-_receipt_for_property.pdf;_ATT00003.htm;
2019_JE_items_returned_to_lawyer.pdf;ATT00004.htm
Begin forwarded message:
From:
(NY) (FBI)"
Date: July 29, 2019 at 2:58:35 PM EDT
To:
)"
Subject: Arrest 302
Hey
,
Attached is the arrest 302, advice of rights, receipt for property from the arrest, along with the receipt of items
turned over to his lawyer on 7/18.
SA
FBI New York
VCAC/Human Trafficking
O:
C:
EFTA00021519


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c0:
=== Page 1 ===
From:
To:
Subject: Re: Epstein meeting at 3
Date: Wed, 14 Aug 2019 13:48:15 +0000
Thanks
Sent from my iPhone
On Aug 14, 2019, at 9:41 AM,
wrote:
Hi all,
has scheduled a brief meeting regarding the Epstein case today at 3pm in the 8th floor library with the PC chiefs,
I, and the Epstein team. I've put it on all of your calendars.
Thanks,
EFTA00021011


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=== Page 1 ===
From: Druyan law
To:
)"
Subject: Re: US V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Date: Tue, 04 May 2021 17:38:38 +0000
Yes, thanks,
I read of your exploits in the Times.
Good luck
MD
Sent from my iPhone
On May 4, 2021, at 10:06 AM,
)
wrote:
Martin,
I I hope all is well. We wanted to let you know that the Court has adjourned the trial date to the fall of 2021. We will
update you when we have more information.
Best,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00023032


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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
Use this form for all fact witnesses within the U.S. except government employees and military personnel, for whom a Request for
Armed Forces or Government-Employee Witness should be used. For foreign witnesses, use the International Witness Travel
Request. Complete an Early or Extended stay memo if the witness is being brought in more than 3 business days prior to court/GJ
testimony. Note that witnesses may only be brought in under the FEWS appropriation for grand jury testimony, court testimony,
or preparation for same. NB: as to grand jury, this applies only in the relatively infrequent occasions where time in the grand jury
has been scheduled and the witness is intended to testify. Any other witness travel for investigative interviews must be covered
by the investigating component from litigative funds (it is generally more common for investigators to travel to the witness). See
28 C.F.R. Part 21, Witness Fees; USAP 3-19.000, Fact Witnesses and Fees and Expenses of Witnesses (FEW) Appropriation;
Guiding Principles for Obtaining Witness Services Under the Fees and Expenses of Witnesses Appropriation,
http://dojnet.doj.gov/usao/eousa/ole/usabook/witn/index.htm
To:
SDNY Victim/Witness Unit
AUSA
United States V. Jeffrey Epstein
Court Docket Number: 19 Cr. 490 (RMB)
USAO No: 2018R01618
Witness Name:
Witness DOB:
(Name/DOB as printed here will be forwarded to travel agency and then to TSA and must exactly match the witness's driver's
license or other travel ID or TSA will not permit the witness to fly)
Witness Address:
Witness Telephone Numbers (mobile):
Witness e-mail:
Needed to Appear in SDNY on August 1, 2019 at 1 p.m.
date
time
For: Trial ( )
Grand Jury ( )
Trial/GJ Prep (x)
Trial Date
Date
Date
Is the person a Fact Witness and not an Expert Witness?
(Yes/No)
Yes
Current Federal Civilian or Military Employee?
(Yes/No)
No
Is the Witness Facing Criminal Charges?
(Yes/No)
No
Does the Witness Reside Outside the Continental United States?
(Yes/No)
No
Is this Witness a Victim-Witness
(Yes/No)
Yes
Hotel Required
(Yes/No)
Yes
Est. Date of Arrival
Est. Date of Departure
EFTA00020934


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=== Page 1 ===
From:
To:
Subject: Travel Authorization 11063602 approved by
, now awaiting further
approval
Date: Fri, 21 Feb 2020 18:35:45 +0000
Importance: Normal
Dear
Travel authorization 11063602 has been approved by
, now awaiting further approval.
Trip ID: 11063602
Traveler name:
Purpose: R20NYS13404 - Epstein Investigation - Witness interview
Destination: Beverly Hills, CA, United States
Dates: 2020-02-25 - 2020-02-29
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0007
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00021149


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=== Page 1 ===
From:
To:
Subject: Final Voucher 10810414-1(1) has received final approval
Date: Sun, 08 Dec 2019 23:53:24 +0000
Importance: Normal
Dear
Final voucher 10810414-1(1) has received final approval.
Trip ID: 10810414-1
Voucher ID: 1
Voucher type: Final
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R20NYS13179 - U.S. V. Epstein - Witness Interview
Destination: Santa Monica, CA, United States
Dates: 2019-11-13 - 2019-11-15
Current status: Voucher Awaiting Payment
Voucher total expenses: 1585.76
Estimated trip cost: 1947.20
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0008
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00020999


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=== Page 1 ===
From:
(USANYS)"
To:
>, , Laura Menninger
, Jeff Pagliuca
Cc:
)"
)"
)"
-
(USANYS) [Contractor]"
Subject: US V. Maxwell, 20 Cr. 330 (AJN)
Date: Sat, 20 Nov 2021 19:53:28 +0000
Attachments:2021.1120_Maxwell_Discovery_Letterpdf;2021.11.20_Maxwell_3500_Cover_Leterpdf
2021.11.20_U.S._v_Maxwell_3500_Index_(Defense).pdf;
2021.11.20_US_v_Maxwell_Non-Testifying_Witness_Material_Index_(Defense).pdf;
2021.11.20_US_v_Maxwell_Government_Exhibit_Index_(Defense).pdf
Counsel,
We have an additional discovery production ready to send to you. Attached please find the accompanying cover letter.
That will be produced on a hard drive to you. In addition, a supplemental production of testifying witness and non-
testifying witness material and exhibits are also ready to send to you. Attached please find the accompanying cover letter
and indices. Those materials will be on the hard drive as well. We will also produce the testifying witness and non-
testifying witness material and exhibits via USAfx.
Please let us know if you would like to pick up the drive today or if you would like us to FedEx it (and if so, to where).
Please let us know if you would like us to send today via FedEx a hard drive with these materials to Ms. Maxwell at the
MDC or bring the hard drive to court on Tuesday.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel:
EFTA00023359


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: Re: Noel/Thomas FOIA Disclosure
Date: Sun, 27 Jun 2021 22:09:27 +0000
Great. Thanks!
On Jun 27, 2021, at 5:54 PM,
(USANYS)
wrote:
Sounds good. We can meet in my office on 8. 3:45?
On Jun 27, 2021, at 5:15 PM,
(USANYS)
wrote:
Hi all,
and I circled up in advance of the meeting tomorrow. I plan to attend in person, and I think
will as well, so
maybe we could meet up in person at 1StA's around 3:30/3:45 to speak before the meeting? If so, please let me know
where would work best for that.
Thanks,
From:
(USANYS)
Sent: Thursday, June 24, 2021 1:48 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Great, thanks
do you guys mind conferring about what's in the production that's likely to become
noteworthy/of interest, and then we can have a brief pre-meeting on Monday to discuss?
just wants a brief
overview of what we're producing and the greatest hits of what's likely to become newsworthy. Thanks very much.
From:
(USANYS)
Sent: Thursday, June 24, 2021 12:44 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
BOP is in the loop, but I do not know how far up it has gone for this round. For earlier issues in the case, I think we
went up to the GC. I can confirm with the FOIA Specialist I've primarily been working with there how far it has gone
this time. (She is in Central Office, not MCC.) I know she went up with one specific issue recently about the production,
so I assume folks there no the whole thing is going out.
EFTA00023388

=== Page 2 ===
I have not been in touch with the Estate at any point, and see no reason to do that. If we were going to reach out to
them, I'd like to clear that with folks on the Civil side.
I've been in touch with
at OIG (told him about the extension today).
Thanks,
From:
(USANYS)
Sent: Thursday, June 24, 2021 12:18 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Defer to
on this. But to the extent it is relevant, on Noel/Thomas's counsel, they know about the FOIA litigation
because we produced some materials to them that were collected after the FOIA action was initiated, so I could easily
give them a call or email on this. The Noel/Thomas team hasn't been giving any updates to the Estate.
From:
(USANYS)
Sent: Thursday, June 24, 2021 12:16 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
asked whether there was any other constituency that we should notify about the upcoming release that hasn't
already been notified (she suggested BOP or Epstein's estate).
,
how high up BOP have you been briefing about
this? And as far as Epstein's estate, we haven't provided notice of anything thus far, correct? I don't see a reason to do
so, and same for Noel/Thomas counsel, but let me know if either of you guys disagree. Thanks.
From:
(USANYS)
Sent: Thursday, June 24, 2021 12:11 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Great. Thanks very much
is sending an email up to
today, and we are anticipating that we'll send a
UMR down to Main Justice early next week. We'll let you know if anyone raises any concerns.
From:
(USANYS)
Sent: Thursday, June 24, 2021 11:07 AM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
All,
Per the attached, the Court granted the one-week extension in the Epstein FOIA. So the production is now due next
Friday, July 2. Please let me know if you foresee any issues with that date.
Please also let me know if you need anything else from me in terms of the processes we discussed yesterday. We are
working with BOP to finalize the production, but please let me know if I should take steps beyond that (e.g., letting
additional people know about the production, etc.).
EFTA00023389

=== Page 3 ===
Also, does anyone want to see the production before it goes out?
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 6:08 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Thank you,
I have no edits, subject to anything else
/
have.
From:
(USANYS)
Sent: Wednesday, June 23, 2021 6:00 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Hi all,
The Times consented to the one-week request. I think it is likely the Court will approve it. I plan to file the attached
letter, which includes the changes we discussed on the phone, around 6:30. Please let me know if you have any issues
or concerns. l'll let you know as soon as the Court rules.
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 5:12 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Hi all,
We now have a 5:45 call scheduled with the Times. Please let me know before then if there's any other info I can share
with them. I'm attaching a draft extension request letter here for review. Please let me know if this looks okay, or if we
need to discuss anything,
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 3:46 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Hi all,
I just spoke with
, who spoke with
I can make this request, but I am not sure it will be successful. Before I
speak to the Times about it, I need to know a little bit more info about what I can share with the Times and what is
EFTA00023390

=== Page 4 ===
going on. Could someone please give me a call at
?1 need to connect with the Times as soon as possible
because we will need to put in the request today to PAE.
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 3:02 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Hi
Could I give you a quick call on this?
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 2:57 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Noel/Thomas FOIA Disclosure
Hi
We understand you had been planning to make the Noel/Thomas FOIA disclosure on Friday. We just ran this by
and she'd like you to ask for a brief (1-2 week) extension to enable us to confer internally regarding the interviews,
which were just completed, to confirm we agree they've fulfilled that requirement of their deferred prosecution
agreements. She's going to speak with
about it as well. Is this doable?
Thanks,
Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
Desk
Cell
EFTA00023391


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=== Page 1 ===
From:
"
(NY) (CON)"
To:
)"
Cc:
(NY) (FBI)"
Subject: Epstein - Palm Beach real property
Date: Fri, 19 Jul 2019 16:33:56 +0000
Attachments: nv_162_18854529_img_12232011_Deed_Epstein_to_Laurel_Inc.pdf
FYI
Palm Beach, FL 33480
Last Deed of Record attached.
Will do due diligence on Laurel, Inc
Squad C-40 (FAST)
Senior Financial Investigator (SFI)
(
EFTA00020948


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: SDNY investigation
Date: Fri, 19 Jul 2019 16:16:35 +0000
Attachments: 2019-07-13,JE,_individual_subpoena,
odf
Following up on our phone conversation a few minutes ago, thank you for being in touch and advising us of your
representation of
in connection with his receipt of a grand jury subpoena, which is attached. So you have
contact info for our full team, we're all reachable anytime at the copied emails or by phone at:
As we discussed on the phone, I understand you'll need to have the opportunity to speak with him further, and so it's fine
for us to speak mid-next week. And as I also mentioned, we don't currently have any reason to believe that
has
done anything wrong; we would like to speak with him about his knowledge of and interactions with Jeffrey Epstein,
particularly in connection with recent statements he has made to the press about comments Epstein made to him about
Epstein's prior conduct.
Please let us know if any additional information would be helpful, and we look forward to being in touch with you next
week.
thank you,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Question re T-Visa
Date: Fri, 22 May 2020 14:32:01 +0000
Thanks! Will call you in a few minutes.
From:
Sent: Friday, May 22, 2020 10:31 AM
To:
Subject: RE: Question re T-Visa
Give me a call and I can walk you through it.
From:
)
Sent: Friday, May 22, 2020 10:31 AM
To:
Cc:
)
is
-
Subject: Question re T-Visa
Hi
attorneys have reached out to us to inquire about our office assisting her in obtaining a T-Visa. She is
currently legally in the U.S. on a work visa, but that expires when her passport expires in August of 2020. We've never
dealt with T-Visas before, so would appreciate any guidance you might be able to provide. Would
qualify for a T-
Visa? If so, what would the process be for sponsoring her?
Also happy to have a call if that's easier, or if there's someone else we should reach out to, please let me know.
Thanks,
EFTA00023116


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Cc:
)"
Subject: RE: Pseudonyms
Date: Wed, 13 Oct 2021 20:06:23 +0000
Attachments: Anonymity_v.1_
).docx; 2019-05-09 - Govt_MiL_vf.docx
Thanks so much for putting this together. Some suggestions/thoughts in the attached. I'm also attaching the brief that
sent me which has a couple of case cites on pages 4-5. I'm happy to take another look later if helpful.
I
think you should also review this.
Feel free to call with any questions.
Thanks,
From:
Sent: Tuesday, October 12, 2021 1:16 AM
To:
is
(USANYS)
Cc:
Subject: Pseudonyms
Hey team,
Attached is a draft MIL for pseudonyms. I'm going to churn out the sympathy MIL tomorrow and then do a heavy edit of
the whole doc, which hopefully will make it shorter and tee it up for
Safe flight tomorrow,
and good luck in California!
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00020810


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=== Page 1 ===
OFFICIAL RECORD
Intake (Rev. 5-23-17)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Intake
Date: 08/03/2020
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Drafted By:
Date/Time Received: 08/02/2020 11:54 AM EDT
Details:
On 08/02/2020, at 11:54 a.m. Eastern Time,
/ cell phone
number
email address
, home
address
North Hollywood, CA United States 91601,
Internet Protocol (IP) address
, which
resolves to North Hollywood, CA 91606, submitted an online tip to the FBI
National Threat Operations Center (NTOC) via tips.fbi.gov, to report
information regarding Jeffrey Epstein and Ghislaine Maxwell.
Date Submitted: 08/02/2020 11:54:17 AM ET
Transaction Number: BA12E05D-6FDF-428D-BFE3-0D9212DA6636
Threat To Life:
Submitted Text:
in 1996 I was 19 years old, my entire art portfolio was finally ready to
apply to art school. I showed my best art to former high school
classmates (several were Israeli, 1 was friends with serbians who were
friends with the princess of Yugoslavia and the lingerie model actress
serbian-Canadian
and her ex boyfriend the actor Matthew
Settle who owed
money and they set up an elaborate plan involving a
false romance and grooming me to ultimately be approached by ghislaine
maxwell and jeffrey epstein several days after all of ny artwork
UNCLASSIFIED
EFTA00020462

=== Page 2 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/03/2020
disappeared while Matthew helped the Israeli moving company Northstar
/Moishe's move me into my very first apartment in July 1997 when I was 20
years old in Los Angeles. In retrospect there was a clear plot taking
place, and I was introduced to Epstein early on at a bar next to were
Matthew Settle Lived. I heard
call him on the phone and ask on
speaker phone sometime between April- June of 1997 if Matthew had her
money yet. He said to me she would send the Serbian mafia to hurt him if
he didn't come up with the money. He did not mention that my artwork was
where the money was going to come from. The friend of mine who told her
serbian friends about my artwork which started chain of events
culminating in the disappearance of all of my artwork is named Jasmine
Dashtizad. One of my stolen paintings is of Bill Clinton's head on a
woman (Hillary Clinton's) body. I painted it between November 1995 to
January 1996. I was a teenager. I drew my own dental impressions in the
Ray Johnson estate collage, I also drew one of my fingerprints. And
that art is made out of pieces of my high school calendar which fell
apart from overuse, so I glued the pieces onto thick cardstock and drew
designs and draeings around the glued pieces. I also traced my own
handprints on that art. I also drew a replica of the art on the cover of
my 12th grade high school play production program and I also wrote the
fictional bio of Ray Johnson.
Violation: Public Corruption, White Collar Crime, Civil Rights
Violation Questions
What was the exact crime that occurred?: Art theft / Art Fraud / Art
Forgery
Does this information involve a government official? If so, what is their
name and position/title?: no
Do you have any evidence to support your claim or know of any witnesses
to the crime (s) ?: Yes and some evidence and witnesses who saw the art
before it disappeared
UNCLASSIFIED
2
EFTA00020463

=== Page 3 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/03/2020
Did you suffer any personal losses (financially or physically) due to the
crime?: yes to both questions I've spent $100,000 my Dad had to give me
to buy my stolen artwork back, but most of it I can't get back because
it's been sold through Sotheby's in June 22, 2017 London catalogue
artwork misattributed to a variety of artists, also the D.B. Henkel
paintings are my stolen forged paintings, some of the Paul Tobeler stolen
paintings are mine, the Adler-Beatty Ray Johnson estate
How long has this activity been going on?: Since 1997 when it disappeared
in Los Angeles, some of it is also in the Adelson gallery, some of it has
been sold to Tony Podesta by a fake artist, 3 paintings are part of
Jeffrey Epstein's estate, 1 of those falsely claimed by Petrina Ryan
Kleid who used my 3 of my paintings as her college portfolio art
Complainant Information
First Name:
Middle Name:
Last Name:
Age:
DOB:
Additional Info:
Type: Cell
Phone:
Extension:
Account:
Type: Residential
UNCLASSIFIED
3
EFTA00020464

=== Page 4 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/03/2020
Address:
City: North Hollywood
State: California
Zip: 91601
Country: United States
Subject Information
First Name: Jeffrey Matthew
Middle Name:
Last Name: Settle
Age: 50
DOB:
Additional Info: Ray johnson estate - online website - the artwork is
listed in the Smithsonian museum's online art and is falsely attributed
to a deceased person in the art gallery world named David Bourdain or
Bourdan for the year 1998. It was stolen from me in July 1997.
Petrina Ryan Kleid has an online presence and has many fake articles
written about my artwork falsely attributed to herself.
One of those paintinhs was originally a painting of Dan Quayle, but
someone has painted over the face to make it look like George Bush Jr.
Instead. That painting used to depict a note tacked on to the wall that
spelled potato wrong (potatoe) which was crossed out and underneath was
written the correct spelling of potatoes. Also, my signature used to be
UNCLASSIFIED
4
EFTA00020465

=== Page 5 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/03/2020
on the front of the desk but it has been painted over. I usually used
permanent marking pen ink for my signature, so it probably can be
detected using the appropriate technologies for analyzing art. This
applies to all of my stolen paintings. But my drawings were often signed
in pencil but I drew my fingerprint, my dental impressions and my traced
handprints on the Ray Johnson estate art that is listed in the
Smithsonian. There is a lot more information about fraud and forgery
going on with Sotheby's London 2017 and db henkel in traverse city. It
would like to share all information in depth, so that all of these fake
/ forged worthless paintings that were stolen from me can be removed
permanently from the big money art market and hopefully returned to me
because they belong to me, they are sentimental personal property and I
will never get over this until these people are stopped from their art
fraud. Another gake artist has a serbian name Biljana Djurdjevic and
Tony Podesta bought all of those stolen paintings of mine, including one
that is a self portrait of myself at 19 years old.
How is Contact Known: this is the person who owed the Serbian- Canadian
model
money who was connected to Mark Epstein, Jeffrey
Epstein, Jean Luc Brunel, Ghislaine Maxwell, Elle McPherson and her
manager Stuart, the professional magician J.B. Benn
Type: Other
Address:
City:
Zip:
Witness Information
First Name: Jeffrey Matthew
Middle Name:
UNCLASSIFIED
5
EFTA00020466

=== Page 6 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/03/2020
Last Name: Settle
Age: 50
DOB:
Additional Info: His full name is Jeffrey Matthew Settle
He became a very successful actor immediately after all my artwork
disappeared. He also was friends with Lady Victoria Hervey a member of
the aristocracy of England at the time when all of my paintings
disappeared. I had shown him every single painting I had ever made.
was friends with "a princess of Yugoslavia" but I don't
kniw which princess this was. She also in recent years has been publicly
linked to Prince Andrew. Jb Benn the magician was also very closely
involved in grooming me yo meet ghislaine maxwell in New York in April
1997 when I was forced by Matthew Settle to go stay with JB in NYC for a
week in the bedroom of his roommate Urim Lekaj who was an Albanian model
who went to Los Angeles while I was staying in his bedroom in Manhatten
at JB's apartment. JB took me to a dinner with reservations required
where Ghislaine was sitting at the table next to us and asked me for my
contact number to send me modeling castings. I looked 15 even though I
was 20 years old at that time in 1997. I am only 5 ft 3 1/2 inches tall
and I was never photogenic enough to do modeling. It was all a scam
...
and I think the goal was primarily to steal all of my artwork which
according to sothebys, thd Smithsonian, Adler-Beatty Gallery, Adelson
Gallery, DB henkel forged paintings that are my stolen paintings, ALL OF
THE PEOPLE INVOLVED ARE MAKING MILLIONS OF DOLLARS SELLING MY STOLEN
PAINTINGS WITH FORGED SIGNATURES AND FALSE PROVENANCE.
How is Contact Known: He very suspiciously showed up outside an audition
I was sent to by the parent of one of my classmates, and began a love
fraud fake romantic relationship with me in July of 1996 which ended
abruptly a year later in July 1997 right after all of my artwork
disappeared. He was also good friends with Mark Epstein who he talked
about a lot. Instead of encouraging me to use my art portfolio to apply
UNCLASSIFIED
6
EFTA00020467

=== Page 7 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/03/2020
to Cooper union art school in NYC where Mark Epstein was director and
where the tuition was free, all Matthew did was tell me I needed to get a
job waitresses at a restaurant, specifically Union Square restaurant in
Manhattan.
Type: Other
Address:
City:
Zip:
Remote IP:
Remote Host: api.fbi.gov
Http Referrer: https://www.justice.gov/interpol-washington/pr/fbi-new-
york-art-crime-team-has-record-number-art-and-cultural-items-returned
User Browser: Mozilla/5.0 (Linux; Android 10; SM-A215U)
AppleWebKit/537.36 (KHTML, like Gecko) Chrome/80.0.3987.99 Mobile
Safari/537.36
Latitude:
Longitude:
Country: US
Region: California
City: North Hollywood
UNCLASSIFIED
7
EFTA00020468

=== Page 8 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/03/2020
Postal Code: 91606
Timezone: -07:00
UNCLASSIFIED
8
EFTA00020469


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=== Page 1 ===
From:
To:
Subject: Drafts of the remaining motions
Date: Sun, 24 Oct 2021 01:52:49 +0000
Attachments: Forbidden_Words_v1.docx; Suppress_ID_v2.docx
Hey team,
Here are drafts of the remaining motions!
Thanks,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00023201


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=== Page 1 ===
From:
To: Bruce Barket
Cc:
Subject: RE: proposed schedule.
Date: Mon, 23 Sep 2019 13:23:28 +0000
Those times work for us. Does the rest of the defense team have a preference?
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From: Bruce Barket
Sent: Saturday, September 21, 2019 1:59 PM
To:
Subject: Re: proposed schedule.
I can make 12:00 1:00 or 4:00
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country road
Garden City, NY 11530
Barket Epstein.com
On Sep 21, 2019, at 9:33 AM,
wrote:
We are free Thursday afternoon except from 2:45 - 4.
EFTA00021692

=== Page 2 ===
Assistant U.S. Attorney
On Sep 21, 2019, at 07:22,
wrote:
Any day next week works for me. Also in my role as Learned Counsel, and in full compliance with the ABA Guidelines, I
will be submitting a proposed schedule for penalty phase pleadings over the weekend.
Thanks
Tonyricco
Original Message
From:
To: Bruce Barket
Sent: Fri, Sep 20, 2019 9:15 pm
Subject: Re: proposed schedule.
We are free next Friday afternoon if that works for you all.
Assistant U.S. Attorney
On Sep 20, 2019, at 12:16, Bruce Barket
wrote:
I think we will be ready to propose a schedule sometime early next week. Is there a day and time when you can meet
to discuss? We will send you a proposed briefing schedule ahead of the meeting. I hope to have ours finalized no later
than Tuesday.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it
is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error;
any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have
received this communication in error, please notify us immediately by telephone or email and immediately delete this
message and all its attachments
EFTA00021693


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=== Page 1 ===
From: Sigrid McCawley <smccawley@bsfllp.com>
To:
)"
Subject: Filing
Date: Mon, 10 Aug 2020 23:57:54 +0000
Attachments: 2020-08-10_[01100-000]_LETTER_addressed_to_Judge_Loretta_A._Preska_from_.pdf
2020-08-10_[01100-001]_Exhibit_A.PDF
Are you able to shed light on what Menninger is trying to intimate in this first paragraph? I just want to prepare if there is
something I need to know about. This letter comes as part of the unsealing process.
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
(t) +1 954 377 4223
(m) +1 954 770 5377
smccawley@bsfllp.com
www.bsfllp.com
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
EFTA00021879


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=== Page 1 ===
Exhibit A
EFTA00023049

=== Page 2 ===
LIST OF PARTICULARS
1. Please provide the full names and full birthdays of the individuals identified in the
Superseding Indictment as Minor Victims-1-3 (11 7, 11, 13, 17, 19).
2. Please identify the dates when, and locations where, Ms. Maxwell allegedly met
and/or interacted with Minor Victim-1 (1 7a).
3. Please identify the dates when, and locations where, Ms. Maxwell allegedly
"groomed" Minor Victim-1 "to engage in sexual acts with Epstein" (I 7a).
4. Please identify the dates when, and locations where, Jeffrey Epstein allegedly
sexually abused Minor Victim-1 (I 7a).
5. Please identify the dates when, and locations where, Ms. Maxwell allegedly "was
present for and involved in" Epstein's sexual abuse of Minor Victim-1 (I 7a).
6. Please identify the dates when, and locations where, Minor Victim-1 participated in
"group sexualized massages" of Epstein (1 7a).
7. Please describe with particularity the conduct that the government contends is a
"group sexualized massage" and identify the criminal statute(s) the conduct allegedly
violates and the other participants in those massages (I 7a).
8. Please describe with particularity how Ms. Maxwell allegedly "involved" Minor
Victim-1 in these massages and how Ms. Maxwell allegedly participated in these
massages (1 7a).
9. Please identify the dates when Minor Victim-1 allegedly traveled "across state lines
for the purpose of sexual encounters with Epstein" (1 7a).
10. Please identify the dates when Ms. Maxwell allegedly enticed Minor Victim-1 "to
travel across state lines for the purpose of sexual encounters with Epstein" and
describe with particularity the actions that Ms. Maxwell allegedly took to entice
Minor Victim-1 to travel (1 7a).
11. Please identify the dates when, and locations where, Ms. Maxwell allegedly met
and/or interacted with Minor Victim-2 (1 7b).
12. Please identify the dates when Minor Victim-2 allegedly traveled across state lines to
and from New Mexico in 1996 (1 7b).
13. Please identify the dates when Ms. Maxwell allegedly "groomed" Minor Victim-2 to
engage in "acts of sexual abuse" with Epstein (1 7b).
EFTA00023050

=== Page 3 ===
14. Please describe with particularity what Ms. Maxwell allegedly did as part of the
"unsolicited massage" of Minor Victim-2 and identify the criminal statute(s) the
conduct allegedly violates (1 7b, 11c, 17c).
15. Please identify the dates when, and locations where, Ms. Maxwell allegedly met
and/or interacted with Minor Victim-3 (I 7c).
16. Please identify the dates when, and locations where, Ms. Maxwell allegedly
introduced Minor Victim-3 to Epstein and the dates and locations of their subsequent
"multiple interactions" (1 7c).
17. Please identify the dates when, and locations where, Ms. Maxwell allegedly
"groomed" Minor Victim-3 to engage in sex acts with Epstein (1 7c).
18. Please identify the dates when, and locations where, Jeffrey Epstein allegedly
sexually abused Minor Victim-3 (1 7c).
19. Please describe with particularity the "sex acts" that Minor Victim-3 allegedly
engaged in with Epstein during massages and identify the criminal statute(s) the
conduct allegedly violates and the other participants in those massages (1 7c).
20. Please identify the dates when Minor Victim-3 allegedly traveled in interstate or
foreign commerce to engage in illegal sexual activity with Epstein (1 7c).
21. Please specify when the conspiracies charged in Count One and Count Three began
and ended. (II 9, 15).
22. Please identify the "others" who allegedly participated in the conspiracies charged in
Count One and Count Three with Epstein and Ms. Maxwell. (II 9-10, 15-16).
23. Please identify any individuals who were enticed to travel, or were transported, in
interstate or foreign commerce to engage in illegal sexual activity with Epstein during
the time period of the charged conspiracies (1994-1997), apart from Minor Victims-1-
3 (1 10, 16).
24. Please identify the dates when, and the locations where, Ms. Maxwell participated in
"group sexualized encounters" with Jeffrey Epstein and Minor Victim-1 (11 11a,
17a).
25. Please describe with particularity the conduct that the government believes constitutes
a "group sexualized encounter" and identify the criminal statute(s) the conduct
violates and the participants in those encounters (11 11a, 17a).
26. Please identify who allegedly enticed Minor Victim-1 to travel from Florida to New
York in 1996 (II 11b, 17b).
EFTA00023051

=== Page 4 ===
27. Please identify from whom Ms. Maxwell was allegedly trying to "conceal her crimes"
when she allegedly lied under oath in depositions in 2016 (1 2).
28. Please identify "the specific events and acts of abuse" about which Ms. Maxwell
allegedly "repeatedly provided false and perjurious statements" (1 8).
29. As to each statement alleged to be perjurious in Counts Five and Six of the
Superseding Indictment please specify why the Government contends the statement
was material (11 21, 23).
EFTA00023052


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=== Page 1 ===
From:
"Ivory, Danielle"
To:
Date:
12/12/2019 3:05 PM
Subject:
NYT FOIA to BOP, Epstein logs
Hi, I am enclosing a FOIA request, below. Please let me know if I can be of
any help in explaining this or narrowing it.
Many thanks,
Danielle
Danielle Ivory
Reporter
The New York Times
620 Eighth Avenue
New York, NY 10018
Office phone:
Mobile phone:
Email:
Dec. 12, 2019
Bureau of Prisons
FREEDOM OF INFORMATION ACT REQUEST
Dear FOIA Officer:
Requested records
"Records" means information of any kind, including writings (handwritten,
typed, electronic or otherwise produced, reproduced or stored), letters,
memoranda, correspondence, notes, applications, completed forms, studies,
reports, reviews, telephone conversations, faxes, emails, documents,
photographs, minutes of meetings, records of meetings in any form, and any
other compilation of data from which information can be obtained. All of
the foregoing are included in this request if they are in the possession of
or otherwise under the New York Times requests for Records of the following
type in the possession, custody, or control of OSHA.
Pursuant to the Freedom of Information Act, 5 U.S.C. Section 552 et seq
("FOIA"), I request copies of (or access to) documents about Jeffrey
Epstein who died at the Metropolitan Correctional Center (MCC) on Aug. 10,
2019, specifically (hereafter described as "the records"):
(1) The full log of Mr. Epstein's phone calls to and from the MCC.
(2) All email correspondence to and from Mr. Epstein while he was at the
MCC (including any correspondence through the Corrlinks system or any other
email system he had access to.)
EFTA00023428

=== Page 2 ===
(3) The full log of people who visited Mr. Epstein while he was at the MCC
and when they visited.
(4) The full list of people that Mr. Epstein had requested to be on his
approved visitor list.
(5) The full list of people that Mr. Epstein had requested to be on his
approved email correspondence list.
(6) The full list of people that Mr. Epstein had requested to be on his
approved call list.
The Bureau of Prisons web-based inmate locator shows that only one Jeffrey
Epstein is listed in the BOP system, so identifying the correct Jeffrey
Epstein should not be a problem for the bureau. For this request, records
generated by BOP employees based in New York, Texas, and in Washington, DC,
should be searched.
I am a reporter for The New York Times, an accredited and recognized
newsgathering organization. I request the Records to inform the public
about matters of public concern.
ONGOING LAW ENFORCEMENT PROCEEDINGS/INVESTIGATIONS
As to any records located in the investigative files of pending
investigations, you may not assert Exemption 7(A) without conducting a
document-by-document review to determine whether release of the records
would interfere with ongoing law enforcement proceedings.
The United States District Court of the District of Columbia recently
"remind[ed] the FBI of its obligation to conduct record-level reviews at
the administrative level before refusing to produce records contained in
its investigative files." Tipograph V. Dep't of Justice, 83 F. Supp. 2d 234
(D.D.C. Mar. 18, 2015)
In addition, the FOIA Improvement Act of 2016 added a provision instructing
federal agencies to withhold records only when their release would work
some foreseeable or is prohibited by law, not just because they may
technically be exempt.
Even if the records might otherwise be exempt, an agency may withhold them
only if their disclosure would actually harm the interest protected by the
exemption, or if it is prohibited by some other law. 5 U.S.C 552(a)(8). The
agency does need to identify what reasonably foreseeable harm would flow
from release of the information being withheld, consider partial disclosure
of the information, take reasonable steps to segregate and release
nonexempt information.
RESPONSE TIME
FOIA requires that your agency respond to this request within 20 business
days. This request is segregable, and your agency may not withhold entire
records because of one section that you believe is exempt from disclosure.
Under federal law, if you choose to withhold any such parts of the records
from disclosure, you must specify in a written response the factual and
legal basis for withholding any part of the Records.
ESTIMATED DATE OF COMPLETION
I respectfully request that you provide me with a reasonably estimated date
of completion. See 5 U.S.C. $ 552(a)(7)(B)(ii). If the estimated date of
completion is being significantly delayed because of a portion of the
request needs to be processed by another agency, please inform me which
agency that is and whether it has provided you with an estimated date of
completion.
EFTA00023429

=== Page 3 ===
FORMAT OF REQUESTED RECORDS
I am further requesting that the Records be provided to me on computer
files in the same format as they are currently maintained at the agency,
pursuant to Burka V. Dept. of Health & Human Svcs., 87 F.3d 508 (D.C. Cir.
1996). As you know, providing documents electronically is cheaper than
mailing hard copies.
FEE WAIVER
I respectfully request that you waive all fees in connection with this
request as provided by 5 U.S.C. § 552(a)(4)(A)(iii). FOIA was designed to
provide citizens a broad right to access government records. FOIA's basic
purpose is to "open agency action to the light of public scrutiny," with a
focus on the public's "right to be informed about what their government is
up to." U.S. Dep't of Justice V. Reporters Comm. For Freedom of Press, 489
U.S. 749, 773-74 (1989) (internal quotation and citations omitted). In
order to provide public access to this information, FOIA's fee waiver
provision requires "[d]ocuments shall be furnished without any charge or at
a [reduced] charge disclosure of the information is in the public
interest because it is likely to contribute significantly to public
understanding of the operations or activities of the government and is not
primarily in the commercial interest of the requester." 5 U.S.C. $
552(a)(4)(A)(iii).
EXPEDITED PROCESSING
There is extreme public interest in records concerning the prison stay and
death of Jeffrey Epstein, who was accused of sexually abusing scores of
women and underage girls. Not only has a person died in federal custody,
but the death has generated multiple theories implicating government works
at the highest levels and taxpayer money. Disclosure of the records request
is in the public interest because disclosure is likely to contribute
significantly to the understanding of the operations or activities of the
government. In addition, as one of the largest circulation newspapers in
the United States, The New York Times plays an important role in sharing
information with the public and helping the public understand how the
federal government works. Disclosure of the records is not primarily in
the commercial interest of myself or The New York Times but is intended to
facilitate reporting on the operations of government.
Please contact me if I may assist in your office's response to this request.
Yours,
Danielle Ivory
Danielle Ivory
The New York Times
Office:
Cell:
Fax:
Signal encrypted chat:
EFTA00023430


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: financial documents (Epstein)
Date: Tue, 23 Jul 2019 17:34:55 +0000
Yup
From:
Sent: Tuesday, July 23, 2019 13:34
To:
is
Subject: RE: financial documents (Epstein)
You guys want to come here? This should be quick.
From:
(NY) (FBI)
Sent: Tuesday, July 23, 2019 1:32 PM
To:
>;
Cc:
(NY) (FBI)
is
Subject: RE: financial documents (Epstein)
We can call your desk line. Give us about 5-10min.
On Jul 23, 2019 1:30 PM,
"
)"
wrote:
Hi all-
Let us know what works best from you on the FBI side. Do you want to call my desk when you're together? On our end,
we have another call at 2, but I don't expect this will take too long.
Thanks,
From:
Sent: Tuesday, July 23, 2019 12:38 PM
To:
Cc:
(NY) (FBI)
is
is
(NY) (FBI)
is
Subject: Re: financial documents (Epstein)
I should be getting in the office around 130-145 today, I'd like to join.
On Jul 23, 2019, at 12:37,
wrote:
Of course - whoever wants to be on should join, the more the merrier
EFTA00021644

=== Page 2 ===
From:
(NY) (FBI)
Sent: Tuesday, July 23, 2019 11:07
To:
is
is
is
(NY) (FBI)
Cc:
Subject: RE: financial documents (Epstein)
1:30 works for me. If possible, I would like
to be on the call.
Best
From:
) [mailto:
Sent: Tuesday, July 23, 2019 10:54 AM
To:
(NY) (FBI)
y
is
>;
(NY) (FBI)
Cc:
Subject: RE: financial documents (Epstein)
Hi
With apologies for the delay in scheduling this, would a call at 1:30 today work? Thanks.
From:
(NY) (FBI)
Sent: Thursday, July 18, 2019 7:33 PM
To:
is
)
>;
is
(NY) (FBI)
Cc:
Subject: RE: financial documents (Epstein)
Looking forward to working with you as well. My Tuesday is open. Set a time that works for you.
Best
From:
) [mailto:
Sent: Thursday, July 18, 2019 6:58 PM
To:
)
is
is
(NY) (FBI)
is
(NY) (FBI)
Cc:
Subject: RE: financial documents (Epstein)
Hi
looking forward to working with you again! Aside from a court conference at 11 on Tuesday, I can make any
time work. Thanks.
EFTA00021645

=== Page 3 ===
From:
Sent: Thursday, July 18, 2019 6:56 PM
To:
is
(NY) (FBI)
is
(NY)
(FBI)
Cc:
is
Subject: RE: financial documents (Epstein)
great to have you onboard, welcome - and as of now I don't have anything scheduled for Tuesday.
From:
Sent: Thursday, July 18, 2019 16:49
To:
)
[Contractor]
Cc:
)
>;
(NY) (FBI)
i
is
-
is
(NY) (FBI)
Subject: Re: financial documents (Epstein)
I've CC'd the forensic accountant
in our squad who will be assisting in this investigation. Let's try and plan
a day next week to meet briefly and discuss a game plan. Are you guys around Tuesday to chat?
On Jul 18, 2019, at 11:17,
) [Contractor]
wrote:
I have the discs, where should I bring them?
From:
)
Sent: Wednesday, July 17, 2019 8:47 PM
To:
)
[Contractor]
Cc:
(NY) (FBI)
is
is
is
)
Subject: RE: financial documents (Epstein)
Tomorrow morning could you please burn the following folders to
disc:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018801618\Investigation\# 2018 SDNY
investigation\Subpoena Returns\ American Express
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY
investigation\Subpoena Returns\Deutsche Bank
and put the disc in an envelope addressed to:
Special Agent
Detective
If it's possible to get the disc by 11:30, we'll give the disc to
at the conference, or if not, if you could
put the envelope with security and reply all that it's ready, they can pick up when convenient.
thanks,
EFTA00021646

=== Page 4 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00021647


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=== Page 1 ===
From:
To:
Subject: RE: Spreadsheets from Denver exports without thumbnails
Date: Thu, 14 Oct 2021 15:27:19 +0000
Attachments: 2021.10.14 MDC - Maxwell_PASSWORD.docx; 2021.10.14_MDC_-
Maxwell_MAIN.docx
Hey
- I'm prepping a disc to go out to MDC today with the materials stamped last night. I've attached the two cover
letters for MDC - if you don't have any edits, I'll convert to PDF and send the disc to MDC today. Thanks!
From:
(USANYS)
Sent: Wednesday, October 13, 2021 11:32 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
- sorry one small thing, can you just list the documents in the index in the letter as "Spreadsheets" not FBI
Spreadsheets? Thanks!
From:
Sent: Wednesday, October 13, 2021 11:31 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
Thanks!
From:
(USANYS)
Sent: Wednesday, October 13, 2021 11:30 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
Great, thanks! I will copy you on the email to defense counsel.
From:
Sent: Wednesday, October 13, 2021 11:22 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
Updated PDF attached, thanks! I can upload to USAfx after you share the correspondence with them. If you have no
objections, I'll share the production with the same people we did last time
Should take only a few minutes to upload. Thanks!
From:
(USANYS)
Sent: Wednesday, October 13, 2021 11:15 PM
EFTA00020817

=== Page 2 ===
Subject: RE: Spreadsheets from Denver exports without thumbhalls
Thanks so much,
Can you please update the bates range in the first paragraph and then send me a PDF of the
letter? Can you please remove the word "discovery" from the title of the PDF? Are you able to share with the defense via
USAfx?
From:
Sent: Wednesday, October 13, 2021 10:55 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
The production is stamped and saved here for your review: \\usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-
2018R01618\Discovery\GM\33 Twenty-Fourth Production (2021-10-13)
I updated the cover letter (attached and saved here) to reflect the updated Bates range of SDNY_GM_02765031-2765061.
Any edits, please let me know. Thanks!
From:
(USANYS)
Sent: Wednesday, October 13, 2021 9:37 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
Here is a cover letter for the production. Just the bates numbers need to be added in. thanks!
From:
)
Sent: Wednesday, October 13, 2021 9:25 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
Hi
Are you able to send this out first thing tomorrow morning, if you're not able to send tonight (and no worries if you can't)
Thanks!
From:
(USANYS)
Sent: Wednesday, October 13, 2021 7:41 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
Sorry for the night email, but we need to send out the spreadsheets
sent us to the defense tonight. Are you able to
get them in a production and stamp them? I'll circulate a discovery letter.
Thanks!
EFTA00020818

=== Page 3 ===
From:
Sent: Wednesday, October 13, 2021 7:10 PM
Subject: [EXTERNAL] Spreadsheets from Denver exports without thumbnails
See attached.
Detective
NYPD/FBI
Child Exploitation Human Trafficking Task Force
Office:
EFTA00020819


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=== Page 1 ===
EXHIBIT D
EFTA00021553

=== Page 2 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 1 of 14
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-Marra/Johnson
JANE DOE #1 and JANE DOE #2
v.
UNITED STATES
/
JANE DOE #3 AND JANE DOE #4's CORRECTED MOTION PURSUANT TO RULE 21
FOR JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as "the new victims"), by and
through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21
to join this action, on the condition that they not re-litigate any issues already litigated by Jane
Doe #1 and Jane Doe #2 (also referred to as "the current victims"). The new victims have
suffered the same violations of their rights under the Crime Victims' Rights Act (CVRA) as the
current victims. Accordingly, they desire to join in this action to vindicate their rights as well.
Because the new victims will not re-litigate any issues previously litigated by the current victims
(and because they are represented by the same legal counsel as the current victims), the
Government will not be prejudiced if the Court grants the motion. The Court may "at any time"
add new parties to the action, Fed. R. Civ. P. 21. Accordingly, the Court should grant the
motion.
1
FACTUAL BACKGROUND
I
As minor victims of sexual offenses, Jane Doe #3 and Jane Doe #4 desire to proceed by
way of pseudonym for the same reasons that Jane Doe #1 and Jane Doe #2 proceeded in this
fashion. Counsel for the new victims have made their true identities known to the Government.
1
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CONFIDENTIAL
EFTA00021554

=== Page 3 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 2 of 14
As the Court is aware, more than six years ago, Jane Doe #1 filed the present action
against the Government, alleging a violation of her rights under the CVRA, 18 U.S.C. § 3771.
DEI. She alleged that Jeffrey Epstein had sexually abused her and that the United States had
entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her
rights. At the first court hearing on the case, the Court allowed Jane Doe #2 to also join the
action. Both Jane Doe #1 and Jane Doe #2 specifically argued that the government had failed to
protect their CVRA rights (inter alia) to confer, to reasonable notice, and to be treated with
fairness. In response, the Government argued that the CVRA rights did not apply to Jane Doe #1
and Jane Doe #2 because no federal charges had ever been filed against Jeffrey Epstein.
The Court has firmly rejected the United States' position. In a detailed ruling, the Court
concluded that the CVRA extended rights to Jane Doe #1 and Jane Doe #2 even though federal
charges were never filed. DE 189. The Court explained that because the NPA barred
prosecution of crimes committed against them by Epstein, they had "standing" to assert
violations of the CVRA rights. Id. The Court deferred ruling on whether the two victims would
be entitled to relief, pending development of a fuller evidentiary record. Id.
Two other victims, who are in many respects similarly situated to the current victims,
now wish to join this action. The new victims joining at this stage will not cause any delay and
their joinder in this case is the most expeditious manner in which to pursue their rights. Because
the background regarding their abuse is relevant to the Court's assessment of whether to allow
them to join, their circumstances are recounted here briefly.
Jane Doe #3's Circumstances
2
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CONFIDENTIAL
EFTA00021555

=== Page 4 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 3 of 14
As with Jane Doe #1 and Jane Doe #2, Jane Doe #3 was repeatedly sexually abused by
Epstein. The Government then concealed from Jane Doe #3 the existence of its NPA from Jane
Doe #3, in violation of her rights under the CVRA. If allowed to join this action, Jane Doe #3
would prove the following:
In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his sexual abuse and sex trafficking scheme. In fact, it became known to the government that
Maxwell herself regularly participated in Epstein's sexual exploitation of minors, including Jane
Doe #3. Maxwell persuaded Jane Doe #3 (who was then fifteen years old) to come to Epstein's
mansion in a fashion very similar to the manner in which Epstein and his other co-conspirators
coerced dozens of other children (including Jane Doe #1 and Jane Doe #2). When Jane Doe #3
began giving Epstein a "massage," Epstein and Maxwell turned it into a sexual encounter, as
they had done with many other victims. Epstein then became enamored with Jane Doe #3, and
with the assistance of Maxwell converted her into what is commonly referred to as a "sex slave."
Epstein kept Jane Doe #3 as his sex slave from about 1999 through 2002, when she managed to
escape to a foreign country and hide out from Epstein and his co-conspirators for years. From
1999 through 2002, Epstein frequently sexually abused Jane Doe #3, not only in West Palm
Beach, but also in New York, New Mexico, the U.S. Virgin Islands, in international airspace on
his Epstein's private planes, and elsewhere.
Epstein also sexually trafficked the then-minor Jane Doe, making her available for sex to
politically-connected and financially-powerful people. Epstein's purposes in "lending" Jane Doe
(along with other young girls) to such powerful people were to ingratiate himself with them for
3
004290
CONFIDENTIAL
EFTA00021556

=== Page 5 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 4 of 14
business, personal, political, and financial gain, as well as to obtain potential blackmail
information.
One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual
relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein's
and well-known criminal defense attorney. Epstein required Jane Doe #3 to have sexual
relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but
also on private planes, in New York, New Mexico, and the U.S. Virgin Islands. In addition to
being a participant in the abuse of Jane Doe #3 and other minors, Deshowitz was an eye-witness
to the sexual abuse of many other minors by Epstein and several of Epstein's co-conspirators.
Dershowitz would later play a significant role in negotiating the NPA on Epstein's behalf.
Indeed, Dershowitz helped negotiate an agreement that provided immunity from federal
prosecution in the Southern District of Florida not only to Epstein, but also to "any potential co-
conspirators of Epstein." NPA at 5. Thus, Dershowitz helped negotiate an agreement with a
provision that provided protection for himself against criminal prosecution in Florida for
sexually abusing Jane Doe #3. Because this broad immunity would have been controversial if
disclosed, Dershowitz (along with other members of Epstein's defense team) and the
Government tried to keep the immunity provision secret from all of Epstein's victims and the
general public, even though such secrecy violated the Crime Victims' Rights Act.
Ghislaine Maxwell was another person in Epstein's inner circle and a co-conspirator in
Epstein's sexual abuse. She was someone who consequently also appreciated the immunity
granted by the NPA for the crimes she committed in Florida. In addition to participating in the
sexual abuse of Jane Doe #3 and others, Maxwell also took numerous sexually explicit pictures
4
004291
CONFIDENTIAL
EFTA00021557

=== Page 6 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 5 of 14
of underage girls involved in sexual activities, including Jane Doe #3. She shared these
photographs (which constituted child pornography under applicable federal laws) with Epstein.
The Government is apparently aware of, and in certain instances possesses some of these
photographs.
Perhaps even more important to her role in Epstein's sexual abuse ring, Maxwell had
direct connections to other powerful individuals with whom she could connect Epstein. For
instance, one such powerful individual Epstein forced Jane Doe #3 to have sexual relations with
was a member of the British Royal Family, Prince Andrew (a/k/a Duke of York). Jane Doe #3
was forced to have sexual relations with this Prince when she was a minor in three separate
geographical locations: in London (at Ghislaine Maxwell's apartment), in New York, and on
Epstein's private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged
girls). Epstein instructed Jane Doe #3 that she was to give the Prince whatever he demanded and
required Jane Doe #3 to report back to him on the details of the sexual abuse. Maxwell
facilitated Prince Andrew's acts of sexual abuse by acting as a "madame" for Epstein, thereby
assisting in internationally trafficking Jane Doe #3 (and numerous other young girls) for sexual
purposes.
Another person in Epstein's inner circle of friends (who becomes apparent with almost
no investigative effort) is Jean Luc Brunel. Epstein sexually trafficked Jane Doe #3 to Jean Luc
Brunel many times. Brunel was another of Epstein's closest friends and a regular traveling
companion, who had many contacts with young girls throughout the world. Brunel has been a
model scout for various modeling agencies for many years and apparently was able to get U.S.
passports for young girls to "work" as models. He would bring young girls (ranging to ages as
5
004292
CONFIDENTIAL
EFTA00021558

=== Page 7 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 6 of 14
young as twelve) to the United States for sexual purposes and farm them out to his friends,
especially Epstein. Brunel would offer the girls "modeling" jobs. Many of the girls came from
poor countries or impoverished backgrounds, and he lured them in with a promise of making
good money. Epstein forced Jane Doe #3 to observe him, Brunel and Maxwell engage in illegal
sexual acts with dozens of underage girls. Epstein also forced Jane Doe #3 to have sex with
Brunel on numerous occasions, at places including Epstein's mansion in West Palm Beach, Little
St. James Island in the U.S. Virgin Islands (many including orgies that were comprised of other
underage girls), New York City, New Mexico, Paris, the south of France, and California.
Epstein also trafficked Jane Doe #3 for sexual purposes to many other powerful men,
including numerous prominent American politicians, powerful business executives, foreign
presidents, a well-known Prime Minister, and other world leaders. Epstein required Jane Doe #3
to describe the events that she had with these men so that he could potentially blackmail them.
The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it
listed her as a victim in the attachment to the NPA. Moreover, even a rudimentary investigation
of Jane Doe #3's relationship to Epstein would have revealed the fact that she had been
trafficked throughout the United States and internationally for sexual purposes. Nonetheless, the
Government secretly negotiated a non-prosecution agreement with Epstein precluding any
Federal prosecution in the Southern District of Florida of Epstein and his co-conspirators. As
with Jane Doe #1, and Jane Doe #2, the Government concealed the non-prosecution agreement
from Jane Doe #3 - all in violation of her rights under the CVRA - to avoid Jane Doe #3 from
raising powerful objections to the NPA that would have shed tremendous public light on Epstein
6
004293
CONFIDENTIAL
EFTA00021559

=== Page 8 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 7 of 14
and other powerful individuals and that would likely have been prevented it from being
concluded in the secretive manner in which it was.
Jane Doe #4's Circumstances
If permitted to join this action, Jane Doe #4 would allege, and could prove at trial, that
she has CVRA claims similar to those advanced by Jane Doe #1 and Jane Doe #2, based on the
following:
As with the other Jane Does, Jane Doe #4 was repeatedly sexually abused by Epstein. In
or around the summer of 2002, Jane Doe #4, an economically poor and vulnerable sixteen-year-
old child, was told by another one of Epstein's underage minor sex abuse victims, that she could
make $300 cash by giving an old man a massage on Palm Beach. An acquaintance of Jane Doe
#4 (also a minor sexual abuse victim of Epstein) telephoned Epstein and scheduled Jane Doe #4
to go to Epstein's house to give him a massage. During that call, Epstein himself got on the
phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to
his mansion in Palm Beach.
Jane Doe #4 then went to Epstein's mansion and was escorted upstairs to Epstein's large
bathroom by one of Epstein's assistants. Shortly thereafter Jeffrey Epstein emerged and lay face
down on the table and told Jane Doe #4 to start massaging him. Epstein asked Jane Doe #3 her
age and she told him she had recently turned sixteen. Epstein subsequently committed illegal
sexual acts against Jane Doe #4 on many occasions.
Epstein used a means of interstate communication (i.e., a cell phone) to arrange for these
sexual encounters. Epstein also frequently travelled in interstate commerce (i.e., on his personal
jet) for purposes of illegally sexually abusing Jane Doe #4.
7
004294
CONFIDENTIAL
EFTA00021560

=== Page 9 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 8 of 14
The acts Epstein committed against Jane Doe #4, constituted numerous federal sex
offenses, some of which do not carry a statute of limitations and thus are not time-barred. See 18
U.S.C. § 3283. And these offenses were the kinds of offenses that the Federal Bureau of
Investigation (FBI) and U.S. Attorney's Office for the Southern District of Florida were pursuing
in 2007. So far as Jane Doe #4 is aware, the U.S. Attorney's Office made no serious effort to
locate her. Instead, after identifying approximately forty separate underage sexually abused
victims, and apparently preparing a 53-page federal indictment and with full awareness of the
existence of many victims like Jane Doe #4 - unidentified and not interviewed - it entered into a
non-prosecution agreement barring prosecution of Epstein's federal crimes against these victims.
This is contrary to the Government's normal approach in prosecuting federal sex offenses. It
also violated Jane Doe #4's rights under the CVRA, including the fact that she had a
"reasonable" right to confer with the U.S. Attorney's Office before they entered into an
agreement with a sex offender barring prosecution of him for the crimes he committed against
her. 18 U.S.C. § 3771(a)(5).
MOTION FOR JOINDER
Jane Doe #3 and Jane Doe #4 now both move to join this action filed by Jane Doe #1 and
Jane Doe #2, pursuant to Rule 21 of the Federal Rules of Civil Procedure. Rule 21 provides that
"[o]n motion or on its own, the court may at any time, on just terms, add a
party."
Rule
21
"grants the court broad discretion to permit a change in the parties at any stage of a litigation."
Ford V. Air Line Pilots Ass'n Int'l, 268 F. Supp. 2d 271, 295 (E.D.N.Y. 2003) (internal quotation
omitted). The new victims should be allowed to join the current victims in this action under Rule
21.
8
CONFIDENTIAL
EFTA00021561

=== Page 10 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 9 of 14
The new victims will establish at trial that the Government violated their CVRA rights in
the same way as it violated the rights of the other victims. The new victims' participation in this
case is important because it appears that the Government intends to raise a factual defense that
somehow it did keep Jane Doe #1 and Jane Doe #2 properly informed of what was happening in
the criminal prosecution. Of course, if four victims all testify consistently that they were not
properly informed by the Government (as we believe they will), that provides a stronger case for
a CVRA violation.
In addition, Jane Doe #3 and Jane Doe #4's participation is relevant to a defense the
Court has allowed the Government to raise. The Court has previously ruled that the victims'
request for rescission of the NPA "implicates a fact-sensitive equitable defense which must be
considered in the historical factual context of the entire interface between Epstein, the relevant
prosecutorial authorities and the federal offense victims - including an assessment of the
allegation of a deliberate conspiracy between Epstein and federal prosecutors to keep the victims
in the dark on the pendency of negotiations between Epstein and federal authorities until well
after the fact and presentation of the non-prosecution agreement to them as a fait accompli." DE
189 at 12 n.6 (emphasis added). Jane Doe #3's and Jane Doe #4's participation in this case will
help to show what the "entire interface" was between the Government and the victims and thus
to respond to the Government's estoppel arguments as well as other defenses that it appears to be
preparing to raise. See, e.g., DE 62 (52-page response from the Government to the victim's
summary judgment motion, raising numerous factually-based and other arguments against the
victim's position).
9
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CONFIDENTIAL
EFTA00021562

=== Page 11 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 10 of 14
Jane Doe #3's and Jane Doe #4's participation is also directly relevant to the discovery
disputes currently pending in this case. The Government has raised various relevancy objections
to the documents that Jane Doe #1 and Jane Doe #2 are attempting to obtain. The current
victims have responded by explaining how these documents are relevant, including explaining
how these documents might bear on the way in which Epstein used his powerful political and
social connections to secure a favorable plea deal, as well as provide proof of the Government's
motive to deliberately fail to investigate certain aspects of the victims' claims in an effort to
maintain the secrecy of the facts and resolve the case without the victims' knowledge. See, e.g.,
DE 266 at 6-10. Jane Doe #3 and Jane Doe #4's participation will help prove the relevancy of
these requests, as well as the need for those requests.
One clear example is Request for Production No. 8, which seeks documents regarding
Epstein's lobbying efforts to persuade the Government to give him a more favorable plea
arrangement and/or non-prosecution agreement, including efforts on his behalf by Prince
Andrew and former Harvard Law Professor Alan Dershowitz. Jane Doe #1 and Jane Doe #2
have alleged these materials are needed to prove their allegations that, after Epstein signed the
non-prosecution agreement, his performance was delayed while he used his significant social and
political connections to lobby the Justice Department to obtain a more favorable plea deal. See,
e.g., DE 225 at 7-8 (discussing DE 48 at 16-18). Jane Doe #3 has directly person knowledge of
Epstein's connection with some of these powerful people and thus how Epstein might have used
them to secure favorable treatment.
Adding two new victims to this case will not delay any of the proceedings. They will
simply join in motions that the current victims were going to file in any event. For example, the
10
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CONFIDENTIAL
EFTA00021563

=== Page 12 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 11 of 14
new victims will simply join in a single summary judgment motion that the current victims
anticipate filing after discovery has been completed.
Nor will adding the new victims prejudice the United States. As the court is aware, this
Court is still in its initial discovery stage. The Court is currently considering whether to reject
the Government's assertion of privilege over documents regarding the case. See DE 265
(victims' reassertion of objections to the Government privilege claims). The new victims do not
seek any additional discovery beyond that previously sought by the current victims.²
Accordingly, the United States will not be prejudiced or burdened by adding them to this case.
The CVRA does not contain any statute of limitations for filing an action to enforce
rights under the statute. Accordingly, were the Court to deny this motion, the result might be
that the new victims would then be forced to file a separate suit raising their claims, which would
then possibly proceed on a separate litigation track. Rather than require duplicative litigation,
the Court should simply grant their motion to join.
Jane Doe #1 and Jane Doe #2 support the joinder motion. Counsel for the victims have
discussed this motion with the Government at length in an effort to avoid any need to file a
substantive pleading on the issue. Counsel for the victims asked the Government during the
summer for its position on joinder. The Government, however, took the matter under
advisement for months. Ultimately, after several inquiries from victims counsel, the
Government indicated without explanation that it opposes this motion. Counsel for the victims
has requested a meeting with the Government on this issue, which will hopefully occur in
2 Jane Doe #3 and Jane Doe #4 have asked the Government to provide them with the
record of their statements that they provided to the FBI. These FBI 302's should be only a few
pages long.
11
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CONFIDENTIAL
EFTA00021564

=== Page 13 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 12 of 14
January. In the meantime, however, counsel for the victims believe that it is no longer
appropriate to delay filing this motion and accordingly file it at this time. Because the
Government is apparently opposing this motion, Jane Doe #3 and Jane Doe #4 have described
the circumstances surrounding their claims so that the Court has appropriate information to rule
on the motion.
12
004299
CONFIDENTIAL
EFTA00021565

=== Page 14 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 13 of 14
CONCLUSION
Jane Doe #3 and Jane Doe #4 should be allowed to join this action, pursuant to Rule 21
of the Federal Rules of Civil Procedure. Their joinder should be conditioned on the requirement
that they not re-litigate any issues previously litigated by Jane Doe #1 and Jane Doe #2. A
proposed order to that effect is attached to this pleading.
DATED: January 2, 2015
Respectfully Submitted,
/s/ Bradley J. Edwards
Bradley J. Edwards
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
And
Paul G. Cassell
Pro Hac Vice
S.J. Quinney College of Law at the
University of Utah
Attorneys for Jane Doe #1 and Jane Doe #2
*
This daytime business address is provided for identification and correspondence
purposes only and is not intended to imply institutional endorsement by the University of Utah
13
004300
CONFIDENTIAL
EFTA00021566

=== Page 15 ===
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 14 of 14
CERTIFICATE OF SERVICE
I certify that the foregoing document was served on January 2, 2015, on the following using
the Court's CM/ECF system:
Attorneys for the Government
/s/ Bradley J. Edwards
14
004301
CONFIDENTIAL
EFTA00021567


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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
April 5, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Judge
Southern District of New York
40 Foley Square
New York, New York 10007
Re:
United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in connection with the Court's Order of
March 24, 2021, regarding the defendant's application for an order authorizing a subpoena
pursuant to Rule 17(c) of the Federal Rules of Criminal Procedure for records from Boies Schiller
Flexner LLP ("BSF"). For the reasons set forth herein, the Government respectfully requests that
the Court (1) direct the defendant to provide the Government with a copy of the proposed subpoena
to BSF and notice of all existing and future applications for subpoenas under Rule 17(c) returnable
in advance of trial, and (2) direct that any productions made in response to Rule 17(c) subpoenas
be produced to the opposing party and marked confidential under the protective order.
I.
Background
As the Court is aware, the Government has produced to the defendant more than 2.7 million
pages of discovery pursuant to the Government's various discovery obligations, including Rule
16. The parties are also in discussions about the timing of further productions by the Government,
including material provided pursuant to 18 U.S.C. § 3500 and Giglio material.
EFTA00022027

=== Page 2 ===
Page 2
Those obligations, and not Rule 17 subpoenas, provide the avenue through which
defendants in criminal cases obtain discovery. As the Supreme Court has explained, "[i]t was not
intended by Rule 16 to give a limited right of discovery, and then by Rule 17 to give a right of
discovery in the broadest terms." Bowman Dairy Co. V. United States, 341 U.S. 214, 220 (1951);
see also United States V. Purin, 486 F.2d 1363, 1368 (2d Cir. 1973) ("A subpoena duces tecum in
a criminal case is not intended as a means of discovery."). Unlike the rules of civil procedure-
permitting the issuance of subpoenas to seek production of documents or materials which, although
themselves not admissible, may lead to admissible evidence-the criminal rules do not authorize
the issuance of such broad pretrial subpoenas under Rule 17. See United States V. Cherry, 876 F.
Supp. 547, 552 (S.D.N.Y. 1995); United States V. Gross, 24 F.R.D. 138, 141 (S.D.N.Y. 1959)
(Rule 17(c) cannot be used "to obtain leads as to the existence of additional documentary evidence
or to seek information relating to the defendant's case. This type of discovery, permissible under
the Federal Rules of Civil Procedure, has not been authorized for criminal trials.").
The purpose of Rule 17(c) is to "expedite the trial by providing a time and place before
trial for the inspection of" specific materials that the parties intend to offer into evidence. See
United States V. Tagliaferro, No. 19 Cr. 472 (PAC), 2021 WL 980004, at *2 (S.D.N.Y. Mar. 16,
2021) (citing Bowman Dairy Co., 341 U.S. at 220 (1951)); see also United States V. Ulbricht, 858
F.3d 71, 109 (2d Cir. 2017) (explaining that the rule "allows parties to subpoena documents and
objects to be introduced at criminal trials"), abrogated on other grounds as recognized by United
States V. Chambers, 751 F. App'x 44, 46 & n.1 (2d Cir. 2018) (summary order). Accordingly,
the Supreme Court has explained that, to require production of materials pursuant to Rule 17(c),
the party seeking production must show that:
(1) that the documents are evidentiary and relevant; (2) that they are
not otherwise procurable reasonably in advance of trial by exercise
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of due diligence; (3) that the party cannot properly prepare for trial
without such production and inspection in advance of trial and that
the failure to obtain such inspection may tend unreasonably to delay
the trial; and (4) that the application is made in good faith and is not
intended as a general "fishing expedition."
United States V. Nixon, 418 U.S. 683, 699-700 (1974) (footnote omitted); see United States V.
Skelos, 988 F.3d 645, 661 (2d Cir. 2021) (affirming a decision to quash subpoenas through
application of Nixon); United States V. Pena, No. 15 Cr. 551 (AJN), 2016 WL 8735699, at *1-*2
(S.D.N.Y. Feb. 12, 2016) (applying Nixon, rather than the "more liberal standard" of United States
V. Tucker, 249 F.R.D. 58 (S.D.N.Y. 2008), to the propriety of a Rule 17(c) subpoena).
The Nixon test is demanding. The defendant must establish that the defense's "application
is made in good faith and is not intended as a general "fishing expedition." Nixon, 418 U.S. at
700; United States V. Yian, No. 94 Cr. 719 (DLC), 1995 WL 614563, at *2 (S.D.N.Y. Oct. 19,
1995) (quashing subpoena that "call[s] for the production of the entire investigative file and is
accurately described as a fishing expedition"); United States V. Cuthbertson, 630 F.2d 139, 144
(3d Cir. 1980) ("[T]est for enforcement is whether the subpoena constitutes a good faith effort to
obtain identified evidence rather than a general "fishing expedition' that attempts to use the rule as
a discovery device." (emphasis added)). Indeed, because the Rule poses such a risk of abuse and
misuse, courts are stringent in holding those seeking to obtain documents to Rule 17(c) to their
burden of demonstrating that the documents sought are (1) relevant, (2) admissible, (3) specifically
identified, and (4) not otherwise procurable, and it is "insufficient" for a party to show only that
the subpoenaed documents "are potentially relevant or may be admissible," United States V. RW
Prof'l Leasing Servs. Corp., 228 F.R.D. 158, 162 (E.D.N.Y 2005) (emphasis added). "[A] mere
hope that the documents, if produced, may contain evidence favorable to the defendant's case will
not suffice. Rule 17(c) requires a showing that the materials sought are currently admissible in
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evidence; it cannot be used as a device to gain understanding or explanation." United States V.
Rich, No. 83 Cr. 579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984) (internal quotation
marks omitted) (emphasis added). Accordingly, subpoenas that call for "any" and "all" records
"do not evince specificity" and "read[] like a discovery request, which is not permitted under Rule
17(c)." Tagliaferro, 2021 WL 980004 at *3; see Pena, 2016 WL 8735699, at *3. And "[g]enerally
the need for evidence to impeach witnesses is insufficient to require its production in advance of
trial." Nixon, 418 U.S. at 701 (citations omitted); see Fed. R. Crim. P. 17(h) ("No party may
subpoena a statement of a witness or of a prospective witness under this rule.").
If a subpoena calls for "personal or confidential information about a victim," the subpoena
may be served "only by court order" following "notice to the victim so that the victim can move
to quash or modify the subpoena or otherwise object." Fed. R. Crim. P. 17(c)(3). After a subpoena
issues, "[t]he court may direct the witness to produce the designated items in court before trial or
before they are to be offered in evidence." Fed. R. Crim. P. 17(c)(1). "When the items arrive, the
court may permit the parties and their attorneys to inspect all or part of them." Id.
II.
The Court Should Direct the Defendant to Provide Notice of Prior and Future
Applications Under Rule 17(c) to the Government
The Government has legitimate and cognizable interests in Rule 17(c) subpoenas issued by
the defense. In particular, courts have routinely found that the Government has standing to move
to quash Rule 17(c) subpoenas that target information about anticipated Government witnesses
"based on the Government's 'interest in preventing any undue lengthening of the trial, any undue
harassment of the witness and his family, and any prejudicial over-emphasis on the witness's
credibility." United States V. Ray, -- F.R.D. --, No. 20 Cr. 110 (LJL), 2020 WL 6939677, at *7
(S.D.N.Y. Nov. 25, 2020) (alterations omitted) (quoting United States V. Giampa, No. 92 Cr. 437
(PKL), 1992 WL 296440, at *1 (S.D.N.Y. Oct. 7, 1992)); see United States V. Bergstein, No. 16
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Cr. 746 (PKC), 2017 WL 6887596, at *2-*3 (S.D.N.Y. Dec. 28, 2017) ("Preventing the undue
harassment of a cooperating witness is a legitimate governmental interest giving rise to standing
in this context."); cf. United States V. Nachamie, 91 F. Supp. 2d 552, 558-60 (S.D.N.Y. 2000)
(concluding that the Government failed to establish a legitimate interest where, among other
things, none of the subpoenaed entities had been "publicly identified by the Government as trial
witnesses, or as particularly vulnerable witnesses"). That is particularly true where the subpoena
at issue seeks material that the defendants would be entitled to, if at all, as Giglio or 3500 material
given that the Government has a cognizable interest in "controlling the timing of disclosures as
to" witnesses who are expected to testify at trial, and for whom the Government has various
disclosure obligations. United States V. Cole, No. 19 Cr. 869 (ER), 2021 WL 912425, at *2
(S.D.N.Y. Mar. 10, 2021); see Bergstein, 2017 WL 6887596, at *3. Finally, the Government has
standing to challenge subpoenas that call for its own communications. See United States V. Carton,
17 Cr. 680 (CM), 2018 WL 5818107, at *3 (S.D.N.Y. Oct. 19, 2018) (quashing a subpoena for
communications with the Government).¹
The only way for the Government to vindicate those interests is with notice so that the
Government may, as appropriate, have an opportunity to quash the subpoenas. There is no avenue,
after a subpoena is issued and fulfilled, for the Government to protect its interests in the timing of
disclosures about victims or the disclosure of the Government's own communications. That is
particularly important given that a subpoena recipient may lack sufficient knowledge about the
1 The Government also has standing to challenge a Rule 17(c) subpoena at the request of a victim,
witness or third-party impacted by the subpoena. See Ray, 2020 WL 6939677, at *7 ("Courts have
acknowledged that the Government has standing to challenge Rule 17(c) subpoenas directed to a
non-party when the non-party authorizes the Government to assert his or her right by request or by
indicating its joinder in a motion to quash." (internal quotation marks and alteration omitted)).
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case or motivation to move to quash an otherwise improper subpoena. 2 Accordingly, the
Government respectfully requests notice of all subpoenas with pretrial return dates issued or sought
to be issued under Rule 17(c). 3
While, as the Court noted in its Order, Rule 17(c) subpoenas are frequently issued ex parte
in this district, the issue is rarely litigated. See, e.g., United States V. States V. Wey, 252 F. Supp. 3d
237, 243 (S.D.N.Y. 2017) (noting, without extended discussion, that subpoena had issued upon ex
parte application); United States V. Earls, No. 03 Cr.0364 (NRB), 2004 WL 350725, at *6 (S.D.N.Y.
Feb. 25, 2004) (noting that the defendant may seek subpoenas ex parte). When courts have considered
the issue, however, many have directed that the parties should give each other notice of Rule 17(c)
subpoenas unless a party can justify proceeding ex parte. See United States V. Skelos, No. 15 Cr.
317 (KMW), 2018 WL 2254538, at *8 (S.D.N.Y. May 17, 2018) (explaining that courts have
permitted ex parte requests "where a reason existed for doing so," and requiring notice "[t]o further
reduce the risk that trial will be delayed, unless a party has a compelling reason for proceeding ex
parte with a subpoena request"), aff' 988 F.3d 645 (2d Cir. 2021); United States V. St. Lawrence,
16 Cr. 259 (CS), Dkt. No. 66 at 6 (S.D.N.Y. Dec. 22, 2016) (requiring motions for Rule 17(c)
subpoenas and permitting ex parte applications "if the movant can articulate a reason why it should
be"); United States V. Boyle, No. 08 Cr. 523 (CM), 2009 WL 484436, at *3 (S.D.N.Y. Feb. 24,
2009) (requiring noticed motions for Rule 17(c) subpoenas to "assur[e] that such subpoenas are
not abused or used for impermissible discovery," and permitting ex parte applications "where a
2 For example, a financial institution may lack sufficient knowledge about the case or motivation
to expend the resources to move to quash what appears to be a routine subpoena that broadly seeks
financial records for a Government cooperator or lay witness to be used for impeachment purposes,
notwithstanding the fact that such a subpoena may run afoul of the Nixon standard.
3 The Government is not seeking notice of subpoenas returnable at trial.
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party can demonstrate" a basis (emphasis omitted)); United States V. Weisman, 01 Cr. 529 (BSJ),
2002 WL 1467845, at *1 (S.D.N.Y. July 8, 2002) (similar); see also United States V. Fox, 275 F.
Supp. 2d 1006, 1012 & n.7 (D. Neb. 2003) (surveying the caselaw and adopting the "majority
view" that Rule 17(c) "does not ordinarily permit the use of ex parte applications by the
government or the defense for subpoenas seeking pretrial production of documents unless the sole
purpose of seeking the documents is for use at trial," and even then, only if "there is a good trial-
related reason" and generally requiring production in the presence of the opposing party); 2 Wright
& Miller, Fed. Prac. & Procedure $ 275 (4th ed.) ("It has been held, however, that in limited
circumstances, both the government and a defendant may make an ex parte application for a pre-
trial subpoena duces tecum" (emphasis added)). But see Ray, 2020 WL 6939677 at *8 ("Courts
in this District have long followed the practice of permitting both the defense and the Government
to submit ex parte applications for Rule 17(c) subpoenas."); United States V. Reyes, 162 F.R.D.
468, 470 (S.D.N.Y. 1995) (permitting ex parte applications because a party must "detail its trial
strategy or witness list in order to convince a court that the subpoena satisfies the Nixon
standards"). Notice of Rule 17(c) subpoenas is similarly appropriate in this case to prevent abuse
and address objections expediently. And such a requirement is consistent with the plain language
of Rule 17: while Rule 17(b) expressly provides for an ex parte procedure for indigent defendants
seeking to subpoena a witness for trial, it makes no such provision for an application for the
production of documents and objects pursuant to Rule 17(c).⁴
4 In Ray, the Court concluded that Rule 17(c) is simply an extension of Rules 17(a) and (b)'s
provisions of subpoenas to witnesses, which may issue without notice. See 2020 WL 6939677, at
*8 (quoting United States V. Florack, 838 F. Supp. 77, 79 (W.D.N.Y. 1993)). However, Rule 17(c)
subpoenas for records are quite unlike subpoenas for trial testimony: they can be made returnable
before trial, and Rule 17(c)'s text provides that materials obtained pursuant to such a subpoena
may be returnable to the Court, which may in turn "permit the parties and their attorneys to inspect
all or part of them," and subjects the subpoenas to motions to quash. Fed. R. Crim. P. 17(c)(1)-(2)
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Moreover, as the information currently available to the Government about the BSF
subpoena makes plain, the Government's concerns are well founded. Indeed, the defendant has
already sought issuance of a subpoena that appears to directly implicate the Government's interests
by expressly and improperly seeking broad categories of victim information and communications
with the Government. While the Government has not seen the subpoena to BSF, it also appears
that the subpoena constitutes a fishing expedition for potential impeachment material, which
plainly runs afoul of the Nixon test. (Letter from BSF to the Court at 2, Dkt. No. 191). Insofar
as the defendant is attempting to engage in such an improper expedition in this case-or even if
the defendant is merely pushing the limits of a Rule 17 subpoena-the Government respectfully
submits that it should be afforded the opportunity to bring its concerns to the Court's attention.
The Government recognizes that some information, such as portions of a defendant's
explanation for why a particular request in a particular subpoena meets the Nixon standard, may
reveal critical defense strategy meriting ex parte consideration by the Court. But the Government
respectfully submits that interest can be served through specific defense requests tailored to the
particular redaction or application at issue, rather than a default whereby the defendant is permitted
to proceed entirely ex parte in seeking documents and materials pursuant to Rule 17(c).
(emphasis added); see United States V. Reyes, 162 F.R.D. 468, 470 (S.D.N.Y. 1995) ("Rules 17(a)
and 17(b), which govern the issuance of subpoenas returnable at trial, also do not provide guidance
as to the proper procedure for obtaining a pretrial subpoena duces tecum."). These procedures are,
at a bare minimum, in tension with proceeding ex parte or under the rules that govern subpoenas
for trial testimony.
5 The Government has also not seen any response filing by the defendant, which per the Court's
March 24, 2021 Order was to be filed on or before April 2, 2021. To the extent the defendant did
file such a response, it was neither docketed nor provided to the Government, and as such, the
Government is unable to address herein any arguments made by the defendant about the BSF
subpoena.
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III.
Any Records Obtained Pursuant to a Rule 17(c) Subpoena Should Be Marked
Confidential Under the Protective Order and Produced to the Opposing Party
Additionally, and to the extent the defendant has issued or will issue other subpoenas ex
parte pursuant to Rule 17(c), the responsive records should be produced to the Government and
marked confidential pursuant to the protective order. See Fed. R. Crim. P. 17(c)(1).
First, materials gathered pursuant to a Rule 17(c) subpoena by either party should be
promptly made available to their adversary. As noted above, the text of Rule 17(c) plainly provides
that materials obtained pursuant to a subpoena may be returned to the Court which "may permit
the parties and their attorneys to inspect all or part of them." Fed. R. Crim. P. 17(c)(1). Nowhere
does the Rule provide for one party's ability to use a subpoena to secretively gather material in
advance of trial, nor does it include a categorical exception due to concerns about defense or trial
strategy. Indeed, because the purpose of Rule 17 is to obtain evidence for use at trial, and not to
investigate for evidence or obtain impeachment material, disclosure of the fruits of a Rule 17(c)
subpoena fits neatly with Rule 16's reciprocal obligations for disclosure of evidence that the
defendant intends to introduce in her case-in-chief. See Fed. R. Crim. P. 16(b)(1)(A); United States
V. St. Lawrence, 16 Cr. 259 (CS), Dkt. No. 66 at 6 (S.D.N.Y. Dec. 22, 2016) ("It seems to the Court
that because Rule 17(c) subpoenas are intended to obtain specific materials that the party expects
to offer into evidence, Rule 16 would oblige the party to make the materials available to the other
side anyway.").6
By contrast, to the extent the defendant has improperly obtained information through a
Rule 17(c) subpoena, the Government should have the opportunity to move to preclude its use at
trial. In order to permit such a motion to be made in a timely manner-and so as to avoid the
6 To the extent the Government makes use of Rule 17(c) subpoenas, it similarly will promptly
produce all material received to the defendant.
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unnecessary delay and disruption that will occur if the Government only learns of the existence of
such material during trial-the Government seeks disclosure of any records obtained in response
to such a subpoena. At a minimum, the Court should order production of subpoena returns directly
to the Court, so it may screen out irrelevant or improper information and determine whether any
materials should be made available to the Government as well as the defendant.
Second, the Court should direct that any material obtained pursuant to a Rule 17 subpoena
be marked confidential and subject to the protective order. As noted above, the BSF subpoena
appears to call for a substantial amount of sensitive personal information about victims. For
instance, according to the letter from BSF, the subpoena to BSF requests the "original, complete
copy" of a victim's diary. (Letter from BSF to the Court at 5, Dkt. No. 191). To the extent the
defendant has obtained or will obtain sensitive information about victims or witnesses, it should
be treated as "confidential" under the protective order much like other such information in this
case.
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IV.
Conclusion
The Government respectfully requests that the Court order the defendant to provide notice
to the Government of pending and future applications for Rule 17(c) subpoenas returnable in
advance of trial, and for the Court to order that any records obtained in response to Rule 17(c)
subpoenas be treated as confidential under the protective order and disclosed to the Government.
Respectfully submitted,
AUDREY STRAUSS
United States Attorney
by:
/s/
Assistant United States Attorneys
cc:
Counsel of Record (by ECF)
EFTA00022037


