# docs_fts_content

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=== Page 1 ===
Event: Accepted:
Start Date: 2019-06-11 17:00:00 +0000
End Date: 2019-06-11 18:00:00 +0000
Organizer:
(
)
Location: Brass meet re Epstein
Class: X-PERSONAL
Comment:
Date Created: 2019-06-10 17:56:05 +0000
Date Modified: 2019-06-10 17:56:05 +0000
Priority: 5
DTSTAMP: 2019-06-10 17:43:13 +0000
EFTA00029506


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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
August 8, 2019
VIA EMAIL
Martin G. Weinberg, Esq.
Martin G. Weinberg, P.C.
Boston, MA 02116
Reid Weingarten, Esq.
Michael Miller, Esq.
Steptoe & Johnson LLP
New York, NY 10036
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Mr. Weinberg:
The Government writes in response to your letters dated July 26, 2019, requesting
preservation and production of seven general categories of documents (the "July Letter"), and
August 1, 2019, requesting preservation and production in connection with a particular individual
(the "August Letter") (collectively, the "Letters").
Without conceding any obligation to preserve any of the categories of documents identified
in the Letters (let alone any obligation to produce responsive documents to the extent any exist),
we will take reasonable steps to ensure the preservation of any documents we believe may be
responsive to the various categories identified in the Letters to the extent such documents are
already within the possession, custody, or control of the U.S. Attorney's Office for the Southern
District of New York (this "Office"). Other than documents within the possession, custody, or
control of this Office, we will not be requesting or directing that any other office or agency, local,
state, federal, or foreign, including any other office or component of the U.S. Department of
Justice, or any other nonparty to this case, including but not limited to victims or their counsel
(collectively, and without limitation, the "Non-Party Entities and Individuals"), to institute such
preservation. Such agencies, departments, entities, and individuals are not parties to this litigation,
are not a part of the prosecution team as that term has been defined under well-established Second
Circuit law, and are beyond the scope of this Office's disclosure obligations in this case. 1
1 We note, in this respect, that your Letters purport to require this Office to direct, without
limitation, preservation and/or production of documents by all 93 U.S. Attorney's Offices across
the nation; an individual prosecutor at another U.S. Attorney's Office; every component of "Main
Justice" as you use that term, including the Office of the Deputy Attorney General, the Criminal
Division, and the Department of Justice Child Exploitation and Obscenity Section; the Securities
EFTA00027234

=== Page 2 ===
We expect to take all necessary steps to comply with our obligations under Federal Rules
of Criminal Procedure 16 and 26.2, Brady V. Maryland and its progeny, and 18 U.S.C. $ 3500
(collectively, this Office's "Production Obligations"). If you have a specific request to make to
pursuant to Rules 16 or 26.2, Brady, or $ 3500, we will address it appropriately.
With respect to the specific requests in the Letters, we note at the outset that a number of
them call for material that falls well beyond the scope of Rule 16 or any recognized obligation
under Brady and its progeny. We further note that many of these requests-which purport to
extend, without temporal limitation, to wide categories of documents that do not involve this
Office and thus are unlikely to be within the possession, custody or control of this Office-appear
to constitute nothing more than general fishing expeditions, which are patently beyond the scope
of the Government's Production Obligations. We note that for purposes of discovery demands, "a
'defendant must make a prima facie showing of materiality, and must offer more than the
conclusory allegation that the requested evidence is material." United States V. Abdalla, 317
F.Supp.3d 786, 790 (S.D.N.Y. 2018) (quoting United States V. Urena, 989 F.Supp.2d 253, 261
(S.D.N.Y. 2013)). Notably, "if the purported defense for which a defendant seeks to compel the
production of certain documents is meritless as a matter of law, then the requested documents are
not 'material' for purposes of Rule 16." Id. at 791.
Regarding the specific requests the July Letter does contain, we respond as follows:
First Request:
Any investigatory files provided to the United States Attorney's Office for the
Southern District of New York (or FBI agents working therewith) by the United
States Attorney's Office for the Southern District of Florida, the Middle District
of Florida, and/or the Northern District of Georgia (or FBI agents working
therewith).
To the extent such materials are within the care, custody and control of the Office and fall
within the scope of our Production Obligations, we will produce such materials consistent with
any schedule agreed upon by the parties or set by the Court.
Second Request: Any investigatory files that were received or accessed by the United States
Attorney's Office for the Southern District of New York (or FBI agents working
therewith) that were sent or disclosed by or originated with the United States
Attorney's Offices of the Southern District of Florida, the Middle District of
Florida, and/or the Northern District of Georgia (or FBI agents working
therewith).
and Exchange Commission; the Department of Homeland Security; the New York [City] Police
Department; the Manhattan District Attorney's Office; the State Attorney's Office for the 15th
Judicial District in and for Palm Beach County; the Palm Beach County Sheriff's Office; the New
Mexico Attorney General's Office; and any other "local, state, or foreign law enforcement entities
involved in any way in regulating or investigating the activities alleged in the Indictment or related
transactions." July Letter at 2-3. Not only is such a request patently overbroad, but we also reject
your assertion, for which you cite no authority, that this Office has "the legal right or practical
ability obtain" material from these dozens of non-party entities and individuals.
EFTA00027235

=== Page 3 ===
To the extent such materials are within the care, custody and control of the Office and fall
within the scope of our Production Obligations, we will produce such materials consistent with
any schedule agreed upon by the parties or set by the Court. We note that certain materials
responsive to this request already have been produced as part of the Government's initial discovery
production to the defendant on July 31, 2019.
Third Request:
Communications regarding Mr. Epstein between and among "Main Justice"
(including the Child Exploitation and Obscenity Section) and the United States
Attorney's Offices for the Southern District of Florida, Middle District of
Florida, Northern District of Georgia, and the Southern District of New York.
To the extent such materials are within the care, custody and control of this Office and fall
within the scope of our Production Obligations, we will produce such materials consistent with
any schedule agreed upon by the parties or set by the Court. However, we note that this request,
on its face, calls for large volumes of documents that are not within the possession, custody or
control of this Office, nor relevant (let alone "material") to any potentially meritorious defense.
We further note that we are not aware of any authority for the proposition that internal
communications within the Department of Justice fall within the scope of Rule 16 or any other
recognized Production Obligation. See Fed. R. Crim. P. 16(a)(2) (noting that Rule 16 does not
authorize the discovery or inspection of internal government documents made by an attorney for
the government or other government agent in connection with investigating or prosecuting the
case); see also United States V. Armstrong, 517 U.S. at 463 (1996) ("[U]nder Rule 16(a)(2), [a
defendant] may not examine Government work product in connection with his case.").
Fourth Request: Any decision to initiate (or not initiate) criminal proceedings against Mr.
Epstein.
We are not aware of any authority for the proposition that internal communications within
the Department of Justice, including communications about the "decision to initiate (or not initiate)
criminal proceedings" fall within the scope of Rule 16 or any other recognized Production
Obligations. See Fed. R. Crim. P. 16(a)(2) (noting that Rule 16 does not authorize the discovery
or inspection of internal government documents made by an attorney for the government or other
government agent in connection with investigating or prosecuting the case); see also Armstrong,
517 U.S. at 463 ("[U]nder Rule 16(a)(2), [a defendant] may not examine Government work
product in connection with his case."). Accordingly, we will not produce any such
communications in the care, custody, or control of this Office that are not subject to our Production
Obligations.
Fifth Request:
The NPA, including but not limited to communications within the Department
of Justice, with counsel for Mr. Epstein, with representatives of the United
States Attorney's offices for the Southern and Middle District of Florida or the
Northern District of Georgia and/or counsel for the alleged victims.
To the extent such materials are within the care, custody and control of this Office and fall
within the scope of our Production Obligations, we will produce such materials consistent with
any schedule agreed upon by the parties or set by the Court. We note that we believe you to already
have access to the NPA itself as well as any "communications
with counsel for Mr. Epstein"
EFTA00027236

=== Page 4 ===
regarding the same, to the extent such materials are called for by this request. We further note that
we are not aware of any authority for the proposition that internal communications within the
Department of Justice fall within the scope of Rule 16 or any other recognized Production
Obligations. See Fed. R. Crim. P. 16(a)(2) (noting that Rule 16 does not authorize the discovery
or inspection of internal government documents made by an attorney for the government or other
government agent in connection with investigating or prosecuting the case); see also Armstrong,
517 U.S. at 463 ("[U]nder Rule 16(a)(2), [a defendant] may not examine Government work
product in connection with his case."). Accordingly, we will not produce any such
communications in the care, custody, or control of this Office that are not subject to our Production
Obligations. Similarly, to the extent communications with counsel for any victim/witness fall
within the Government's Production Obligations, those will be produced substantially closer to
trial and consistent with any schedule for the production of 3500 material agreed upon by the
parties or set by the Court.
Sixth Request:
Communications with alleged victims (or their counsel), including but not
limited to consultations conducted in relation to the government's response to
the court's summary judgment order and proposed remedies in Jane Doe V.
United States, No. 08-cv-80736 (S.D.FI.).
To the extent such materials are within the care, custody and control of this Office and fall
within the scope of our Production Obligations, we will produce such materials consistent with
any schedule agreed upon by the parties or set by the Court. In particular, as noted above, to the
extent this Office has had communications with any alleged victims or their counsel that constitute
3500 and/or Giglio material, such material will be produced substantially closer to trial and
consistent with any schedule agreed upon by the parties or set by the Court.
However, we note that on its face, this request purports to call for the production of material
that is not within the possession, custody or control of this Office which is not a party to the
litigation of Jane Doe V. United States, No. 08-cv-80736 (S.D. Fl.), nor relevant to the prosecution
of this matter.
Seventh Request: Information provided by alleged victims (or their counsel) related to Mr.
Epstein prior to the return of the above-captioned Indictment.
To the extent such materials are within the care, custody and control of this Office and fall
within the scope of our Production Obligations, we will produce such materials consistent with
any schedule agreed upon by the parties or set by the Court. We note, in this respect, that by letter
dated July 31, 2019, this Office has already made an initial production of certain information
responsive to this request. To the extent this request calls for materials covered by Section 3500
and/or Giglio, we will produce such material substantially closer to trial and pursuant to any
scheduled agreed upon by the parties or set by the Court.
.Finally, regarding the specific requests contained in the August Letter, all of which relate
to a particular employee of the U.S. Attorney's Office for the Southern District of Florida, to the
extent such materials are within the care, custody and control of this Office and fall within the
scope of our Production Obligations, we will produce such materials consistent with any schedule
agreed upon by the parties or set by the Court. However, we note that on their face, these
EFTA00027237

=== Page 5 ===
supplemental requests call for materials-including communications-to which this Office was
not a party and involving an individual who is not now and has never been a member of this Office
or the prosecution team in this matter. We further note that to the extent these requests call for
internal documents or communications involving one or more employees of the U.S. Attorney's
Office for the Southern District of Florida, we are not aware of any authority for the proposition
that internal communications within the Department of Justice fall within the scope of Rule 16 or
any other recognized Production Obligations. See Fed. R. Crim. P. 16(a)(2) (noting that Rule 16
does not authorize the discovery or inspection of internal government documents made by an
attorney for the government or other government agent in connection with investigating or
prosecuting the case); see also Armstrong, 517 U.S. at 463 ("[U]nder Rule 16(a)(2), [a defendant]
may not examine Government work product in connection with his case.").
Very truly yours,
GEOFFREY S. BERMAN
By
Assistant United States Attorneys
Southern District of New York
Tel:
EFTA00027238


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=== Page 1 ===
From:
To:
Cc:
Subject: RE:
Date: Tue, 24 Aug 2021 19:55:14 +0000
Attachments: 2021.08.24_Court_Subpoena_
Attached. Thanks.
From:
Sent: Tuesday, August 24, 2021 12:41 PM
To:
Cc:
Subject: Re:
Yes I think that's appropriate. Could you send that along and we were cut a lead.
On Aug 24, 2021, at 12:38,
wrote:
Thanks for the update. We would issue a trial subpoena- - let me know if you need one.
On Aug 23, 2021, at 4:02 PM,
wrote:
I just got in touch with him on his home phone
(
). He did not seem all that excited to speak
about the case and told me maybe he could speak next week. I am not confident that he will agree to a
conversation. Is this someone you would like to subpoena if he refuses?
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
From:
Sent: Friday, August 20, 2021 5:41 PM
To:
Cc:
Subject:
CAUTION! EXTERNAL SENDER
STOP WHEN UNSURE. Never click on links or open attachments if sender is unknown, and never provide
user ID or password. Suspicious? Please report to this email address: reportphishing@nypd.org
EFTA00029167

=== Page 2 ===
Hi
Sending this email as a reminder, as we discussed. Thanks for looking into this. Have a great weekend!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00029168


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=== Page 1 ===
From:
Subject: Accepted: Conference: Jeffrey Epstein
Date: Wed, 17 Jul 2019 19:23:42 +0000
Importance: Normal
Attachments: unnamed
EFTA00028080


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=== Page 1 ===
From:
To
Cc:
Subject: US V. Maxwell, 20 Cr. 330 (AJN)
Date: Wed, 10 Nov 2021 02:16:17 +0000
Attachments: 2021.11.09_Maxwell_Cover_Letter.pdf;
2021.11.09_U.S._v_Ghislaine_Maxwell_3500_Index_(Defense).pdf;_3502-037.pdf; 3502-
038.pdf; 3502-039.pdf; Final_Daubert_Hearing_Exhibits.zip
Counsel,
We have a supplemental production of testifying witness material, which I have attached to this email, along with an
accompanying cover letter and index. I'm also attaching exhibits for tomorrow's hearing.
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
EFTA00027655


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com"
Subject: Final Voucher 10810414(1) prepared by a travel arranger is pending your review
Date: Wed, 20 Nov 2019 15:05:35 +0000
Importance: Normal
Dea
Final voucher 10810414(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 10810414
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13179 - U.S. V. Epstein - Witness Interview
Destination: Santa Monica, CA, United States
Dates: 2019-11-13 - 2019-11-15
Current status: Pending Voucher Approval
Voucher total expenses: 1517.64
Estimated trip cost: 1583.95
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0012
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.
EFTA00028109


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=== Page 1 ===
Date: 7/13/06
PALM BEACH POLICE DEPARTMENT
Page:
. 45
Time: 9:27:55
Incident Report
Program: CMS301L
NARRATIVE # 14
NA
Reported By:
11/07/05
Entered By.:
11/07/05
On October 20, 2005, I assisted Defective
in the execution of
a search warrant at 358 El Brillo Way, Palm Beach, Florida, 33480.
Upon the announcement of the search warrant, immediate contact was
made with three white males who came out of the house or surrounding
structures. Those males were identified as
, and
.
As other members of the police department
cleared the home, I kept watch over these three males. Once the house
was cleared, those males were turned over to Detective
Detective
and I were assigned to assist in the search of the
main house, the cabana and the servant's quarters. We started in the
garage. All areas of the garage were searched to include four
vehicles. These vehicles were three black Mercedes Benz cars
registered to Jeffrey Epstein. The fourth vehicle was a Harley
Davidson motorcycle, green in color, registered to Jeffrey Epstein.
Nothing was recovered from the garage.
A towel closet and pantry located off the kitchen were searched and
yielded negative results.
The kitchen was searched and taken into evidence was a phone message
book that was located near a house phone.
North of the kitchen was an office room which contained a computer.
The room had a closet that contained a locked gun locker.
combination was entered by
in the presence of Sgt.
and
the safe was opened. Items were taken from the room. See the
completed property receipt for a detailed list.
A green bathroom located on the first floor was searched and nothing
was taken.
A closet located just west of the green bathroom was searched. Two
massage tables were located in the closet along with a photo of a nude
EFTA00028568

=== Page 2 ===
Date: 7/13/06
PALM BEACH POLICE DEPARTMENT
Page:
46
Time: 9:27:55
Incident Report
Program: CMS301L
Case No.
: 1-05-000368
(Continued)
female from the waist up. See the property receipt for details.
I searched two bedrooms and their adjoining bathrooms, which were
located on the second floor on the East side of the house. In the
Northeast bedroom closet I found adult sex toys called Twin Torpedoes.
Soap made in the shape of a penis and vagina were also found in these
upstair bedrooms. See the property receipt for details.
I searched the pool cabana located on the South side of the pool.
Photos were taken from the wall. See the property receipt for
details.
I assisted in the search of
living quarters. Numerous CD S
along with a message book was seized. See the property receipt for
details.
EFTA00028569


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=== Page 1 ===
Event: Declined: Mark Epstein Meeting
Start Date: 2019-11-07 15:00:00 +0000
End Date: 2019-11-07 16:00:00 +0000
Location: 863
Class: X-PERSONAL
Comment:
Date Created: 2019-10-30 12:57:55 +0000
Date Modified: 2019-10-30 12:57:55 +0000
Priority: 5
DTSTAMP: 2019-10-30 12:48:16 +0000
Attendee:
(USANYS)
EFTA00028784


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Epstein Travel.
Date: Sat, 24 Aug 2019 12:34:35 +0000
$10,000 for Australia flight. Is the team working on an interview schedule for all these people?
Associate U.S. Attorney, SDNY
Begin forwarded message:
From:
(USANYS)"
Date: August 23, 2019 at 9:46:53 PM EDT
To:
(USANYS)"
Subject: Fwd: In order for the Government to pay travel I would have to make the arrangements.
Sent from my iPhone
Begin forwarded message:
From:
(USANYS)"
Date: August 23, 2019 at 9:33:25 PM EDT
To:
(USANYS)"
Subject: Re: In order for the Government to pay travel I would have to make the arrangements.
Please include
in these emails.
Sent from my iPad
On Aug 23, 2019, at 6:20 PM,
(USANYS)
wrote:
Received from
Cost would be $10,673.40 one way.
From:
Sent: Friday, August 23, 2019 6:00 PM
To: Sigrid McCawley
is
(USANYS)
Subject: Re: In order for the Government to pay travel I would have to make the arrangements.
EFTA00027942

=== Page 2 ===
Thank you so much
for getting back to me, my amazing lawyer Sigrid was able to get me there- due
to the short notice & long flight I was afraid I was going to miss the hearing, so she got me there
impressive!! Thank you so much Sigrid!!
On the return
- that would be great if you could help out with the cost. I can give you my details if
needed. Also due to an ongoing medical condition, I would need to fly business. It does help me with not
being stuck in a position for 24+ hours. Thank you so very much!!
All the best,
On Saturday, August 24, 2019, 5:26 am, Sigrid McCawley
wrote:
We have that covered because she has some safety concerns so we selected a hotel with that in mind.
Thank you.
From:
(USANYS) [mailto:
Sent: Friday, August 23, 2019 3:15 PM
To: Sigrid McCawley
i
Subject: RE: In order for the Government to pay travel I would have to make the arrangements.
Not a problem we can do the return. Do you want me to put her in a hotel in New York?
From: Sigrid McCawley
Sent: Friday, August 23, 2019 3:10 PM
To:
(USANYS)
Subject: RE: In order for the Government to pay travel I would have to make the arrangements.
Thank you so much. We have not booked a return flight for her so we may need assistance with that
arrangement but I will confer with her and get back to you. Thank you very much.
From:
(USANYS) [mailto:
Sent: Friday, August 23, 2019 3:09 PM
To: Sigrid McCawley
i
Subject: RE: In order for the Government to pay travel I would have to make the arrangements.
Can I help her get to New York
EFTA00027943

=== Page 3 ===
From: Sigrid McCawley
Sent: Friday, August 23, 2019 3:04 PM
To:
(USANYS)
Subject: RE: In order for the Government to pay travel I would have to make the arrangements.
Thank you
We already booked the ticket for
and made arrangements for a hotel. She has
some safety concerns so we are taking care of the arrangements. We understand that means the
government cannot reimburse. Thank you for following up.
Best,
Sigrid
From:
(USANYS) [mailto:
Sent: Friday, August 23, 2019 2:58 PM
To:
Cc: Sigrid McCawley
Subject: In order for the Government to pay travel I would have to make the arrangements.
Please give me a call or you can give me the nearest airport when you want to leave Australia and your
name exactly as it is on your passport and DOB.
I will arrange transportation, hotel and car service from airport.
Victim Witness Coordinator
United States Attorney's Office
Southern District of New York
1 St. Andrews Plaza
New York, New York 10007
Tel.
EFTA00027944

=== Page 4 ===
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.l 08201831BSF
EFTA00027945


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=== Page 1 ===
From: "Miller, Michael"
To: "
)"
111
,
111
Cc: "Weingarten, Reid"
>, "Martin G. Weinberg"
i
"Scavelli, Michael"
"Lucas, Morgan"
>, , "Brochin, Jim"
, "Meade, Jason"
Subject: U.S. V. Epstein
Date: Fri, 02 Aug 2019 00:18:05 +0000
Attachments: Discovery_Letter_Aug_1,_2019_-c2.pdf
Dear
and
-
Please see the attached letter.
Mike
Michael C. Miller
Partner
fax
Steptoe
Steptoe & Johnson LLP
1114 Avenue of the Americas I New York, NY 10036
www.steptoe.com
This message and any attached documents contain information from the law firm Steptoe & Johnson LLP that may be confidential and/or privileged. If you
are not the intended recipient, please do 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.
EFTA00028442


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
)"
)"
Subject: https://www.foxnews.com/media/abc-amy-robach-jeffrey-epstein-hot-mic
Date: Tue, 05 Nov 2019 18:19:32 +0000
EFTA00028830


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Cc:
USANYS)"
)"
)"
Subject: FW: Defense Rule 16 Disclosure
Date: Tue, 09 Nov 2021 02:40:11 +0000
Attachments: 2021.11.08_Letter_to_Government_re_Rule_16_DisclosurePDF:
Ex_A_AT&T_Certification.pdf; Ex_B_FedEx_Certification.pdf;
Ex_C_List_of_Certified_FedEx_Invoices.pdf; Ex._D_Interlochen_Records.pdf;
Ex_E_A._Farmer_Release_(Redacted).pdf_Ex_F_Epstein_NPA.pdf
Inline-Images: image001.gif; image002.jpg
Hi
-could you please save these on the shared? Thanks!
From: Christian Everdell <
Sent: Monday, November 8, 2021 9:32 PM
To:
)
)
(USANYS)
Cc: Jeff Pagliuca
; Laura Menninger
Subject: [EXTERNAL] Defense Rule 16 Disclosure
Attached is the defense Rule 16 disclosure.
Regards,
Chris
Christian R Everdell
COHEN & GRESSER LLP
www.conengresser.com
New York Paris Washington DC London
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
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=== Page 1 ===
From:
To:
Cc:
,
"Blachman, Eric (USANYS)"
Subject: Subpoena and Request for Emails
Date: Fri, 12 Jul 2019 01:43:06 +0000
Importance: High
Attachments: 2019-07-11,_subpoena_to_MCC_(Epstein_calls).pdf
Attached please find a subpoena for recordings of Jeffrey Epstein's phone calls, excluding any attorney calls.
In addition to the materials requested in the enclosed subpoena, please accept our written request for the e-mail
correspondence of inmate Jeffrey Epstein (76318-054) from July 6, 2019 through July 11, 2019 - excluding any
correspondence between Epstein and the following attorneys: Marc Fernich (maf@fernichlaw.com), Martin Weinberg
(owlmgw@att.net), and Reid Weingarten
(
).
As you can see on the subpoena, we have set the return date for tomorrow (July 12, 2019). We would be grateful if
we could receive the requested materials as soon as possible. As always, please feel free to call
with
any questions or concerns.
Thanks very much
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=== Page 1 ===
From:
(OIG)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Re: Question from HQ
Date: Sat, 17 Aug 2019 18:55:50 +0000
Thank you
Sent from mobile device, please excuse typos.
Special Agent
Office of the Inspector General
On Aug 17, 2019, at 2:54 PM,
(USANYS)
wrote:
We conferred with our chiefs and the answer is no, there were no additional SDNY or court requirements as related to
inmate phone use or monitoring. Thanks.
From:
(OIG)
Sent: Saturday, August 17, 2019 11:43 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Question from HQ
As you may know IG
was a prosecutor in the SDNY and I believe he wants to know if the BOP disregarded
requests, directives or court orders from the prosecutors or Judge in the SDNY on the underlying case as it related to
phone use.
I believe HQ wants to know if the SDNY prosecutors office or Judge had any additional requirements, requests, directives
or court orders that the BOP needed to comply with that are above standard BOP policy for his phone use. Such as
specific recording of phone calls made, reporting to the SDNY of when phone calls were made, to whom, discussion
topics, observing or monitoring phone calls, writing memorandums of what they BOP staff may of heard.
U.S. Department of Justice
Office of the Inspector General
New York Field Office
EFTA00027180

=== Page 2 ===
From:
(USANYS)
Sent: Saturday, August 17, 2019 11:28 AM
To:
(OIG)
Cc:
(USANYS)
Subject: Re: Question from HQ
Does "memorialize Epstein's phone calls" mean was SDNY required to keep its own log of Epstein's calls at MCC?
On Aug 17, 2019, at 10:01 AM,
(OIG)
wrote:
I just received clarification on the question that OIG HQ has regarding the underlying case. The question and
clarification are below.
In addition to BOP policies, did SDNY have requirements to memorialize Epstein's phone calls related to the
underlying case? If so, were they followed?
Did BOP need to take notes on the conversation (since it's not recorded) or were they just required to keep a
phone number log?"
U.S. Department of Justice
Office of the Inspector General
New York Field Office
From:
(USANYS)
Sent: Friday, August 16, 2019 8:10 PM
To:
(OIG)
Cc:
(USANYS)
Subject: Re: Question from HQ
What do you mean by "memorialize phone calls"?
On Aug 16, 2019, at 7:17 PM,
(OIG)
wrote:
My HQ has the following question on the underlying case, can you please forward this to the prosecutors on the
underlying case? Thank you.
In addition to BOP policies, did SDNY have requirements to memorialize Epstein's phone calls related to
the underlying case? If so, were they followed?
U.S. Department of Justice
Office of the Inspector General
New York Field Office
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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
20 Cr. 330 (AJN)
V.
:
:
GHISLAINE MAXWELL,
:
Defendant.
:
:
:
X
REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT
OF HER MOTION TO DISMISS EITHER COUNT ONE OR COUNT THREE OF THE
SUPERSEDING INDICTMENT AS MULTIPLICITOUS
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Christian R. Everdell
COHEN & GRESSER LLP
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
Attorneys for Ghislaine Maxwell
EFTA00028968

=== Page 2 ===
The government does not dispute that Counts 1 and 3 charge Ms. Maxwell with the same
crime, conspiracy in violation of 18 U.S.C. $ 371, nor that the charges are based on identical
facts. Effectively conceding that the counts are multiplicitious, the government argues that the
motion is "premature," focusing only on the jeopardy problem that would occur if Ms. Maxwell
were convicted on both counts at trial and ignoring the prejudice to Ms. Maxwell attendant to the
overcharging. The government argues that the Court should defer ruling on this motion until
"after the completion of trial" which will "ensure" a full factual record. Resp. at 172. The
government is wrong.
The Court can, and should, grant this Motion, direct the government to elect which of the
conspiracy charges it will prosecute, and dismiss the other. The identical facts are plainly alleged
in the superseding indictment ("Indictment"), and the government has presented no factual
distinction in its response. Accordingly, no additional record is necessary and very clear
authority exists supporting the relief requested by Ms. Maxwell, dismissal of one of the
multiplicitous counts. "District courts presented with what are recognized before or during trial
to be multiplicitous indictments will avoid any problem by requiring the prosecution to elect
between counts charged rather than by merging the counts at sentencing." United States V.
Polizzi, 257 F.R.D. 33, 36-37 (E.D.N.Y. 2009). The Court should order such an election and
dismissal here.
I. The Motion is Not Premature, and the Court has Discretion to Direct Election
and Dismissal Pretrial
The government's "prematurity" argument is misplaced. Pursuant to Federal Rule of
Criminal Procedure 12(b)(3)(B)(ii), a defendant is required to raise arguments based
on defects in the indictment, including "charging the same offense in more than one count
(multiplicity)," by pretrial motion "if the basis for the motion is then reasonably available and the
1
EFTA00028969

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motion can be determined without a trial on the merits." See United States V. Dervishaj, 787 F.
App'x 12, 15 (2d Cir. 2019), cert. denied, 140 S. Ct. 2548 (2020) (multiplicity argument waived
because the defendant failed to raise the issue by pretrial motion).
The government also ignores ample Second Circuit authority that authorizes the relief
requested by Ms. Maxwell:
The defendant may move to have the prosecution elect among the multiplicitous
counts, with all but the one elected dismissed. This is a matter for trial court
discretion, and is most appropriate when the mere making of the charges would
prejudice the defendant with the jury.
United States V. Reed, 639 F.2d 896, 905 (2d Cir. 1981). I
The reason for this discretion is clear:
The law protects an individual against multiplicitous indictments to avoid multiple
sentences for a single offense and to eliminate the prejudice which such indictments
may generate in the eyes of a jury. For when an indictment charges numerous
offenses arising from the same conduct it may falsely suggest to a jury that a
defendant has committed not one but several crimes.
Once such a message is conveyed to the jury, the risk increases that the jury will be
diverted from a careful analysis of the conduct at issue. Compromise verdicts or
assumptions that, with so many charges pending the defendant must be guilty on at
least some of them, pose significant threats to the proper functioning of the jury
system.
United States V. Clarridge, 811 F. Supp. 697, 702 (D.D.C. 1992) (cleaned up). 2
Ms. Maxwell has been charged with the identical conduct in Counts 1-4. These multiple
counts falsely suggest to the jury that Ms. Maxwell is alleged to have committed more than one
crime. The defect in the Indictment is patent and prejudicial, and the Court should remove the
1 See also United States V. Ketchum, 320 F.2d 3, 7 (2d Cir.1963); United States V. Carter, 576
F.2d 1061, 1064 (3d Cir.1978); and United States V. Langford, 946 F.2d 798, 802 (11th Cir.1991).
2 See also United States V. Chacko, 169 F.3d 140, 145 (2d Cir.1999) (A multiplicitous indictment
creates an exaggerated impression of a defendant's criminal activity by charging "an offense multiple
times, in separate counts, when, in law and fact, only one crime has been committed.").
2
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=== Page 4 ===
defect by requiring the government to elect which of the conspiracy charges it will move forward
with and dismiss the remaining conspiracy charge.
II. The Government Failed to Meet its Burden of Establishing the Two Alleged
Conspiracies Are Distinct.
To guard against the "well recognized danger" that prosecutors can easily "draft
indictments that allege what appear to be separate conspiracies but may actually be parts of an
overall conspiracy," where a defendant "makes a non-frivolous showing that two indictments in
fact charge only one conspiracy, the burden shifts to the prosecution to show, by a
preponderance of the evidence, that there are in fact two distinct conspiracies." United States V.
Lopez, 356 F.3d 463, 467 (2d Cir. 2004) (citing United States V. DelVecchio, 800 F.2d 21, 22 (2d
Cir. 1986)). As demonstrated in Ms. Maxwell's moving papers, application of the Korfant
multifactor test results in an identical overlap of alleged: participants, time, similarity of
operation, overt acts, geography, objectives, and interdependence. Mot. at 2. The government has
failed to proffer any evidence to the contrary, and Ms. Maxwell's Motion should be deemed
confessed.
CONCLUSION
For the reasons stated in Ms. Maxwell's original Motion and this Reply, she requests that
the Court enter an order requiring the government to elect the conspiracy charge it intends to
prosecute and dismiss the remaining count.
Dated: March 15, 2021
3
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=== Page 5 ===
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Christian R. Everdell
COHEN & GRESSER LLP
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
Attorneys for Ghislaine Maxwell
4
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=== Page 6 ===
Certificate of Service
I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the
Court's individual practices in criminal cases, the Reply Memorandum of Ghislaine Maxwell in
Support of Her Motion to Dismiss Either Count One Or Count Three of the Superseding
Indictment as Multiplicitous upon the following:
U.S. Attorney's Office, SDNY
s/ Christian R. Everdell
5
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Event: Accepted:
Start Date: 2019-06-11 17:00:00 +0000
End Date: 2019-06-11 18:00:00 +0000
Organizer:
Location: Brass meet re Epstein
Class: X-PERSONAL
Comment:
Date Created: 2019-06-10 17:55:22 +0000
Date Modified: 2019-06-10 17:55:22 +0000
Priority: 5
DTSTAMP: 2019-06-10 17:38:48 +0000
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=== Page 1 ===
Court Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the United States District Court for the Southern District of New York, 40 Foley Square, in the
Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the
following date, time and place:
Appearance Date:
November 29, 2021
Appearance Time: 9:00 a.m.
Appearance Place:
40 Foley Square, Courtroom 906
to testify and give evidence in the following matter:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
All records relating to your employment by Jeffrey Epstein.
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
August 24, 2021
/s
AUDREY STRAUSS
United States Attorney for the
DEPARTMENT UNITED COURT
Southern District of New York
STATE
THE
Assistant United States Attorney
RICT
YORK
One St. Andrew's Plaza
New York, New York 10007
Rev. 02.01.12
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From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: RE:
Date: Wed, 05 Jun 2019 17:48:18 +0000
Importance: Normal
Hey team
Spoke to
this morning. No updates. She will call
again today.
is out for two weeks starting
Friday, which limits the ability for approaches, and I asked them to consider an approach tomorrow, not sure if they'll be
able to do that. Will let you know if I hear anything.
From:
(USANYS)
Sent: Monday, June 3, 2019 10:01 AM
To:
(USANYS)
Subject: Re:
Go ahead and give them a call this morning if you want - I'll be in later but don't wait on me.
Sent from my iPhone
On Jun 3, 2019, at 09:58,
(USANYS)
wrote:
Hope you had a great trip! FYI, I haven't heard back about this. As far as I know, no calls have been made yet.
From:
(USANYS)
Sent: Friday, May 31, 2019 10:13 AM
To:
(NY) (FBI)
Cc:
(USANYS)
Subject: FW: RE:
Hi
Hope you had a good flight back. Any luck with the calls to
? In case you're looking for the email with
contact info, it's below.
Thanks,
From:
(USANYS)
Sent: Tuesday, May 14, 2019 12:11 PM
To:
(NY) (FBI)
is
Byrne
(
Cc:
(USANYS)
is
(USANYS)
Subject: RE:
EFTA00029450

=== Page 2 ===
After a lot of back and forth, we've gotten the best contact number for
which was one of the ones on your list -
it's
(It's our understanding that she's not currently represented, though of course if she wants to have
counsel, as with everyone else, she can obtain an attorney or we can also assist in getting her appointed counsel. And
also similarly, we can jump on a call with her to explain the basics too if that's helpful, but also happy to just have you
guys make initial contact and then us meet her in person.)
So it's fine to call her, and she should know that we have an investigation and that we were planning to be in touch,
though as always we're playing a game of telephone on our end so hard to know for sure. If you're able to make contact
with her, I think it would make sense to explain what's happening generally but hopefully see if we can go out to
California to meet with her sometime this month.
Quick background on her
Happy to chat further if that's useful, otherwise green light to give her a call.
thanks,
Assistant U.S. Attorney
Southern District of New York
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From:
)"
To:
CRM)"
Cc:
)"
Subject: RE: SDNY investigation
Date: Wed, 30 Sep 2020 17:49:31 +0000
Thanks
For some reason we're required to attach an approval email to our package of paperwork, so if it's okay
with you I'll send you a separate email about that so that I can submit the response to EOUSA. Thanks!
From:
(CRM)
Sent: Wednesday, September 30, 2020 1:45 PM
To:
Cc:
Subject: Re: SDNY investigation
You can just say I have approved for OIA.
U.S. Department of Justice Attaché - London
US Mobile:
On Sep 30, 2020, at 6:42 PM,
)
wrote:
Is there a counterpoint at OIA in Washington we should be emailing for OIA approval, or should we send you an email
requesting approval?
Thanks,
From
(CRM)
Sent: Wednesday, September 30, 2020 11:18 AM
To:
Cc:
Subject: RE: SDNY investigation
Is she OK with the Met Police knowing about her speaking with us?
From:
Sent: Wednesday, September 30, 2020 4:17 PM
To: McNeil, John (CRM)
Cc:
Subject: RE: SDNY investigation
EFTA00029031

=== Page 2 ===
Hi
We have not seen the statement she has given, and we do not know the names of the police officers involved.
Thanks,
From:
(CRM)
Sent: Wednesday, September 30, 2020 11:16 AM
To:
Cc:
Subject: RE: SDNY investigation
Thanks. Very helpful. Am I correct in assuming that you have not seen the statement she
gave to the police? Also, do you have the names of the Met officers involved?
From:
Sent: Wednesday, September 30, 2020 3:53 PM
To:
CRM)
Cc:
)
Subject: RE: SDNY investigation
Hi
Thank you. We have not interviewed this witness, so we have not confirmed the details about where the abuse
happened, who the perpetrator was, or how old she was when it happened. What we do know is (1) she is currently in
(2) she is a
national, and (3) according to her lawyer, she recently made a statement to the Met Police
reporting some sort of past abuse by Jeffrey Epstein (and not necessarily the full scope of the information she may have
in connection with our investigation), so we would be open to the possibility of sharing her name with the Met Police if,
in your view, that was necessary.
We are preparing travel paperwork on our end, and will try to get this moving quickly. Thanks so much for your
guidance on this.
Best,
From
CRM)
Sent: Wednesday, September 30, 2020 7:07 AM
To:
is
-
>
Subject: RE: SDNY investigation
One other question. If there is anything that would implicate UK government interests in
this witness (other than any connection with witness PA) - if she was assaulted in
connection with a UK gov't function, or was a UK gov't employee, etc. - that would also be
helpful to know.
From:
(CRM)
Sent: Wednesday, September 30, 2020 11:05 AM
To:
is
)
Subject: RE: SDNY investigation
EFTA00029032

=== Page 3 ===
In speaking with LEGAT colleagues about how to do this without disclosing the witness
identity, they said the UK will want to know if the conduct is also a UK crime. So a few
questions:
is the victim a UK national;
did the alleged conduct occur on UK soil;
if the conduct occurred elsewhere, was the perp a UK national and the victim under age (I
think it has to be under age 16)?
Also, what country is the victim currently in - England/Wales; Scotland, or N. Ireland (they
each have their own procedures)?
Did the victim ever report the conduct to UK law enforcement?
Thx,
From
(London)
Sent: Tuesday, September 29, 2020 6:40 PM
To:
CRM)
Cc:
Subject: Re: SDNY investigation
My apologies. I haven't been able to get back on the line.
John T. McNeil
U.S. Dept. of Justice Attaché - London
UK Mobile:
Sent from a mobile device
From:
Sent: Tuesday, September 29, 2020 6:09:57 PM
To: McNeil, John T (London)
>; ; McNeil, John (CRM)
Cc:
)
Subject: RE: SDNY investigation
Hi John,
Thanks again for taking the time to talk to us today. We can use this conference line:
passcode
From
London)
Sent: Monday, September 28, 2020 11:58 AM
To
(CRM)
is
Subject: Re: SDNY investigation
I'll be in court much of the day tomorrow, so how about 1:30 pm EDT or later? Thx
U.S. Dept. of Justice Attaché - London
UK Mobile:
EFTA00029033

=== Page 4 ===
Sent from a mobile device
From:
(CRM)
Sent: Friday, September 25, 2020 8:14:17 PM
To
(London)
Subject: FW: SDNY investigation
From:
)
Sent: Friday, September 25, 2020 8:14:13 PM (UTC+00:00) Dublin, Edinburgh, Lisbon, London
To:
(CRM)
Cc:
);
(USANYS)
Subject: Re: SDNY investigation
Thanks very much. Is there a time on Tuesday that works best for you?
Sent from my iPhone
On Sep 25, 2020, at 1:49 PM,
(CRM)
wrote:
Hi
- I will be out of the office on Monday, but could do it any other day of the week. If
Monday is a critical day, I could do a call on Monday evening BST - which would be mid-afternoon
your time.
Let me know what works.
Thx,
U.S. Department of Justice Attache
United States Embassy - London
U.K. Mobile:
From:
)
Sent: Friday, September 25, 2020 3:16 PM
To:
CRM)
Cc:
is
(USANYS)
Subject: SDNY investigation
Hi
I hope you're doing well. Are you possibly available for a brief call on Monday?
Thanks very much,
EFTA00029034

=== Page 5 ===
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
From:
To:
Cc:
Christian Everdell
>, BOBBI C STERNHEIM
>, , Laura Menninger
, Jeff Pagliuca
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Government Motions in Limine
Date: Tue, 19 Oct 2021 03:58:29 +0000
Attachments: 2021-10-18_Gov't_letter_re_Proposed_Redactions_to_MILs_Ifinal].pdf
Government_MIL_[final,_unredacted].pdf;
Government_MIL_[final,_proposed_redactions].pdf,2021-10-
18_SEALED_Gov't_letter_re_to_accompany_MILs_[final].pdf
Good evening,
Attached please find the Government's motions in limine in the above-referenced case, which the Government requests
be accepted temporarily under seal.
Also attached is a cover letter, which has been filed on ECF, and a second letter, which the Government respectfully
requests be accepted for filing under seal.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Subject: Read: US V. Epstein
Date: Thu, 01 Apr 2021 13:17:50 +0000
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From:
To:
Subject: RE: STA exclusion letter
Date: Mon, 26 Apr 2021 23:40:19 +0000
Attachments: 2021-04-XX_GM_Govt_Letter_re_Exclusion_of_Time.docx
One small nit from me, thanks very much.
From:
Sent: Monday, April 26, 2021 12:06 AM
To:
Subject: RE: STA exclusion letter
No edits from me. Thanks,
!
A very quick skim of the cases makes it seem like this is worth doing.
From:
Sent: Sunday, April 25, 2021 11:45 PM
To:
is
is
Subject: STA exclusion letter
Draft attached. Any edits? I'll plan to file this week.
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From:
(USANYS)"
To:
)"
Cc:
)"
)"
Subject: Re: Maxwell testifying witness folder
Date: Wed, 07 Jul 2021 03:06:45 +0000
Good call. Thanks,
I was trying to find the notes of our conversation with her but wasn't able to find
them. I'll look again tomorrow but flagging in case you locate.
On Jul 6, 2021, at 10:59 PM,
)
wrote:
We already produced these in Rule 16 discovery, but I figure it makes sense to pull these and produce them as part of
's 3500 assuming we call her to testify just about the seizure of this evidence.
From:
Sent: Tuesday, July 6, 2021 10:59 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS)
)
Subject: Maxwell testifying witness folder
Hi
Would you please create a testifying witness folder for
and save the two attached pdfs in the
relevant folders?
Thanks,
<2007-08-10 INVESTIGATIVE CASE MANAGEMENT COLLECTED ITEMS FOR A CASE
08_10_2007.pdf>
<2006-09-06 DESCRIPTION OF PROPERTY LOG REGARDING EPSTEIN, JEFFREY
pdf>
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=== Page 1 ===
U
S.J. QUINNEY
PAUL G. CASSELL
COLLEGE OF LAW
Ronald N. Boyce Presidential Professor of Criminal Law
Telephone: 801-585-5202
cassellp@law.utah.edu
THE UNIVERSITY OF UTAH
TM
July 31, 2015
Assistant Commissioner
Specialist Crime and Operations
New Scotland Yard
London SW1H 0BG
Re:
International Sex Trafficking by Jeffrey Epstein and Ghislaine Maxwell
Ref: AC/SCO/82/201582/2015
Dear Commissioner
I write on behalf of my client -
I sent you a letter on May 4,
2015 (and an amended letter a few days later). I received your response on May 11,
2015, indicating that you would look into matter and be back in touch in due course.
Having not heard back from you, I wanted to follow up to see how your
investigation is proceeding. And I wanted to reiterate
offer to help you in
any way possible in your investigation.
Thank you in advance for any information you can provide.
Sincerely,
Paul G. Cassell
cc:
Brad Edwards, Esq.
Sigrid McCawley, Esq.
Jack Scarola, Esq.
www.law.utah.edu
Main Office (801) 581-6833
Facsimile (801) 581-6897
332 South 1400 East, Room 101
Salt Lake City, Utah 84112-0730
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=== Page 1 ===
From:
To:
Subject: RE: US V. Maxwell - discovery production
Date: Fri, 02 Oct 2020 13:08:17 +0000
Attachments: 2020.10.02_MDC - Maxwell_MAIN.pdf; 2020.10.02_MDC - Maxwell_PASSWORD.pdf;
2020.10.02_Maxwell_Discovery_Letter.pdf
Of course - here are all three PDFs. I'm printing now and will have these out ASAP!
From:
Sent: Friday, October 2, 2020 9:05 AM
To:
is
Subject: RE: US V. Maxwell - discovery production
Thank you! These are all good to go, please go ahead and send these out.
Also, would you please pdf them and send back to me so I can email the attorney letter to the attorneys and the MDC
letters to legal counsel at the MDC?
From:
Sent: Friday, October 2, 2020 9:01 AM
To:
is
Subject: RE: US V. Maxwell - discovery production
Attached are the three letters (so sorry to make you look at a screen again,
!)
"Maxwell Discovery Letter" - contains password; to be loaded on each drive and then emailed to the attorneys
"Maxwell MAIN" - to be printed and mailed with Maxwell's drive to MDC
"Maxwell PASSWORD" - contains password; to be mailed in a separate envelope to MDC
From:
Sent: Friday, October 2, 2020 8:43 AM
To:
is
Subject: RE: US V. Maxwell - discovery production
Thank you! What's your desk number? I just want to talk the next steps through (I'm a little fried and want to make sure
I'm absorbing everything)
From:
Sent: Friday, October 2, 2020 8:42 AM
To:
is
Subject: RE: US V. Maxwell - discovery production
Great, thank you!
Both drives have finished loading; Maxwell's drive contains the Reproductions, the Fourth Production, and VLC. The
attorneys' drive contains the Fourth Production and VLC (just in case). I will update the cover letter with the password for
EFTA00029036

=== Page 2 ===
the drives and print two copies, one for Maxwell (sent in a separate envelope) and one for the attorneys.
Do you have a specific address for Maxwell at the MDC? I can get these out by 9am, I believe - thanks so much!
From:
Sent: Thursday, October 1, 2020 8:54 PM
To:
is
Subject: RE: US V. Maxwell - discovery production
Perfect, thank you very much! Maxwell's drive should be FedEx'd to the MDC. The drive should be in one envelope and a
cover letter with the password should be sent by a different FedEx envelope. The attorneys' drive can be left for pick-up.
Fine to produce these tomorrow. Just let me know when they've finished loading.
From:
Sent: Thursday, October 1, 2020 6:52 PM
To:
is
Subject: RE: US V. Maxwell - discovery production
Hi all,
The cover letter (attached) has been updated with instructions for viewing those problem files, if you'd like to review.
Maxwell's drive is still copying; when and how are these to be picked up? It likely will be pretty late tonight that her drive
finishes, and then I can start on the drive for the defense.
Thanks!
From:
Sent: Thursday, October 1, 2020 4:37 PM
To:
Cc:
Subject: Re: US V. Maxwell - discovery production
I'd prefer that both be encrypted, please.
On Oct 1, 2020, at 4:33 PM,
wrote:
At least the one to Maxwell does. The one to defense could be unencrypted so long as it's hand delivered/picked up.
From:
Sent: Thursday, October 1, 2020 4:29 PM
To:
Cc:
Subject: RE: US V. Maxwell - discovery production
It needs to be encrypted, right?
EFTA00029037

=== Page 3 ===
From:
Sent: Thursday, October 1, 2020 4:27 PM
To:
Subject: RE: US V. Maxwell - discovery production
My apolgoies, one more question - should Maxwell's drive be encrypted or non-encrypted (read-only)?
From:
Sent: Thursday, October 1, 2020 4:18 PM
To:
Subject: FW: US V. Maxwell - discovery production
See below-would you please pick them up?
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Thursday, October 1, 2020 4:08 PM
To:
>
Cc: Mark S. Cohen <mcohen@CohenGresser.com>; Laura Menninger <Imenninger@hmflaw.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>;
is
)
Subject: RE: US V. Maxwell - discovery production
The drives have been delivered.
Thanks,
Chris
From:
Sent: Thursday, October 01, 2020 3:30 PM
To: Christian Everdell
Cc: Mark S. Cohen; Laura Menninger; Jeff Pagliuca;
);
)
Subject: RE: US V. Maxwell - discovery production
Chris,
Thank you very much. That is acceptable, and I will inform our paralegals that they should pick up the drives from the
CSOs and immediately begin loading the production onto the drives. We will send Ms. Maxwell's drive to the MDC as
soon as it is loaded, and we will let you know when your drive is ready for pickup.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00029038

=== Page 4 ===
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Thursday, October 1, 2020 3:28 PM
To:
>
Cc: Mark S. Cohen <mcohen@CohenGresser.com>; Laura Menninger <lmenninger@hmflaw.com>; Jeff Pagliuca
<jpagliuca@hmflaw.com>;
)
is
)
Subject: RE: US V. Maxwell - discovery production
Tom Powers from our office will be coming by 1 St. Andrew's within the hour to deliver two hard drives for these
productions - one for us and one for Ms. Maxwell in the MDC. He will leave them with the CSOs with an indication that
they should be delivered to you. Please confirm that this is acceptable.
We strongly request that you deliver the drive to Ms. Maxwell tomorrow that she is able to use the weekend to begin
reviewing the discovery.
Thanks,
Chris
From:
Sent: Thursday, October 01, 2020 1:18 PM
To: Christian Everdell
Cc: Mark S. Cohen; Laura Menninger; Jeff Pagliuca;
);
)
Subject: US V. Maxwell - discovery production
Chris,
Our office has prepared replacement files for the documents Ms. Maxwell has been unable to open at the MDC.
Additionally, we have prepared a new discovery production, which is ready for production both to you and to Ms.
Maxwell at the MDC. In order to produce these, we will need two hard drives - one for production to you and one for
production to the MDC. Would you please provide us with drives to load? For the MDC production, please let us know
if you would like us to ask the MDC to send us one of the drives that we previously sent to your client for us to load with
the new materials.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 18, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits its motions in limine, which the Government is
submitting to the Court under seal by email with proposed redactions. The Government's proposed
redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch V.
Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the Government's motions in
limine are judicial documents subject to the common law presumption of access, the proposed
redactions are narrowly tailored to protect the privacy interests of victims-including victims who
have not identified themselves on the record in this case and who have not publicly identified
themselves as victims referenced in the Indictment in this case-and third parties referenced in the
document.
In addition, the Government seeks redaction of Section X at least until the conclusion of
trial. Additional justification for this sealing request is located in footnote 11 on page 49 of the
Government's motions in limine.
EFTA00027704

=== Page 2 ===
Page 2
Accordingly, the Government respectfully requests that the Court permit the Government
to publicly file its motions in limine with its proposed redactions.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By: s/
Assistant United States Attorneys
Southern District of New York
Cc: Defense counsel (By ECF)
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=== Page 1 ===
From:
To:
Subject: FW: [EXTERNAL] URGENT: Ghislaine Maxwell 02879-509
Date: Fri, 29 Oct 2021 18:42:48 +0000
Original Message
From:
Sent: Friday, October 29, 2021 12:23 PM
To:
>; BOBBI C STERNHEIM
Cc: Christian Everdell
Subject: Re: [EXTERNAL] URGENT: Ghislaine Maxwell 02879-509
I am following up with the appropriate department.
BOBBI C STERNHEIM
10/29/2021 11:50 AM
Further my earlier email today, as of 10:30 a.m., USPO tracking lists the following 4 items of legal mail
"Available for Pickup" and does not indicate that MDC has retrieved or received them.
Ms. Maxwell has not received legal mail in more than a week.
Please confirm IMMEDIATELY the status of these items on your end.
Failure to response today will result in the filing of an order to show cause requiring your presence in Court.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
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.
>
V
V
V
V
> Isabel Maxwell, Paralegal, Leah Saffian, Inc.
> LAW OFFICES OF LEAH SAFFIAN; LEAH SAFFIAN BA JD LLM
> 11420 SANTA MONICA BLVD #25424 LOS ANGELES, CA 90025, USA
EFTA00028100

=== Page 2 ===
V
> NOTICE: The information transmitted by this email is intended only
for the person or entity to which it is addressed. This email may contain proprietary, business-confidential and/or
legally privileged material. If you are not the intended recipient of this message, be aware that any use, review,
retransmission, distribution, reproduction or any action taken in reliance upon this message is strictly prohibited.
If you received this in error, please contact the sender Isabel Maxwell at Tel
and delete the
material from all computers.
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From:
(USANYS)"
To:
Subject: FW: Second Circuit oral arguments this week (April 26-30, 2021)
Date: Mon, 26 Apr 2021 14:00:58 +0000
Pls cal the Thursday argument only.
From:
Sent: Monday, April 26, 2021 9:35 AM
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>; USANYS-CRIMINAL PARALEGALS <USANYS-
CRIMINALPARALEGALS@usa.doj.gov>; USANYS-INVESTIGATORS <USANYS-INVESTIGATORS@usa.doj.gov>
Subject: Second Circuit oral arguments this week (April 26-30, 2021)
The Office has two oral arguments in criminal cases scheduled before the Second Circuit this week. They will be argued by
phone/zoom, and you can listen to the livestream at this link. Also, you can click on the hyperlinks below to access our
briefs.
Monday, April 26, 2021
(Leval, Lohier, Sullivan)
United States V. Ghislaine Maxwell
arguing
Bail appeal
First on calendar; scheduled to start at 10:00 am
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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
Cc:
)"
(USANYS)"
Subject: RE: Discovery Issues
Date: Mon, 29 Mar 2021 19:04:18 +0000
Inline-Images: image001.jpg; image002.jpg
Hello
I will send this information to PAE and set up a time for a phone call.
Thank you.
From:
Sent: Monday, March 29, 2021 2:59 PM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: FW: Discovery Issues
Hi
We just received the below and attached regarding discovery in the Maxwell case. Many of these questions relate to
productions that PAE prepared. Would you please take a look and let me know when would be a good time this week for
a call to discuss?
Thanks,
From: Christian Everdell
Sent: Monday, March 29, 2021 2:40 PM
To:
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; ; Laura Menninger
>; Bobbi Sternheim
Subject: Discovery Issues
and
-
We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a
call to discuss.
1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created
(without the highly confidential items). You had said you would check to see if you could facilitate this. We have
not heard back from you. Are you able to send Ms. Maxwell the hard drive?
2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and
must use the prison computer. But the prison computer cannot read some of the files. We can include these files
EFTA00027861

=== Page 2 ===
on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please
advise which way you would like to proceed.
3. A number of the emails in the discovery - over 109,000 - were produced without their attachments (see tab 1 of
the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the
missing attachments, if they exist.
4. A number of electronic documents - over 110,000 - that were extracted from one of Epstein's devices, as identified
by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or
afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with the original
metadata for these files.
5. A number of photographs - over 6500 - were produced in native format, but do not have a CART number and have
"date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please
provide the CART number for these photographs or specify which device they came from. Also, we request that
you produce a metadata overlay with the original metadata for these files.
6. A number of the audio/visual files - over 460 - have similar metadata issues (see tab 4 of the attached Excel file).
These fall into the following buckets:
a. SDNY GM SUPP: these have CART numbers, but were produced without metadata load files and have
"date created" and "date last modified" dates in September-November 2020, after the date the device was
seized. We request that you produce a metadata overlay with the original metadata for these files.
b. SDNY005 (October 20, 2020 production): these are a few videos from the SDFL or PBPD investigations that
were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that
you produce a metadata overlay with the original metadata for these files.
C. SDNY011 (November 9, 2020 production): these were produced in native form with load files, but do not
reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these
files or indicate their source. Also, we request that you produce a metadata overlay with the original
metadata for these files.
7. There is a gap between 11/18 and 12/18 production numbers (SDNY_GM_02742044 to 2742183). Was that
intentional or are we missing those documents?
Please let us know your responses as soon as possible.
Thanks,
Chris
Christian R Everdell
COHEN & GRESSER LLP
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
GG
EFTA00027862

=== Page 3 ===
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
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From:
To:
Subject: Voucher for Trip 10643456-2 is late
Date: Sat, 05 Oct 2019 04:03:35 +0000
Importance: Normal
Dear
Your travel voucher for the trip below is now late based on your customer settings. Please submit your voucher
for this trip and mark it as Final if you have no additional expenses to claim.
Trip ID: 10643456-2
Traveler name:
Destination: Santa Monica
Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews
Trip Dates: 2019-09-17 - 2019-09-20
Current status: Authorization Approved
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0013
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
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=== Page 1 ===
From:
"
(OIG)"
To:
(USANYS)"
Subject: Declined: Mark Epstein Meeting
Date: Wed, 30 Oct 2019 12:48:19 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From:
To:
Subject: Bannon iPhone 7
Date: Mon, 12 Apr 2021 00:33:28 +0000
Hi,
Wanted to let you know that there are a number of text messages between Steve Bannon and Jeffrey Epstein on Bannon's
iPhone 7. They aren't responsive to our warrant.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel:
Cell:
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=== Page 1 ===
Event: Tentative: Epstein estate
Start Date: 2019-10-23 18:30:00 +0000
End Date: 2019-10-23 19:00:00 +0000
Location: Skype Meeting;
Class: X-PERSONAL
Comment:
Date Created: 2019-10-23 13:47:15 +0000
Date Modified: 2019-10-23 13:47:15 +0000
Priority: 5
DTSTAMP: 2019-10-23 13:24:11 +0000
Attendee: Weinstein, Marc A.
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From:
To:
Subject: Automatic reply: Sources: Jeffrey Epstein dies by suicide in Manhattan jail I abc7.com
Date: Sat, 10 Aug 2019 13:05:02 +0000
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses may be
delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of Florida
500 South Australian Ave., Suite 400
West Palm Beach, FL 33401
(561) 820-8711
Facsimile: (561) 820-8777
June 30, 2008
NOTIFICATION OF IDENTIFIED VICTIMS
On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
followed by an additional six months' imprisonment, followed by twelve months of
Community Control 1, with conditions of community confinement imposed by the Court.
In light of the entry of the guilty plea and sentence, the United States has agreed to
defer federal prosecution in favor of this state plea and sentence, subject to certain
conditions.
One such condition to which Epstein has agreed is the following:
"Any person, who while a minor, was a victim of a violation of an offense
enumerated in Title 18, United States Code, Section 2255, will have the same
rights to proceed under Section 2255 as she would have had, if Mr. Epstein
had been tried federally and convicted of an enumerated offense. For purposes
of implementing this paragraph, the United States shall provide Mr. Epstein's
attorneys with a list of individuals whom it was prepared to name in an
Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
authority interpreting this provision, including any authority determining
which evidentiary burdens if any a plaintiff must meet, shall consider that it is
the intent of the parties to place these identified victims in the same position
as they would have been had Mr. Epstein been convicted at trial. No more; no
less."
Initials of Jeffrey Epstein
Initials of Jack Goldberger
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=== Page 1 ===
From:
(USAFLS)"
To:
(USAFLS)"
Bcc:
(USAFLS)"
Subject: FW: Epstein
Date: Tue, 08 Jul 2008 16:14:31 +0000
Importance: Normal
Attachments: Conf_Plea_Negotiations_final.wpd
— Please see below.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
From:
(USAFLS)
Sent: Thursday, September 06, 2007 5:47 PM
To:
(USAFLS)
Subject: RE: Epstein
Hi
- Funny you should ask. I have been wondering the same thing. Here is the term sheet and guidelines
calculation that we provided at the last meeting. You and
and I had also discussed a possible federal plea to
an Information charging a 371 conspiracy, with a Rule 11 plea with a two-year cap, but I think
must have
asked Alex about it and it was nixed. Just to be prepared for tomorrow, I was just starting to draft a Rule 11 plea
agreement in case Alex changes his mind and a formal non-prosecution agreement containing the state plea
terms. As soon as those are ready, I will e-mail them to you.
<<Conf Plea Negotiations final.wpd>>
There are three concerns that I hope we can address tomorrow. First, that there is an absolute drop-dead date for
accepting or rejecting because it is strategically important that we indict before the end of September, which
means presenting the indictment on September 25th. Second, the agents and I have not reached out to the
victims to get their approval, which as
politely reminded me, is required under the law. And third, I do not
want to make any promises about allowing Epstein to self-surrender because I still believe that we have a good
chance of getting him detained.
On another note, Junior got a call today from the Palm Beach Police Chief because he got information that there
will be an article released tomorrow about our meeting and that Epstein is going to plead to a state charge and
the Chief wanted to know if the victims had been consulted about the deal. There has been some coverage in the
New York press about Ken Starr, but I haven't seen anything local yet.
Assistant U.S. Attorney
EFTA00014090

=== Page 2 ===
From:
(USAFLS)
Sent: Thursday, September 06, 2007 5:35 PM
To:
. (USAFLS)
Subject: Epstein
Please refresh my recollection. What is the "deal" on the table?
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From:
(USAFLS)"
To:
(FBI)"
Bcc:
-
(USAFLS)"
Subject: RE: Epstein Work Release Case File
Date: Tue, 25 Nov 2008 20:04:36 +0000
Importance: Normal
I am glad to hear that your paranoia hasn't faded. Mine hasn't either.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
From:
(FBI)
Sent: Tuesday, November 25, 2008 3:00 PM
To:
(USAFLS)
Subject: Re: Epstein Work Release Case File
I got the truck # for comcast I thought about tracking down the driver and showing him a lineup to C if Epstein was there:)
anyways have a great Thanksgiving. Let me know if u hear from the Col.
From:
. (USAFLS)
To:
Sent: Tue Nov 25 14:57:47 2008
Subject: RE: Epstein Work Release Case File
Nope. That's okay. I told
to let me know if he hears about the planes going anywhere.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
From:
(FBI)
Sent: Tuesday, November 25, 2008 2:55 PM
To:
(USAFLS)
Subject: Re: Epstein Work Release Case File
I went by the house friday. The surburban and the escalade were in the driveway. Comcast truck was there as well. If u
would like I can ask
to go by the house on a reg basis.
From:
. (USAFLS)
To:
Sent: Tue Nov 25 14:50:02 2008
Subject: RE: Epstein Work Release Case File
EFTA00014041

=== Page 2 ===
Just talked to
Have you heard anything from
lately? I talked to the Captain yesterday and he said
was planning to check out E's house. I really think if E is going to run it will be in the next few days.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
From:
. (FBI)
Sent: Tuesday, November 25, 2008 2:46 PM
To:
(USAFLS)
Subject: Re: Epstein Work Release Case File
Hey, sorry I have not heard back maybe u will have better luck. Ask
if he could contact the jail's records dept and
maybe he would have luck that way. I am surprise we did not hear back from them when u left a# for them to contact u or I.
I have the col's direct # if we need to I could have
get it off my desk. Let me know and good luck.
From:
. (USAFLS)
To: gaugerm@pbso.org
Cc:
;
.
Sent: Tue Nov 25 14:35:51 2008
Subject: Epstein Work Release Case File
Hi
:
I know that
asked to get a copy of the Epstein work release case file before she went out of town. Can I
stop by to pick it up? I can even make the copies if everyone else has left on vacation.
Thank you.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
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=== Page 1 ===
From:
USANYS)
To:
)"
Subject: Accepted: Call w/ SDNY re: discovery, Epstein investigation
Date: Thu, 22 Oct 2020 17:02:29 +0000
Importance: Normal
Attachments: unnamed
EFTA00010299


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=== Page 1 ===
From:
Subject: FYI--Second Circuit Decision re: unsealing of Epstein files
Date: Wed, 03 Jul 2019 15:00:09 +0000
Importance: Normal
https://assets.documentcloud.org/documents/6181300/Epstein-ca2-20190703.pdf
Public Affairs
U.S. Attorney's Office for the Southern District of New York
Email:
Website: www.justice.gov/usao-sdny.
Facebook: https://www.facebook.com/usaosdny
Follow us on Twitter: @SDNYnews
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=== Page 1 ===
From:
)"
To:
USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Phone Call Follow-Up
Date: Fri, 30 Oct 2020 18:27:31 +0000
Inline-Images: image001.png
Thanks Ted. To be clear, the productions they are sending today consist of the 40,000 images, documents from the FBI
Florida boxes, and documents from the FBI FOIA office. They are not sending, and have not sent, us any productions from
the electronic devices.
From:
(USANYS)
Sent: Friday, October 30, 2020 2:24 PM
To:
;
;
(USANYS)
Cc:
(USANYS)
Subject: FW: Phone Call Follow-Up
See below for the update from PAE. The good news is that they're getting this back to us on a rolling basis, and it looks like
we'll have at least some of this stuff in time to produce it by 11/9. The bad news is it does not seem like we'll have all of it
by that date. It does seem like we'll have greater clarity by early next week.
I confess, I don't feel like I fully understand all of the steps in this process or why it takes as long as it does, but I'm happy
to go back to
with additional questions if that would be helpful. I'm also happy to ask that he set up a call with us and
PAE if that would be helpful. Please let us know what we can do.
From: Tyrrell, Edward (USANYS)
Sent: Friday, October 30, 2020 12:51 PM
To:
(USANYS)
; ; Donaleski, Rebekah (USANYS)
Subject: FW: Phone Call Follow-Up
Some of the data is being sent to use today by FedEX. However, there is a ton of stuff still being processed. That stuff is
still being imaged. Then it gets marked. Then copied to us. I have spoken to
He thinks it is not possible to
meet the November 9 date. He thinks the next step might be done on Tuesday, and then a better estimate of completion
might be possible.
From: Koontz, Nicholas [US]
Sent: Friday, October 30, 2020 12:25 PM
To: Tyrrell, Edward (USANYS)
Cc:
(USANYS) [Contractor]
Subject: Phone Call Follow-Up
Good Afternoon Ed:
Following up on our earlier phone conversation, a hard drive with the following productions is being sent to SDNY via
FedEx with the following productions in the US V. Epstein workspace:
1) SDNYPROD008
2) SDNYPROD009
3) SDNYPROD010
4) SDNYPROD011 (Note: this is a six-part production)
5) SDNYPROD012
6) SDNYPROD013
7) SDNYPROD014
There are approximately 1.2 million records currently being imaged. The images will be available on Monday, November 2,
2020 at the earliest. The production of the records will begin as soon as the images are available in the workspace.
Please feel free to contact me if you have any questions.
Thanks,
EFTA00013205

=== Page 2 ===
Lead E-Discovery Analyst
e
7799 Leesburg Pike, Suite 300N
Falls Church, Virginia 22043
PAE
IMPORTANT: The information contained in this message may be privileged, business sensitive, proprietary,
copyrighted, protected from disclosure and/or subject to US export controls. If you are not the intended
recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify me immediately by replying
to the message and deleting it from your computer. #-SEC-#
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Epstein -- Release of USMS information
Date: Fri, 13 Sep 2019 18:26:05 +0000
Let us know if you have some time this afternoon. We have something at 2:30 but are otherwise free.
From:
(USANYS)
Sent: Friday, September 13, 2019 2:01 PM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Epstein -- Release of USMS information
As you are undoubtedly aware, there has been some press coverage since yesterday about the release pursuant to FOIA of
some USMS records. I just spoke with the Associate General Counsel at the USMS, who wanted to provide us with the
actual source materials (USM 11s (equivalent of 302s)) that were inadvertently released, because they were not in all
circumstances accurately reported, and he wanted to make sure that if we are concerned about any harm to our
investigation from the release, that we have the original materials. He also offered to serve as a POC if we have any
questions.
Chief, Criminal Division
United States Attorney's Office, SDNY
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=== Page 1 ===
From:
"
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To: "
(USAFLS)"
Subject: Funny epstein story
Date: Thu, 17 Jul 2008 17:31:27 +0000
Importance: Normal
Well,
epstein's pricey lawyers may have cost him $200 million. I reviewed the docket sheets for the 4 pending federal
suits (they are all jeff herman suits) and judge marra has issued orders to show cause why default judgments shouldn't be
entered for all 4. Herman asked for $50 million in each one. Apparently epstein tried to avoid service and ignored the
deadline when the complaints were mailed to him (thinking that was ineffective service). All I can say is, so much money,
so little skill.
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=== Page 1 ===
Event: Epstein meetings
Start Date: 2007-09-07 17:00:00 +0000
End Date: 2007-09-07 21:00:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2015-04-04 00:21:57 +0000
Date Modified: 2015-07-22 20:34:54 +0000
Priority: 5
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=== Page 1 ===
Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 1 of 32
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
JANE DOE 1 AND JANE DOE 2,
Civil Action No.
PETITIONERS,
08-80736-CIV-MARRA
v.
UNITED STATES OF AMERICA,
RESPONDENT.
Government's Response to Petitioners' Submission on Proposed Remedies
The United States of America, by Byung J. Pak, United States Attorney for the
Northern District of Georgia, and Jill E. Steinberg and Nathan P. Kitchens,
Special Attorneys for the Southern District of Florida, files this response to
Petitioners' proposed remedies.
INTRODUCTION
The question before this Court is what remedies, if any, should be accorded
Petitioners under the Crime Victims' Rights Act (CVRA) based on this Court's
finding that the government failed to confer with Petitioners prior to entering
into a non-prosecution agreement (NPA) with Jeffrey Epstein.¹ Petitioners seek
1 This Court previously found that Petitioners are crime victims under the
CVRA; a crime victim's rights under the CVRA attach before the
government brings formal charges against a defendant; the CVRA's
"reasonable right to confer" extends to conferring about non-prosecution
agreements; the CVRA authorizes the rescission of a non-prosecution
agreement reached in violation of a prosecutor's conferral obligations; and
the government violated the CVRA by failing to advise the victims that it
intended to enter into the NPA with Epstein. The government will not
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Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 2 of 32
what they call "rescission remedies," "apology remedies," "informational
remedies," "educational remedies," and "miscellaneous remedies" - all of which
constitute equitable relief, and none of which is authorized by the CVRA. But
even if the statute did allow equitable relief, Petitioners are not entitled to the
specific relief they are seeking.
Nevertheless, the government believes that it should have communicated its
resolution of the federal criminal investigation of Epstein to his victims more
effectively and in a more transparent manner. Although we cannot turn back
time and put the victims back in the position they would have been in over a
decade ago, the government believes the following proposed remedies would
respect their rights under the CVRA, balance the constitutional and statutory
obligations imposed on the government, and bring some level of finality to all
the parties.
DISCUSSION
1. The Government's Proposed Remedies.
A. The government should have communicated in a more transparent way
with victims.
As a matter of law, the government's position is that the legal obligations
under the CVRA do not attach prior to the government charging a case. Nor does
the CVRA authorize any of the remedies sought by the Petitioners - in part
because the CVRA does not contemplate its invocation in the context of
revisit these findings here except to note that it maintains all of its
objections.
2
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Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 3 of 32
uncharged criminal conduct. 2 At the same time, the government strives to
communicate with crime victims effectively and as transparently as possible.
There are myriad reasons why a prosecutor may decline to indict a case or
resolve a case with a plea to a less serious charge. These considerations are
highly contextual and involve a host of factors based upon the current state of
the law and provable evidence, as well as the experience that prosecutors and
their law enforcement partners develop working cases over many years. There
are instances when victims of a crime or third parties may disagree with a
prosecutor's decision, but that decision nevertheless remains with the prosecutor
and her supervisors, and this discretion is expressly preserved in the CVRA. See
18 U.S.C. $ 3771(d)(6).
Although the CVRA may not have required it, here, the government engaged
with the Petitioners about the status of the investigation and advised them that
the case was being actively pursued. At the same time, potential federal charges
were being resolved with a state court guilty plea in conjunction with the NPA.
Regardless of whether the government ultimately chose to pursue, decline, or
2 Indeed, under the CVRA, "crime victim" is a person directly and
proximately harmed as a result of the "commission of a Federal offense." 18
U.S.C. $ 3771(e)(2)(A). Thus, without identifying exactly which federal offense
was committed by filing formal charges, it is difficult to determine who was
directly and proximately harmed. Moreover, the crime victims' rights are tied to
a court proceeding, see 18 U.S.C. $ 3771(b)(1), which indicates that formal charges
are required prior to the attachment of rights under the CVRA. By Department
policy and practice, however, federal prosecutors usually go above and beyond
the obligations defined by the CVRA and interact with victims early on in a case.
3
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Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 4 of 32
otherwise resolve federal prosecution - a decision upon which we do not opine
here - the government should have communicated with the victims in a
straightforward and transparent way. Because the government did not
communicate more clearly and directly with the victims, the resolution in this
case has led some to conclude that the government chose for improper reasons
not to prosecute Epstein, a conclusion that remains unsubstantiated. The
government places high value in its work to support victims of crime, and its
communications with victims must reflect that value. The government regrets
that the manner in which it communicated the resolution of the Epstein case to
the victims fell short.
B. The Department of Justice's commitment to victims of human
trafficking and child exploitation supports targeted remedies to give the
Epstein victims a voice, an explanation, and finality.
Over the past decade, the Department of Justice has made combatting human
trafficking and child exploitation a national priority.3 Between Fiscal Years (FY)
2009 and 2016, the Department increased the number of human trafficking cases
3 See Department of Justice Releases First National Strategy for Child Exploitation
Prevention and Interdiction (Aug. 2, 2010), https://www.justice.gov/opa/pr/
department-justice-releases-first-national-strategy-child-exploitation-prevention-
and (Eric Holder comments); Introduction by Attorney General Loretta Lynch,
National Strategy to Combat Human Trafficking (January 2017),
https://www.justice.gov/humantrafficking/page/file/922791/download
(hereinafter National Strategy to Combat Human Trafficking); Attorney General Jeff
Sessions Delivers Remarks at National Law Enforcement Training on Child Exploitation
(June 6, 2017), https://www.justice.gov/opa/speech/ attorney-general-jef-
sessions-delivers-remarks-national-law-enforcement-training-child.
4
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=== Page 5 ===
Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 5 of 32
charged, defendants charged, and defendants convicted by roughly 70 percent in
comparison to the prior eight years, in addition to higher prosecution results in
cases involving child sex trafficking.4 In FY 2009, the Department charged 2,315
child exploitation cases involving 2,427 defendants; in FY 2015, that number
almost doubled to 4,211 cases involving 4,458 defendants.⁵ In addition, through
its Office of Justice Programs, the Department funds 61 coordinated task forces to
fight internet-facilitated crimes against children (ICAC).6 In FY 2008, the task
forces were funded at $16.9 million; in FY 2018 the funding for the ICAC
program was $28.6 million.⁷ Through its Office for Victims of Crime (OVC), the
Department provides more grant funding than any other federal agency to
programs that provide direct services to victims of human trafficking.8 Indeed,
this month, OVC announced its FY 2019 grant, which will award millions of
4 National Strategy to Combat Human Trafficking at 1.
5 National Strategy for Child Exploitation Prevention and Interdiction (Aug. 2010),
at 5, https://www.justice.gov/psc/docs/natstrategyreport.pdf; National Strategy
for Child Exploitation Prevention and Interdiction (Apr. 2016), at 110-11,
https://www.justice.gov/psc/file/842411/download (hereinafter 2016 National
Strategy for Child Exploitation Prevention).
6 Program Summary, Internet Crimes Against Children Task Force Program,
https://www.ojjdp.gov/programs/ProgSummary.asp?pi=3.
7 Id.
8 Announcements, Office for Victims of Crime,
https://ovc.ncjrs.gov/humantrafficking/announcements.html.
5
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=== Page 6 ===
Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 6 of 32
dollars in funding to assist victims of trafficking.9 In April 2016, the Department
published a comprehensive strategy, in conjunction with several other federal
agencies, to combat child exploitation, including child sex trafficking.10 In 2013,
the Department and other agencies published a victim-dedicated action plan that
described the process by which the government will combat trafficking offenses
with a focus on providing support and services to victims.11
These programs and accomplishments matter because they reflect a
commitment on the part of the Department of Justice, which includes all federal
prosecutors, to combat human trafficking and crimes against children and fully
support and protect victims of crime. Any remedy the Court imposes in this
matter should reflect the fact that any mistakes made in this case stand in
contrast to the Department's commitment to victims.
Any remedy the Court imposes should also have a nexus to the purpose of
the CVRA, which is to give victims a voice in the criminal justice process, but not
decision-making authority over prosecution decisions. Here the Court found that
the government violated the CVRA by failing to confer with the victims about
the NPA. The past cannot be undone; the government committed itself to the
terms of the NPA, and the parties have not disputed that Epstein complied with
9 OVC Fiscal Year (FY) 2019 Direct Services to Support Victims of Human
Trafficking, https://www.ovc.gov/grants/pdftxt/FY19-Direct-Services-Human-
Trafficking-Solicitation.pdf.
10 2016 National Strategy for Child Exploitation Prevention.
11 Federal Strategic Action Plan on Services for Victims of Human Trafficking,
https://www.ovc.gov/pubs/FederalHumanTraffickingStrategicPlan.pdf.
6
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=== Page 7 ===
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its provisions. A number of Epstein's victims subsequently invoked the NPA to
enter into civil settlements with Epstein and, in that respect, also relied on its
terms.¹² Any remedy for the CVRA violation should thus serve to give the
victims a voice, even though the prosecution decision remains out of their hands.
As such, the government proposes the following remedies:
The Department of Justice will designate a representative to meet with
Petitioners, and any other Epstein victim who wishes to participate, to
discuss the government's decision to resolve the Epstein case and engage
in an open dialogue about that decision.
The government will participate in a public court proceeding, presided
over by this Court, in which the Petitioners, and any other Epstein victim
who wishes to participate, can make a victim impact statement. That
hearing would be handled in a manner similar to the way the Court would
handle victim impact statements in the context of a criminal sentencing.
All criminal prosecutors in the United States Attorney's Office for the
Southern District of Florida (USAO-SDFL) will undergo additional
training on the CVRA, victim rights, and victim assistance issues to be
completed no later than one year from the date of the Court's final order in
this case.
2. The CVRA Specifies the Enforcement Mechanism To Address Violations of
Its Terms and Does Not Authorize the Equitable Remedies Petitioners
Seek.
The government offers the proposed remedies above, not because it is
required to do so by law, but because it believes these corrective actions are
12 Based on information provided in response to the government's recent
efforts to confer with victims, more than a dozen victims invoked the NPA to
enter civil settlements with Epstein while protecting their anonymity.
7
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=== Page 8 ===
Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 8 of 32
necessary to give a voice to the victims of Jeffrey Epstein and an opportunity for
them to understand the true reasons why the government resolved the case in
the manner it did since they did not have that opportunity at the time. These
remedies are generally consistent with several remedies proposed by Petitioners.
But the law does not authorize this Court to grant other remedies Petitioners
seek, nor would such remedies promote the underlying purpose of the CVRA to
promote victims' participatory rights in the criminal justice process while
respecting their dignity and privacy.
Although Petitioners assert that the CVRA gives this Court "broad power to
craft appropriate remedies," Doc. 458 at 7, the statute's plain language says
otherwise. That language explicitly provides that a crime victim may not seek
damages against the United States:
No cause of action. - Nothing in this chapter shall be construed to
authorize a cause of action for damages or to create, to enlarge, or to imply
any duty or obligation to any victim or other person for the breach of
which the United States or any of its officers or employees could be held
liable in damages.
18 U.S.C. $ 3771(d)(6) (emphasis in original).
Perhaps because Congress provided no cause of action for damages, it sought
compliance a different way: it included a section in the CVRA entitled
"Procedures to [P]romote [C]ompliance," in which it directed the United States
Attorney General to "promulgate regulations to enforce the rights of crime
victims and to ensure compliance by responsible officials with the obligations"
8
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=== Page 9 ===
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set out by statute. 18 U.S.C. $ 3771(f). Congress further directed that these
regulations: (1) designate someone within the Department of Justice to receive
and investigate complaints relating to a rights violation; (2) require that DOJ
officials be trained on crime victims' rights and assist such employees in
responding to crime victims' needs; (3) provide "disciplinary sanctions,
including suspension or termination from employment, for employees of the
Department of Justice who willfully or wantonly fail to comply with provisions
of Federal law pertaining to the treatment of crime victims"; and (4) instruct that
the "Attorney General, or the designee of the Attorney General, shall be the final
arbiter of the complaint, and that there shall be no judicial review of the final
decision of the Attorney General by a complainant." Id. at (f)(1)(A)-(D).
The Department of Justice did as Congress directed, and the resulting
regulations are found at 28 C.F.R. $ 45.10. These regulations outline the
procedures a crime victim shall take when he or she believes that one of their
CVRA rights has been violated. 28 C.F.R. $ 45.10(c). Notably here, the regulations
provide that the Department of Justice Victims' Rights Ombudsman is "the final
arbiter of the complaint," and the complainant "may not seek judicial review" of
that determination. Id. at (c)(7)-(8). The Ombudsman alone decides whether to
notify the complainant of the result of the investigation. Id. at (c)(9). Empowering
the Ombudsman to remedy a victim's complaint without the risk of delay from
prolonged litigation is consistent with congressional intent that the CVRA's
administrative remedy should "create[] a framework to quickly enforce victims'
rights." 150 Cong. Rec. 7312 (statement of Sen. Orrin Hatch).
9
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=== Page 10 ===
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With respect to disciplinary sanctions, if the Ombudsman finds that a DOJ
employee violated a crime victim's rights, but not in a willful or wanton manner,
the Ombudsman shall require the employee "to undergo training on victims'
rights." 28 C.F.R. $ 45.10(d). If, however, the Ombudsman finds that the DOJ
employee willfully or wantonly violated a crime victim's rights, the Ombudsman
shall recommend "a range of disciplinary sanctions." Id. at (e)(1). "Disciplinary
sanctions" means "those sanctions provided under the Department of Justice
Human Resources Order, 1200.1," which include written reprimands,
suspensions, reductions in grade or pay, removals, and furloughs for 30 days or
less. Id. at (e)(2); DOJ Human Resources Order, 1200.1, Part 3, B(2). Thus, the
CVRA provides sanctions that the government and its employees may be
subjected to if they violate the CVRA.
The CVRA's plain text lays out the procedures that crime victims must follow
when they believe their CVRA rights have been violated, the actions DOJ must
take when it receives a complaint, and the sanctions DOJ may employ when a
violation has occurred. And this carefully crafted and detailed enforcement
scheme undermines any suggestion that Congress intended, but simply forgot, to
provide additional remedies beyond those already specified. Courts agree. See
United States v. Monzel, 641 F.3d 528, 542 (D.C. Cir. 2011) (holding that the
CVRA's "carefully crafted and detailed enforcement scheme," provides "strong
evidence that Congress did not intend to authorize other remedies that it simply
forgot to incorporate expressly") (quoting Mertens v. Hewitt Associates, 508 U.S.
248, 254 (1993)); United States v. Hunter, 548 F.3d 1308, 1315 (10th Cir. 2008)
10
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=== Page 11 ===
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(declining to "to read additional remedies" into the CVRA beyond those
expressly contained in the Act); see also Karahalios v. Nat'l Fed'n of Fed. Employees,
489 U.S. 527, 533 (1989) ("[I]t is
an 'elemental canon' of statutory construction
that where a statute expressly provides a remedy, courts must be especially
reluctant to provide additional remedies.") (quoting Transamerica Mortgage
Advisors, Inc. v. Lewis, 444 U.S. 11, 19 (1979)); Nat'l R.R. Passenger Corp. v. Nat'l
Ass'n of R.R. Passengers, 414 U.S. 453, 458 (1974) ("[W]hen legislation expressly
provides a particular remedy or remedies, courts should not expand the
coverage of the statute to subsume other remedies."); McDonald v. Southern Farm
Bureau Life Ins. Co., 291 F.3d 718, 725 (11th Cir. 2002) ("When Congress creates
certain remedial procedures, we are, 'in the absence of strong indicia of contrary
congressional intent,
compelled to conclude that Congress provided precisely
the remedies it considered appropriate.") (quoting Karahalios, 489 U.S. at 533).
Because Petitioners seek remedies not authorized by the CVRA's plain language,
their requests should be denied.
What's more, the plain text is supported by the CVRA's location in the United
States Code. Specifically, the CVRA is found in Part II of Title 18, which is the
part of the United States Code specifically devoted to "Criminal Procedure." The
CVRA does not contemplate civil litigation, and the civil remedies that
Petitioners seek are simply unavailable under the CVRA. Doc. 147 at 15-19.
Instead of authorizing a victim to institute a civil action, the CVRA created a
specific victims-rights-enforcement scheme within the federal criminal justice
process - indeed, within Title 18 of the United States Code, which addresses
11
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"Crimes and Criminal Procedure." That rights-enforcement scheme is based on
the filing of a "motion asserting a victim's rights" - not a civil complaint or a civil
lawsuit. 18 U.S.C. $ 3771(d)(3); see Sieverding v. U.S. Dept. of Justice, 693 F. Supp.
2d 93, 110 (D.D.C. 2010) (recognizing that it is "only through a motion" that the
CVRA "permits" individuals to assert statutory rights arising under the CVRA,
such as the "right to confer" and "discuss
allegations of criminal acts and
[DOJ's] decisions to prosecute or not prosecute") (citing 18 U.S.C. $ 3771(d)(3));
see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA
contemplates that individuals asserting victim status may bring a motion in the
district court even when criminal proceedings are not ongoing, and that the
district court's denial of such a motion is reviewable by mandamus.") (citing 18
U.S.C. $ 3771(d)(3)); compare Fed. R. Civ. P.3 ("A civil action is commenced by
filing a complaint with the court."). Congress expressly recognized in enacting
the CVRA that the statute did not "[a]llow[] victims to vindicate their rights
through separate proceedings for damages instead of through mandamus actions
in the criminal case." 150 Cong. Rec. 7306 (2004) (statement of Sen. Patrick Leahy)
(expressing regret that the CVRA "den[ied] victims any cause of action for
damages in the event that their rights are violated"); 150 Cong. Rec. 7312
(statement of Sen. Orrin Hatch) ("For those who may be concerned that this bill
might lead to new tort causes of action, let me assure you, that victims are not
seeking to sue the government and get rich.
Accordingly, the bill states that
there will be no cause of action for damages.").
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The cases cited by Petitioners do not advance their efforts to expand the
CVRA into a civil remedial scheme allowing for civil equitable relief. Those cases
support the unremarkable proposition that courts generally have power to grant
appropriate relief for recognized civil causes of action, but, as previously
explained, there is no civil cause of action under the CVRA. And the case to
which they do cite, In re Dean, 527 F.3d 391 (5th Cir. 2008), is not applicable here.
Specifically, in In re Dean, a criminal charge was actually filed, and the case
involved a plea agreement that the court would have to accept or reject; here,
however, the NPA was never before this Court. Regardless, the Court in In re
Dean never opined on the types of equitable relief Petitioners seek here.
In addition, Petitioners identify no other federal statute under which they can
bring their claims for relief. Because the law does not provide Petitioners an
avenue for the relief they seek, this Court must find that it does not have the
authority to order the government to do as Petitioners ask, but may still accept
the government's proposed remedies.
3. Even if the CVRA Allows for Civil Relief, the Remedies Petitioners Seek
Go Well Beyond What Is Appropriate.
But even if the CVRA or some other statute allowed equitable relief, the
remedies that Petitioners seek go well beyond what equity allows.
A. Petitioners' request for partial rescission
Petitioners have repeatedly requested some form of rescission of the NPA, but
their submission on remedies is telling more for what they seek to preserve from
that agreement than what they seek to rescind. Specifically, Petitioners do not
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ask the Court to scrap the agreement in its entirety; instead, Petitioners request
that the Court leave in force all but three sentences of the agreement and stress
that they "are only seeking that these particular provisions be set aside." Doc.
458 at 13 n.5, 19.
Petitioners' effort to preserve almost the entirety of the NPA is
understandable because eliminating the complete agreement could harm many
of the very victims the CVRA was designed to protect. As the Court is well
aware, the NPA guaranteed a felony conviction and more than a year of
incarceration for Epstein, which he agreed not to appeal; required him to register
as a sex offender; provided for an attorney representative for victims, at Epstein's
expense; and gave victims the equivalent of uncontested restitution by
mandating that he waive his right to contest liability for victims who pursued a
claim for damages under 18 U.S.C. $ 2255. Doc. 48-5. Rescission could imperil
these penalties as well as the benefits and settlements obtained by the more than
dozen victims who invoked the NPA terms.
Petitioners attempt to avoid that outcome by asking the Court to spare
provisions of the NPA they like while excising portions they do not. Given the
potential harm that complete rescission would pose for many victims, the
government understands this proposal to be well-meaning. Indeed, the
government itself would benefit from partial rescission by reaping the
advantages arising from Epstein's concessions without having to abide by its
own commitments in the agreement. But partial rescission is not a proper
remedy in this action because it would harm certain victims, has no basis under
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the law,¹³ and would undermine the CVRA's purpose to encourage proper
treatment of victims.
i.
Partial rescission would pose harm to, and is contrary to the
desires of, certain victims.
Despite Petitioners' best intentions, partial rescission would pose a significant
risk of harm to certain victims, which must be considered in crafting an equitable
remedy. The Eleventh Circuit has admonished courts considering equitable
remedies to "bear in mind that a poorly crafted remedy may achieve justice for
one by working a substantial injustice on another." Walters v. City of Atlanta, 803
F.2d 1135, 1149 (11th Cir. 1986); see also Doll v. Brown, 75 F.3d 1200, 1205 (7th Cir.
1996) ("Of course the effect on innocent third parties is a factor to be taken
into account in the formulation of an equitable remedy"); Byron v. Clay, 867 F.2d
1049 (7th Cir. 1989) (noting that "equitable" relief "may have effects on third
parties
and so should not be entered without consideration of those effects").
13 For the reasons stated in the Government's prior filings, Docs. 119 & 147,
the Government respectfully maintains that rescission is not an authorized
remedy under the CVRA for the agreement in this matter. Petitioners'
submission highlights the problematic logic underpinning their request for any
form of rescission. Petitioners claim that the CVRA's limitations on efforts to "re-
open a plea" under 18 U.S.C. $ 3771(d)(5) do not apply here because rescission of
a non-prosecution agreement is not a request to re-open a plea, Doc. 458 at 9, but
the Court found that rescission of a non-prosecution agreement was authorized
under Section 3771(d)(5) precisely because re-opening a non-prosecution
agreement is akin to re-opening a plea. Doc. 189 at 7-9. Petitioners thus embrace
the Court's finding while contradicting its underlying reasoning, all in an effort
to avoid the consequences of their inability to fulfill all of the conditions on relief
outlined in Section 3771(d)(5). Petitioners cannot have it both ways.
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The government's recent effort to confer with victims has established that
eliminating the immunity provisions would benefit certain victims and harm
others. The government contacted all attorneys representing victims known to
the government at the time of the NPA, attempted to locate other victims known
at the time of the NPA, and conferred with additional victims who were not
known at the time of the NPA. Indeed, the government has repeatedly invited
Petitioners to confer with U.S. Attorney Pak in person "to share with [him]
directly their thoughts about how the government should handle every aspect of
this matter, both in civil and potential criminal proceedings." Letter from Byung
J. Pak to Paul G. Cassell (May 7, 2019), attached as Exhibit 1. This invitation
remains open. The government's efforts to speak with victims are ongoing, and it
will seek leave to make a supplemental filing summarizing the steps taken to
confer with victims and the victims' opinions on a proper remedy to ensure that
their diverse voices are heard.
Based on the conversations with victims to date, it is apparent that any form
of rescission would cause unintended harm to many of them. During these
discussions with victims and their representatives, several victims passionately
expressed their desire to see Epstein be prosecuted and were eager to serve as
witnesses in any investigation of Epstein. On the other hand, other victims
stated, through their counsel, that while they would like to see Epstein
prosecuted for his crimes, they valued anonymity above all and were not willing
to speak with law enforcement or otherwise participate in any criminal or civil
litigation due to the risk that their involvement may become known to family,
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friends, or the public. Several victims previously expressed, during the
investigation of Epstein, that they suffered emotional distress and were troubled
by the prospect of any involvement in the government's investigation. Doc. 403-
18 T 12. For these victims, setting aside the immunity provisions in a partial
rescission could only undermine their desire to stay anonymous more than ten
years after obtaining settlements from Epstein.
The passage of more than ten years since the NPA was entered only
compounds the potential harm to victims that would arise from partial
rescission. The Court is well aware of "Petitioners' counsel's initial 'indecision'
on whether to seek rescission, as expressed at an earlier hearing held in August
2008," Doc. 189 at 12 n.6, in which counsel stated that "because of the legal
consequences of invalidating the current agreement, it is likely not in my clients'
best interest to ask for the relief that we initially asked for." Doc. 403-21 at 4.
Petitioners' counsel told the Court in 2008 that "an immediate resolution was not
necessary, Doc. 99 at 4, and the CVRA case then "stalled" for eighteen months
"as petitioners pursued collateral civil claims against Epstein," resulting in the
CVRA case being administratively closed in late 2010.¹⁴ Doc. 189 at 5. Even if
rescission is a permissible remedy for certain violations of the CVRA, the more
than decade-long delay here renders this remedy inappropriate given these
14 For the reasons stated in its prior filings, Doc. 147 at 8-12; Doc. 401-2 at 28-
29, the government maintains that Petitioners should be estopped from seeking
any form of rescission based on this delay.
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unique circumstances and exacerbates the harm to victims who have attempted
to readjust their lives in the interim. 15
ii.
Partial rescission contravenes governing tenets of contract law.
In addition to the potential harm posed to innocent third parties, the law
unfortunately restricts the government's and Court's ability to rewrite the NPA a
decade later. It is not uncommon for one party to a contract to wish to rework or
eliminate terms after entering the agreement. But no matter how regrettable an
agreement may appear in hindsight, fundamental tenets of contract law prohibit
the rewriting of terms when the parties intended the agreement to be fulfilled in
its entirety. Such principles bind the government's hands in this case.
Although the parties agree that the NPA should be governed by principles of
contract law, Doc. 458 at 18, Petitioners cite no authority providing for partial
rescission of a prosecutorial agreement, including a non-prosecution agreement,
and ignore precedent foreclosing such a remedy when "the entire fulfillment of
the contract is contemplated by the parties as the basis of the arrangement." Local
No. 234 v. Henley & Beckwith, 66 So. 2d 818, 821 (Fla.1953); see also Frankenmuth
Mutual Ins. v. Escambia County, 289 F.3d 723, 728 (11th Cir. 2002) (interpreting
15 Although Petitioners' counsel have not spoken with the majority of the
victims, they acknowledge that certain victims would be eager for rescission
while
a
"large
group will respond by saying 'I have buried these experiences
deep in the past and I don't want to do anything at all to unearth all the hurt and
pain it has taken me this long to process."
Prosecutors finally want
to hear from Jeffrey Epstein's victims, MIAMI HERALD, 2019,
https://www.miamiherald.com/news/state/florida/article230275434.html (lasi
visited June 21, 2019).
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Florida law). Partial rescission of an agreement is "a remedy that is not generally
cognizable under Florida law except in the unusual circumstances where a
contract is clearly divisible." Galaxy Cable, Inc. v. Cablevision of Marion Cty., LLC,
No. 5:05-CV-303-OC-GRJ, 2006 WL 2265419, at *3 (M.D. Fla. Aug. 8, 2006). A
contract is considered to be "indivisible" when "each and all of its parts appear
to be interdependent and common to one another and to the consideration."
Local No. 234, 66 So. 2d at 822 (holding that contract was indivisible when "it is
impossible to conclude that the very significant promise on one side. can be
entirely eliminated from the contract and still leave a valid working arrangement
fairly reflecting the original mutual understanding between the parties"); see also
Wilderness Country Club Partnership v. Groves, 458 So. 2d 769, 771 (Fla. Dist. Ct.
App. 1984) (concluding that, despite the illegality of only one contract provision,
partial rescission was improper because illegal term was "vital," and severing
that term "eliminates the essence of the contracting parties' agreement"). Courts
determine whether an agreement is divisible based on the "intention of the
parties" as revealed "by a fair construction of the terms and provisions of the
contract itself, and by the subject matter to which it has reference." Local No. 234,
66 So. 2d at 822 (quotation marks omitted).
Here, excising the "immunity" or non-prosecution provisions plainly would
eliminate the essence of the "Non-Prosecution Agreement." The three sentences
that Petitioners seek to write out of the agreement are the only contractual
consideration that the government provided in exchange for Epstein's
concessions to a felony conviction, prison sentence, sex offender registration, and
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uncontested restitution settlements. Doc. 48-5. Moreover, the agreement
expressly states that its provisions were indivisible, noting that "each of these
terms is material to this agreement and is supported by independent
consideration," and a breach of any condition allowed the government to
terminate the entire agreement. Id. at 7. Accordingly, omitting the immunity
provisions "eliminates the essence of the contracting parties' agreement," and the
NPA is thus an indivisible agreement not subject to partial rescission. Wilderness
Country Club Partnership, 458 So. 2d at 771. Petitioners' request thus must be
denied as a matter of law.
Petitioners point to authority setting aside agreements containing illegal
provisions in support of their request, Doc. 458 at 15-17, but this argument is
meritless for two reasons. First, while Petitioners contend that the government
failed to accord victims their rights in communicating the terms of the NPA,
Petitioners have not identified any illegal provision in the NPA itself. Doc. 147 at
4-5. Petitioners cite no precedent authorizing the rescission of an agreement
containing legally valid terms based solely on an extrinsic violation in
communicating the terms of that agreement to a third party. Second, none of
Petitioners' cases authorizes partial rescission, the remedy they request here. 16
16 See United States v. Walker, 98 F.3d 944 (7th Cir. 1996) (holding that complete
rescission of plea agreement was only permissible remedy when defendant was
induced to enter plea based on mistake of law); Craig v. People, 986 P.2d 951, 966
(Colo. 1990) (noting that if plea was induced by illegal promise, proper remedy
was defendant's option to withdraw from plea agreement in its entirety); State v.
Garcia, 582 N.W.2d 879, 882 (Minn. 1998) (holding that if plea agreement could
not be fulfilled based on illegal term, only remedy was withdrawal from entire
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iii.
Partial rescission would reward, not remedy, a violation of the
CVRA.
Even if there were a legal basis for partial rescission, granting partial
rescission in this matter would have the perverse effect of harming certain
victims, who must be treated with "respect for [their] dignity and privacy" under
the CVRA, 18 U.S.C. $ 3771(a)(8), while rewarding the government for what the
Court determined was a violation of the CVRA. The parties appear to have
agreed for the purposes of this litigation that Epstein has fully performed his
obligations under the NPA. By eliminating the immunity provisions of the
agreement, Petitioners' proposal would thus allow the government to enjoy all
the benefits of Epstein's compliance without binding it to its commitments under
the NPA. Accordingly, Petitioners would place the government in a more
favorable position than if it had fully conferred with victims prior to entering the
NPA. Such a result would not encourage strict adherence to the CVRA, and
partial rescission in this case would not foster the goals of the CVRA.
B. Petitioners' request for declaratory relief
Petitioners also request that this Court declare that the Constitution permits
the government to prosecute Epstein in the event of rescission, but they cite no
legal basis for this request. Declaratory relief serves only to clarify the legal
relationship between the parties and does not serve to make factual
plea agreement); State v. Wall, 502 S.E.2d 585, 588 (N.C. 1998) (same); Ex parte
Rich, 194 S.W.3d 508, 515 (Tex. Crim. App. 2006) (same); State v. Mazzone, 572
S.E.2d 891, 897 (W.Va. 2002) ("[A] plea agreement which cannot be fulfilled
based upon legal impossibility must be vacated in its entirety.").
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determinations. See Medmarc Cas. Ins. Co. v. Pineiro & Byrd PLLC, 783 F. Supp. 2d
1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity
Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D. Fla. 2009); Eisenberg v. Standard Ins.
Co., No. 09-80199, 2009 WL 1809994, at *3 (S.D. Fla. June 25, 2009)). But that is
precisely what Petitioners seek here. Accordingly, Petitioners fail to allege a basis
on which declaratory relief would be appropriate.
C. Petitioners' request for injunctive relief
Next, Petitioners ask this Court to:
order the government to issue a letter of apology, Doc. 458 at 5, 22-23;
enjoin the government to make its "best efforts" to protect the victims'
rights and confer with the victims and give them accurate and timely
notice of future cases, id. at 5, 21;
order DOJ to provide training to the USAO-SDFL, id. at 6, 29;
order the government to meet with the victims, confer about the case, and
explain why it chose not to prosecute Epstein, id. at 5, 23;
hold a hearing where victims can be heard, id. at 5, 23-24; and
order that the government provide all information in its possession;
provide all grand jury materials; provide any information regarding FBI
Miami's investigation, including un-redacted 302s; provide all sealed
materials previously submitted for in camera review; and provide all
materials covered by its previously filed motions, id. at 5-6, 24-29.
As a threshold matter, Petitioners do not have standing to seek injunctive
relief. As the Supreme Court held in City of Los Angeles v. Lyons, 461 U.S. 95, 102-
03 (1983), "federal courts are without jurisdiction to entertain" claims for
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injunctive relief where a defendant points only to "past exposure to illegal
conduct," and does not show "a continuing, present adverse effect." But even if
Petitioners had standing to bring their request for injunctive relief, each request
fails.
With respect to Petitioners' request for a letter of apology, such a remedy is
not cognizable. In Woodruff v. Ohman, 29 F. App'x 337, 346 (6th Cir. 2002), the
Sixth Circuit held that the district court exceeded its equitable powers when it
ordered a party to apologize. In so holding, the court cited the Ninth Circuit,
which has recognized that courts "are not commissioned to run around getting
apologies," and reasoned that the law is not usually concerned with procuring
apologies to make morally right a legal wrong done to the plaintiff. Id. (quoting
McKee v. Turner, 491 F.2d 1106, 1107 (9th Cir. 1974)). And certainly, a court may
not order a defendant to speak in a manner that may contravene the beliefs the
defendant holds. See id.; see also Burkes v. Tranquilli, No. 08-474, 2008 WL 2682606,
at *4 (W.D. Pa. 2008) (citing Woodruff, 29 F. App'x at 346) ("Here, the district court
exceeded its equitable power when it ordered [defendant] to apologize.").
Petitioners' request that this Court order the government to use its "best
efforts" to comply with the CVRA and "confer" with the victims pursuant to the
CVRA asks the Court to order the government to follow the law.¹⁷ Such "obey-
the law" injunctions are "disfavored because they often run afoul of Rule 65(d)'s
17 Petitioners' request that the Court enjoin the government to confer with
Jane Doe 1 and 2 is particularly unnecessary and unjustified in light of the
government's standing invitation for them to do precisely that. See Exhibit 1.
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requirement that injunctions state their terms specifically and 'describe in
reasonable detail' the 'act or acts restrained or required." United States v. Askins
& Miller Orthopaedics, P.A., 924 F.3d 1348, 1361 (11th Cir. 2019) (quoting Fed. R.
Civ. P. 65(d)). Obey-the-law injunctions are proper only when the "statutory
terms are specific and the defendant clearly knows what conduct is prohibited or
required." Id. at 1362 (citing SEC v. v. Goble, 682 F.3d 934, 950 (11th Cir. 2012)).
Accordingly, such injunctions are permissible if they require parties to follow
statutory terms with "specific, objective criteria for compliance," Goble, 682 F.3d
at 951, or specify "numerous concrete actions for the defendants to take
well
beyond" what the law requires, Askins & Miller Orthopaedics, 924 F.3d at 1362.
Obey-the-law injunctions concerning statutes lacking specific terms, or that
require consultation with an "ever-changing judicial landscape" to interpret, do
not inform the defendant of what conduct is forbidden under Rule 65(d). Goble,
682 F.3d at 951-52 (noting that "in some instances an injunction which merely
tracks the language of the securities statutes and regulations will not clearly and
specifically describe permissible and impermissible conduct"). Here, a statute
requiring the government to make its "best efforts" to protect victims, 18 U.S.C.
$ 3771(c)(1), plainly does not provide "specific, objective criteria for compliance,"
Goble, 682 F.3d at 951. The requested obey-the-law injunction is thus both
unwarranted and in violation of Rule 65(d).
So too would any order requiring the government to conduct training. The
CVRA itself mandates that DOJ regulations "require a course of training for
employees
of the Department of Justice that fail to comply" with victim
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protections under federal law. 18 U.S.C. $ 3771(f)(2)(B). DOJ regulations do so. 28
C.F.R. $ 45.10(d). There is no need to require the government to do what it has
already undertaken to do, and prescribing the specific content or duration of
such training would contravene the constitutional doctrine of separation of
powers. Still, the government recognizes that training is always beneficial and
offers to do so, as explained above.
Next, Petitioners seek to meet with the government, attend a hearing, and
review all government documents as a way of putting themselves in the position
they would have been in had the government conferred with them before
entering into the NPA. See Doc. 458 at 23 (explaining that "[a] chance to discuss
this matter with Mr. Acosta to get answers about that and other related questions
will, Jane Doe 1 and 2 believe, provide the kind of information that they would
have received had the U.S. Attorney's Office properly conferred in a timely
fashion back in 2007"); id. at 24-25 ("If the Government had properly conferred
with the two Jane Does [t]hese events would have provided Jane Doe 1 and 2
with much more information about Epstein's criminal conspiracy and its scope
and operation," and "[s]ince one of the harms that flows from that illegality is the
loss of any chance to obtain information, the obvious remedy is to disclose that
information"). But the problem with Petitioners' requests is that they, if granted,
would place Petitioners in an entirely different position than the CVRA allows.
The law does not countenance such a result. See Feldkamp v. Long Bay Partners,
LLC, 773 F. Supp. 2d 1273, 1285 (M.D. Fla. 2011) (holding that an injured party
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=== Page 26 ===
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shall not be placed in a position "better than that which he would have occupied
had the contract been performed").
To begin, while the CVRA grants victims the right to "confer" with the
government, this means only that, and not necessarily that the government is
required to explain the "next steps" it intends to make or to share confidential
information, including grand jury materials or sensitive information from other
witnesses. Petitioners' request would intrude on the government's exercise of
prosecutorial discretion, which is expressly prohibited by the CVRA. 18 U.S.C.
$ 3771(d)(6). Moreover, such an order would violate, or fall perilously close to
violating, the separation-of-powers doctrine undergirding our democracy. It is
axiomatic that "federal district courts cannot order a United States Attorney to
conduct an investigation or to initiate a prosecution because it would violate the
doctrine of separation of powers." O'Connor v. Nevada, 507 F. Supp. 546, 549 (D.
Nev. 1981) (citing United States v. Cox, 342 F.2d 167, 171 (5th Cir. 1965) ("[T]he
attorney for the United States is an executive official of the Government, and
it is as an officer of the executive department that he exercises a discretion as to
whether or not there shall be a prosecution in a particular case
and courts are
not to interfere with the free exercise of the discretionary powers of the [United
States attorneys] in their control over criminal prosecutions."). The decision
whether to prosecute Epstein lies solely within the Executive Branch, and any
order today, by this Court, as to what the government must do in the future
would be wholly inappropriate.
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Nor does it mean that the government must give victims the discovery in the
criminal case. As one court has explained, the CVRA does "not authorize an
unbridled gallop to any and all information in the government's files." United
States v. Rubin, 558 F. Supp. 2d 411, 425 (E.D.N.Y. 2008); see also United States v.
Moussaoui, 483 F.3d 220, 235 (4th Cir. 2007) (noting that CVRA did not empower
district court in a civil matter to order disclosure of documents to victims); United
States V. Hunter, 548 F.3d 1308, 1317 (10th Cir. 2008) (holding "that the CVRA
does not provide 'victims' with a right of access to the government's files"); cf. In
re Siler, 571 F.3d 604, 609 (6th Cir. 2009) (holding that "the CVRA does not
provide an independent right to obtain PSRs"); Kenna v. United States, 453 F.3d
1136, 1137 (9th Cir. 2006) (affirming district court's rejection of victim's argument
that the CVRA conferred a general right for crime victims to obtain disclosure of
PSRs). The CVRA provides victims with rights associated with the defendant's
trial, such as notice of proceedings against the defendant, the right to be heard at
a proceeding, and the right to confer with the government's attorney, but is silent
as to documents offered during the trial. See In re Siler, 571 F.3d at 609-10.
Petitioners' argument that they are entitled to grand jury records similarly
fails. The traditional rule of grand jury secrecy may be set aside under certain
circumstances prescribed by Federal Rule of Criminal Procedure 6(e). The
Supreme Court has explained that a party seeking disclosure of grand jury
materials must make a showing of a "particularized need." United States v.
Aisenberg, 358 F.3d 1327, 1348 (11th Cir. 2004) (citing Douglas Oil Co. v. Petrol
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Stops Northwest, 441 U.S. 211, 222 (1979)). For the reasons previously found by the
Court, Petitioners have not, and cannot, make such a showing. Doc. 330 at 7-10.
In addition, the law enforcement investigative privilege protects the
documents Petitioners seek. The purpose of this privilege is "to prevent
disclosure of law enforcement techniques and procedures, to preserve the
confidentiality of sources, to protect witnesses and law enforcement personnel, to
safeguard the privacy of individuals involved in an investigation, and otherwise
to prevent interference with an investigation." In re Dep't of Investigation of the
City of New York, 856 F.2d 481, 482 (2nd Cir. 1988) (citations omitted). Disclosure
to third parties of the interview reports of the young women sexually abused by
Epstein could cause their identities to become widely known and result in their
harm or embarrassment. The disclosure of information contained in the FBI
investigative file to third parties could cause additional psychological trauma,
disruption of family relationships or professional careers, and possible public
release of personal information.18
The law enforcement investigative privilege is recognized under the Freedom
of Information Act (FOIA), 5 U.S.C. $ 552, which specifically exempts from
18 Disclosure of information from the FBI file would also reveal sensitive FBI
investigative and operational methods, procedures, and techniques. Information
contained within an FBI investigative file, if revealed, might compromise the
effective use of such methods in future cases. The FBI's investigative tools must
remain confidential so that law enforcement can retain an element of surprise
and prevent the use of countermeasures by targets and suspects to thwart
effective law enforcement.
28
EFTA00010569

=== Page 29 ===
Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 29 of 32
disclosure "records of information compiled for law enforcement purposes" that
"could reasonably be expected to constitute an unwarranted invasion of personal
privacy" or "would disclose techniques and procedures for law enforcement
investigations or prosecutions
" 5 U.S.C. $ 552(b)(7)(C) and (E). Certainly
Congress did not contemplate granting victims an end-run around the FOIA
disclosure exemptions when it drafted the CVRA.
D. Petitioners' request for monetary damages
Finally, Petitioners assert that they are entitled to "monetary sanctions,"
attorneys' fees, and restitution. As explained above, however, the CVRA
explicitly prohibits a cause of action for damages against the United States
arising from any violation of the CVRA. 18 U.S.C. $ 3771(d)(6). Attempting to
recast a claim for damages as monetary "sanctions" does not make it any less an
impermissible claim for damages.
Regarding restitution, Petitioners are entitled under the CVRA to "[t]he right
to full and timely restitution as provided in law." 18 U.S.C. $ 3771(a)(6). Congress
modified a crime victim's entitlement to restitution by restricting it to only those
circumstances "provided in law," thus recognizing that there would be
numerous situations when it would be impossible for a victim to receive
restitution. See In re W.R. Huff, 409 F.3d 555, 563 (2d Cir. 2005). The statute under
which Petitioners urge this Court to award restitution does not make the
government liable for restitution for harms caused by others. Calling something
"restitution" does not make it so. In reality, Petitioners seek money damages
from the government, and this they cannot do.
29
EFTA00010570

=== Page 30 ===
Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 30 of 32
With respect to attorneys' fees, the doctrine of sovereign immunity bars an
award of attorneys' fees against the United States unless there is express
statutory authorization for such an award. Joe v. United States, 772 F.2d 1535, 1536
(11th Cir. 1985). Waivers of sovereign immunity are to be strictly construed in
favor of the sovereign. Id. (citing United States v. Sherwood, 312 U.S. 584, 590
(1941)). The CVRA does not provide for attorneys' fees against the United States,
and thus Petitioners' argument that they are entitled to attorneys' fees must be
rejected.
CONCLUSION
Regardless of what the CVRA required the government to do in this matter,
the victims are right to expect better from their Justice Department. The
government's commitment in the decade since this action was filed to combat
human trafficking and child exploitation and protect victims of such offenses
underscores that its conduct in this matter, no matter how well-intentioned, fell
short of the government's dedication to serve victims to the best of its ability.
While the Court cannot unwind the past, the remedies proposed by the
government would give the victims a meaningful opportunity to have their
voices heard and to understand, if not accept, the decisions made in this matter.
Petitioners' requested remedies, on the other hand, run afoul of the remedial
scheme contemplated by the CVRA, are contrary to law, and may cause
unintended harm to the victims whose interests are also protected by the CVRA.
30
EFTA00010571

=== Page 31 ===
Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 31 of 32
For the foregoing reasons, the Court should endorse the government's proposed
remedies.
Respectfully submitted,
BYUNG J. PAK
United States Attorney
/s/
Special Attorney
Georgia Bar No.
/s/
Special Attorney
Georgia Bar No.
31
EFTA00010572

=== Page 32 ===
Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 32 of 32
Certificate of Service
I served this document today by filing it using the Court's CM/ ECF system,
which automatically notifies the parties and counsel of record.
June 24, 2019
/s/
Special Attorney
EFTA00010573


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=== Page 1 ===
From:
To:
Subject: updated draft for 1:00 call
Date: Wed, 20 May 2020 16:49:12 +0000
Attachments: 2020-05-19,_perjury_and_Farmer_supplement.docx
So we're all looking at the same thing.
EFTA00013457


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=== Page 1 ===
From:
)"
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Date: Tue, 05 Jan 2021 01:28:34 +0000
That would be great, thanks. Would Thursday at 11:30 work for you?
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Sure. Does Wednesday or Thursday morning work?
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Are you available for a call sometime in the next few weeks? We have one or two follow up questions
that would be helpful to talk through.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, December 30, 2020 2:37 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
EFTA00013279

=== Page 2 ===
Hi
Sorry about the delay. Interlochen doesn't have any other documents regarding tuition payment information or
payments by Epstein or Epstein entities.
Let me know if you have any other questions.
Thanks,
Jeff Jocks
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>, "
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
From:
Sent: Monday, November 16, 2020 3:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)
>;
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. I'm following up on our conversation from earlier this month to see if you have any updates on
the categories of documents we discussed.
Thanks very much,
EFTA00013280

=== Page 3 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 11:15 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
That works for me. I will call in at 10am Monday.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line:
Thanks,
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
EFTA00013281

=== Page 4 ===
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still
be grateful if you could get back to me on this point, please.
EFTA00013282

=== Page 5 ===
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com, "Donnini, George B." <donnini@butzel.com>
Cc:
)"
i
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
EFTA00013283

=== Page 6 ===
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would you
please confirm that your production included all records of any tuition payments that Epstein (or his entities) made for
any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow
and will have limited availability this week, but my colleagues
and
(both cc'd) should be
able to coordinate with you as needed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
Cc:
is
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
)"
EFTA00013284

=== Page 7 ===
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey Epstein
and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00013285


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=== Page 1 ===
From: "Weinstein, Marc A."
To:
Subject: FW: Epstein Estate
Date: Mon, 09 Nov 2020 21:25:45 +0000
Importance: Normal
Attachments: unnamed
Inline-Images: ATT90747_1.jpg
Original Appointment
From: Weinstein, Marc A.
Sent: Monday, November 9, 2020 10:35 AM
To: Weinstein, Marc A.;
Andrew Tomback
Subject: Epstein Estate
When: Monday, November 9, 2020 4:30 PM-5:00 PM (UTC-05:00) Eastern Time (US & Canada).
Where: Skype Meeting; Conference ID: 570 579 045;
HHR OnlineMeetingCenter
Dial-In Information (for meetings with no presentations or video)
Dial-In Number: +1 (201) 630-0824
Conference ID: 570579045
One touch dial-in from mobile phone (via cellular service)
Additional Dial-In Numbers
Brazil +55 11 3181-5692
Canada +1 647-749-1240
China +86 400 842 8305
France +33 1 73 24 04 53
Germany +49 69 667737017
India +91 22 6001 6148
Ireland +353 1 566 1143
Israel +972 3 3762055
Japan +81 3-4510-7259
Korea (Seoul) +82 70-7488-2208
Singapore +65 3157 0147
United Kingdom +44 20 3443 6288
United States +1 (201) 630-0824
Full list of dial-in numbers
Meetings with a presentation or video
Connect from computer or mobile device (via network/internet connection)
Help
Try Skype Web App if you are having trouble joining
Joining from a computer using the "Connect from computer or mobile device" link provides additional
capabilities, however you can simply call in from your telephone using the number provided above if your
meeting will not include video or a presentation. Click the "Help" link for additional information if you are a
guest joining a Skype for Business meeting from your computer or mobile device for the first time.
For meeting organizers: Reset your dial-in PIN?
EFTA00009914


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=== Page 1 ===
From:
To:
Subject: RE: Special Master's Selection of Attorney Representative
Date: Fri, 19 Oct 2007 20:04:05 +0000
Importance: Normal
- FYI -- The story of the lawsuit filed by the girl in New York has made the national news (it was on Fox News several
times today and it is on ABC News' website). I think that may be the real reason for the delay in the change of plea. Epstein's
group is concerned that the guilty plea will be used against him in civil suits and they want to knock that lawsuit out before the
guilty plea to deter others. One of the newspapers also reported that Epstein's camp had planted the false stories about girls
who "just sat in his kitchen" filing suit in an attempt to discredit the girls.
From:
Sent:
To:
Subject: RE: Special Master's Selection or Attorney Representative
l'll contact him but before I do we'll chat. Jay was supposed to send me his comments to our proposed letter but I haven't
gotten them yet.
From
Sent: Friday. October 19 2007 3:27 PM
To:
Subject: RE: Special Master's Selection of Attorney Representative
Will you contact him or do you want me to do that?
Thanks.
From:
Sent: Fri 10/19/2007 3:24 PM
To:
Subject: RE: Special Master's Selection of Attorney Representative
has not been contacted yet.
From:
Sent: Friday, October 19, 2007 2:58 PM
To:
Subject: Special Master's Selection of Attorney Representative
Hi
Has the special master made his selection yet? Several of the girls are getting calls from attorneys, and they
have been seeing all the news and are concerned. If the selection has not yet been made, may I call Judge Davis and ask
the status of the decision?
Thank you.
EFTA00013618


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=== Page 1 ===
Event: 3:30 Epstein Conference Call
Start Date: 2008-01-07 20:30:00 +0000
End Date: 2008-01-07 21:30:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2015-04-04 00:21:50 +0000
Date Modified: 2015-07-22 20:34:55 +0000
Priority: 5
EFTA00013481


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=== Page 1 ===
From:
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To: "Acosta, Alex (USAFLS)"
Subject: FW: Epstein
Date: Tue, 16 Oct 2007 21:27:55 +0000
Importance: Normal
fyi
From:
(USAFLS)
Sent: Tuesday, October 16, 2007 5:16 PM
To:
(USAFLS)
Subject: RE: Epstein
Hi
- This looks perfect. Thank you for all of the time that you spent on this.
Assistant U.S. Attorney
Fax 561 820-8777
From:
(USAFLS)
Sent: Tuesday, October 16, 2007 3:51 PM
To:
(USAFLS)
Subject: RE: Epstein
,
Here's our version that we plan to send to Lefkowitz. Alex and I have read your proposed
letter to Judge Davis and other than parts of the last paragraph concerning "consulting with
the victims", it looks good.
1. The United States has the right to assign to an independent third-party the responsibility
for consulting with and, subject to the good faith approval of Epstein's counsel, selecting
the attorney representative for the individuals identified under the Agreement. If the United
States elects to assign this responsibility to an independent third-party, both the United
States and Epstein retain the right to make good faith objections to the attorney
representative suggested by the independent third-party prior to the final designation of the
attorney representative.
2. The parties will jointly prepare a short written submission to the independent third-party
regarding the role of the attorney representative and regarding Epstein's Agreement to pay
such attorney representative his or her regular customary hourly rate for representing such
victims subject to the provisions of paragraph 3, infra.
3. Pursuant to additional paragraph 1, Epstein has agreed to pay the fees of the attorney
representative selected by the independent third party. This provision, however, shall not
obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if
EFTA00013747

=== Page 2 ===
after consideration of potential settlements, an attorney representative elects to file a
contested lawsuit pursuant to 18 U.S.C. S 2255 or elects to pursue any other contested remedy,
the paragraph 7 obligation of the Agreement to pay the costs of the attorney representative,
as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs
such as those contained in S 2255 to bear the costs of the attorney representative, shall
cease.
From:
. (USAFLS)
Sent: Monday, October 15, 2007 9:38 AM
To:
(USAFLS)
Subject: Epstein
Hi
- I have prepared this as a letter from you to Judge Davis. I am going to call
to see if we have
nailed down the final number of victims so that you can include the information in the letter. You can get me on
my cell phone.
Thank you!
File: 071015 Special Master Letter.wpd
>>
Assistant U.S. Attorney
Fax 561 820-8777
EFTA00013748


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=== Page 1 ===
From:
(USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=
To: "Jay Lefkowitz"
Cc: "Acosta, Alex (USAFLS)"
(USAFLS)"
Subject: Epstein
Date: Mon, 22 Oct 2007 20:40:35 +0000
Importance: Normal
Attachments: 071015_Special_Master_Letter3.wpd; Addendum.wpd
Jay,
The Judge Davis issue is a non-starter. We've beaten that horse to death. Regarding your contention that "the attorney
representative be told clearly that Mr. Epstein has agreed to pay the lawyer's hourly rate only for the time he or she spends
working to effectuate settlements for the identified women," Alex and I agree that paragraph 7C is sufficient, Regarding the
other points, we have made the following concessions:
1. Regarding the language concerning a lawyer whose firm is sizeable enough to litigate multiple trials simultaneously, I
have removed paragraph 4 on page 3 of the letter.
2. Regarding the 150k statutory limit language, I have included a footnote which should satisfy your concern.
3. Regarding language there may be discovery to test the claims of alleged "victims", please see new paragraph 4 on
page 3 which now states as criteria that the firm should have "Experience litigating against large law firms and high profile
attorneys who may test the veracity of the victims' claims."
I have attached the Addendum and the revised letter to Judge Davis. Jay, this needs to be concluded. Alex and I believe
that this is as far as we can go. Therefore, please advise me whether we have a deal no later than COB tomorrow,
Tuesday, October 23, 2007. Thanks,
Original Message
From: Jay Lefkowitz [mailto:
Sent: Friday, October 19, 2007 4:05 PM
To:
(USAFLS)
Subject: Re:
-
I have reviewed your proposed language and wanted to raise a few areas of concern.
First, I am not sure why we are not just asking Judge Davis to represent these women. If he is available, that would save
us a whole additional layer of process. I had thought that was initially the idea. I am not sure why you seem to be moving
in another direction.
I also cannot understand why the draft affirmatively requests that J Davis select a lawyer whose firm is sizeable enough to
litigate multiple trials simultaneously. That seems to be directly at odds with the purpose of the agreement, which is to
facilitate out of court settlements. Indeed, to the extent any woman were to elect to bring an action against Mr. Epstein,
she would not only be free to select any lawyer of her choice, but would be restricted from using the lawyer representative
in this capacity due to the conflicts of interests that would cause. This part of your proposed language is of signficiant
concern to me.
Your letter also indicates the 150k statutory limit without reference to the pre-existing 50G limit. To be sure, any of the
women are free to seek whatever settlement they want, but given the question that exists about the statutory amount, the
letter should not state definitely that it will be 150k.
EFTA00013508

=== Page 2 ===
In addition, you have omitted a few important items from your proposal. Given that Judge Davis or any other potential
attorney representative should understand the scope of the work, the language should make clear that there may be
discovery to test the claims of alleged "victims."
Finally, I think it is important that the attorney representative be told clearly that Mr. Epstein has agreed to pay the lawyer's
hourly rate only for the time he or she spends working to effectuate settlements for the identified women.
Jay
Original Message
From:
(USAFLS)"
Sent: 10/17/2007 01:58 PM AST
To: Jay Lefkowitz
Subject: RE:
<<071015 Special Master Letter2.wpd>> Jay,
Here's our proposed letter to the special master.
Original Message
From: Jay Lefkowitz [mailto:
Sent: Tuesday, October 16, 2007 9:26 AM
To:
(USAFLS)
Subject:
- is there a time today we can speak?
How about 430 pm?
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
EFTA00013509

=== Page 3 ===
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=== Page 1 ===
U.S. Department of Justice
Federal Bureau of Prisons
ATTORNEY'S GUIDE TO THE
METROPOLITAN CORRECTIONAL
CENTER
NEW YORK, NEW YORK
* BUREAU OF OF JUSTICE: R SNOSIS *
APRIL 2008
EFTA00009676

=== Page 2 ===
TABLE OF CONTENTS
I.
INTRODUCTION
1
A.
Address
1
B.
Telephone Numbers
1
C.
Bureau of Prisons' Web Address
2
II.
PRETRIAL DETENTION
3
A.
Legal Visiting
3
1. Visiting Hours
3
2. Attorney Processing
4
3. Identification
4
4. Property Brought Into the Visiting Room
5
5. Private Conference Rooms
6
6. Multiple Client Visits
6
7. Dress Code
7
8. Legal Representatives
7
9. Polygraphs
8
10. Depositions
8
11. Separation Assignment/Co-Defendant: Meetings
9
12. Foreign Attorneys
10
13. Social Visiting
10
B.
Telephone Calls
10
1. Unmonitored Telephone Calls
10
2. Inmate Telephone System (ITS)
11
3. Emergency Telephone Calls
12
C.
Legal Mail
12
1. Legal Mail Envelopes
12
2. Legal Mail Packages
13
3. FedEx and UPS
13
4. Stamps
13
5. Court Clothing
14
6. Mail for Multiple Defendants
14
D.
Release of Records/Information
14
1. Subpoenas
14
2. Medical Records
15
E
Inmate Legal Activities
15
1. Law Library
15
2. Access to Computerized Discovery Materials
16
3 Leisure Library
16
4. Service of Process
16
F.
Administrative Remedy Program
17
G.
Inmate Designations
18
Court Ordered Studies
19
H.
Health Services
19
1. Sick Call
19
2. Emergency Care
19
3. Medication
19
4. Independent Medical Exams
20
5. Visits with Inmates in Hospital
20
I.
Special Housing Unit
20
J.
Miscellaneous
21
1. Religious Programs
21
2. Food Service
21
3. Inmate Commissary
21
4. Marriage
22
5. Personal Property
22
6. Admission and Orientation Handbook
22
ATTACHMENTS
Attachment A-Application to Enter Institution as Representative Form
Attachment B-National Crime Information Center Form
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=== Page 3 ===
I. INTRODUCTION
The Metropolitan Correctional Center, in New York, New York (MCC
New York), is owned and operated by the Federal Bureau of Prisons
(Bureau), an agency of the United States (U.S.) Department of
Justice. The primary mission of MCC New York is to serve federal
courts in the Southern and Eastern Districts of New York by
providing pretrial detention in conjunction with the U.S.
Marshals Service (USMS).
This guide outlines the relevant policies and procedures
applicable to attorneys representing defendants incarcerated at
MCC New York. The procedures cover issues such as legal
visiting, attorney-client communication, and release of
information.
A. Address
1.
Mailing address
Staff:
Inmates:
Staff Name and Title
Inmate Name and Reg. No.
MCC New York
MCC New York
Metropolitan Correctional
Metropolitan Correctional
Center
Center
150 Park Row
150 Park Row
New York, NY 10007
New York, NY 10007
B. Telephone Numbers
1.
MCC New York
Main Number
(646) 836-6300
2.
Legal Department
Because all calls must be cleared through the Control Center for
security purposes, direct extensions are not allowed to be
disseminated. The legal department is comprised of two staff
attorneys and an administrative assistant.
Legal Dept. Fax No.
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=== Page 4 ===
C. Bureau of Prisons' Web Address
The web address is http://www.bop.gov. You can access the Inmate
Locator, Bureau Program Statements, and procedures for requesting
documents under the Freedom of Information Act.
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=== Page 5 ===
II. PRETRIAL DETENTION
MCC New York staff are aware of the importance of the
institution's pretrial detention mission. MCC New York staff
are expected to act in a professional manner and are governed by
a code of employee conduct. Attorneys who feel that they have
been treated unprofessionally by a staff member are asked to put
their complaint in writing to the Warden's Office, MCC New York,
150 Park Row, New York, NY 10007. All complaints will be looked
into and appropriate action will be taken if necessary.
In turn, our staff appreciate the professionalism and courtesy
expected from attorneys and other officers of the court.
Attorneys are expected not only to abide by the Attorney Guide,
but generally to act in a professional manner. In addition, all
visitors are expected to refrain from using profanity and keep
their voices at a conversational level when speaking with staff,
inmates and other visitors. All visitors, including attorneys,
are prohibited from using cell phones within the institution,
including the lobby.
All visitors, including attorneys, who violate MCC New York's
visiting rules, create disturbances at the institution or in any
way jeopardize the security or orderly operation of the
institution may have their visiting privileges restricted or
suspended.
The information contained in this Guide is meant to be a general
guideline and is not all-inclusive. We cannot envision every
circumstance that could occur, and thus the Guide does not
contain the answers to all questions. For example, in the event
of an institution emergency, security needs of the institution
will override any portion of this Attorney Guide.
A. Legal Visiting
1.
Visiting Hours
Legal visitation hours are as follows:
Monday-Sunday (including Federal Holidays) 8:00 a.m. - 7:00
p.m.
Visits during these hours do not need to be scheduled in advance.
Special legal visits outside of these hours may be requested
through MCC New York's Legal Department with at least 24 hours
notice (The Legal Department is open Monday-Friday 7:30 a.m.-
4:00 p.m. so a request for Monday must be in by the preceding
Friday). Requests should be faxed to: "
, Attn:
Legal Department." Every effort will be made to accommodate
such requests, but final approval is contingent upon the
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=== Page 6 ===
availability of staff. In the event an attorney requires an
emergency visit outside normal legal visiting hours and has not
pre-requested it, he/she must contact the Operations Lieutenant.
If there is any problem with a legal visit during off duty hours,
attorneys should ask to speak with the Institution Duty Officer
or Operations Lieutenant.
2. Attorney Processing
MCC New York conducts a daily count of all inmates at 4:00 p.m.,
with an additional count at 10:00 a.m. on Saturdays, Sundays and
federal holidays. Additional unscheduled counts may also occur
in emergencies. During a count, inmates must be at their
assigned cell or bunk, unless the inmate has been authorized to
be in another area. In order to guarantee an accurate count, a
request that an inmate remain in the visiting room during the
count must be made at least one hour before the count, i.e.,
3:00 p.m. for the 4:00 p.m. count and 9:00 a.m. for the 10:00
a.m. count. When this approval is granted, the inmate is placed
on the "out count" and will be required to remain in the
visiting room until the count has been completed. Inmates who
have not been placed on the out count must terminate their legal
visits a half hour before the count begins, i.e., 3:30 p.m. and
9:30 a.m. Attorneys who arrive at the institution within an
hour before the start of a count, i.e., after 3:00 p.m. or 9:00
a.m., will not be able to visit their client until after the
count clears.
Counts usually take approximately 30-40 minutes to clear. During
this time, all movement in the institution ceases. Consequently,
attorneys and/or their representatives will not be allowed to
enter or exit the Visiting Room during official counts. Visits
should be scheduled accordingly to avoid unnecessary delays.
3. Identification
To receive attorney entrance privileges, an individual must be
able to establish his or her status as an attorney by presenting
identification that verifies active membership in any state bar.
Excluding Legal Aid Society Federal Defender's, NY State
Attorneys are required to have a Secure Pass Identification card
for entrance. Upon notification that a NY State attorney is not
in possession of a Secure Pass, and upon approval from the Legal
Department, attorneys will be permitted to enter the institution
for 60 days from their date of approval without the Secure Pass.
If an attorney is licensed in a state other than New York,
he/she must contact the legal department at least 24 hours in
advance so that their status as an attorney in good standing may
be verified. Provided the Legal Department can verify the
attorney's status, the attorney will be added on a list located
in the lobby, authorizing the attorney's entrance for a one year
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=== Page 7 ===
period with government issued picture identification, such as a
drivers license. It is ultimately the attorney's responsibility
to establish his or her membership in a State Bar.
After completing the Notification to Visitor form, attorneys must
be processed through the metal detector, have their hand stamped
and sign the bound logbook before being allowed entry into the
institution. By signing the Notification to Visitor forms,
attorneys certify that they are not carrying firearms,
explosives, weapons, ammunition, metal cutting tools, recording
equipment, cellular phones, cameras, food items, narcotics,
marijuana, alcoholic beverages, prescription drugs or any other
item deemed contraband. All legal materials and briefcases will
be searched for contraband and processed through the fluoroscope.
Handbags, newspapers, portable telephones, and non-legal
materials are not permitted in the Visiting Room.
Official Visitors: Federal employees, including Assistant U.S.
Attorneys, law enforcement officers, U.S. Court officials, U.S.
Probation Officers, and Assistant Federal Public Defenders, will
be permitted to visit upon presentation of appropriate
identification. All visitors must present official
identification, sign in and out of the logbook, and pass through
the metal detector.
4.
Property Brought into the Visiting Room
Legal Material
An attorney may bring into the visiting room legal materials
related to an inmate's case, including CDs, or audio/videotapes
as well as dollar bills for the vending machines. An attorney
(not a paralegal, investigator, mitigation specialist or
interpreter) will be authorized to provide a reasonable (not
to exceed four inches) amount of legal materials to the inmate at
the conclusion of the attorney visit. The inmate will be allowed
to take these legal materials with him/her to his/her unit after
the Officer determines the items are of a legal nature and he/she
inspects them for contraband. Legal materials should not be read
for content but examined only to determine that they are indeed
legal materials and they are free of contraband. Inmates housed
in the Special Housing Unit (SHU) will be allowed to take legal
materials to their unit minus folders, paperclips, staples,
rubber bands, or any other items that could be
considered a security concern. All other materials, including
cellular phones, pagers, newspapers, magazines, tissues, wallets
and keys, are prohibited and must be secured in a lobby locker
before entering the secure confines of the institution.
Additionally, legal videos, CDs and audio tapes, cannot be
provided to an inmate during a legal visit but may be placed in
the Lobby legal mail drop box for delivery to the inmate. Mail
deposited in these boxes must be small enough to fit through the
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=== Page 8 ===
opening of the box. Larger packages may be broken down into
several smaller envelopes. These boxes are emptied Monday-
Friday, excluding federal holidays, and the contents are
processed with other mail received from the post office that
day. Envelopes must be clearly marked with the attorney's name
(including language that identifies that person as an attorney),
inmate's name and register number and the following statement:
"SPECIAL MAIL-OPEN ONLY IN THE PRESENCE OF THE INMATE." See
below, page 12. Unauthorized items found in the inmate's
possession will be treated as contraband.
Tape Players, VCRs & Computers to Review Discovery Material
Due to security concerns, attorneys may not bring electronic
equipment into the secure confines of the institution. However,
MCC New York has tape players, VCRs and televisions for
attorneys to review discovery materials with clients in visiting
rooms. These items are available on a first come, first served
basis by oral request to the visiting room officer.
MCC New York also has a computer that attorneys may use to
review computer CDs with their clients. The computer is
available during attorney visiting hours and should be reserved
at least 24 hours in advance by calling the Legal Department.
Attorneys who make an appointment to use the computer will have
preference over those who do not make an appointment. Attorneys
should bring a copy of the CD discovery when meeting with an
inmate.
Audio and video cassettes and CDs may also be mailed directly to
an inmate via the legal mail procedures explained below in the
Legal Mail section, C1. Inmates may review their DVD and CD-Rom
discovery material as described in the Law Library Section, E1.
5.
Private Conference Rooms
These rooms are available on a first come, first served basis.
There are twelve conference rooms in the building. Institutional
security and fire safety regulations restrict the total number
of people that may be in the visiting room at any one time.
Ultimately, it is a correctional decision where any visit will
take place.
6.
Multiple Client Visits
Attorneys are not limited in the number of inmates they may
visit in one day. However, only one inmate may be brought down
to the visiting room at any time. Please see below in
Separation/Codefendant Meeting Section 11 for instruction on Co-
Defendant Meetings. When an attorney has finished the legal
visit and the inmate has been sent back to the unit, another
inmate may be brought down to the visiting room.
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=== Page 9 ===
Approved legal representatives (law clerk, paralegal,
interpreter, investigator, psychologist, and other experts) may
accompany an attorney into the Visiting Room. If visiting
independently, representatives must follow the requirements set
forth in the "Legal Representatives" section below. See Section
8.
Attorneys are ordinarily not permitted to bring material
witnesses into the Visiting Room. Prior approval to do so must
be received from the Warden and requires a court order. Written
requests for such approval should clearly outline the specific
circumstances requiring this type of visit. Visits will not be
approved if alternative arrangements are available to defense
counsel.
7.
Dress Code
All visitors, including attorneys, are required to dress in a
manner appropriate for a correctional environment. Excessively
provocative, immodest or revealing attire is reason to deny
visiting. Visitors over the age of 12 will not be allowed into
the institution in short skirts, mini skirts, shorts or dresses
exceeding three inches above the kneecap in length. See-through
clothing, halter-tops, tube tops, tank tops, any top that
reveals the midriff area, low-cut shirts or blouses, revealing
front and/or backless clothing, skin-tight clothing, spandex
clothing and sweat pants are not allowed. Furthermore, clothing
which may impede identification (e.g., hoods) or easily hide
contraband (e.g., coats) present security concerns and are also
prohibited. All visitors are required to wear shoes (no shower
shoes, flip-flops, toe-revealing or backless shoes of any kind)
and undergarments (including bras for females). The Warden has
delegated to the Institution Duty Officer the ultimate decision-
making authority regarding what attire is appropriate inside the
Visiting Room. If the Duty Officer is not available, the
Operations Lieutenant will make the final decision. A
memorandum containing clothing guidelines is posted in the lobby
of MCC New York. It is the responsibility of visitors to
familiarize themselves with this memo and watch for updates.
8.
Legal Representatives
Attorneys are allowed to visit their clients upon providing
evidence of their professional status. However, attorneys often
need other individuals, e.g., paralegals, interpreters,
mitigation specialists, private investigators, to visit their
clients in connection with legal representation. These
individuals do not receive the same entry privileges granted to
attorneys and must first submit an application (See ATTACHMENT
A) signed by a sponsoring attorney and pass a background check
before being granted permission to enter MCC New York.
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=== Page 10 ===
Once approved, the individual will be included on a list
maintained in the lobby and allowed to enter the institution for
one year with appropriate government issued ID. The entry
application may be requested from and mailed to the Legal
Departments of either MCC New York or MDC Brooklyn. Once
approved the individual may enter both institutions.
For mitigation specialists, every time they visit the
institution for a new inmate, they must submit a court order to
the Legal Department which authorizes them to enter the
institution to visit with that specific inmate. Upon reapplying
at the end of their one year entry period, mitigation
specialists and doctors are required to produce a new order,
reflecting the new year.
9.
Polygraphs
The Warden may permit polygraph tests in connection with state or
federal criminal felony investigations. See 28 C.F.R. $551.71.
Polygraph tests in connection with misdemeanor offenses, civil
proceedings, or any other matters are generally disapproved,
absent a federal court order. See Id. Requests for polygraph
examinations must be submitted to the Legal Department with
approval by the Warden. The written request should include at
least the following information:
(1) Inmate's name and register number;
(2) Case caption, case number and nature of matter;
(3) Requested date and time;
(4) Expected length of polygraph;
(5) Name, title, and organization of each person
attending (all non-attorneys and non-legal
representatives will have to fill out an application so
MCC can complete a background check (See ATTACHMENT B);
(6) List of all equipment to be used; and
(7) Indication of whether the inmate's consent has been
obtained.
The Warden must be able to confirm the validity of the request
and the inmate being examined must give written consent on a form
provided for that purpose. Requesters are responsible for
meeting all state and local requirements in administering the
test.
10. Depositions
Requests for Depositions for state matters, both civil and
criminal, must be submitted to the Legal Department for review.
All deposition requests must be made in writing and include the
following information:
(1) Inmate's name and register number;
(2) A court order or similar court signed document for the
Page 8 of 22
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=== Page 11 ===
deposition;
(3) Case caption, case number and nature of matter;
(4) Requested date and time;
(5) Expected length of deposition;
(6) Name, title, and organization of each person attending
(all non-attorneys and non-legal representatives must
fill out an application so MCC can complete a
background check (See Attachment B) ) ;
(7) List of all equipment to be used; and
(8) Indication of whether the inmate's consent has been
obtained.
Video or tape recorders are not allowed inside the institution.
Furthermore, all equipment is subject to inspection prior to
entering the institution.
11. Separation Assignments/Co-Defendant Meetings
Co-defendant meetings must be requested at least 24 hours in
advance of the meeting, e.g. for a meeting on Tuesday at 2:00
P.M., the request must be submitted by Monday at 2:00 P.M.
Written requests should be faxed to the MCC New York Legal
Department,
, and should include the names of
everyone attending the meeting, including, but not limited to,
attorneys, paralegals, interpreters, investigators, co-defendants
on bail and co-defendants at MCC New York. Please indicate which
attorney represents each inmate. Also, please include with the
request a copy of the first page of the indictment showing that
the requested parties are co-defendants. This must be provided
every time a meeting is requested.
Separation Orders: An inmate with a "separation order" is
prohibited from coming in contact with the inmate from whom he or
she is separated. Such a restriction would normally prevent a
co-defendant meeting. Ordinarily, the request can be
accommodated if the AUSA who placed the separation order notifies
the institution that the separation does not apply to co-
defendant meetings. However, if the inmates have been separated
due to security concerns, whether based on information developed
by an outside agency or the Bureau of Prisons, MCC has the
discretion to not allow the meeting. Attorneys who are aware of
separation orders between co-defendants should include with their
request the name and phone number of the AUSA assigned to the
case in question. These requests should be made as far in
advance as possible, as the meeting will not be scheduled if the
responsible Assistant United States Attorney cannot be contacted.
For co-defendant meetings that involve one or more inmates from
MCC New York and one or more inmates from MDC Brooklyn, it is the
responsibility of the defense attorney to contact the responsible
Assistant United States Attorney, who will, in turn, contact the
USMS to arrange transportation of the inmate. The Bureau of
Prisons does not transport inmates for co-defendant meetings.
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=== Page 12 ===
The request for the meeting should be sent to both MCC and MDC
Legal Departments. MDC Brooklyn's Legal Department fax number is
(718) 840-4250.
12. Foreign Attorneys
Attorneys who are not licensed in a state or jurisdiction of the
United States must provide verification of their status as a
licensed attorney in good standing in a foreign jurisdiction,
prior to their initial visit. Foreign attorneys should contact
their respective Consulate Office, who will provide the attorney
official documentation (raised seal for most countries) stating
that the individual is in fact an attorney in good standing in
that country. The attorney must provide to the MCC New York
Legal Department, the original letter from his or her consulate
verifying the foreign attorney's status as a licensed attorney
in good standing. Once the status of the foreign attorney has
been confirmed, that attorney will be processed as a legal
visitor for future visits for one year only. The attorney may
request to be placed on the list on an annual basis by following
the above described procedure.
13. Social Visitors
See www.bop.gov, MCC New York Visiting Regulations.
B. Telephone Calls
1.
Unmonitored Telephone Calls
Inmates may place unmonitored telephone calls to their attorneys.
See 28 C.F.R. $540.105; and Program Statement 5264.07, Sec.8,
Telephone Regulations for Inmates. All housing units, excluding
Special Housing Unit (SHU), have access to unmonitored telephones
with a direct connection to the SDNY Federal Public Defenders'
Office. Some units also have unmonitored telephones with a
direct connection to the EDNY Federal Public Defenders' Office.
If the inmate's attorney cannot be contacted on the provided
telephones, the inmate must specifically request Unit Team staff
assistance in writing. The Unit Team staff will review the
request, and if approved, the call may be placed from the Unit
Team's unmonitored telephones. In order to receive an
unmonitored attorney call, the inmate or the inmate's attorney
must request Unit Team approval, demonstrating that other
correspondence, visiting, and normal telephone use is inadequate.
Inmate requests for unmonitored attorney calls are carefully
reviewed insofar as important Bureau interests are not affected.
Frequent unmonitored telephone calls increase an inmate's
opportunity to pursue illegal activities without detection.
Additionally, staff time and attention is unfairly focused on the
single inmate receiving numerous unmonitored telephone calls at
the expense of the many other inmates on a caseload.
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=== Page 13 ===
An attorney may not call an inmate. Attorneys who need to speak
with an inmate and do not anticipate that the inmate will call
them must visit the inmate in person or contact the inmate by
letter. Similarly, attorneys may not fax documents to inmates
or to MCC New York staff for delivery to inmates.
2. Inmates Telephone System (ITS)
The Bureau of Prisons extends telephone privileges to inmates as
part of its overall correctional management strategy. See 28
C.F.R. $540.100, et seq., Subpart I - Telephone Regulations for
Inmate; and Program Statement 5264.07, Telephone Regulations for
Inmates. Telephone privileges are a supplemental means of
maintaining community and family ties that may contribute to an
inmate's personal development. An inmate may request to call a
person of his or her choice outside the institution on a
telephone provided for that purpose. However, limitations and
conditions may be imposed upon an inmate's telephone privileges
to ensure adherence to other aspects of the Bureau's correctional
management responsibilities. In addition to the procedures set
forth in this subpart, inmate telephone use is subject to those
limitations which the Warden determines are necessary to ensure
the security or good order, including discipline, of the
institution or to protect the public. Restrictions on inmate
telephone use may also be imposed as a disciplinary sanction.
See 28 C.F.R. Part 541.
Inmates must submit a list of numbers they wish to be placed on
their approved telephone list. Inmates can only call numbers
placed on their approved telephone list. Once an inmate submits
the initial list, it will be processed as soon as possible.
Inmates may submit additional telephone numbers once they are
assigned a Correctional Counselor or Case Manager from the Unit
Team.
Inmates are advised of the institution's telephone monitoring
capability. See 28 C.F.R. $540.102. A notice is posted next to
each inmate telephone advising that calls are monitored.
Ordinarily, calls are paid for by the inmate, but in some cases
the receiving party pays. See 28 C.F.R. $540.105. Third party,
conference calls or use of two phones on the same number, or
other alternative call arrangements are not permitted, thus
limiting the opportunity for inmates to use the phones for
criminal or other inappropriate purposes. Inmates who use the
telephone improperly are subject to disciplinary actions which
may result in the loss of telephone privileges, and in some cases
criminal charges.
Inmates may place attorneys on their approved telephone list.
However, the calls are recorded and subject to monitoring. Such
calls are not attorney-client privileged calls. Inmates seeking
attorney-client privileged calls must request an unmonitored
telephone call as described above in section B(1).
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=== Page 14 ===
3.
Emergency Telephone Calls
Inmates requiring an emergency social phone call due to a death
or serious illness of an immediate family member shall submit a
request to the Religious Services Department. Likewise, if an
individual needs to contact an inmate for these reasons, they
should call the main number and ask to speak to the Religious
Services Department.
C. Legal Mail
All legal mail must be addressed to the inmate. All mail
addressed to staff on behalf of an inmate will be returned to
sender. Inmates may not receive documents via facsimile.
1.
Legal Mail Envelopes:
The Bureau has established procedures by which an inmate may
receive confidential legal mail. See 28 C.F.R. $ 540.18; and
Bureau of Prisons Program Statement 5800.10, Mail Management
Manual ("PS 5800.10") The Code of Federal Regulations provides
that special mail, which may only be opened in the presence of
the inmate, will be treated as such "if the sender is adequately
identified on the envelope, and the front of the envelope is
marked 'Special Mail - Open only in the presence of the
inmate. 28 C.F.R. $ 540.18 (a). However, the presence of a
return address with a firm name does not sufficiently identify
the sender of the material as an attorney.
Specifically, the attorney must be adequately
identified on the envelope as an attorney
The
use of the title "Esquire" without additional
indication of the sender's occupation does not
establish the bearer as an attorney or legal aid
supervisor. Mail from individuals using the title
"Esquire" as the exclusive identification of their
status shall not be handled as special mail, even if
the envelope contains some special mail markings.
P.S. 5800.10, Ch. 3, p.5. To maintain consistent handling of
legal mail, strict compliance with these procedures will be
enforced by MCC New York mail room staff. To properly identify
legal mail, counsel must write their name (not just the firm's
name) and their legal status (i.e., attorney), in the return
address portion of the envelope. This information, in addition
to writing elsewhere on the envelope "Special Mail - Open only
in presence of inmate," will ensure that legal mail is treated
as confidential attorney-client communication.
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=== Page 15 ===
2.
Legal Mail Packages:
Bureau of Prisons policy requires that incoming inmate property
packages be authorized in advance unless otherwise approved
under another Bureau policy. Packages containing only legal
material do not need to be pre-approved; however:
packages must be marked with words such as 'Authorized
by Bureau Policy.' This is to alert mail room staff
that enclosed materials contain matter which does not
require prior approval.
A package received
without an appropriately completed [authorization
form], or without markings indicating authorized
materials enclosed, is considered unauthorized and
shall be returned to the sender.
PS 5800.10, Ch. 3, pp.8-9.
This additional marking, i.e., "Authorized by Bureau Policy," is
only required on packages and should be in addition to the legal
mail markings explained above. Any legal mail that is delivered
in a box, a padded envelope or is wrapped in shipping paper is
considered a package and will be handled pursuant to the above
policy. An attorney who is unsure whether a legal shipment will
be considered a package or an envelope should write "Authorized
by Bureau Policy" to ensure that the shipment is not rejected.
(Note: An inmate who wishes to receive a non-legal material
package from anyone, including an attorney, must contact a
member of the Unit Team to complete the appropriate paperwork
and receive approval.)
3. FedEx:
Attorneys should not send packages via FedEx because no inmate
mail is received directly at MCC New York. Staff pick up all
inmate mail at the United States Post Office. FedEx will only
deliver to the actual prison and staff are prohibited from
receiving a package for an inmate that is hand-delivered to MCC
New York. Attorneys who wish to expedite the delivery of
documents or materials to their clients are advised to pass them
during a legal visit, place the materials in one of the
institution's legal drop boxes or send the materials via the
Postal Service's Express or Priority Mail services.
4.
Stamps
Inmates may not receive stamps or stamped items other than
issuance from the institution or by purchase from the commissary.
28 C.F.R. $540.21(j). These items will be treated as contraband
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=== Page 16 ===
in the institution. Attorneys are permitted to send self-
addressed envelope without affixed postage.
5.
Court Clothing
Court clothing for trial can be delivered in one of two ways:
1) Prior to an individual bringing in clothes, it is the
inmate's responsibility to submit an "Authorization to Receive A
Package or Property BP-331" to his Unit Counselor. This form
can be obtained from the inmate's Unit Team. The Unit Counselor
will then deliver one copy of that form to the Receiving and
Discharge (R&D) Department. The inmate will receive the other
copies of that form so that he may mail one to the individual
who will be dropping off the court clothes. The individual
bringing the clothing should call R&D staff in advance before
dropping off clothes. Once authorized, they must bring the copy
of the BP-331 form with the package and notify the lobby officer
who will contact a staff member from the R&D department. An R&D
staff member will then report to the lobby and accept the
clothing.
2) A court order can be obtained in lieu of the BP-331 form
mentioned above. A call to R&D in advance of dropping the
clothing must still be made. Inmates are allowed up to two sets
of trial clothes.
6. Mail for multiple defendants
If a case involves several co-defendants who will need to view
the same discovery material, the package/envelope of discovery
must be addressed to the Legal Department, as described above,
and the mailing must contain a cover letter indicating all
inmates and Register Numbers who are to have access to this
discovery material.
D. Release of Records/Information
1. Subpoenas
Subpoenas for documents may be faxed to the MCC New York Legal
Department at
.
Upon receipt of the fax, MCC New
York will begin gathering the requested documents. Please be
advised that the Privacy Act prohibits the release of any
information pursuant to a subpoena without the written
permission of the individual to whom the records pertain. This
requirement applies to attorneys requesting documents about
their clients. Therefore, an attorney must provide an original
signed consent for release of information from his or her client
along with any subpoena for information. Any records to which
an inmate normally has access, i.e., the inmate's medical
records and central file, will be provided directly to the
Page 14 of 22
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=== Page 17 ===
requesting attorney with the proper inmate consent. However,
all other subpoenaed records will be provided to the United
States Attorney's Office for a determination of whether to
release the documents, pursuant to the Touhy regulations, 28
C.F.R. $ 16.21 et seq.
2.
Medical Records
Medical records may be obtained by defense counsel with a Consent
to Release Authorization signed by the inmate-the original
consent form is required. The request can be mailed to the Legal
Department. If the inmate is no longer assigned to MCC New York,
then the requesting attorney must file a FOIA request to the
following address:
Freedom of Information Act/Privacy Act Section
Office of General Counsel, Room 841
Federal Bureau of Prisons
320 First Street, N.W.
Washington, D.C. 20534
Health Services staff are not at liberty to discuss information
with an inmate's attorney related to that inmate's medical
condition. Attorneys are encouraged to seek such information
directly from their clients.
If a newly arriving inmate has prior non-Bureau medical records,
you may send the materials to MCC New York, ATTN: Health Services
Unit.
E. Inmate Legal Activities
1. Law Library
The law library at MCC New York consists of legal books, electric
typewriters, and computers on which inmates may access and view
discovery material on CD-ROM format. The Education Department
also provides copy machines for inmates to use in preparing any
legal documents.
Typically, inmates at MCC New York may access the law library
during their scheduled law library hours, which are one day a
week, Monday through Thursday. Inmates should check the bulletin
boards in their respective housing units for days and times
scheduled. Inmates may sign up to access the law library between
the hours of 7:45 a.m. and 10:40 a.m., and from 12:30 p.m.
through 3:30 p.m. Since MCC New York is a high-rise building,
each floor is allowed access to the law library one day per week
because many of the inmates must be separated from each other at
all times for security purposes. In addition, inmates who are
pro se or who have a demonstrated legal need, such as an imminent
court deadline or an excessive amount of discovery material to
Page 15 of 22
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=== Page 18 ===
review, may be granted an additional six hours of library time on
Fridays by making a request to the Education Department. All
requests for additional law library time are, of course, subject
to staff availability, number of inmate requests, and security
concerns. If the pretrial inmate is pro se, as in representing
his/herself, the inmate should provide the Education Department
with official court documentation verifying his/her status.
There is also a basic law library in the Special Housing Unit
(SHU).
If the law library does not have the reference material the
inmate needs to do the research, the inmate may consult with the
Education Department staff on the possibility of requesting
additional materials.
2.
Access to Computerized Discovery Materials
MCC New York's law library has computers which inmates may access
during their scheduled law library hours.
All electronic discovery materials must be sent in CD-ROM formats
instead of DVD disks. MCC New York currently does not have the
equipment to support DVDs. Material from DVD disks should be
broken down and distributed onto several CDs. MCC New York
computers have the capability to play industry standard audio or
video files in the following formats:
1. video clips of AVI, MPG, MPEG, WMV
2. audio clips of WAV, MP3, WMA
3. documents in PDF form, HTML, TXT, JPG, DOC
Due to licensing issues, MCC New York does not support RealPlayer
recorded audio or video formats, CD-RW disks, files made for a
non-Microsoft computer (such as MacIntosh) or discovery in non-
standard/proprietary format.
3. Leisure Library
All housing units have been assigned a time for utilizing the
leisure library. Inmates should check the unit bulletin board
for days and times scheduled.
4. Service of Process
Bureau staff are prohibited from effecting service of process on
inmates. MCC New York policy requires that an inmate be served
by a federal, state or local law enforcement official (Marshals
or Sheriffs). Because service of process occurs within the
secure confines of the institution, private process servers, who
are not also law enforcement officials, may not serve inmates.
The qualified process server must contact MCC New York's Inmate
Systems Management department to schedule an appointment before
coming to the institution.
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=== Page 19 ===
F. Administrative Remedy Program
It is imperative that inmates attempt to resolve any condition of
confinement issues internally either by speaking to appropriate
staff or through the Administrative Remedy Process. Further, all
housing units have bulletin boards that have information
explaining sick call procedures, access to discovery directions,
etc.
The Bureau's Administrative Remedy Program is a process through
which inmates may seek formal review of an issue relating to
virtually any aspect of their confinement, if informal procedures
have not resolved the matter. See 28 C.F.R. Part 542 -
Administrative Remedy; and Program Statement 1330.13,
Administrative Remedy Program. This program applies as follows:
(1) to inmates confined in institutions operated by the Bureau of
Prisons; (2) to inmates who are designated to contract
Residential Reentry Centers (RRCs), formally known as Community
Corrections Centers, under Bureau of Prisons responsibility; and
(3) to former inmates for issues that arose during their
confinement. See C.F.R. $542.10.
Inmates are obligated to attempt informal resolution of
grievances prior to filing a formal request for administrative
remedy. See 28 C.F.R. $542.13. The deadline for completion of
informal resolution and submission of a formal written
Administrative Remedy Request, on the appropriate form, is 20
calendar days following the date on which the basis for the
Request occurred. See 28 C.F.R. $542.14. Once an inmate has
filed a formal grievance at the institution level (BP-9), the
Warden of that facility has 20 calendar days to investigate and
provide the inmate a written response. See 28 C.F.R. $542.18.
If the inmate is not satisfied with the Warden's response, he/she
has 20 calendar days to file a Regional Administrative Remedy
Appeal (BP-10). See 28 C.F.R. $542.15. Once received in the
Regional Office, the Regional Director has 30 calendar days to
investigate and provide the inmate a written response. See 28
C.F.R. $542.18. If the inmate is not satisfied with the Regional
Director's response, he/she has 30 calendar days to file a
Central Office Administrative Remedy Appeal (BP-11). See 28
C.F.R. $15. Once received in the Central Office, the
Administrator, National Inmate Appeals, has 40 days to
investigate and provide the inmate a written response. 28 C.F.R.
$542.18. After receiving the Administrator's response, the
inmate has exhausted the Bureau's Administrative Remedy Program.
The program provides for expedited investigations and responses
in emergency situations, as well as extensions of time for both
filing grievances and receiving responses. At any level, an
Administrative Remedy may be rejected if it does not fully comply
with Program Statement 1330.13, Administrative Remedy Program.
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=== Page 20 ===
If complaining about a sensitive issue, in the sense that the
inmate's safety or well-being would be placed in danger if the
request became known at the institution, the inmate may submit
his administrative remedy directly to the appropriate Regional
Director, marking "Sensitive" upon the request and explaining, in
writing, the reason for not submitting the request at the
institution. See Program Statement 1330.13, Sec.8 (d) (1),
Administrative Remedy Program. If the Regional Administrative
Remedy Coordinator agrees that the request is sensitive, the
request shall be accepted, investigated, and responded to.
Otherwise, the request will not be accepted, and the inmate will
be advised in writing of that determination, without return of
the request. The inmate may then pursue the matter by submitting
a request for Administrative Remedy locally to the Warden. The
Warden shall allow a reasonable extension of time for such a
resubmission. See 28 C.F.R. $542.17.
Special procedures regarding the appeal of Disciplinary Hearing
Officer (DHO) actions may be found at 28 C.F.R. $542.14 (d) (2).
Appeals from DHO actions shall be submitted initially to the
Regional Director for the region where the inmate is currently
located.
G. Inmate Designations
The majority of inmates at MCC New York are pre-trial inmates
who, if sentenced, will serve their sentence in another
institution. However, an inmate is not transported to a new
institution immediately upon sentencing. The sentencing court
must first provide to the USMS the final presentence
investigation report and a signed judgement and commitment order.
The USMS must then forward these documents along with a request
for designation to the Designation and Sentence Computation
Center (DSCC), located in Grand Prairie, Texas. When designating
an institution for an inmate to serve a sentence, the Bureau
considers many factors, including but not limited to, the
security level of the inmate, medical or psychiatric concerns and
judicial recommendations. Once an institution has been
designated, the inmate will be transported on the next bus or
airlift on which space is available. This entire process often
takes several weeks to complete. Contact information for DSCC is
as follows:
Designation and Sentence Computation Center
Grand Prairie Office Complex
U.S. Armed Forces Reserve Complex
346 Marine Forces Drive
Grand Prairie, TX 75051
Phone:
Fax:
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=== Page 21 ===
Court Ordered Studies
At anytime during an inmate's pre-trial confinement, the judge
may order one of numerous studies found at 18 U.S.C. $4241 et
seq. Once a judge signs the request for designation, the court
must send a copy to the USMS and Probation who will then contact
DSCC. Since the inmate is not sentenced, he is not yet in Bureau
custody, therefore the Bureau cannot make the designation without
an official request from the USMS to the Bureau in Grand Prairie.
Neither the Legal Department nor any institution staff have a
role in the process. It is up to the attorneys on the criminal
case to make sure the order is processed as described in this
paragraph. If questions arise, the attorneys may contact the
DSCC (contact info. above).
H.
Health Services
1. Sick Call
Inmates are advised during their initial screening and physical
examination that if they wish to be evaluated by the Health
Services Department, they must submit a sick call slip to the
department. It is imperative that inmate's use this system, as
it helps the department track requests and have inmates seen on a
first need to be seen basis. If an inmate has a verified chronic
condition (i.e. diabetes, hypertension, etc.) he will be placed
in a chronic care clinic and scheduled for appointments
automatically.
Sick call slips are available on the housing units and there is a
sick call box on each unit in which to submit the slips. The
sick call box on each housing unit will be emptied daily by a
member of Health Services Staff and given to the medical staff
for triage. Requests will be prioritized in accordance with
greatest medical need. Inmates will be charged a $2.00 co-pay
fee for all non-chronic care, non-emergent appointments.
2. Emergency Care
Any time there is a medical emergency on a unit, the inmate
should notify the unit officer who can call the on-duty P.A.
3. Medication
With regards to medication, MCC New York staff will make every
effort to continue an inmate on a specific medication as long as
the inmate has proof that he is on that medication (a
prescription, a prescription bottle, etc.). However, for safety
of staff and other inmates, there are several medications that an
inmate may be on that are not on the national Bureau of Prisons
formulary. In this instance, if medical staff find it necessary
to prescribe a substitute medication, they will do SO. If an
inmate is prescribed a medication that has refills, it is their
responsibility to notify the pharmacy when they need a refill.
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=== Page 22 ===
This can be accomplished by placing the empty bottle on the daily
pill line cart that comes around to each housing unit at least
once a day. If medical staff feel that an inmate should not be
in possession of certain medications they need (certain
psychiatric medications), the inmate will be administered the
medication by pharmacy during daily pill line.
4. Independent Medical Examinations (IME)
If an attorney seeks a court order for an IME, the following
information must be included:
(1) Inmate's name and register number;
(2) A court order or similar court signed document for the
examination;
(3) A provision for time and date to be determined by all
affected parties;
(4) Expected length of examination;
(5) Name, title, and organization of each person attending
(all-non attorneys and non-legal representatives will
have to fill out an application so MCC can complete a
background check (See Attachment B) ;
(6) List of all equipment to be used; and
(7) An indication of whether the inmate's consent has been
obtained.
All of the above should be faxed to the Legal Department who will
make arrangements with the medical department for a convenient
time and date. The physician entering will be subject to using
the equipment available at MCC New York. The physician will also
have to complete Attachment B.
5.
Visits with Inmates in Local Hospital
All USMS inmates (inmates who have not yet been sentenced) will
be referred to the USMS for visiting, whether legal or social.
I. Special Housing Unit (SHU)
MCC New York has a SHU to house inmates separate from the general
population. The SHU consists of two categories of cells:
administrative detention and disciplinary segregation.
Disciplinary Segregation Status. A form of separation from the
general population in which inmates who commit serious violations
of Bureau rules are confined by the Discipline Hearing Officer,
for specified periods of time, in a cell removed from the general
population. The DHO imposes the sanction of disciplinary
segregation upon determining that no other available disposition
will adequately achieve the purpose of punishment and deterrence
necessary to regulate an inmate's behavior within acceptable
limits.
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=== Page 23 ===
Administrative Detention Status. A non-punitive form of
separation from the general population used when the continued
presence of the inmate within the general population would pose a
serious threat to life, property, self, staff or other inmates,
or to the security or orderly running of the institution. This
housing status may also include inmates who require protective
custody, those who cannot be placed in local population because
they are en route to another institution (holdovers), and those
who are awaiting a hearing before the Unit Discipline Committee
or Discipline Hearing Officer. Program Statement 5270.07, Inmate
Discipline and Special Housing Units, found at Bureau's public
website.
Additionally, all newly arriving inmates at MCC are placed in the
Special Housing Unit until they are screened and an appropriate
housing unit (general population or SHU) is determined.
J. Miscellaneous
1. Religious Programs
Title 28 C.F.R. $548, Religious Programs and Program Statement
5360.09, Religious Beliefs and Practices set forth the Bureau of
Prisons' policy for inmates who wish to practice their religion
while incarcerated. Chaplains are available at all institutions.
See 28 C.F.R. $548.12. In addition, contract religious clergy
and volunteers from the community augment Bureau staff to make
available a wide variety of programs, including those involving
group worship, individual religions counseling, spiritual
guidance, and the study of sacred writings. See 28 C.F.R.
$548.14. Inmates must make all religious requests, including
common fare diets, through the Religious Services Department.
2.
Food Service
Title 28 C.F.R. $548, Subpart C - Special Food and Meals,
provides that special diets are available to meet the medical
needs of diabetics and others who require low-salt, low-calorie,
or other special diets. Additionally, "common-fare" meals are
offered to inmates whose religious practices require dietary
restrictions. See 28 C.F.R. $547.20 (b) and 548.20; Program
Statement 5360.09, Religious Beliefs and Practices. The common
fare program is designed to meet the dietary requirements of
different religions.
3.
Inmate Commissary
Inmates' families and friends may send inmates funds through
Western Union's Quick Collect Program or through the National
Lock Box. Please see instructions at the following address:
http://www.bop.gov/inmate programs/money.jsp
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=== Page 24 ===
4.
Marriage
Inmates who seek authorization to marry while in confinement must
submit a written request through their Case Manager.
5.
Personal Property
Bureau of Prisons policy on inmate retention of personal property
is found in Program Statement 5580.07, Personal Property, Inmate.
See also 28 C.F.R. Part 553 - Inmate Property. Inmates may
possess only that property which by policy is authorized. See 28
C.F.R. $553.11. Those rules contribute to the management of
inmate personal property in the institution, and contribute to a
safe environment for staff and inmates by reducing fire hazards,
security risk, and sanitation problems. Personal hygiene items
are issued by the institution for indigent inmates. Inmates may
also purchase personal property items from the institution
commissary.
Inmates going out to court may bring legal material relevant to
their current court proceedings. Inmates are not allowed to
return from court with additional legal materials. Attorneys
wishing to provide inmates with additional legal materials must
send such material in the mail or deposit them material in the
lobby legal mail drop boxes.
6.
A&O Handbook
Inmates entering MCC New York are provided with an Admission and
Orientation ("A&O") Handbook, which explains institution rules
and procedures. The A&O Handbook addresses subjects such as
purchasing items from the commissary, inmate correspondence and
the inmate administrative remedy process.
Page 22 of 22
EFTA00009699

=== Page 25 ===
ATTACHMENT A
EFTA00009700

=== Page 26 ===
OF JUSTICE DEPA * * PRISONS FEDERAL OF BUREAU
METROPOLITAN DETENTION CENTER
METROPOLITAN CORRECTIONAL CENTER
100 29ᵀᴴ STREET
150 PARK ROW
BROOKLYN, NEW YORK 11232
NEW YORK, NEW YORK 10007
(718) 840-4200
(646) 836-6300
Dear Sir/Madam:
We are in receipt of your request that you, or a person whom you employ or supervise, be allowed
to visit and correspond in relation to legal matters with
,
Federal Register Number
-
In order for such visiting or correspondence to be conducted, we must request that you, or your
employee or your student, complete and sign the enclosed questionnaire. Please answer the
questionnaire, and ensure that all sections are completed. In addition, we must request that the
sponsoring attorney execute the Attorney's Statement at the end of the questionnaire. Please return
the form upon completion, either by regular or overnight mail.
**BE ADVISED THAT APPLICATIONS WILL NOT BE ACCEPTED AT THE FRONT
LOBBY OF THE INSTITUTION. APPLICATIONS SENT TO THIS OFFICE VIA
FACSIMILE WILL BE DESTROYED UPON RECEIPT. ONLY ORIGINAL
APPLICATIONS WILL BE PROCESSED.*
The information supplied on this questionnaire may be used for investigative purposes in
determining whether to grant this request to visit and correspond with inmates. The processing of
the applications takes a minimum of 14 days from the date of receipt. It is your responsibility to
contact the Legal Department to ascertain whether you, or your employee or student, will be
allowed to visit or correspond with the above-referenced inmate.
Upon approval, the applicants admittance to enter will expire (1) year from the applicants date
of approval. It is the applicant's responsibility to reapply upon their expiration.
Page 1 of 10
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EFTA00009701

=== Page 27 ===
GENERAL
This information is provided pursuant to Public Law 93-579, the Privacy Act of December 31, 1974.
PURPOSES & USES
The information you supply may be used as a basis for an investigation regarding your
correspondence with
, Federal
Register Number
. In the process of conducting the investigation, the
Bureau of Prisons may disclose the information to federal, state, or local law enforcement agencies.
EFFECTS OF NONDISCLOSURE
You are not required to supply the information requested on the attached questionnaire. If you do
not furnish the information requested, the processing of your request will be suspended, and you will
receive no further consideration. If you furnish only part of the information required, the processing
of your request will be attempted; however, it may be significantly delayed. If the information
withheld is found to be essential to processing your request properly, you will be so informed, and
your request will receive no further consideration unless you supply the missing information.
Although no penalties are authorized for failure to supply the requested information, failure to
supply the information could result in your not being considered for or allowed admittance to the
institution or correspondence privileges with the inmate in question.
Page 2 of 10
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EFTA00009702

=== Page 28 ===
PARALEGAL* (See Page 5)
MITIGATION SPECIALIST (See Page 10)
INTERPRETER
OTHER
PRIVATE INVESTIGATOR (See Page 9)
APPLICATION TO ENTER AN INSTITUTION OR CORRESPOND WITH A FEDERAL
PRISONER AS THE REPRESENTATIVE OF A LICENSED ATTORNEY.
This form has three parts:
1. Questionnaire: This questionnaire is to be completed by each paralegal, legal assistant, clerk,
student, interpreter, mitigation specialist or private investigator who seeks to enter an institution of
the Federal Bureau of Prisons to visit or correspond with a federal prisoner as the representative of
a licensed attorney. This application will not be processed unless this questionnaire with the original
signature is received at the Legal Department.
2. Certification: Each person seeking to enter a federal institution to visit or correspond with a
federal prisoner must sign the certification which follows the questionnaire.
3. Attorney's Statement: The licensed attorney sponsoring you must sign the sponsoring
statement. This application will not be processed if the Attorney's Sponsoring Statement is not
signed.
QUESTIONNAIRE
NOTE: Answer all questions. If a question does not apply to you , write "Not Applicable" in the
space provided for the answer.
1. Name:
A:
Any alias or other name ever used:
Name:
When Used:
2. A. Social Security Number:
B. Date of Birth:
C. Place of Birth:
D. Sex:
E. Race:
Page 3 of 10
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=== Page 29 ===
3.
A. Present Residential Address:
B. Length of time at this address:
C. Home telephone number:
D. List all residential addresses (including street and number, city and state) for the last
five (5) years and dates you resided at each address:
Addresses
Dates
4. A. Present Place of Employment:
I. Name of immediate supervisor:
II. Employer's business address:
III. Employer's telephone number:
IIII. Dates of Employment:
B. List all previous employers for the past five (5) years, including employers' addresses and
dates of your employment with each employer:
EMPLOYER
ADDRESS
DATES OF EMPLOYMENT
5. A. List all schools, universities, or other educational institutions attended from grade
Page 4 of 10
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EFTA00009704

=== Page 30 ===
10 to present (this should include any and all legal training that you have received):
SCHOOL
ADDRESS
DEGREE & DATE RECEIVED
*B. Paralegal entrance privileges are ONLY extended to paralegals in the employ of the
sponsoring attorney, not self-employed paralegals who are consulted by attorneys.
Paralegal applications require the applicant A) be a current law school student or graduate
B) provide a copy of their paralegal certificate or C) have a minimum of (6) months
experience as a paralegal working with their sponsoring attorney AND provide a letter
from the sponsoring attorney stating the applicant's duties.
6. Have you ever been convicted of ANY criminal offense?
If so, complete the following. You may exclude any convictions for minor traffic violations
(fine of $150.00 or less)
OFFENSE
DATE OF CONVICTION
NAME & LOCATION OF COURT
7. Have you ever been confined in any jail, prison or penal institution?
If so, complete the following:
Type of Institution
Location
Dates of Confinement
(State, Federal, Municipal County)
Page 5 of 10
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=== Page 31 ===
8. Have you ever been charged with a criminal offense? If yes, please briefly summarize
circumstances and legal disposition of the case.
9. A Have you ever been denied permission to visit or correspond with an inmate by an institution
within the Federal Bureau of Prisons (social or legal)?
B. If so, state the institution(s), inmate(s) and date(s) of denial.
10. Are you a citizen of the United States? A.
If not, give the name of the country of which you are a citizen or subject: B.
Alien Registration Number: C.
11. Are you a relative of or have a social relationship with the inmate(s) you are seeking to visit
with
at the MDC/MCC? If yes, explain relationship.
12. Are you currently on, or seeking to be placed on the social visiting list of any inmate(s)
housed at a federal institution?
Page 6 of 10
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EFTA00009706

=== Page 32 ===
STATEMENT OF APPLICANT
I certify that I am authorized to act as the legal representative of
,
who is a licensed member of the bar of the State of
.
I request that I be allowed to interview and correspond with
,
Federal Register Number
, who is confined at the MDC/MCC.
I am aware of my responsibility as a representative of the above-named attorney and certify
that I am able to meet this responsibility. I am also aware of the Bureau of Prisons' Policy
on Inmate Legal Activities and certify that I am able to and will adhere to the requirements
of this policy. I pledge to abide by Bureau of Prisons regulations and institution guidelines.
I hereby certify that all of the information contained in this questionnaire is true and correct
to the best of my knowledge. Furthermore, I understand that all information contained in this
questionnaire may be investigated and verified through the use of federal, state and local
authorities.
Applicant's printed name:
Applicant's signature:
Date Completed:
Private Investigators must submit a copy of their Private Investigators Certificate and Private
Investigator's photo identification.
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=== Page 33 ===
STATEMENT OF SPONSORING ATTORNEY
I hereby certify that I am a licensed member of the bar of the State of
and that I employ or supervise
.
I authorize
to represent me and request that as my
representative she/he be allowed to interview and correspond with
,
Federal Register Number
, who is currently confined at MDC
Brooklyn/ MCC New York, I further certify that
is aware
of the responsibility of her/his role as my representative and is able to meet this
responsibility. I pledge that I will supervise my representative's activities. I accept personal
and professional responsibility for all acts of my representative which affect the institution,
its inmates or staff.
Attorney's printed name:
Address:
Telephone Number:
Attorney's Signature:
Date Completed:
Page 8 of 10
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=== Page 34 ===
PRIVATE INVESTIGATOR APPLICANTS
The following visiting procedures will be applied to Private Investigators entering the
institutions:
Private Investigators on the approved list will be permitted to enter the institution without the
accompaniment of their sponsoring attorney.
Private Investigators will be required to submit a statement of sponsoring attorney as well as a
copy of their Private Investigator's License EACH TIME THEY WANT TO VISIT ON
BEHALF OF AN ATTORNEY OTHER THAN THE INITIAL SPONSORING ATTORNEY.
Your admittance to enter will expire one year from the date of your approval or upon the
expiration of your private investigators license (which ever comes first).
Private Investigators will be permitted to bring pre-approved interpreters, if necessary.
Please be advised that it is the responsibility of the Private Investigator to make her/his sponsoring
attorney aware of the above procedures. The enclosed Sponsoring Statement form can be
reproduced locally.
Page 9 of 10
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=== Page 35 ===
MITIGATION SPECIALIST/ DOCTOR APPLICANTS
The following visiting procedures will be applied to Mitigation Specialists entering this
institution:
Mitigation Specialists/ Doctors on the approved list will be permitted to enter the institution
without the accompaniment of their sponsoring attorney.
Mitigation Specialists/ Doctors will be required to submit a court order along with the statement
of sponsoring attorney EACH TIME THEY WANT TO VISIT ON BEHALF OF AN
ATTORNEY OTHER THAN THE INITIAL SPONSORING ATTORNEY.
A new order must be produced for each inmate that the Mitigation Specialist/ Doctor seeks to
correspond with, additionally, a new order must be produced when the mitigation specialist is
renewing their application after expiration.
Mitigation Specialists/Doctors will be permitted to bring pre-approved interpreters, if necessary.
Mitigation Specialists/ Doctors must schedule visits by faxing a copy of the order and a letter
specifying the date and time requested. The letter should include the inmate's name and register
number. The request needs to be faxed to the respective Legal Department for the institution you
need to visit.
Please be advised that it is the responsibility of the Mitigation Specialist/ Doctors to make her/his
sponsoring attorney aware of the above procedures. The enclosed Sponsoring Statement form can
be reproduced locally.
Page 10 of 10
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EFTA00009710

=== Page 36 ===
ATTACHMENT B
EFTA00009711

=== Page 37 ===
BP-A0660.012
NCIC CHECK CDFRM
MAR 99
U.S. DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF PRISONS
AUTHORIZATION FOR RELEASE OF INFORMATION
NCIC (National Crime Information Center) CHECK
I hereby authorize a representative of the Federal Bureau of Prisons to obtain any
information on my criminal history background. I understand that this check must be done
before I am allowed to enter/serve at any Bureau facility. I also understand that refusal
to provide all necessary information may result in 1) denial of entry into a Bureau
facility and 2) denial of volunteer/contract status.
1. Name (Last, First, Middle)
2. Address (Street address) (City, State, County, Zip Code)
3. Home Telephone Number (Area Code, Number):
4. Aliases/Nickname:
5. Citizenship (List the country you are a citizen of):
6. Social Security Number:
7. Date of Birth (Month, day, year):
8a. Sex:
8b. Race:
8c. Height:
8d. Weight:
Be. Color of Eyes:
8f. Color of Hair:
9. Place of Birth (City, State, County), (List city, county and country if outside the
U.S.A)
10. The above listed information is true
10a. Date
and correct. Applicant's Signature
PRIVACY ACT NOTICE
Authority for Collecting Information: E.O. 10450; 5 USC 1303-1305; 42 USC 2165 and 2455;
22 USC 2585 and 2519; and 5 USC 3301
Purposes and Uses: Information provided on this form will be furnished to individuals in
order to obtain information regarding activities in connection with an investigation to
determine (1) fitness for Federal employment, (2) clearance to perform contractual service
for the Federal Government, (3) security clearance or access. The information obtained
may be furnished to third parties as necessary in the fulfillment of official
responsibilities.
Effects of Non-disclosures: Furnishing the requested information is voluntary, but failure
to provide all or of part the information may result in lack of further consideration for
employment, clearance or access, or in the termination of your employment.
(This form may be replicated via NP)
EFTA00009712


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=== Page 1 ===
From:
Cc:
Subject: Letter re GM requests for redactions and in camera proceeding
Date: Wed, 02 Dec 2020 15:13:45 +0000
Attachments: 2020.11.30_Letter_to_Judge_Nathan_re_Sealing_Exhibit_B.PDF;
2020.11.30_Letter_to_Judge_Nathan_re_Sealing.pdf;
2020.11.25_Letter_to_Judge_Nathan_re_Sealing_of_Renewed_Bail_Motion.PDF;
2020.11.30_Letter_to_Judge_Nathan_re_Sealing_Exhibit_A.PDF;
2020.12.01_AJN_Order_directing_Govt_to_Respond_to_GM_sealing_requests.pdf;2020.
12-02_GM_letter_regarding_defense_request_for_sealing_&_in_camera_hearing_vl.docx:
Chiefs,
Attached for review is a draft letter responding to Maxwell's requests for redactions and an in camera proceeding. For
reference, attached are the relevant filings and Judge Nathan's order directing us to respond. This is due today.
Thanks,
EFTA00010189


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=== Page 1 ===
IN RE:
INVESTIGATION OF
JEFFREY EPSTEIN
/
NON-PROSECUTION AGREEMENT
IT APPEARING that the City of Palm Beach Police Department and the State
Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter,
the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey
Epstein (hereinafter "Epstein");
IT APPEARING that the State Attorney's Office has charged Epstein by indictment
with solicitation of prostitution, in violation of Florida Statutes Section 796.07;
IT APPEARING that the United States Attorney's Office and the Federal Bureau of
Investigation have conducted their own investigation into Epstein's background and any
offenses that may have been committed by Epstein against the United States from in or
around 2001 through in or around September 2007, including:
(1)
knowingly and willfully conspiring with others known and unknown to
commit an offense against the United States, that is, to use a facility or means
of interstate or foreign commerce to knowingly persuade, induce, or entice
minor females to engage in prostitution, in violation of Title 18, United States
Code, Section 2422(b); all in violation of Title 18, United States Code, Section
371;
(2)
knowingly and willfully conspiring with others known and unknown to travel
in interstate commerce for the purpose of engaging in illicit sexual conduct, as
defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18,
United States Code, Section 2423(b); all in violation of Title 18, United States
Code, Section 2423(e);
(3)
using a facility or means of interstate or foreign commerce to knowingly
persuade, induce, or entice minor females to engage in prostitution; in
violation of Title 18, United States Code, Sections 2422(b) and 2;
(4)
traveling in interstate commerce for the purpose of engaging in illicit sexual
conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation
Page 1 of 7
EFTA00014046

=== Page 2 ===
of Title 18, United States Code, Section 2423(b); and
(5)
knowingly, in and affecting interstate and foreign commerce, recruiting,
enticing, and obtaining by any means a person, knowing that the person had
not attained the age of 18 years and would be caused to engage in a
commercial sex act as defined in 18 U.S.C. $ 1591(c)(1); in violation of Title
18, United States Code, Sections 1591(a)(1) and 2; and
IT APPEARING that Epstein seeks to resolve globally his state and federal criminal
liability and Epstein understands and acknowledges that, in exchange for the benefits
provided by this agreement, he agrees to comply with its terms, including undertaking certain
actions with the State Attorney's Office;
IT APPEARING, after an investigation of the offenses and Epstein's background by
both State and Federal law enforcement agencies, and after due consultation with the State
Attorney's Office, that the interests of the United States, the State of Florida, and the
Defendant will be served by the following procedure;
THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for
the Southern District of Florida, prosecution in this District for these offenses shall be
deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the
following conditions and the requirements of this Agreement set forth below.
If the United States Attorney should determine, based on reliable evidence, that,
during the period of the Agreement, Epstein willfully violated any of the conditions of this
Agreement, then the United States Attorney may, within ninety (90) days following the
expiration of the term of home confinement discussed below, provide Epstein with timely
notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its
prosecution on any offense within sixty (60) days' of giving notice of the violation. Any
notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the
United States learning of facts which may provide a basis for a determination of a breach of
the Agreement.
After timely fulfilling all the terms and conditions of the Agreement, no prosecution
for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have
been the subject of the joint investigation by the Federal Bureau of Investigation and the
United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury
investigation will be instituted in this District, and the charges against Epstein if any, will be
dismissed.
Page 2 of 7
EFTA00014047

=== Page 3 ===
Terms of the Agreement:
1.
Epstein shall plead guilty (not nolo contendere) to the Indictment as
currently pending against him in the 15th Judicial Circuit in and for
Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging
one (1) count of solicitation of prostitution, in violation of Fl. Stat. §
796.07. In addition, Epstein shall plead guilty to an Information filed
by the State Attorney's Office charging Epstein with an offense that
requires him to register as a sex offender, that is, the solicitation of
minors to engage in prostitution, in violation of Florida Statutes Section
796.03;
2.
Epstein shall make a binding recommendation that the Court impose a
thirty (30) month sentence to be divided as follows:
(a)
Epstein shall be sentenced to consecutive terms of twelve (12)
months and six (6) months in county jail for all charges, without
any opportunity for withholding adjudication or sentencing, and
without probation or community control in lieu of
imprisonment; and
(b)
Epstein shall be sentenced to a term of twelve (12) months of
community control consecutive to his two terms in county jail
as described in Term 2(a), supra.
3.
This agreement is contingent upon a Judge of the 15th Judicial Circuit
accepting and executing the sentence agreed upon between the State
Attorney's Office and Epstein, the details of which are set forth in this
agreement.
4.
The terms contained in paragraphs 1 and 2, supra, do not foreclose
Epstein and the State Attorney's Office from agreeing to recommend
any additional charge(s) or any additional term(s) of probation and/or
incarceration.
5.
Epstein shall waive all challenges to the Information filed by the State
Attorney's Office and shall waive the right to appeal his conviction and
sentence, except a sentence that exceeds what is set forth in paragraph
(2), supra.
6.
Epstein shall provide to the U.S. Attorney's Office copies of all
Page 3 of 7
EFTA00014048

=== Page 4 ===
proposed agreements with the State Attorney's Office prior to entering
into those agreements.
7.
The United States shall provide Epstein's attorneys with a list of
individuals whom it has identified as victims, as defined in 18 U.S.C.
§ 2255, after Epstein has signed this agreement and been sentenced.
Upon the execution of this agreement, the United States, in consultation
with and subject to the good faith approval of Epstein's counsel, shall
select an attorney representative for these persons, who shall be paid for
by Epstein. Epstein's counsel may contact the identified individuals
through that representative.
8.
If any of the individuals referred to in paragraph (7), supra, elects to
file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the
jurisdiction of the United States District Court for the Southern District
of Florida over his person and/or the subject matter, and Epstein waives
his right to contest liability and also waives his right to contest damages
up to an amount as agreed to between the identified individual and
Epstein, so long as the identified individual elects to proceed
exclusively under 18 U.S.C. § 2255, and agrees to waive any other
claim for damages, whether pursuant to state, federal, or common law.
Notwithstanding this waiver, as to those individuals whose names
appear on the list provided by the United States, Epstein's signature on
this agreement, his waivers and failures to contest liability and such
damages in any suit are not to be construed as an admission of any
criminal or civil liability.
9.
Epstein's signature on this agreement also is not to be construed as an
admission of civil or criminal liability or a waiver of any jurisdictional
or other defense as to any person whose name does not appear on the
list provided by the United States.
10.
Except as to those individuals who elect to proceed exclusively under
18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's
signature on this agreement, nor its terms, nor any resulting waivers or
settlements by Epstein are to be construed as admissions or evidence of
civil or criminal liability or a waiver of any jurisdictional or other
defense as to any person, whether or not her name appears on the list
provided by the United States.
11.
Epstein shall use his best efforts to enter his guilty plea and be
Page 4 of 7
EFTA00014049

=== Page 5 ===
sentenced not later than October 26, 2007. The United States has no
objection to Epstein self-reporting to begin serving his sentence not
later than January 4, 2008.
12.
Epstein agrees that he will not be afforded any benefits with respect to
gain time, other than the rights, opportunities, and benefits as any other
inmate, including but not limited to, eligibility for gain time credit
based on standard rules and regulations that apply in the State of
Florida. At the United States' request, Epstein agrees to provide an
accounting of the gain time he earned during his period of
incarceration.
13.
The parties anticipate that this agreement will not be made part of any
public record. If the United States receives a Freedom of Information
Act request or any compulsory process commanding the disclosure of
the agreement, it will provide notice to Epstein before making that
disclosure.
Epstein understands that the United States Attorney has no authority to require the
State Attorney's Office to abide by any terms of this agreement. Epstein understands that
it is his obligation to undertake discussions with the State Attorney's Office and to use his
best efforts to ensure compliance with these procedures, which compliance will be necessary
to satisfy the United States' interest. Epstein also understands that it is his obligation to use
his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding
recommendation regarding the sentence to be imposed, and understands that the failure to
do so will be a breach of the agreement.
In consideration of Epstein's agreement to plead guilty and to provide compensation
in the manner described above, if Epstein successfully fulfills all of the terms and conditions
of this agreement, the United States also agrees that it will not institute any criminal charges
against any potential co-conspirators of Epstein, including but not limited to
Further, upon execution of this
agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury
investigation will be suspended, and all pending federal Grand Jury subpoenas will be held
in abeyance unless and until the defendant violates any term of this agreement. The
defendant likewise agrees to withdraw his pending motion to intervene and to quash certain
grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence
requested by or directly related to the grand jury subpoenas that have been issued, and
including certain computer equipment, inviolate until all of the terms of this agreement have
been satisfied. Upon the successful completion of the terms of this agreement, all
outstanding grand jury subpoenas shall be deemed withdrawn.
Page 5 of 7
EFTA00014050

=== Page 6 ===
By signing this agreement, Epstein asserts and certifies that each of these terms is
material to this agreement and is supported by independent consideration and that a breach
of any one of these conditions allows the United States to elect to terminate the agreement
and to investigate and prosecute Epstein and any other individual or entity for any and all
federal offenses.
By signing this agreement, Epstein asserts and certifies that he is aware of the fact that
the Sixth Amendment to the Constitution of the United States provides that in all criminal
prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further
is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court
may dismiss an indictment, information, or complaint for unnecessary delay in presenting
a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein
hereby requests that the United States Attorney for the Southern District of Florida defer such
prosecution. Epstein agrees and consents that any delay from the date of this Agreement to
the date of initiation of prosecution, as provided for in the terms expressed herein, shall be
deemed to be a necessary delay at his own request, and he hereby waives any defense to such
prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of
the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the
United States to a speedy trial or to bar the prosecution by reason of the running of the statute
of limitations for a period of months equal to the period between the signing of this
agreement and the breach of this agreement as to those offenses that were the subject of the
grand jury's investigation. Epstein further asserts and certifies that he understands that the
Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all
felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees
and consents that, if a prosecution against him is instituted for any offense that was the
subject of the grand jury's investigation, it may be by way of an Information signed and filed
by the United States Attorney, and hereby waives his right to be indicted by a grand jury as
to any such offense.
111
111
111
Page 6 of 7
EFTA00014051

=== Page 7 ===
By signing this agreement, Epstein asserts and certifies that the above has been read
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated:
By:
ASSISTANT U.S. ATTORNEY
Dated: 9/24/07
JEFFREY S
Dated:
GERALD LEFCOURT, ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated:
LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
Page 7 of 7
EFTA00014052

=== Page 8 ===
By signing this agreement, Epstein asserts and certifies that the above has been read
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated:
By:
ASSISTANT U.S. ATTORNEY
Dated:
JEFFREY EPSTEIN
Dated: 9/24/07
LEFCOURT ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated:
LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
Page 7 of 7
EFTA00014053

=== Page 9 ===
By signing this agreement, Epstein asserts and certifies that the above has been read
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated:
By:
ASSISTANT U.S. ATTORNEY
Dated:
JEFFREY EPSTEIN
Dated:
GERALD LEFCOURT, ESQ.
Dated: 9-24-07
LILLY ANN SANGHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
Page 7 of 7
EFTA00014054

=== Page 10 ===
IN RE:
INVESTIGATION OF
JEFFREY EPSTEIN
/
ADDENDUM TO THE NON-PROSECUTION AGREEMENT
IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7
of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as
follows:
7A.
The United States has the right to assign to an independent third-party the responsibility
for consulting with and, subject to the good faith approval of Epstein's counsel, selecting
the attorney representative for the individuals identified under the Agreement. If the
United States elects to assign this responsibility to an independent third-party, both the
United States and Epstein retain the right to make good faith objections to the attorney
representative suggested by the independent third-party prior to the final designation of
the attorney representative.
7B.
The parties will jointly prepare a short written submission to the independent third-party
regarding the role of the attorney representative and regarding Epstein's Agreement to
pay such attorney representative his or her regular customary hourly rate for representing
such victims subject to the provisions of paragraph C, infra.
7C.
Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney
representative selected by the independent third party. This provision, however, shall not
obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus,
if after consideration of potential settlements, an attorney representative elects to file a
contested lawsuit pursuant to 18 U.S.C. $ 2255 or elects to pursue any other contested
remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney
representative, as opposed to any statutory or other obligations to pay reasonable
attorneys fees and costs such as those contained in S 2255 to bear the costs of the attorney
representative, shall cease.
EFTA00014055

=== Page 11 ===
By signing this Addendum, Epstein asserts and certifies that the above has been read and
explained to him. Epstein hereby, states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated:
By:
ASSISTANT U.S. ATTORNEY
Dated: 10/29/07
X SEFEREY EPSTEIN
Dated:
GERALD LEFCOURT, ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated:
LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
EFTA00014056

=== Page 12 ===
By signing this Addendum, Epstein asserts and certifies that the above has been read and
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated:
By:
ASSISTANT U.S. ATTORNEY
Dated:
JEFFREY EPSTEIN
Dated: 10/29/07
GERALD LEFCOURT ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated:
LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
EFTA00014057

=== Page 13 ===
By signing this Addendum, Epstein asserts and certifies that the above has been read and
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated:
By:
ASSISTANT U.S. ATTORNEY
Dated:
JEFFREY EPSTEIN
Dated:
GERALD LEFCOURT, ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated: 10-29-07
LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
EFTA00014058

=== Page 14 ===
Dec-07-07 04:55pm From-Fowler-Whi to Burnett
3057899201
T-966 P.003/004 F-976
Affirmation
I, Jeffrey E. Epstein do hereby re-affirm the Non-Proscoution Agreement and Addendum to
same dared October 30, 2007.
Jeffrey x E. Epstein
12/7/04
Date
EFTA00014059


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=== Page 1 ===
Exhibit V
EFTA00011221

=== Page 2 ===
William JULIÉ
avocat à la cour - attorney at law
Ghislaine Maxwell
Opinion on French Extradition Law
OVERVIEW
This report was written pursuant to a request from Olivier Laude, a partner at the French
firm Laude Esquier Champey acting on behalf of Cohen & Gresser LLP as counsel for
Ms Ghislaine Maxwell, in the context of ongoing bail proceedings involving the latter
in the United States of America (hereafter "USA"), where Ms Ghislaine Maxwell is
being detained pre-trial on charges relating to her alleged role in sexual activities
between Jeffrey Epstein and certain minor girls, from 1994 to 1997.
Olivier Laude has instructed me to draft an opinion regarding the French extradition
procedure and the possibility for Ms Ghislaine Maxwell to be extradited from France to
the USA if she were to flee to France after being released on bail in the USA.
As requested, I have attached a resume. (See Exhibit A).
EXECUTIVE SUMMARY
The principle against the extradition of French nationals does not constitute a binding
rule of international law and is not considered a constitutional principle under French
law.
The extradition of French nationals can be prohibited under the terms of an international
treaty. However, the existing Extradition Treaty between France and the USA of 23
April 1996 does not contain such prohibition. As a result, the extradition of a French
national to the USA is legally permissible under French law.
In order to assure the US authorities that she will not attempt to contest her extradition
as a French citizen or otherwise, we are informed that Ms Maxwell is about to execute
an irrevocable waiver of her right to seek the protection of the French Courts to fight
- 75017 paris - tél.
- fax.
-
1
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=== Page 3 ===
William JULIÉ
avocat à la cour - attorney at law
any extradition request from the US Government to the competent French Authorities
("The Waiver"). (See Exhibit B).
All extradition requests from the USA to France must be examined by the Investigating
Chamber of the competent Court of appeal, which has jurisdiction over the legality of
extradition requests in France.
Under the circumstances of this case, where Ms Maxwell would have fled from the USA
to France prior to her trial in violation of her bail conditions, it is highly likely that Ms
Maxwell would be placed in custody in France from the earliest stages of the extradition
proceedings.
As the principle against the extradition of nationals is not part of the Extradition Treaty
between the USA and France, the Investigating Chamber of the Court of appeal would
not oppose the extradition of Ms Ghislaine Maxwell on the ground that she is a French
citizen.
The final decision to extradite and its execution would ultimately be a matter for the
executive.
In the recent past, I am not aware that the French authorities would have had to address
the situation in which the United States sought extradition of a French citizen who was
also a United States citizen. Thus, there is no precedent to draw from in that
regard. However, it is our view that under the specific and unique facts of this case, it
is highly unlikely that the French government would refuse to issue and execute an
extradition decree against Ms Maxwell because of several critical factors, namely: her
United States citizenship; the fact that she has signed an irrevocable Waiver in the USA;
the fact that in the present situation, the only way the issue would be raised in France is
if Ms. Maxwell would have already fled to France in violation of very strict bail
conditions, and the fact that a failure by French authorities to grant extradition would
result in an obligation to try Ms. Maxwell before French courts for the conduct described
in the Indictment. Finally, France would be inclined to preserving the interests of the
USA for obvious diplomatic reasons.
With regard to timing, if the requested person has consented to extradition, the
Investigating Chamber must deliver its ruling no later than 14 working days after the
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2
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=== Page 4 ===
William JULIÉ
avocat à la cour - attorney at law
person has first appeared before the Public Prosecutor¹. If the legal conditions of
extradition are satisfied, the Investigating Chamber must issue a positive opinion to
extradition, which is not subject to appeal. Following the Investigating Chamber's
ruling, there is no specified time frame within which the government must issue an
extradition decree. However, if the requesting State emphasizes the urgent nature of the
request, the extradition decree is generally issued in only a few weeks. Therefore, the
overall procedure is likely to be disposed of expediently under these circumstances.
1 The 14 days period is divided as follows: the requested person must appear before the Public Prosecutor within
2 days of arrest, he or she must be heard by the Investigating Chamber no later than 5 working days after appearing
before the Public Prosecutor, and the Investigating Chamber must then deliver its final opinion on the legality of
the extradition request within 7 days. This procedure will be explained in more details in Part I of this opinion.
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=== Page 5 ===
William JULIÉ
avocat à la cour - attorney at law
Table of Contents
Background
Part I - The French Extradition Procedure
A. Request for temporary arrest
B. Application for extradition (Ministerial phase)
C. Arrest and presentation before the Prosecutor General (beginning of the
judicial phase)
D. Decision of the Investigating Chamber of the competent Court of appeal
E. Decision of the French government (Extradition Decree)
F. Possible application before the European Court of Human Rights
Part II - The likely outcome of an extradition request from the United States of America
to France in the case of Ms Ghislaine Maxwell
A. General bars to extradition
B. The protection of nationals from extradition under French law and the
Extradition Treaty between the USA and France: Lack of an absolute
protection
Conclusion
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=== Page 6 ===
William JULIÉ
avocat à la cour - attorney at law
Background
1. At the bail hearing of Ms Ghislaine Maxwell on 14 July 2020, the US Government made
the following point in support of its motion to detain the defendant:
"The government has spoken with the Department of Justice attachés in the
United Kingdom and France. With respect to France, we have been informed
that France will not extradite a French citizen to the United States as a
matter of law, even if the defendant is a dual citizen of the United States. "2.
2. The international ties of Ms Ghislaine Maxwell and her French nationality appear as one
of the grounds for which bail was denied by the Court, which found that:
"Ms Maxwell's history and characteristics support the position of her posing a risk of
flight. Ms Maxwell has substantial international ties and could facilitate living abroad
if she were to flee the United States. She holds multiple foreign citizenships, has familial
and personal connections abroad, and owns at least one foreign property of significant
value. In particular, she is a citizen of France, a nation that does not appear to
extradite its citizens"
3. The present report intends to evaluate whether the contention that France is a nation that
does not extradite its citizens is correct as a matter of law.
4. It will first set out the various steps of the French extradition procedure (Part I), and
then outline the grounds on which extradition requests are analyzed under French law,
and especially the status of the rule against extradition of nationals, in order to assess the
application of these principles to an extradition request made by the USA, in particular
where, as in this case, the requested person has executed an irrevocable waiver of his/her
right to contest extradition and is present in France only because she fled the United
States in violation of her bail conditions. (Part II).
2 At p. 27 of the transcript.
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=== Page 7 ===
William JULIÉ
avocat à la cour - attorney at law
Part I - The French Extradition Procedure
5. Extradition requests between the United States and France are governed by the
Extradition Treaty between the USA and France signed in Paris on 23 April 1996³, the
Agreement on Extradition between the United States of America and the European
Union signed in Washington on 25 June 20034, and the Instrument Amending the Treaty
of 23 April 1996 between the United States of America and France signed in the Hague
on 30 September 2004⁵.
6. For matters not covered in these agreements, extradition requests made by the USA are
governed by provisions of the French Code of Criminal Procedure (Articles 696 et seq.).
A. First stage: Request for temporary arrest
7. Under Article 13.1 of the Extradition Treaty between the USA and France, in case of
urgency, the requesting State may seek the provisional arrest of the person sought
pending the presentation of the request for extradition6.
8. This procedure can be summarized as follows:
- Based on a request for provisional arrest, the Prosecutor General may order the
arrest of the requested person.
- Upon arrest, the requested person must appear within 48 hours before the Prosecutor
General, who informs him/her of the existence and contents of the request for
temporary arrest and of his/her rights.
- The Prosecutor may decide to release the requested person, based on the relevant
flight risks.
- If the Prosecutor considers that the requested person should be detained, the
requested person appears before the 1st President of the Court of appeal, who can
decide to order either his/her release (without any control, or under judicial
3 The Extradition Treaty between the USA and France entered into force in France on February 1, 2002 (by Decree
n° 2002-117 of 29 January 2002).
4 The object of this agreement is "to provide for enhancements to cooperation in the context of applicable
extradition relations between the Member States and the United States of America governing extradition of
offenders" (Article 1).
5 The Instrument Amending the Treaty of April 23, 1996 between the USA and France entered into force in France
on February 1, 2010 (by Decree n° 2010-490 of 12 May 2010).
6 A request for provisional arrest may be transmitted directly between the United States Department of Justice
(hereafter, "DOJ") and the Ministry of Justice of the French Republic, through INTERPOL or the diplomatic
channel.
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supervision, or under house arrest with electronic surveillance) or incarceration at
the remand prison of the Court of appeal in which jurisdiction he/she has been
apprehended.
- The decision of the 1st President of the Court of Appeal can be challenged before
the Investigating Chamber of the Court of Appeal.
- In case of incarceration, the requested person can file an application for release
before the Investigating Chamber of the Court of appeal at any time during the
extradition procedure.
9. Under Article 13.4 of the Extradition Treaty between the USA and France, if, within 60
days of arrest, the government of the requested State has not received from the requesting
State the formal extradition request as well as supporting documents required by the
Treaty⁷, the requested person is discharged from custody. If the government has received
the relevant documents, the normal extradition procedure may begin.
10. If the person has been discharged from custody pursuant to Article 13.4 of the Treaty,
such release does not preclude a subsequent re-arrest if an extradition request and
supporting documents are delivered at a later date (Article 13.5).
B. Second stage: Application for extradition (Ministerial phase)
11. Article 10.1 of the Extradition Treaty between the USA and France provides that "all
requests for extradition shall be submitted through the diplomatic channel".
12. The Extradition Treaty between the USA and France does not specify which internal
procedures must be followed in each contracting State following the transmission of the
extradition request through the diplomatic channel pursuant to Article 10. We must
therefore refer to provisions of the French Code of Criminal Procedure to outline the
procedure followed by French institutions upon receipt of an extradition request made
by the USA.
13. Under Article 696-9 of the French Code of Criminal Procedure, the procedure followed
in France is as follows:
7 Article 10 of the Extradition Treaty between the USA and France
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-
The Minister of Foreign Affairs first verifies that the file is properly constituted in
accordance with the requirements of the Extradition Treaty. The Minister of Foreign
Affairs only verifies that the request contains all the required documents.
-
The file is then transmitted to the Minister of Justice, which verifies the regularity
of the request. At this stage, the French nationality of the requested person does not
influence the control of the Minister of Justice.
- The Minister of Justice must then forward the file to the Prosecutor General. This
obligation to transmit the file to the Prosecutor General is binding, as Article 696-9
uses imperative language requiring the Minister of Justice to do so.
C. Third stage: Arrest and presentation before the Prosecutor General (beginning of
the judicial phase)
14. Any person arrested pursuant to an extradition application must be transferred to the
territorially competent Prosecutor General within 48 hours after the arrest8.
15. The Prosecutor General informs the requested person, in a language he or she
understands, of:
- the existence and the content of the extradition application;
- the right to be assisted by an advocate and to have an interview with this advocate
immediately;
-
the right to consent to or to oppose his or her extradition, and the legal consequences
of consenting to extradition;
-
the right to waive the principle of specialty (according to which the person who is
extradited can be prosecuted only for the crimes specified in the extradition request),
and the legal consequences of such renunciation.
16. The Prosecutor General hears the statements of the person and his or her counsel, and in
particular, the consent or opposition to extradition, which shall be officially recorded.
17. The Prosecutor General decides whether to release the requested person or not. If he
considers that the requested person should remain in detention, the requested person then
appears before the 1st President of the Court of appeal, who may order the person's
release (without any control, or with judicial supervision, or under house arrest with
electronic surveillance) or his/her incarceration. The 1st President's decision may be
8 Article 696-10 of the French Code of Criminal Procedure.
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appealed before the Investigating Chamber of the Court of appeal, by the Prosecutor
General or the requested person.
D. Fourth stage: Decision of the Investigating Chamber of the competent Court of
appeal
18. Once the requested person has declared to the Prosecutor General whether he consents
or not to extradition, the Investigating Chamber is immediately seized of the case. This
phase varies depending on whether the requested person consents to extradition.
19. If the requested person has declared to the Prosecutor General that he or she consents to
extradition, Article 696-13 of the French Code of Criminal Procedure provides that he
or she must appear before the Investigating Chamber within 5 working days from the
date of presentation before the Prosecutor General. The same provision states that the
requested person may also decide to waive the rule of specialty before the Prosecutor
General.
20. If, at this appearance, the requested person confirms his or her consent to be extradited
and the legal conditions for extradition are fulfilled, the Investigating Chamber informs
the person of the legal consequences of such consent and formally acknowledges this
consent within 7 days from the date of appearance, unless additional investigations have
been ordered⁹.
21. The rules of this simplified extradition procedure must be read in light of Article 11 of
the Agreement on Extradition between the European Union and the USA of 25 June
2003 ("Simplified extradition procedures"), which states that "if the person sought
consents to be surrendered to the requesting State, the requested State may, in
accordance with the principles and procedures provided for under its legal system,
surrender the person as expeditiously as possible without further proceedings. The
consent of the person sought may include agreement to waiver of protection of the rule
of specialty"10. This provision, together with Article 696-13 of the French Code of
Criminal Procedure, demonstrates that extradition law is considerate of the requested
9 Article 696-14 of the French Code of Criminal Procedure.
10 Such Article 11 of the Agreement on Extradition between the European Union and the USA of 25 June 2003
has been directly incorporated in the Extradition Treaty between the USA and France signed in Paris on 23 April
1996 by the Instrument Amending the Treaty of 23 April 1996 between the United States of America and France
signed in the Hague on 30 September 2004.
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person's intentions and recognizes that the person may legally waive some of the rights
that attach to extradition proceedings.
22. Where the requested person has consented to extradition, the Investigating Chamber's
ruling is not subject to appeal or any other legal challenge¹¹
23. If the requested person has declared to the Prosecutor General that he or she does not
consent to extradition, he or she must appear before the Investigating Chamber within a
period of 10 working days from the date of presentation before the Prosecutor¹².
24. If the requested person reiterates to the Investigating Chamber that he or she does not
consent to extradition, the Court delivers a reasoned opinion on the extradition request.
Unless additional investigations have been ordered, the Court delivers its opinion within
one month from the requested person's appearance before it¹³.
25. The Investigating Chamber may authorize the requesting State to participate in the
hearing. This possibility is expressly provided for in the Agreed Minute on
Representation annexed to the Extradition Treaty between the USA and France.
26. The Investigating Chamber issues a positive opinion if it considers that the legal
requirements of extradition are satisfied.
E. Fifth stage: Decision of the French government
27. Extradition is authorized by a decree of the French Prime Minister upon the advice of
the Minister of Justice.
28. The decree may impose conditions to authorize extradition, such as guarantees not to
seek or impose the death penalty against the requested person.
29. The decree of extradition can only intervene after the end of the judicial phase.
11 Id.
12 Article 696-15 of the French Code of Criminal Procedure.
13 Id.
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30. The requested person has to be handed over by the agents of the requested State within
one month after the extradition decree has been notified to the requesting State¹⁴.
14 Article 15.4 of the Extradition Treaty between the USA and France of 23 April 1996.
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F. Sixth stage: Possible application before the European Court of Human Rights
31. Once all domestic remedies have been exhausted, it is possible to file a written
application against France before the European Court of Human Rights, within six
months from the date of the final decision at the domestic level, alleging the violation of
human rights protected by the European Convention of Human Rights, such as the rights
to life, to a fair trial, not to be tortured, etc.
32. An application before the European Court of Human Rights may be accompanied by a
written request for interim measures, pursuant to Rule 39 of the Rules of Court, such as
a request to suspend the extradition of the applicant pending the outcome of the
proceedings.
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Part II - The likely outcome of an extradition request from the United States of
America to France in the case of Ms Ghislaine Maxwell
33. In this case, if an extradition request were to be transmitted by the USA against Ms
Ghislaine Maxwell, the French judicial authorities would most certainly decide that she
has to remain in custody given her flight from the USA and the violation of her bail terms
and conditions in this requesting State.
34. Having outlined the different stages of the French extradition procedure, the second part
of this opinion will examine the likely outcome of an extradition request against the
person of Ms Ghislaine Maxwell, if she were to be released on bail and decided to flee
from the USA to France. It will first outline the general bars to extradition (A), and then
analyze the status of the protection of nationals from extradition in the French legal
system and in the Extradition Treaty between the USA and France (B). It will conclude
that Ms Ghislaine Maxwell's extradition from France to the USA would not be legally
barred by her French citizenship, and that it is highly unlikely, under the specific and
unique circumstances of this case, that French authorities will refuse to enforce an
extradition decree.
A. General bars to extradition
35. Several bars to extradition may classically be invoked before French courts, namely (i)
a claim that the requested person would be at risk of human rights violations in the
requesting State (with regards to the right to a fair trial and the right to be free from
torture, inhumane or degrading treatment); (ii) the dual criminality rule; and (iii) a claim
that the extradition request is politically motivated.
(i)
Human rights bars
36. Under the case law of the French Cour de cassation, the Investigating Chamber of the
Court of appeal must consider allegations of human rights violations pertaining to the
conditions of trial and detention in the requesting State¹⁵ These claims center on the
right to a fair trial (Article 6 ECHR)¹⁶ and the right to be free from torture, inhumane
15 Cass. Crim., 26 March 2019, nNo. 19-81731.
16 Einhorn V. France, 16/10/2001, Application No. 71555/01.
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and degrading treatments in custody (Article 3 ECHR)¹⁷. If the Investigating Chamber
finds that the requested person would face a risk of being subject to violations of their
Article 3 rights, or that there is a risk of a "flagrant denial of "justice" in the requesting
State, it must deliver a negative opinion to the extradition request.
37. In the recent years, human rights bars to an extradition request made by the United States
of America are only the subject to in-depth scrutiny by French courts when the requested
person faces the imposition of the death penalty18 or the imposition of a life
imprisonment sentence without the possibility of parole in the USA. We understand that
this is not the case here. It can be underlined that, when needed, the USA can commit
not to impose such a sentence and that such a commitment suffices to allow extradition.
38. As long as the French government receives necessary assurances related to human rights
when requested, such an argument would be very likely to be rejected in this case.
(ii)
Dual criminality
39. A further possible bar to extradition is the dual criminality rule, which requires the
conduct in respect of which extradition is sought to constitute a criminal offense in the
law of both requested and requesting States.
40. Article 2.1 of the Extradition Treaty between the USA and France expressly states that
"[a]cts shall be extraditable if they are punished under the laws in both States by
deprivation of liberty for a maximum of at least one year or by a more severe penalty. If
extradition is requested for purposes of enforcing a judgment, the time remaining to be
served must be at least six months."
41. There is no doubt that the conduct referred to in the Grand Jury charges against Ms
Ghislaine Maxwell, contained in the Superseding Indictment SI 20 Cr. 330 (AJN), filed
on July 8th, 2020, also constitutes criminal conduct under French law, as the crime of
"proxénétisme".
42. Article 225-5 of the French Criminal Code defines the crime of "proxénétisme" as "the
fact, by anyone, in any manner whatsoever: 1° To aid, assist or protect the prostitution
17 Soering v United Kingdom, 07/07/1989, Application No. 14038/88; Cass. Crim., 26 March 2019, No. 19-81731.
18 In this regard, see Article 7 of the Extradition treaty between France and the USA.
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of others; 2° To profit from the prostitution of others, to share the proceeds of
prostitution or to receive subsidies from a person habitually engaged in prostitution; 3°
To hire, entice or divert a person to engage in prostitution or to exert pressure on him
or her to engage or continue to engage in prostitution. 19" Article 225-6 of the French
Criminal Code provides that the crime is also established by "the fact, by whoever, in
any way whatsoever: 1° To act as an intermediary between two persons, one of whom
engages in prostitution and the other exploits or remunerates the prostitution of
others20".
43. In French law, the conduct charged in all four counts21 would qualify as the crime of
"proxénétisme" under Articles 225-5 and 225-6 of the French Criminal Code.
44. When committed against a minor, Article 225-7 of the French Criminal Code provides
that the crime is punished by an enhanced sentence, namely a statutory maximum of 10
years imprisonment (as opposed to 7 years, when committed against an adult)²².
45. Thus, dual criminality would not constitute an obstacle to Ms Ghislaine Maxwell's
extradition from France to the USA.
(iii)
Political offense and manifest inconsistency
46. Finally, the requested person may argue that the extradition request is politically
motivated, or that the charges contained in the extradition request are manifestly
inconsistent with the conduct thereunder.
19 In French, « Le proxénétisme est le fait, par quiconque, de quelque manière que ce soit :1° D'aider, d'assister
ou de protéger la prostitution d'autrui ; 2° De tirer profit de la prostitution d'autrui, d'en partager les produits ou
de recevoir des subsides d'une personne se livrant habituellement à la prostitution ; 3° D'embaucher, d'entrainer
ou de détourner une personne en vue de la prostitution ou d'exercer sur elle une pression pour qu'elle se prostitue
ou continue à le faire ».
20 In French, (( Est assimilé au proxénétisme et puni des peines prévues par l'article 225-5 le fait, par quiconque,
de quelque manière que ce soit : 1° De faire office d'intermédiaire entre deux personnes dont l'une se livre à la
prostitution et l'autre exploite ou rémunère la prostitution d'autrui [...] >>.
21 Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts; Enticement of a Minor to Travel to Engage
in Illegal Sex Acts; Conspiracy to Transport Minors with Intent to Engage in Criminal Sexual Activity;
Transportation of a Minor with Intent to Engage in Criminal Sexual Activity.
22 "Proxénétisme is punishable by ten years imprisonment and a fine of 1,500,000 euros when committed: 1° With
regard to a minor [...]". In French « Le proxénétisme est puni de dix ans d'emprisonnement et de 1 500 000 euros
d'amende lorsqu'il est commis : 1° A l'égard d'un mineur ».
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47. Article 4 of the Extradition Treaty between the USA and France provides that
"[e]xtradition shall not be granted by France when the offense for which extradition is
requested is considered by France as a political offense or as an offense connected with
a political offense or as an offense inspired by political motives".
48. A political motivation claim requires the Investigating Chamber to examine, to some
extent, the merits of the case. The Court is also required to look into the merits of the
case where the requested person argues that there is a manifest inconsistency between
the conduct and the legal offenses in respect of which the extradition is sought²³.
49. The conduct described in the indictment does not appear to be manifestly inconsistent
with the offenses charged therein.
50. As to political motivation, French courts have never opposed extradition requests from
the USA on this ground²⁴. In fact, in the past ten years, only one published decision of
the Cour de cassation has denied an American extradition request, on the ground that
the Investigating Chamber had not verified that the criminal conduct described in the
request constituted a crime in France at the time of commission²⁵. All other published
decisions which have ruled on a request from the USA have granted extradition²⁶.
51. In light of the elements contained in the Superseding Indictment, Ms Ghislaine Maxwell
could not oppose her extradition to the USA on the basis of a political motivation claim,
that would have no serious ground, and therefore the Investigating Chamber would not
look into the merits of the case against her.
B. The protection of nationals from extradition under French law and the Extradition
Treaty between the USA and France: Lack of an absolute protection
23 Cass. Crim., 21 November 2007, No. 07-87540.
24 See by contrast, a 2016 recent decision of the Conseil d "Etat to deny extradition to Russia of a prominent figure
of the Kazakh opposition, Moukhtar Abliazov, on the ground that the request was politically motivated (available
at:
https://www.legifrance.gouv.fr/ceta/id/CETATEXT000033581187/).
25 Cass. Crim., 14 October 2015, No. 15-84426.
26 Cass. Crim., 11 March 2020, No. 19-84023 ; Cass. Crim., 21 February 2017, No. 16-87102 ; Cass. Crim., 23
February 2010, No. 09-88021 ; Conseil 'Etat - 2ème et 7ème SSR, 15 April 2016, No. 390860 ; Conseil d'Etat
- 2èᵐᵉ et 7èᵐᵉ SSR, 19 October 2018, No. 421762 ; Cass. Crim., 4 June 2019, No. 18-84398 ; Cass. Crim., 26
November 2019, No. 19-80274 ; Conseil d'État - 2èᵐᵉ et 7ème SSR, 1 June 2011, No. 342419 ; Cass. Crim., 21
June 2016, No. 16-81981 ; Cass. Crim., 4 October 2016, No. 16-84450 ; Cass. Crim., 11 May 2011, No. 11-
80942, No. 11-80943 ; Cass. Crim., 10 May 201, No. 11-80989 ; Conseil d'Etat, - 2èᵐᵉ et 7èᵐᵉ SSR, 7 May
2012, No. 352573 ; Cass. Crim, 13 February 2008, No. 07-88009 ; Cass. Crim., 3 March 2015, No. 14-88308 ;
Cass. Crim., 11 June 2013, No. 13-81979.
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52. Chapter V of the French Code of Criminal Procedure (Articles 696 to 696-47-1) sets out
legislative provisions pertaining to extradition.
53. The rule against the extradition of nationals is set out under Article 696-4, which states
that extradition shall not be granted when the requested person is a French national, and
that nationality shall be assessed at the time of the facts in respect of which extradition
is sought (« Extradition is not granted: 1° When the person sought has the French
nationality, the latter being assessed at the time of the offence for which extradition is
requested. »²⁷).
54. The rule under Article 696-4 only applies "in the absence of an international
convention stipulating otherwise"28. Therefore, we must determine whether the rule
against the extradition of nationals contained in the French Code of Criminal
Procedure applies in respect of an extradition request made by the USA.
55. Extradition requests between the United States and France are governed by the
Extradition Treaty between the USA and France 1996²⁹, which supersedes French law
as mentioned explicitly in Article 696 of the French Code of Criminal Procedure.
56. Article 3(1) of the Extradition Treaty between France and the United States provides:
"There is no obligation upon the Requested State to grant the extradition of a
person who is a national of the Requested State, but the executive authority of the
United States shall have the power to surrender a national of the United States if,
in its discretion, it deems it proper to do so. The nationality of the person sought
shall be the nationality of that person at the time the offense was committed".
27 In French : « L'extradition n'est pas accordée : 1° Lorsque la personne réclamée a la nationalité française, cette
dernière étant appréciée à l'époque de l'infraction pour laquelle l'extradition est requise ».
28 Article 696 of the French Code of Criminal Procedure: "In the absence of an international convention stipulating
otherwise, the conditions, procedure and effects of extradition shall be determined by the provisions of this chapter.
These provisions shall also apply to matters which would not have been regulated by international conventions". (In
French, « En l'absence de convention internationale en stipulant autrement, les conditions, la procédure et les
effets de l'extradition sont déterminés par les dispositions du présent chapitre. Ces dispositions s'appliquent
également aux points qui n'auraient pas été réglementés par les conventions internationales »).
29 The Extradition treaty between the USA and France was signed in Paris on April 23, 1996 and entered into force
on February 1, 2002 (by Decree No. 2002-117 of 29 January 2002).
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57. If extradition is refused solely on the basis of the nationality of the person sought, Article
3(2) requires the requested State to submit the case to its authorities for prosecution, if
so requested by the requesting State.
58. Consequently, the Extradition Treaty between France and the USA does not
contain any prohibition on the extradition of nationals. Instead, it merely states that
there is no obligation upon the requested State to grant the extradition of a person who
is one of its nationals.
59. The Extradition Treaty between France and the USA must therefore be distinguished
from several international agreements on extradition ratified by France, which, by
contrast, contain a clear rule against the extradition of French citizens³⁰.
60. For example, France has made the following declaration pursuant to Article 6 of the
European Convention on Extradition 1957, which gives Contracting States "the right to
refuse extradition of nationals":
"Extradition shall be refused when the person sought had French nationality at the time
of the alleged offence
61. Therefore, France does not surrender French citizens under the European Convention on
Extradition³²
62. The Extradition Treaty between France and the USA is similar to other international
agreements signed by France which also do not contain a prohibition against the
extradition of nationals. These are generally treaties signed with Common law
jurisdictions, which do not oppose the extradition of their nationals³³.
30 See, for example, the Extradition treaty between France and Morocco, or the Extradition treaty between France
and China.
31 See France's instrument of ratification of the European Convention on Extradition, deposited on 10 February
1986.
32 The European Convention on Extradition 1957 is an instrument of the Council of Europe which was signed in
Paris on December 13th, 1957 and came into force on April 18th, 1960. The European Convention on Extradition
is open to signature by non-Council of Europe States, as such it was ratified by South Africa, Israel, and the
Republic of Korea. It was ratified by France on February 10th, 1986.
33 For example, the Extradition Treaty between France and Canada, signed in Ottawa on 17 November 1988,
contains a similar provision to the United States Treaty: "The requested State shall not be bound to extradite its
own nationals. Nationality shall be determined as of the date of the offence for which extradition is requested"
(Article 3).
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63. The wording of these international agreements, which do not contain a prohibition on
the extradition of nationals, raises some important questions. In particular, could France
decide to extradite its nationals on the basis of these international agreements without
violating applicable international law, European law, or French constitutional law?
64. In order to determine whether the French government may grant an extradition request
relating to a French citizen under the Extradition Treaty between France and the USA, it
is thus necessary to evaluate the strength and status of the prohibition of the extradition
of nationals under (i) applicable international law, (ii) European law, and (iii) French
constitutional law.
(i)
International law
65. As outlined, international treaties pertaining to extradition generally leave Contracting
States a right not to extradite their nationals, and State practice largely varies in this
regard. Some States are strongly committed to the rule against the extradition of nationals
and have conferred the principle constitutional status (Germany, Poland, Greece,
Portugal, Estonia, Austria). Others have codified the principle in their national legislation
(France, Lebanon, Chili, Qatar, Slovenia). By contrast, many States - in particular,
Common law jurisdictions, including the United Kingdom, Australia, and the USA,
extradite their own citizens.
66. Thus, there is no uniform rule regarding the extradition of nationals under international
law.
(ii)
European law
67. European law does not prohibit the extradition of nationals either. As mentioned, Article
6 of the European Convention on Extradition 1957 provides States with a discretionary
right on whether or not to extradite their own citizens.
68. More interestingly, the European Arrest Warrant Framework Decision of 13 June 2002
(hereafter, "EAW FD"), which governs extradition matters between Member States of
the European Union, does not allow Member States the possibility to refuse the surrender
of their nationals when the EAW is issued for the purpose of conducting a criminal
prosecution. In fact, the surrender of a national who is the subject of criminal proceedings
in another Member State of the European Union is at the cornerstone of the EAW FD.
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William JULIÉ
avocat à la cour - attorney at law
69. Articles 3 and 4 of the EAW FD set out a number of grounds for refusing the enforcement
of a EAW, that are respectively mandatory and optional. Article 4(6) on optional grounds
provides that a Member State may refuse the execution of a EAW « issued for the
purposes of execution of a custodial sentence or detention order, where the requested
person is staying in, or is a national or a resident of the executing Member State and that
State undertakes to execute the sentence or detention order in accordance with its
domestic law ». This article is the only provision in the EAW FD that allows Member
States to consider nationality in the execution of a EAW. As such, nationality can only
act as a bar to the execution of a EAW issued for the purpose of executing a custodial
sentence, not conducting a criminal prosecution.
70. It follows that European Union law does not prohibit the extradition of nationals.
(iii)
French constitutional law
71. As regards the status of the protection of nationals from extradition under French law,
the fact that France did not have to change its Constitution or domestic laws regarding
the extradition of nationals to incorporate the EAW FD effectively means that the
prohibition against the surrender of a French citizen to foreign authorities does not
constitute an absolute prohibition per se under French law³⁴.
72. The Conseil Constitutionnel (French constitutional Court) has long considered that France
could not ratify an international amendment which went against the Constitution, thereby
necessitating a modification of the text of the Constitution prior to the ratification of the
purported international treaty35. For example, the Constitution had to be amended prior to
the ratification of the Rome Statute, to create an exception to the rule that the President of
the Republic cannot be found criminally liable in respect of acts committed during his
mandate. By contrast, the provisions of the Rome Statute which require Contracting Parties
to surrender their nationals when the jurisdiction of the International Criminal Court is
established did not trigger an amendment to the French Constitution. Like the EAW FD,
the example of the Rome Statute must be taken as evidence that there is no constitutional
principle against the extradition of nationals in France.
34 By contrast, several Member States of the EU such as Germany, Poland or Cyprus, had to amend their national
constitutions prior to incorporating the EAW FD, following constitutional courts' rulings.
35 Décision No. 98-408 DC, 22 Janvier 2009.
- 75017 paris - tél.
- fax.
-
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EFTA00011241

=== Page 22 ===
William JULIÉ
avocat à la cour - attorney at law
73. The Conseil d'Etat was once asked by the French government to deliver an opinion
precisely on this point. It stated that the government's practice of refusing the extradition
of nationals "finds no basis in a principle of constitutional value. None of the rights and
liberties of the citizen, as proclaimed by the Declaration of the Rights of Men and
Citizens of 1789 and by the preamble of the Constitution of 1946, implies that nationals
cannot be extradited [...] No doubt the laws adopted and the international conventions
signed by France attest to the authority of the rule that nationals are not extradited. But,
in support of this rule, there are no grounds for considering it as a fundamental principle
recognized by the laws of the Republic, having constitutional value by virtue of the
Preamble to the Constitution of 1946. »³⁶.
74. Therefore, the French Constitution does not prevent the executive from extraditing
French citizens.
75. It follows from this opinion and the above that the decision to apply the principle against
the extradition of nationals is a matter for the executive, which could choose not to
enforce it and thus choose to extradite a national without violating French constitutional
law, European law or international law, taking into account the provisions of the
Extradition Treaty between the USA and France of 23 April 1996 which supersede
French law and do not prohibit the extradition of French nationals.
Conclusion
76. In the event that Ms Ghislaine Maxwell were to flee to France and become the subject
of an extradition request, and where she has already executed an irrevocable waiver of
her right to contest extradition, the Investigating Chamber would have to rule on the
legality of the extradition request in accordance with the procedure described in Part I.
Because the extradition of French nationals is not prohibited by the Constitution or the
Extradition Treaty between the USA and France, the Investigating Chamber would not
be legally bound to oppose to the extradition request. It would then become a matter for
the French government to decide on whether or not to issue an extradition decree against
Ms Ghislaine Maxwell.
77. In the recent past, I am not aware that the French authorities have had to address the
situation in which the United States sought extradition of a French citizen who was also
36 « Avis Consultatif, Conseil l'Etat, 24 November 1994, No. 356-641 », available at https://www.conseil-
etat.fr/jadefile/avisadm/356641.pdf
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- fax.
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=== Page 23 ===
William JULIÉ
avocat à la cour - attorney at law
a United States citizen. Thus, there is no precedent to draw from in that
regard. However, it is our view that under the specific and unique facts of this case, it is
highly unlikely that the French government would refuse to issue and execute an
extradition decree against Ms Maxwell because of several critical factors.
78. First, under the applicable Extradition Treaty between the USA and France, a State party
may refuse extradition on the basis of nationality, however if it does so, it is obliged to
prosecute the requested person itself, on the basis of the conduct and the allegations
contained in the request. In the case of Ms Ghislaine Maxwell, it is highly unlikely that the
French government would be inclined to conducting such prosecution, considering that all
the relevant facts were committed in the USA, a long time ago, and that witnesses are also
located in the USA.
79. Secondly, France is mindful to preserve its good extradition relations with the United
States, as evidenced by a number of recent cases we reviewed or conducted in which
French competent authorities proved highly cooperative with US authorities. If Ms
Ghislaine Maxwell were to flee to France, and the USA decided to issue an extradition
request, it would be difficult for French authorities - from a diplomatic point of view - to
deny such an extradition request, considering that no legal bar applies.37
80. Thirdly, the fact that Ms Ghislaine Maxwell also holds American nationality, and has
substantial ties to the USA, would, in all likelihood, be taken into account by the French
government as one more element weighing in favor of extradition.
81. Similarly, and fourthly, the fact that Ms Ghislaine Maxwell signed a legally binding
Waiver under US law, and would have subsequently fled to France in violation of her bail
conditions, could equally be taken into account by the French government as an incentive
not to grant Ms Ghislaine Maxwell the benefit of her French nationality as a ban to
extradition.
William Julié
37 Of the 36 reported Supreme Court decisions involving extradition requests from the United States in the last 20
years, the French authorities granted extradition in 34 of these cases. Lower court decisions granting extradition
were quashed only twice for procedural deficiencies not at issue in this case.
- 75017 paris - tél.
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-
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EFTA00011243

=== Page 24 ===
Exhibit A
EFTA00011244

=== Page 25 ===
WILLIAM JULIÉ
AVOCAT
75017 Paris
Date of birth:
French English and German national
Set up my own practice in 2002
www.wjavocats.com
Marathon Runner (Paris, 2013, 2h57)
EMPLOYMENT
Since 2002
Founding partner of William Julié Avocats
INTERNSHIPS & LAW STUDIES
2000-2002
Internships specialized in human rights and criminal law:
Henri Leclerc (President of the French Ligue des Droits de l'Homme)
Eric Plouvier (Human Rights barrister)
2000
Admitted to the Paris Bar
1999
Postgraduate Specialization Diploma: Criminal Law and Criminal Justice
Policy in Europe
Thesis Supervisor Mme Delmas Marty, University of Paris Sorbonne
1999
Certificate of criminal sciences, University of Paris Assas
EXTRADITION LAW
Extradition cases in and outside the EU, including USA, Saudi Arabia, China, Russia,
South Korea, Japan, Irak, Iran, Lebanon, India
Regularly appears as French judicial expert before Common law courts on extradition issues
and prison detention conditions (UK, Hong Kong, USA)
Mutual legal assistance: cooperation with various investigation authorities on international
cases (DEA, FBI, SFO, OCTRIS), cross-border penitentiary law (repatriation)
Obtained in 2017 a major change in French extradition law (right to challenge European arrests
warrants issued against foreigners - Michael Ofsowitz case)
CRIMINAL LAW
Testified before the Parliamentary Enquiry into miscarriages of justice during the Outreau trial
Fraud cases, including Emmanuel Henning 40 million pounds mobile phone VAT fraud in the
UK, and Marseilles 385 Million carbon gas fraud
Business criminal law (money laundering, bribery and corruption, misappropriation of public
funds, misuse of company assets, offenses related to public tenders, stock exchange law)
Important drug cases involving international issues and organized crimes (Morocco, Lebanon,
Holland, Germany, GB), including 4 tons cocaine Tobago clipper case
EFTA00011245

=== Page 26 ===
LEGAL ADVICE
Presidential party members and officials in Dakar, Senegal
Former Tunisian Ambassador in Paris and prominent Tunisian diplomats
Members of the Royal family of Saudi Arabia
Members of leading Lebanese political party
Opposition leaders in Irak and Lybia
Italian State
MEMBERSHIPS
International criminal law Officer of the IBA (International Bar Association)
Member of DELF (Defense extradition Lawyers Forum, UK)
Co-Chair of the criminal committee of the corporate firms lawyers association (France)
Member of the ECBA (European Criminal Bar association)
Member of the Franco British Lawyers Society
EFTA00011246

=== Page 27 ===
Exhibit B
EFTA00011247

=== Page 28 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
Docket No. 20-CR-330 (AJN)
- against -
GHISLAINE MAXWELL,
AFFIDAVIT AND WAIVER OF
EXTRADITION
Defendant.
Ghislaine Maxwell, being duly sworn, deposes and says:
1.
I am the named defendant in the above-captioned case. I am a citizen of the
United States, the United Kingdom, and France. I have resided in the United States since
approximately 1991. I am currently incarcerated at the Metropolitan Detention Center in
Brooklyn, New York.
2.
I have reviewed with my counsel, Mark S. Cohen and Christian R. Everdell of
Cohen & Gresser, LLP, the charges contained in the superseding indictment in the above-
captioned case (the "Indictment"). In addition, I have been informed by United States and French
counsel, with whom I am satisfied, of my rights under French law on extradition, under the
Extradition Treaty between the United States of America and France signed 23 April 1996 (the
"Treaty"), under the Agreement on Extradition between the United States of America and the
European Union signed 25 June 2003 (the "USA/EU Agreement on Extradition"), under the
Instrument Amending the Treaty of April 23, 1996 between the United States of America and
France signed 30 September 2004 (the "Instrument Amending the Treaty"), and under the
provisions of the French Code of Criminal Procedure. I understand that, in proceedings in France
under the aforementioned provisions in respect of an extradition request by the United States
EFTA00011248

=== Page 29 ===
under the Treaty as amended by the Instrument Amending the Treaty and/or under the USA/EU
Agreement on Extradition in connection with the Indictment, I would be entitled to argue that I
should not be extradited to the United States on the ground of my French citizenship. I
understand that in the absence of my consent to extradition, I cannot be surrendered to the United
States authorities unless and until a court in France issues a ruling finding that there are no bars to
my extradition, followed by an extradition decree issued by the French government.
3.
If I am released on bail in connection with the Indictment, I hereby voluntarily and
irrevocably waive any rights to contest any extradition request by the United States under the
Treaty as amended by the Instrument Amending the Treaty as well as under the USA/EU
Agreement on Extradition with respect to the offenses charged in the Indictment. Specifically, I
consent to extradition in accordance with Article 11 of the USA/EU Agreement on Extradition as
incorporated in the Treaty by the Instrument Amending the Treaty, in connection with the
offenses charged in the Indictment. In addition, to the extent that it might be relevant, I waive
any rights to assert that any bars to extradition apply, and I confirm that no such bars apply.
4.
In the event that I violate my bail conditions after being released, I understand that
the purpose of this affidavit is for the government to offer it to the authorities in France when my
extradition is sought by the United States government in relation to the charges in the Indictment.
I understand that France authorities may use this affidavit to assist in determining my
extraditability.
5.
I make this waiver freely and voluntarily, after having consulted with counsel.
Dated this
day of December 2020.
Ghislaine Maxwell
2
EFTA00011249

=== Page 30 ===
I hereby certify that on this - day of December 2020, Ghislaine Maxwell personally appeared
before me and made her oath in due form of law that the statements herein are true.
The Honorable Alison J. Nathan
United States District Judge
Southern District of New York
3
EFTA00011250


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=== Page 1 ===
From:
To:
Subject: RE: travel approval request
Date: Tue, 16 Jul 2019 12:06:48 +0000
Importance: Normal
Thanks!
From:
Sent: Tuesday, July 16, 2019 8:02 AM
To:
Cc:
is
is
Subject: Re: travel approval request
Approved for both of you.
Sent from my iPad
On Jul 16, 2019, at 8:00 AM,
wrote:
Hi
We would like to request approval to travel to Fort Lauderdale tomorrow to interview a victim who has recently come
forward. The trip will be a round trip on the same day, so the flight will be the only expense. I think I will be only
traveler, but it's possible
will join as well.
Thanks,
From:
Sent: Wednesday, June 12, 2019 3:28 PM
To:
Cc:
>;
Subject: RE: travel approval request
Approved.
From:
Sent: Wednesday, June 12, 2019 2:51 PM
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
EFTA00010813

=== Page 2 ===
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference
room at the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
)
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week
EFTA00010814

=== Page 3 ===
for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night
and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00010815


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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Phone Call Follow-Up
Date: Fri, 30 Oct 2020 18:35:01 +0000
Inline-Images: image001.png
Those are the images we sent to PAE in September with a request that PAE mass bates stamp them and mark them all
confidential. PAE then de-duped the images without asking us first, so they had to re-do the production. We have been
waiting on those 40,000 images for more than a month.
From:
(USANYS)
Sent: Friday, October 30, 2020 2:30 PM
To:
is
)
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Phone Call Follow-Up
Oh, I see. Do you know/are you able to recall when we asked them to burn the 40,000 images? Presumably at some
point prior to 10/21-22?
From:
Sent: Friday, October 30, 2020 2:28 PM
To:
(USANYS)
is
>;
(USANYS)
Cc:
(USANYS)
Subject: RE: Phone Call Follow-Up
Thanks
To be clear, the productions they are sending today consist of the 40,000 images, documents from the FBI
Florida boxes, and documents from the FBI FOIA office. They are not sending, and have not sent, us any productions from
the electronic devices.
From:
(USANYS)
Sent: Friday, October 30, 2020 2:24 PM
To:
)
is
is
(USANYS)
Cc:
(USANYS)
Subject: FW: Phone Call Follow-Up
See below for the update from PAE. The good news is that they're getting this back to us on a rolling basis, and it looks
like we'll have at least some of this stuff in time to produce it by 11/9. The bad news is it does not seem like we'll have all
of it by that date. It does seem like we'll have greater clarity by early next week.
I confess, I don't feel like I fully understand all of the steps in this process or why it takes as long as it does, but I'm happy
to go back to
with additional questions if that would be helpful. I'm also happy to ask that he set up a call with us and
PAE if that would be helpful. Please let us know what we can do.
EFTA00013202

=== Page 2 ===
From:
(USANYS)
Sent: Friday, October 30, 2020 12:51 PM
To:
(USANYS)
is
(USANYS)
Subject: FW: Phone Call Follow-Up
Some of the data is being sent to use today by FedEX. However, there is a ton of stuff still being processed. That stuff is
still being imaged. Then it gets marked. Then copied to us. I have spoken to
He thinks it is not possible to
meet the November 9 date. He thinks the next step might be done on Tuesday, and then a better estimate of completion
might be possible.
From: Koontz, Nicholas [US]
Sent: Friday, October 30, 2020 12:25 PM
To:
(USANYS)
Cc:
(USANYS) [Contractor]
Subject: Phone Call Follow-Up
Good Afternoon
Following up on our earlier phone conversation, a hard drive with the following productions is being sent to SDNY via
FedEx with the following productions in the US V. Epstein workspace:
1) SDNYPROD008
2) SDNYPROD009
3) SDNYPROD010
4) SDNYPROD011 (Note: this is a six-part production)
5) SDNYPROD012
6) SDNYPROD013
7) SDNYPROD014
There are approximately 1.2 million records currently being imaged. The images will be available on Monday, November
2, 2020 at the earliest. The production of the records will begin as soon as the images are available in the workspace.
Please feel free to contact me if you have any questions.
Thanks,
Nick
Nicholas D. Koontz
Lead E-Discovery Analyst
e.
Falls Church, Virginia 22043
PAE
IMPORTANT: The information contained in this message may be privileged, business sensitive, proprietary,
EFTA00013203

=== Page 3 ===
copyrighted, protected from disclosure and/or subject to US export controls. If you are not the intended recipient,
you are hereby notified that any dissemination, distribution or copying of this communication is strictly
prohibited. If you have received this communication in error, please notify me immediately by replying to the
message and deleting it from your computer. #-SEC-#
EFTA00013204


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=== Page 1 ===
From:
To: "Jay Lefkowitz"
Cc: "Acosta, Alex (USAFLS)" <AAcosta@usa.doj.gov>
Subject: RE: Epstein
Date: Tue, 23 Oct 2007 21:36:09 +0000
Importance: Normal
Jay,
Can't speak tonight. Won't send it out tonight. l'll check with Alex in the morning and will call you then.
From: Jay Lefkowitz [mailto
Sent: Tuesday, October 23, 2007 5:34 PM
To:
Cc: Acosta, Alex (USAFLS)
Subject: Epstein
- I have to leave the office shortly, but please let me know if you want to set up a time to speak regarding your letter to
Judge Davis. As you can see from my email earlier, we actually only have a few limited areas of disagreement with your
letter. I would hope you would not send it out before we have a chance to speak.
Regarding the addendum to the contract, I am getting the appropriate signatures and will send them tomorrow.
Best, Jay
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
EFTA00013749


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=== Page 1 ===
From:
To:
Subject: Re: Emailing: Work Release Notice
Date: Fri, 05 Dec 2008 11:12:42 +0000
Importance: Normal
Fine
Original Message
From
To: S
Sent: Thu Dec 04 17:24:05 2008
Subject: Emailing: Work Release Notice
I have attached a draft letter to victims notifying them of Epstein's work release. I will fill in the blank tomorrow. Any objections to the
language?
Thanks.
The message is ready to be sent with the following file or link attachments:
Work Release Notice --
Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your
e-mail security settings to determine how attachments are handled.
EFTA00014034


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=== Page 1 ===
From:
)"
To:
USANYS)"
(USANYS)"
(USANYS)"
Subject: GM/Cosby
Date: Fri, 02 Jul 2021 18:05:15 +0000
Attachments: 127129390538.pdf
FYI, filed today.
EFTA00010413


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=== Page 1 ===
From: Christian Everdell
To:
Cc:
"Mark S. Cohen"
"BOBBI
C STERNHEIM"
'Jeff Pagliuca'
>,
'Laura Menninger'
Subject: U.S. V. Ghislaine Maxwell, 20 Cr. 330 (AJN) -- Renewed Bail Motion and Exhibits (to be
Filed Under Seal)
Date: Tue, 08 Dec 2020 22:20:09 +0000
Attachments: 2020.12.8_Cover_Letter_to_Judge_Nathan_re_Renewed_Bail_Motion.pdf;
Memorandum_re_Second_Bail_Application_Final.PDF;Exhibit_A.pdfExhibit_B.pdf;
Exhibit_C.pdf; Exhibit_D.pdf; Exhibit_E.pdf
Inline-Images: image001.gif; image003.jpg
Dear Judge Nathan -
Attached please find the following documents submitted to the Court and all counsel under seal pursuant to the Court's
order (Dkt. 89):
1. Cover letter
2. Renewed bail motion (unredacted)
3. Accompanying exhibits A-E (unredacted)
Due to the volume of materials, we will be sending them in successive emails.
Regards,
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
|
view bio
www.cohengresser.com
New York Paris | Washington DC London
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
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=== Page 1 ===
From:
To:
Subject: RE: Special Master's Selection of Attorney Representative
Date: Fri, 19 Oct 2007 20:23:27 +0000
Importance: Normal
Thank you,
On another FYI -- FBI Seattle and FBI Las Vegas executed a search today on a warehouse owned by Epstein's favorite
cohort, David Copperfield, in connection with allegations that Copperfield raped an adult female. Copperfield spoke with the
girls at Epstein's home on several occasions and tickets with "backstage passes" were a favorite "birthday gift" for Epstein to
give the girls. I asked
0 contact the case agent to just stay in touch.
From:
Sent: Fri 10/19/2007 4:08 PM
To:
Subject: RE: Special Master's Selection of Attorney Representative
l'll push
From:
Sent: Friday. October 19 2007 4:04 PM
To:
Subject: RE: Special Master's Selection of Attorney Representative
- FYI -- The story of the lawsuit filed by the girl in New York has made the national news (it was on Fox News several
times today and it is on ABC News' website). I think that may be the real reason for the delay in the change of plea.
Epstein's group is concerned that the guilty plea will be used against him in civil suits and they want to knock that lawsuit
out before the guilty plea to deter others. One of the newspapers also reported that Epstein's camp had planted the false
stories about girls who "just sat in his kitchen" filing suit in an attempt to discredit the girls.
From:
Sent: Fri 10/19/2007 3:47 PM
To:
Subject: RE: Special Master's Selection of Attorney Representative
l'll contact him but before I do we'll chat. Jay was supposed to send me his comments to our proposed letter but I haven't
gotten them yet.
From:
Sent: Friday, October 19, 2007 3:27 PM
To:
Subject: RE: Special Master's Selection of Attorney Representative
Will you contact him or do you want me to do that?
Thanks.
From:
Sent: Fri 10/19/2007 3:24 PM
To:
Subject: RE: Special Master's Selection of Attorney Representative
EFTA00013506

=== Page 2 ===
has not been contacted yet.
From:
Sent: Friday. October 19. 2007 2:58 PM
To:
Subject: Special Master's Selection of Attorney Representative
Hi
Has the special master made his selection yet? Several of the girls are getting calls from attorneys, and they
have been seeing all the news and are concerned. If the selection has not yet been made, may I call Judge Davis and ask
the status of the decision?
Thank you.
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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: Re: CVRA Suit
Date: Mon, 07 Jul 2008 23:22:33 +0000
Importance: Normal
Hi
Yes an agreement has been signed and has already been partially performed. The agreement is confidential and has been filed
under seal in the state court proceedings.
He could be filing his motion on behalf of 3 different jane does
Was not fully identified until after the agreement was signed.
was notified and her notification resulted in claims of prosecutorial misconduct by Epstein's lawyers. I am checking to see if the third,
was notified prior to the signing of the agreement.
Original Message
From:
To:
Sent: Mon Jul 07 18:52:42 2008
Subject: CVRA Suit
The Attorney General Guidelines for Victim and Witness Assistance (May 2005) provides that "responsible officials should make
reasonable efforts to notify identified victims of, and consider victims' views about, prospective plea negotiations." Article IV, Services
to Victims and Witnesses, p. 30.
Has an agreement been signed with Epstein? Did we notify Jane Doe that an agreement was about to be negotiated, and the outlines of
that proposed agreement? Thanks.
EFTA00013974


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Writeups
Date: Fri, 08 Jan 2021 20:58:48 +0000
Attachments: Public_Corruption_-_January_2021_Updates.1.8.21.docx
Per your request, a short write up on:
Maxwell
obstruction
EFTA00013270


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
=
Cc:
"
(USANYS)"
Subject: Epstein
Date: Fri, 26 Apr 2019 15:34:59 +0000
Importance: Normal
S going to meet with Brad Weinshiemer on Monday - can you guys put together an update memo this
afternoon on where we are, what we've done since the last update memo, and next steps? This just for
for now, not for sending down to DC.
Sent from my iPhone
EFTA00013354


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=== Page 1 ===
From:
"
(FBI)"
To:
(USAFLS)"
Subject: Re: Epstein Plea
Date: Fri, 27 Jun 2008 20:16:07 +0000
Importance: Normal
Call me when u can.
Original Message
From:
(USAFLS)
To:
Cc:
; Richards, Jason R.
Sent: Fri Jun 27 15:47:54 2008
Subject: Epstein Plea
Wow, am I good. Here it is already. I think our faxes crossed in cyber-space. Sorry for the poor quality, that is how it came to me.
Epstein Plea001.pdf>
Assistant U.S. Attorney
EFTA00013881


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Call?
Date: Wed, 17 Nov 2021 01:14:11 +0000
Attachments: SDNY_GM_00000812-SDNY_GM_00000814.pdf; SDNY_GM_00000815-
SDNY_GM_00000819.pdf; SDNY_GM_00000820-SDNY_GM_00000833.pdf;
SDNY_GM_02753139-SDNY_GM_02753141.pdf_SDNY_GM_02753142-
SDNY_GM_02753143.pdf;SDNY_GM_00000799-SDNY_GM_00000805.pdf
SDNY_GM_00000806-SDNY_GM_00000811.pdf
Thanks so much for chatting. Documents attached here.
Thanks,
From:
Sent: Tuesday, November 16, 2021 7:23 PM
To:
Cc:
Subject: [EXTERNAL] RE: Call?
Hi
Can do the 1-2 or after 5 - whichever is easier/quicker for you. Just give me a call on the below cell phone.
Am also free now if feasible.
Assistant Special Agent in Charge
Homeland Security Investigations
UNCLASSIFIED // LAW ENFORCEMENT SENSITIVE
WARNING: This document is UNCLASSIFIED (U) and is designated LAW ENFORCEMENT SENSITIVE (LES). It contains
information that may be exempt from public release under the Freedom of Information Act (5 USC 552). This document
is to be controlled, handled, transmitted, distributed, and disposed of in accordance with Department of Homeland
Security policies relating to U//LES information, and is not to be released to the public or personnel who do not have a
valid "need to know" without prior approval from the appropriate management official. Please notify the sender if this
email has been misdirected and immediately destroy all originals and copies of the original.
From:
Sent: Tuesday, November 16, 2021 7:18 PM
To:
Subject: Call?
EFTA00010241

=== Page 2 ===
CAUTION: This email originated from outside of DHS. DO NOT click links or open attachments unless you recognize and/or trust the
sender. Contact ICE SOC SPAM with questions or concerns.
Hi
I hope you are well. Do you have a few minutes for a call? I am free this week anytime after 5 pm or have a window from
1-2 pm if that works for you.
Thanks so much!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00010242


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=== Page 1 ===
From:
To:
Subject: Are you back in the office?
Date: Mon, 13 Aug 2007 15:57:32 +0000
Importance: Normal
wants me to run something past you about Epstein. Thanks.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
EFTA00013735


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=== Page 1 ===
U.S. Department
Aviation Safety
of Transportation
Oklahoma City, Oklahoma 73125-0504
Federal Aviation
Toll Free:
Administration
WEB Address:
Date of Issue: July 22, 2021
N550GP LLC
ONTARIO, CA 91764-5496
Fax
ATTENTION: IATS
T216269
This facsimile must be carried in the Aircraft as a Temporary Certificate of
Registration for
N550GP GULFSTREAM AEROSPACE GV-SP (G550) Serial 5173 and is valid until Aug
21, 2021.
This is not an airworthiness certificate. For airworthiness information, contact the nearest
Federal Aviation Administration Flight Standards District Office.
for
Acting Manager, Aircraft Registration Branch
Federal Aviation Administration
REGAR-FAX-4 (02/21)
EFTA00010620

=== Page 2 ===
EFTA00010621

=== Page 3 ===
:
Return Ceriificate I.A.T of Registration to S
DECLARATION
of
PRIORITY
Accepted CF Jul/22/2021
INTERNATIONAL OPERATIONS
The undersigned owner of aircraft N 550GP , Manufacturer Gulfstream Accospace
Model GVSP
Serial Number 5173
declares that this aircraft is scheduled to make an international flight* on 7-25-2021.
(date)
as flight Number
departing Ontario California (KONT)
(City/State)
with a destination of
Naples Italy (LIRN)
(City/Country)
*[If required route between two points in the United States involves international navigation, explain under
Comments below, e.g. "partly over Canada" or "partly in international airspace".)
Expedited registration in support of this international flight is requested this
21st
day of July
2021 with knowledge that:
Whoever, in any matter within the jurisdiction of the executive branch of the
Government of the United States, knowingly and willfully makes or uses any
false writing or document knowing the same to contain any materially false,
fictitious or fraudulent statement of representation shall be fined under Title 18
United States Code or imprisoned not more than 5 years, or both. 18 U.S.C.
$1001(a).
Name of Owner
N550GP, LLC
Signature
X
CAR COPY
Typed Name and Title of Signer
Manager
Phone:
Fax:
Comments:
*[If required route between two points in the United States involves international
navigation, explain under comments below, e.g. "partly over Canada" or "partly in
international airspace".]
Comments: Please fax the flying time wire to Insured Aircraft Title Service Inc. at
Filed by:
Insured Aircraft Title Service LLC
Phone
EFTA00010622

=== Page 4 ===
EFTA00010623
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2021 JUL 22 AM 8: 10
OKLAHOMA CITY
OKLAHOMA

=== Page 5 ===
ASSIGNMENT OF SPECIAL
Special Registration Number
REGISTRATION NUMBERS
N550GP
U.S. Department
Aircraft Make and Model
Present Registration Number
of Transportation
GULFSTREAM AEROSPACE GV-SP (G550)
N212JE
Federal Aviation
Serial Number
Issue Date:
Accepted CF Jul/22/2021
Administration
5173
Feb 24, 2021
ICAO AIRCRAFT ADDRESS CODE FOR N550GP 51600017
This is your authority to change
the United States registration
number on the above described
N550GP LLC
aircraft to the special
registration number shown
ONTARIO CA 91764-5496
Carry duplicate of this form in the
aircraft together with the
old registration certificate as
interim authority to operate the
aircraft pending receipt of revised
certificate of aircraft registration.
The latest FAA Form 8130-6,
Application For Airworthiness
on file is dated:
Mar 07, 2008
The airworthiness classification
and category:
STD TRANSP
INSTRUCTIONS:
SIGN AND RETURN THE ORIGINAL of this form to the Civil Aviation Registry, Aircraft Registration Branch, within 5 days
after the special registration number is placed on the aircraft. A revised certificate of aircraft registration will then be issued.
Obtain a revised certificate of airworthiness from your nearest Flight Standards District Office.
The authority to use the special number expires: Feb 24, 2022
CERTIFICATION: I certify that the special registration number was placed
RETURN FORM TO:
on the aircraft described above.
Civil Aviation Registry
Signature of Owner: 1
Aircraft Registration Branch
Oklahoma City, Oklahoma 73125-0504
manager
Title of Owner: CHEF FINANCIAL OFFICER
Date Placed on Aircraft: 3-19-2021
AC FORM 8050-64 (5/2005) Supersedes Previous Edition
Return Certificate of Registration to
I.A.T.S
EFTA00010624

=== Page 6 ===
EFTA00010625
FILED WITH FAA
AIRCRAFT
AIRCRAFT FILED WITHFAA
REGISTRATION BR
2021 JUL 20 AM 7 31
2021 MAR 26 AM 8: 32
OKLAHOMA OKLAHOMA CITY
OKLAHOMA CITY
OKLAHOMA
(

=== Page 7 ===
U.S. Department
Aviation Safety
of Transportation
Oklahoma City, Oklahoma 73125-0504
Federal Aviation
Toll Free:
Administration
WEB Address:
Date of Issue: February 24, 2021
N550GP LLC
ONTARIO, CA 91764-5496
Fax
HAND DELIVERED TO IN THE PD ROOM
T211438
This facsimile must be carried in the Aircraft as a Temporary Certificate of
Registration for
N212JE GULFSTREAM AEROSPACE GV-SP (G550) Serial 5173 and is valid until Mar
26, 2021.
This is not an airworthiness certificate. For airworthiness information, contact the nearest
Federal Aviation Administration Flight Standards District Office.
for
Acting Manager, Aircraft Registration Branch
Federal Aviation Administration
REGAR-FAX-4 (02/21)
EFTA00010626

=== Page 8 ===
EFTA00010627

=== Page 9 ===
LETTER OF EXTENSION
(For Authority to Operate an Aircraft Pending Registration )
The authority to operate Aircraft N212JE, GULFSTREAM AEROSPACE GV-SP
(G550), S/N 5173 is extended for 120 days from the date stamped below, or until the
Certificate of Aircraft Registration (AC Form 8050-3) is issued, whichever date occurs
first.
DATE
CF
Feb 24, 2021
This Letter of Extension must be carried in the aircraft with a copy of the aircraft
registration application as temporary authority to continue to operate the aircraft without
registration within the United States. This is not an authorization to operate the aircraft
without an appropriate Airworthiness Certificate (FAA Form 8100-2 or 8130-7), or its
equivalent.
U.S. Department
of Transportation
Federal Aviation
Civil Aviation Registry
Administration
Oklahoma City, Oklahoma 73125-0504
REGAR-37 (08/19)
EFTA00010628

=== Page 10 ===
EFTA00010629

=== Page 11 ===
Return Certificate of Registration to
I.A.T.S
DECLARATION
of
Accepted PRIDATTY Go Feb/24/2021
INTERNATIONAL OPERATIONS
The undersigned owner of aircraft N 212JE
, Manufacturer Gulfstream Acrospace
Model G550 GV-SP
Serial Number 5173
declares that this aircraft is scheduled to make an international flight* on 02-26-2021
,
(date)
as flight Number N212JE
departing Chino/California
(City/State)
with a destination of Cabo San Lucas/Mexico
-
(City/Country)
*[If required route between two points in the United States involves international navigation, explain under
Comments below, e.g. "partly over Canada" or "partly in international airspace".]
Expedited registration in support of this international flight is requested this
17
day of February
2021 with knowledge that:
Whoever, in any matter within the jurisdiction of the executive branch of the
Government of the United States, knowingly and willfully makes or uses any
false writing or document knowing the same to contain any materially false,
fictitious or fraudulent statement of representation shall be fined under Title 18
United States Code or imprisoned not more than 5 years, or both. 18 U.S.C.
$1001(a).
Name of Owner
N550GP, LLC
Signature
xXx CAR COPY
Typed Name and Title of Signer
CFO of FH 11,40 It's Member
Phone:
Fax:
Comments:
*[If required route between two points in the United States involves international
navigation, explain under comments below, e.g. "partly over Canada" or "partly in
international airspace".]
Comments: Please fax the flying time wire to Insured Aircraft Title Service Inc. at
Filed by:
Insured Aircraft Title Service LLC
Phone
SCARY
EFTA00010630

=== Page 12 ===
EFTA00010631
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2021 FEB 23 AM 11: 09
OKLAHOMA CITY
OKLAHOMA

=== Page 13 ===
ACTION
2/NCG
I
A
Insured Aircraft Title Service, LLC
Accepted CF Jul/22/2021
T
S
FEDERAL AVIATION ADMINISTRATION
CENTRAL RECORDS DIVISION
OKLAHOMA CITY, OKLAHOMA
Date: February 11, 2021
Dear Sir/Madam:
Please Reserve N
in NAME ONLY for:
N# CHANGE REQUEST
Please Reserve N 550GP** and assign for the following aircraft:
Θ
2
N 212JE Make Gulfstream Aerospace Model GV-SP (G550) Serial #
5173
Which is (1) being purchased by
XX (2) registered to
XX
:
N550GP, LLC
Ontario, CA 91764
Payment of the required $10.00 fee per number to reserve/assign is attached. If the preferred N number is not
available, please contact the undersigned for a selection of a new number. Please send the confirmation of
reservation/8050-64 form to Insured Aircraft Title Service, LLC in the Public Documents room of the FAA.
Additional Information: **Relinquishment Attached
210421440037
$20 00 02/11/2021
Requested by
Fee:
$20.00
EFTA00010632

=== Page 14 ===
EFTA00010633
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2021 FEB 11 PM 2: 02
OKLAHOMA CITY
OKLAHOMA

=== Page 15 ===
UNITED STATES OF AMERICA- DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION - MIKE MONRONEY AERONAUTICAL CENTER
AIRCRAFT REGISTRATION APPLICATION
1) UNITED STATES
1. Individual
REGISTRATION
N
212JE
4) TYPE OF REGISTRATION
2. Partnership
NUMBER
3. Corporation
2) AIRCRAFT
4. Co-Owner
MANUFACTURER
GULFSTREAM AEROSPACE GV-SP (G550)
Accepted GC Feb/24/2021
AND MODEL
5. Government
(Check one box.)
3) AIRCRAFT
7. Limited Liability Company (LLC)
SERIAL
8. Non-Citizen Corporation
5173
NUMBER
9. Non-Citizen Corporation Co-Owner
6) NAME(S) OF APPLICANT(S) (Person(s) shown on evidence of ownership If individual give last name, first name and middle initial.)
N550GP, LLC
6) TELEPHONE NUMBER (909) 354-8000
7) MAILING ADDRESS (Permanent mailing address for first applicant on list.)
NUMBER AND STREET
RURAL ROUTE
P.O. BOX
CITY: Ontario
STATE: CA
ZIP: 91764
8) PHYSICAL ADDRESS/LOCATION IF PO BOX MAIL DROP OR RURAL ROUTE BOX USED FOR MAILING ADDRESS
NUMBER AND STREET
DESCRIPTION OF
LOCATION
CITY:
STATE
ZIP:
9)
CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS
10) CERTIFICATION
WE CERTIFY:
(1) That the above aircraft is owned by the undersigned applicant who is: (MUST CHECK AND/OR COMPLETE a. D.C. or d)
a. A citizen of the United States as defined by 49 USC 40102(a)(15):
b. A resident alien with alien registration (Form 1-551) No.
c. A non-citizen corporation organized and doing business under the laws of (state)
and said aircraft
is based and primarily used in the United States. Records of flight hours are available for inspection at (provide complete physical address)
d. A corporation using a voting trust to qualify. Enter name of trustee
(2) If box C or d above is checked I, the below signed, certify that am authorized by the applicant shown above, to sign corporate documents and to
seek aircraft registration on behalf of the entity and that I will provide the same authorization if requested
(3) That the aircraft is not registered under the laws of any foreign country: and
(4) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration
ANY AND ALL SIGNATORIES OF THIS APPLICATION MUST READ THE FOLLOWING AND UNDERSTAND THAT, BY APPLYING
A SIGNATURE TO THIS DOCUMENT, THEY ARE SUBJECT TO THE REFERENCED STATUTES AND ASSOCIATED PENALTIES.
I/we hereby certify that the information provided in, and in any attachments to, this application for aircraft registration is true, accurate and correct to the best of my/our
knowledge and belief. I/we understand that the FAA administrator will rely on the information I/we provide in determining my/our qualification for aircraft registration. I/we
understand that whoever, in any matter within the jurisdiction of any department or agency of the United States. knowingly and willfully falsifies, conceals, or covers up by
any trick, scheme, or device any material fact(s). statement(s), representation(s) or entry(ies) may be fined up to $500,000 or imprisoned for not more than five (5) years or
both (18 U.S.C. §§ 1001 and 3571). I/we understand that to knowingly and wilfully: a) falsify or conceal a material fact; or b) use a document knowing it contains a false,
fictitious or fraudulent statement/entry: or c) provide any inaccurate, false statement/information can subject me to criminal prosecution (49 U.S.C. § 46306), and the
registration of the subject aircraft may be delayed, denied and/or revoked.
NOTE: If executed for co-ownership, all applicants must sign. Use next page and add page(s) if necessary.
SIGNATURE Digitally signed by
id.L7Vgs0zcDDNTb7I4PFh9DNwfrk4
DATE: 12-22-2020
11)
TYPED/PRINTED
NAME:
TITLE: Manager of Frontier JV LLC, its Member
SIGNATURE
DATE:
12)
TYPED/PRINTED
NAME:
TITLE:
NOTE: Except when the most recent registration of the subject aircraft is expired or cancelled, 14 CFR 47.31(c) provides for an airworthy
U.S. aircraft to be operated for up to 90 days within the United States when a copy of the signed aircraft registration application is carried
in the aircraft while awaiting issuance and receipt of the new registration certificate.
AC Form 8050-1 (02/20)
Page 1
EFTA00010634

=== Page 16 ===
EFTA00010635
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2020 DEC 22 AM 10: 53
OKLAHOMA CITY
OKLAHOMA

=== Page 17 ===
UNITED STATES OF AMERICA
OMB Control No. 2120-0042
U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION
Exp. 04/30/2017
AIRCRAFT BILL OF SALE
FOR AND IN CONSIDERATION OF $ 1.00 + OVC THE
UNDERSIGNED OWNER(S) OF THE FULL
LEGAL
AND BENEFICIAL TITLE OF THE AIRCRAFT
DESCRIBED AS FOLLOWS:
UNITED STATES
REGISTRATION NUMBER
N212JE
AIRCRAFT MANUFACTURER & MODEL
GULFSTREAM AEROSPACE, GV-SP (G550)
AIRCRAFT SERIAL No.
5173
DOES THIS
22nd
DAY OF December
, 2020
HEREBY SELL, GRANT, TRANSFER AND
DELIVER ALL RIGHTS, TITLE, AND INTERESTS
GC009140 Conveyance Recorded Feb/24/2021 04:21 PM FAA
IN AND TO SUCH AIRCRAFT UNTO:
Do Not Write In This Block
FOR FAA USE ONLY
NAME AND ADDRESS
(IF INDIVIDUAL(S), GIVE LAST NAME, FIRST NAME, AND MIDDLE INITIAL.)
N550GP, LLC
PURCHASER
Ontario, CA 91764
DEALER CERTIFICATE NUMBER
AND TO ITS SUCCESSORS
EXECUTORS, ADMINISTRATORS, AND ASSIGNS TO HAVE AND TO HOLD
SINGULARLY THE SAID AIRCRAFT FOREVER, AND WARRANTS THE TITLE THEREOF:
I
IN TESTIMONY WHEREOF
MY
HAVE SET
HAND AND SEAL THIS 22nd DAY OF Dec., 2020
NAME(S) OF SELLER
SIGNATURE(S)
TITLE
(TYPED OR PRINTED)
(IN INK) (IF EXECUTED FOR
(TYPED OR PRINTED)
CO-OWNERSHIP, ALL MUSTSIGN.
Six G Aviation LLC
Digitally signed by
d.L7Qk3ydgQQUTMtmpmSrdBNsco
Manager
SELLER
ACKNOWLEDGMENT (NOT REQUIRED FOR PURPOSES OF FAA RECORDING: HOWEVER, MAY BE REQUIRED BY LOCAL LAW FOR
VALIDITY OF THE INSTRUMENT.)
ORIGINAL: TO FAA:
AC Form 8050-2 (01/12) (NSN 0052-00-629-0003)
EFTA00010636

=== Page 18 ===
EFTA00010637
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2020 DEC 22 AM 10: 53
OKLAHOMA CITY
OKLAHOMA

=== Page 19 ===
UNITED STATES OF AMERICA
OMB Control No. 2120-0042
Exp. 04/30/2017
U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION
AIRCRAFT BILL OF SALE
FOR AND IN CONSIDERATION OF $ 1.00 + OVC THE
UNDERSIGNED OWNER(S) OF THE FULL
LEGAL
AND BENEFICIAL TITLE OF THE AIRCRAFT
DESCRIBED AS FOLLOWS:
UNITED STATES
REGISTRATION NUMBER
N212JE
AIRCRAFT MANUFACTURER & MODEL
GULFSTREAM AEROSPACE, GV-SP (G550)
AIRCRAFT SERIAL No.
5173
DOES THIS 22nd
DAY OF December
, 2020
HEREBY SELL, GRANT, TRANSFER AND
DELIVER ALL RIGHTS, TITLE, AND INTERESTS
GC009139 Conveyance Recorded Feb/24/2021 04:20 PM FAA
IN AND TO SUCH AIRCRAFT UNTO:
Do Not Write In This Block
FOR FAA USE ONLY
NAME AND ADDRESS
(IF INDIVIDUAL(S), GIVE LAST NAME, FIRST NAME, AND MIDDLE INITIAL.)
Six G Aviation LLC
PURCHASER
DEALER CERTIFICATE NUMBER
AND TO ITS SUCCESSORS
EXECUTORS, ADMINISTRATORS, AND ASSIGNS TO HAVE AND TO HOLD
SINGULARLY THE SAID AIRCRAFT FOREVER, AND WARRANTS THE TITLE THEREOF:
I
IN TESTIMONY WHEREOF
MY
HAVE SET
HAND AND SEAL THIS 22nd DAY OF Dec., 2020
NAME(S) OF SELLER
SIGNATURE(S)
TITLE
(TYPED OR PRINTED)
(IN INK) (IF EXECUTED FOR
(TYPED OR PRINTED)
CO-OWNERSHIP, ALL MUSTSIGN
Plan D, LLC
Digitally signed by LAWRENCE VISOSKI
d.VMWHSt2egufPTNsiukc0doo2ykX
Manager
SELLER
ACKNOWLEDGMENT (NOT REQUIRED FOR PURPOSES OF FAA RECORDING: HOWEVER, MAY BE REQUIRED BY LOCAL LAW FOR
VALIDITY OF THE INSTRUMENT.)
ORIGINAL: TO FAA:
AC Form 8050-2 (01/12) (NSN 0052-00-629-0003)
EFTA00010638

=== Page 20 ===
EFTA00010639
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2020 DEC 22 AM ID: 53
OKLAHOMA CITY
OKLAHOMA

=== Page 21 ===
DOCUMENT LEVEL ANNOTATIONS FOR DOCUMENT ARE012112330
Agency Tracking ID: 76060977022 $5.00 12-22-2020
EFTA00010640

=== Page 22 ===
EFTA00010641

=== Page 23 ===
DocuSign Envelope ID: 7E781336-7F28-41F4-9361-8263DC960592
PRINT PAGE 1
PRIVACY ACT STATEMENT
OMB Control Number 2120-0729
Expires 05/31/2014
Paperwork Reduction Act Statement: The information collected on this form is necessary to maintain aircraft registration. We estimate that it will take approximately 30 minutes
to complete the form. Please note that an agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid
OMB control number. Form Approved, OMB No. 2120-0729 "Comments concerning the accuracy of this burden and suggestions for reducing the burden should be directed to
the FAA at: 800 Independence Avenue SW, Washington, DC 20591. ATTN: information Collection Clearance Officer, AES-200."
FAILURE TO RENEW REGISTRATION WILL
DEPARTMENT OF TRANSPORTATION - FEDERAL AVIATION ADMINISTRATION
RESULT IN CANCELLATION OF REGISTRATION
AIRCRAFT REGISTRATION RENEWAL APPLICATION
AND REGISTRATION NUMBER ASSIGNMENT
Accepted CW Feb/27/2020
(See 14 C.F.R. $5 47.15(i), 47.40 and 47.41)
AIRCRAFT REGISTRATION NUMBER
SERIAL NUMBER
N 212JE
5173
MANUFACTURER
MODEL
Gulfstream Aerospace
GV-SP (G550)
DATE OF ISSUANCE
DATE OF EXPIRATION
TYPE OF REGISTRATION
3-31-2017
3-31-2020
LLC
ENTER REGISTERED OWNER(S) & ADDRESS FROM FAA FILE
HELPFUL INFORMATION
(Owner 1) Plan D LLC
Review Aircraft Registration File Information for this aircraft
(Owner 2)
at: http://registry.faa.gov/aircraftinquiry.
Note: Enter any additional owner names on page two.
Assistance may be obtained
(Address)
at our web page: http://registry.faa.gov/renewregistration,
by e-mail at: faa.aircraft.registry@faa.gov. or
(Address)
by telephone at: (866) 762- 9434 (toll free), or
City St. Thomas
State VI Zip 00802
When mailing fees, please use a check or money order made
Country Virgin Islands USA
payable to the Federal Aviation Administration.
Physical Address: Required when mailing address is a P.O. Box or mail drop.
Signature and Title Requirements for Common Registration Types:
Individual
(Address)
owner must sign. title would be "owner".
- Partnership
general partner signs showing "general partner" as title.
(Address)
- Corporation
corporate officer or manager signs, showing full title.
City
State
Zip
- Limited Liability Co
authorized member, manager, or officer identified in the
LLC organization document signs, showing full title.
Country
- Co-owner
each co-owner must sign; showing "co-owner" as title.
Government
authorized person must sign and show their full title.
TO RENEW REGISTRATION: REVIEW aircraft registration information,
Note: All signatures must be in Ink, or other permanent media.
SELECT the appropriate statement, ENTER any change in address in the
spaces below, SIGN. DATE. & SEND form with the $5 renewal fee to the:
To correct entries: Draw a single line through error. Make correct entry in
FAA Aircraft Registry.
Oklahoma City OK 73125-0504, or
remaining space, or complete the form on-line. An application form will be
by courier to: 6425 S Denning Room 118, Oklahoma City OK 73169-6937
rejected if any entry is covered by correction tape or similarly obscured
I (WE) CERTIFY, THE NAME(S) AND ADDRESSES FROM THE FAA FILES
FOR THE OWNER(S) OF THIS AIRCRAFT ARE CORRECT, OWNERSHIP
TO CANCEL THE REGISTRATION FOR THIS AIRCRAFT:
MEETS CITIZENSHIP REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS
CHECK all applicable blocks below, COMPLETE SIGN. DATE & MAIL this
NOT REGISTERED UNDER THE LAWS OF ANY FOREIGN COUNTRY.
form with any fees to the: FAA Aircraft Registry.
Oklahoma City, OK, 73125-0504, or by courier to:
UPDATE THE MAILING / PHYSICAL ADDRESS AS SHOWN BELOW.
Oklahoma City OK 73169-6937
1 (WE) CERTIFY THE: NAME(S) SHOWN ABOVE FOR THE OWNER(S) OF
THIS AIRCRAFT IS CORRECT, OWNERSHIP MEETS THE CITIZENSHIP
CANCELLATION OF REGISTRATION IS REQUESTED.
REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS NOT REGISTERED
UNDER THE LAWS OF ANY FOREIGN COUNTRY.
THE AIRCRAFT WAS SOLD TO:
(Show purchaser's name and address.)
NEW MAILING ADDRESS c/o Kellerhals Ferauson Kroblin PLLC
St. Thomas USVI 00802
THE AIRCRAFT IS DESTROYED OR SCRAPPED.
NEW PHYSICAL ADDRESS: complete if physical address has changed, or
THE AIRCRAFT WAS EXPORTED TO:
the new mailing address is a PO Box or Mail Drop.
c/o Kellerhals Ferguson Kroblin PLLC
St. Thomas USVI 00802
OTHER, Specify
PLEASE RESERVE N-NUMBER IN THE OWNER'S NAME
AND ADDRESS. The $10 reservation fee is enclosed.
SIGNATURE OF field)
PRINTED NAME OF SIGNER
(required field)
TITLE
(required field)
DATE
lawrence Visoski
Lawrence Visoski
Manager
2-21-2020
SIGNATURE OF OWNEREB12002F44C9
PRINTED NAME OF SIGNER
TITLE
DATE
Use page 2 for additional signatures.
200521518371
Return Certificate of Registration 185.00 02/21/2020
AC Form 8050-1B (04/12)
I.A.T.S
EFTA00010642

=== Page 24 ===
EFT
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2020 FEB 21 PM 3: 12
OKLAHOMA CITY
OKLAHOMA

=== Page 25 ===
ASSIGNMENT OF SPECIAL
Special Registration Number
N212JE
REGISTRATION NUMBERS
U.S. Department
Aircraft Make and Model
Present Registration Number
of Transportation
GULFSTREAM AEROSPACE GV-SP (G550)
N415LM
Federal Aviation
Serial Number
Issue Date:
Accepted OT Jan/24/2018
Administration
5173
Aug 23, 2017
ICAO AIRCRAFT ADDRESS CODE FOR N212JE - 50340675
This is your authority to change
the United States registration
number on the above described
PLAN D LLC
aircraft to the special
registration number shown.
ST THOMAS VI VI 00802
Carry duplicate of this form in the
aircraft together with the
old registration certificate as
interim authority to operate the
aircraft pending receipt of revised
certificate of registration.
Obtain a revised certificate of
airworthiness from your near-
est Flight Standards District
Office.
The latest FAA Form 8130-6,
Application For Airworthiness
on file is dated:
Mar 07, 2008
The airworthiness classification
and category:
STD TRANSP
INSTRUCTIONS:
SIGN AND RETURN THE ORIGINAL of this form to the Civil Aviation Registry, AFS-750, within 5 days after the special
registration number is placed on the aircraft. A revised certificate will then be issued.
The authority to use the special number expires: Aug 23, 2018
CERTIFICATION: I certify that the special registration number was placed
RETURN FORM TO:
on Signature the aircraft of Owner: described above. Visoski
Civil Aviation Registry, AFS-750
Oklahoma City, Oklahoma 73125-0504
Title of Owner: MANAGER PLAN D, we
Date Placed on Aircraft: JANUARY 2ND. 2018
AC FORM 8050-64 (5/2005) Supersedes Previous Edition
EFTA00010644

=== Page 26 ===
OKLAHOMA
OKLAHOMA CITY
2018 JAN 5 AM 11 45
AIRCRAFT REGISTRATION OR
FILED WITH FAA
EFTA00010

=== Page 27 ===
PLAN D, LLC Gulfstream G550 Serial #5173
Accepted oT Jan/24/2018
Thomas U.S.V.I. Quarters B3 00802
1
08/07/2017
To Whom it may concern / Ms Nancy,
FAA Registry,
At this time I'm requesting approval to apply N number N212JE to our Gulfstream G550 which is currently N415LM.
I have already pay the $10.00 Fee from past correspondence,.
Please mail the 8050-64 / Assignment of Special Registration Numbers to my airport address below if possible:
Plan D. LLC c/o Larry Visoski Atlantic Aviation
West Palm Beach, FL 33406
Thank you,
are Larry Visoski
Manager,
Plan D, LLC
EFTA00010646

=== Page 28 ===
EFTA00010647
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2017 AUG 9 AM 11 05
OKLAHOMA CITY
OKLAHOMA

=== Page 29 ===
DOCUMENT LEVEL ANNOTATIONS FOR DOCUMENT ARE008895928
Receipt # 171881203014 $10.00 07/07/2017
EFTA00010648

=== Page 30 ===
EFTA00010649

=== Page 31 ===
U.S. Department
Flight Standards Service
of Transportation
Aircraft Registration Branch,
Oklahoma City, Oklahoma 73125-0504
AFS-750
Federal Aviation
Toll Free:
Administration
WEB Address:
Date of Issue: March 31, 2017
PLAN D LLC
ST THOMAS, VI VI 00802
HAND DELIVERED TO IATS IN THE PD ROOM
T172058
This facsimile must be carried in the Aircraft as a Temporary Certificate of
Registration for
N415LM GULFSTREAM AEROSPACE GV-SP (G550) Serial 5173 and is valid until Apr
30, 2017.
This is not an airworthiness certificate. For airworthiness information, contact the nearest
Federal Aviation Administration Flight Standards District Office.
for
Manager, Aircraft Registration Branch, AFS-750
Federal Aviation Administration
AFS-750-FAX-4 (01/14)
EFTA00010650

=== Page 32 ===
EFTA00010651

=== Page 33 ===
PRIORITY
DECLARATION
Accepted CF Mar/31/2017
of
INTERNATIONAL OPERATIONS
The undersigned owner of aircraft N 415LM , Manufacturer GULFSTREAM Aerospace
Model GV.SP (G550)
Serial Number 5173
declares that this aircraft is scheduled to make an international flight* on APRIL 3 2017
(date)
as flight Number 41.5LM departing (KTEB) TETERBORO NJ
(City/State)
with a destination of (TIST) ST Thomas SVRGINISLANDS
(City/Country)
*[If required route between two points in the United States involves international navigation, explain under
Comments below. e.g. "partly over Canada" or "partly in international airspace".]
Expedited registration in support of this international flight is requested this
29th day of march
2017 with knowledge that:
Whoever, in any matter within the jurisdiction of the executive branch of the
Government of the United States, knowingly and willfully makes or uses any
false writing or document knowing the same to contain any materially false,
fictitious or fraudulent statement of representation shall be fined under Title 18
United States Code or imprisoned not more than 5 years, or both. 18 U.S.C.
$1001(a).
Name of Owner
PLAN D LLC
Signature
NVC
Typed Name and Title of Signer
LAWRENCE Visaski MANAGER
Phone:
Fax:
Comments:
Please send the Fly Time Wire to IATS via fax number
Please return the Certificate of Registration to IATS via the PD Room at the FAA.
Return Certificate of Registration to
Return Certificate of Registration to
LA.T.S
I.A.T.S
CAR
AFS-750-DIO-1 (02/12)
COPY
can
EFTA00010652

=== Page 34 ===
EFTA00010653
BR
MAR 29 A 11: 04
OXLAHOMA CITY

=== Page 35 ===
UNITED STATES OF AMERICA- DEPARTMENT OF TRANSPORTATION
OMB Control No. 2120-0042
Federal Aviation Administration - Mike Monroney Aeronautical Center
Collection Expires 4/30/2017
U.S. Department
of Transportation
AIRCRAFT REGISTRATION APPLICATION
Federal Aviation
Administration
UNITED STATES
REGISTRATION
N
415LM
TYPE OF REGISTRATION (Check see box)
Accepted CF Mar/31/2017
NUMBER
1. Individual
AIRCRAFT
2. Partnership
MANUFACTURER Gulfstream Aerospace GV-SP (G550)
2
a. Corporation (includes LLC's)
AND MODEL
4. Co-Owner
AIRCRAFT
5. Government
SERIAL 5173
8. Non-Cilizen Corporation
NUMBER
9. Non-Cifizen Corporation Co-Owner
NAME(S) OF APPLICANT(S) (Person(s) shown on evidence of ownership. If individual, give last name, first name and middle Initial]
Plan D, LLC
TELEPHONE NUMBER: ( )
MAILING ADDRESS (Permanent mailing address for first applicant listed above.)
NUMBER AND STREET: 6100 Red Hook Quarter, B3
RURAL ROUTE:
P.O. BOX
CITY: St. Thomas
STATE: USVI:
ZIP: 00802
PHYSICAL ADDRESS/LOCATION IF PO BOX OR RURAL ROUTE BOX USED FOR MAL NO ADDRESS
NUMBER AND STREET:
DESCRIPTION OF LOCATION:
CITY:
STATE:
ZIP:
CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS
ATTENTION! Read the following statement before signing this application.
This portion must be completed.
A false or dishonest answer to any question in this application
may be grounds for punishment by fine and/or imprisonment.
(U.S. Code, Title 18, Section 1001)
CERTIFICATION
I/WE CERTIFY:
(1) That the above aircraft is owned by the undersigned applicant who other is a citizen (including corporations) of the United States
OR meets the aircraft registration citizenship requirements of 14 CFR Part 47 BE (CHECK AND COMPLETE a. b, or c)
a. A resident elen with alon registration (Form 1-551) No.
b. A non-citizen corporation organized and doing business under the laws of (state)
and said aircraft is based and primarily used in the United States. Records of flight hours are available for
Inspection at
c. A corporation using a voting trust to quality Enter name of trustee
(2) That the aircraft is not registered under the lews of any foreign country; and
(3) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration
NOTE: If executed for ownership, all applicants must sign. Use next page If necessary.
SIGNATURE:
TYPED/PRINTED
HC Lawrence Visoski
DATE: March 29, 2017
1
NAME:
TITLE: Manager
SIGNATURE:
DATE:
2
TYPED/PRINTED
NAME:
TITLE:
SIGNATURE:
DATE:
3
TYPED/PRINTED
NAME:
TITLE:
NOTE: When curried In the aircraft with an appropriate current airworthiness certificate or a special flight permit,
a copy of this completed application provides authority to operate the aircraft in the United States for up to 90 days.
AC Form 8050-1 (03/18)
1
EFTA00010654

=== Page 36 ===
EFTA00010655
AIRCRAFT REGISTRATION ER
FILED WITH FAA
2017 MAR 29 A q: 09
OKLAHOMA CITY
OKLAHOMA

=== Page 37 ===
UNITED STATES OF AMERICA
OMB Control No. 2120-0042
U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION
Exp. 04/30/2017
AIRCRAFT BILL OF SALE
FOR AND IN CONSIDERATION OF $ 1.00 & OVC THE
UNDERSIGNED OWNER(S) OF THE FULL
LEGAL
AND BENEFICIAL TITLE OF THE AIRCRAFT
DESCRIBED AS FOLLOWS:
UNITED STATES
REGISTRATION NUMBER
N415LM
AIRCRAFT MANUFACTURER & MODEL
Gulfstream Aerospace GV-SP (G550)
AIRCRAFT SERIAL No.
5173
DOES THIS
29
DAY OF March
, 2017
CF004381 Conveyance Recorded Mar/31/2017 08:26 AM FAA
HEREBY SELL, GRANT, TRANSFER AND
DELIVER ALL RIGHTS, TITLE, AND INTERESTS
IN AND TO SUCH AIRCRAFT UNTO:
Do Not Write in This Block
FOR FAA USE ONLY
NAME AND ADDRESS
(IF INDIVIDUAL(S), GIVE LAST NAME, FIRST NAME, AND MIDDLE INITIAL)
Plan D. LLC
PURCHASER
St. Thomas, USVI 00802
DEALER CERTIFICATE NUMBER
AND TO its successors
EXECUTORS, ADMINISTRATORS, AND ASSIGNS TO HAVE AND TO HOLD
SINGULARLY THE SAID AIRCRAFT FOREVER, AND WARRANTS THE TITLE THEREOF:
IN TESTIMONY WHEREOF we
HAVE SET
our
HAND AND SEAL THIS 29 DAY OF March 2017
NAME(S) OF SELLER
SIGNATURE(S)
TITLE
(TYPED OR PRINTED)
(IN INK) (IF EXECUTED FOR
(TYPED OR PRINTED)
CO-OWNERSHIP, ALL MUSTSIGN.
Chevron U.S.A., Inc.
Attorney Fact
SELLER
ACKNOWLEDGMENT (NOT REQUIRED FOR PURPOSES OF FAA RECORDING: HOWEVER MAY BE REQUIRED BY LOCAL LAW FOR
VALIDITY OF THE INSTRUMENT.)
ORIGINAL: TO FAA:
AC Form 8050-2 (01/12) (NSN 0052-00-629-0003)
170880913227
$5.00 03/29/2017
EFTA00010656

=== Page 38 ===
EFTA00010657
AIRCRAFTREGISTRATION
BR
2017 MAR 29 A %09
OKLAHOMA CITY

=== Page 39 ===
ASSIGNMENT OF SPECIAL
Special Registration Number
N415LM
REGISTRATION NUMBERS
U.S. Department
Aircraft Make and Model
Present Registration Number
of Transportation
GULFSTREAM AEROSPACE GV-SP (G550)
N401HB
Accepted IR Mar/16/2017
Federal Aviation
Serial Number
Issue Date:
Administration
5173
Feb 01, 2017
ICAO AIRCRAFT ADDRESS CODE FOR N415LM - 51163671
This is your authority to change
the United States registration
number on the above described
CHEVRON U.S.A.INC.
aircraft to the special
registration number shown.
OAKLAND CA 94621-4543
Carry duplicate of this form in the
aircraft together with the
old registration certificate as
interim authority to operate the
aircraft pending receipt of revised
certificate of registration.
Obtain a revised certificate of
airworthiness from your near-
est Flight Standards District
Office.
The latest FAA Form 8130-6,
Application For Airworthiness
on file is dated:
Mar 07, 2008
The airworthiness classification
and category:
STD TRANSP
INSTRUCTIONS:
SIGN AND RETURN THE ORIGINAL of this form to the Civil Aviation Registry, AFS-750, within 5 days after the special
registration number is placed on the aircraft. A revised certificate will then be issued.
The authority to use the special number expires: Feb 01, 2018
CERTIFICATION: I certify that the special registration number was placed
RETURN FORM TO:
on the
Civil Aviation Registry, AFS-750
Signature
Oklahoma City, Oklahoma 73125-0504
Title of Owner: Assistant Secretary
Date Placed on Aircraft: march7, 2017
AC FORM 8050-64 (5/2005) Supersedes Previous Edition
Please reserve N401HB Back to Chevron U.S.A. Inc.
$10.00 is attached
170661345326
$10.00 03/07/2017
EFTA00010658

=== Page 40 ===
EFTA00010659
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2017 MAR-7 P 1:17
OKLAHOMA CITY
OKLAHOMA

=== Page 41 ===
ACTION
2 / NCG
A
Insured Aircraft Title Service, Inc.
Accepted IR Mar/16/2017
Oklahoma City, Ok 73144
T
S
Oklahoma City, Ok 73159
FAX
FEDERAL AVIATION ADMINISTRATION
CENTRAL RECORDS DIVISION
OKLAHOMA CITY, OKLAHOMA
Date:
Jaunary 30, 2017
Dear Sir/Madam:
Please Reserve N
in NAME ONLY for:
D
N# Change Request
Please Reserve N 415LM
and assign for the following aircraft:
N 401HB Make Gulfstream Aerospace
Model GV-SP (G550) Serial #
5173
Which is (1) being purchased by
X
(2) registered to
:
Chevron US A Inc.
Oakland, CA 94621
Payment of the required $10.00 fee per number to reserve/assign is attached. If the preferred N number is not
available, please contact the undersigned for a selection of a new number. Please send the confirmation of
reservation/8050-64 form to Insured Aircraft title Service, Inc. in the Public Documents room of the FAA.
Additional Information: Please reserve and assign N415LM to N401HB
Requested by:
Fee:
$20.00
170300828499
$20.00 01/30/2017
EFTA00010660

=== Page 42 ===
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2017 JAN 301A 8:31
OKLAHOMA CITY
OKLAHOMA

=== Page 43 ===
OMB Control Number 2120-0729
Expires 04/30/17
Paperwork Reduction Act Statement: The information collected on this form is necessary to maintain aircraft registration. We estimate that it will take approximately 30
minutes to complete the form. Please note that an agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a
valid OMB control number. Form Approved, OMB No. 2120-0729 "Comments concerning the accuracy of this burden and suggestions for reducing the burden should be
directed to the FAA at: 800 Independence Avenue SW, Washington, DC 20591. ATTN: Information Collection Clearance Officer, AES-200."
FAILURE TO RENEW REGISTRATION WILL
DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION
RESULT IN CANCELLATION OF REGISTRATION
AIRCRAFT REGISTRATION RENEWAL APPLICATION
AND REGISTRATION NUMBER ASSIGNMENT
(See 14 C.F.R. §§ 47.15(i), 47.40 and 47.41)
AIRCRAFT REGISTRATION NUMBER
SERIAL NUMBER
N 401HB
5173
MANUFACTURER
MODEL
GULFSTREAM AEROSPACE
GV-SP (G550)
DATE OF ISSUANCE
DATE OF EXPIRATION
TYPE OF REGISTRATION
04/02/2008
04/30/2020
CORPORATION
ENTER REGISTERED OWNER(S) & ADDRESS FROM FAA FILE
HELPFUL INFORMATION
(Owner 1) CHEVRON U S A INC
Review Aircraft Registration File Information for this aircraft
at: http://registry.faa.gov/aircraftinquiry.
(Owner 2)
Note: Enter any additional owner names on page two.
Assistance may be obtained
at our web page: http://registry.faa.gov/renewregistration,
(Address)
by e-mail at: faa.aircraft.registry@faa.gov.or
(Address)
by telephone at:: (866) 762 9434 (toll free), or
City OAKLAND
State CA Zip 94621-4543
When mailing fees, please use a check or money order made
Country UNITED STATES
payable to the Federal Aviation Administration
Physical Address: Required when mailing address is a P.O. Box or mail drop.
Signature and Title Requirements for Common Registration Types:
(Address)
Individual
owner must sign, title would be "owner".
Partnership
general partner signs showing "general partner" as
(Address)
title.
City
State
Zip
- Corporation
corporate officer or manager signs, showing full title.
Country
- Limited Liability Co
authorized member, manager, or officer identified in
the LLC organization document signs, showing full title.
TO RENEW REGISTRATION: REVIEW aircraft registration information,
Co-owner
each co-owner must sign; showing "co-owner" as title.
Government
authorized person must sign and show their full title.
SELECT the appropriate statement, ENTER any change in address in the
spaces below, SIGN. DATE & SEND form with the $5 renewal fee to the:
Note: All signatures must be in ink, or other permanent media.
FAA Aircraft Registry,
Oklahoma City OK 73125-0504, or
To correct entries: Draw a single line through error. Make correct entry in
by courier to:
Oklahoma City OK 73169-6937
remaining space, or complete the form on-line. An application form will be
rejected if any entry is covered by correction tape or similarly obscured.
I (WE) CERTIFY, THE NAME(S) AND ADDRESSES FROM THE FAA FILES
TO CANCEL THE REGISTRATION FOR THIS AIRCRAFT:
FOR THE OWNER(S) OF THIS AIRCRAFT ARE CORRECT, OWNERSHIP
MEETS CITIZENSHIP REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS
CHECK All applicable block(s) below, COMPLETE SIGN. DATE & MAIL
NOT REGISTERED UNDER THE LAWS OF ANY FOREIGN COUNTRY.
this form with any fees to the: FAA Aircraft Registry,
Oklahoma City, OK, 73125-0504, or by courier to:
UPDATE THE MAILING / PHYSICAL ADDRESS AS SHOWN BELOW.
Oklahoma City OK 73169-6937
I (WE) CERTIFY THE: NAME(S) SHOWN ABOVE FOR THE OWNER(S) OF
THIS AIRCRAFT IS CORRECT, OWNERSHIP MEETS THE CITIZENSHIP
CANCELLATION OF REGISTRATION IS REQUESTED.
REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS NOT REGISTERED
THE AIRCRAFT WAS SOLD TO:
UNDER THE LAWS OF ANY FOREIGN COUNTRY.
(Show purchaser's name and address.)
NEW MAILING ADDRESS
THE AIRCRAFT IS DESTROYED OR SCRAPPED.
NEW PHYSICAL ADDRESS: complete if physical address has changed, or
THE AIRCRAFT WAS EXPORTED TO:
the new mailing address is a PO Box or Mail Drop.
OTHER, Specify
PLEASE RESERVE N-NUMBER IN THE OWNER'S NAME
AND ADDRESS. The $10 reservation fee is enclosed.
SIGNATURE OF OWNER 1
(required field)
PRINTED NAME OF SIGNER
(required field)
TITLE
(required field)
DATE
Electronically Certified by Registered Owners
12/2/2016
SIGNATURE OF OWNER 2
PRINTED NAME OF SIGNER
TITLE
DATE
Use page 2 for additional signatures.
Fee paid: $5 (201612021356474332NB)
AC Form 8050-1B (04/12)
EFTA00010662

=== Page 44 ===
EFTA00010663

=== Page 45 ===
OMB Control Number 2120-0729
Expires 04/30/17
Note: Twelve (12) owner names may be entered on this page. If you require more, enter the first 12 names and then print
this page by pressing the 'Print Page 2' button below. Next click the 'Reset' button to clear the data fields (from page 2
only) to add more names. Repeat action as needed.
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
AC Form 8050-1B (04/12)
REF N-NUM: 401HB
EFTA00010664

=== Page 46 ===
EFTA00010665

=== Page 47 ===
OMB Control Number 2120-0729
Expires 2/29/15
Paperwork Reduction Act Statement: The information collected on this form is necessary to maintain aircraft registration. We estimate that it will take approximately 30
minutes to complete the form. Please note that an agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a
valid OMB control number. Form Approved, OMB No. 2120-0729 "Comments concerning the accuracy of this burden and suggestions for reducing the burden should be
directed to the FAA at: 800 Independence Avenue SW, Washington, DC 20591. ATTN: Information Collection Clearance Officer, AES-200."
FAILURE TO RENEW REGISTRATION WILL
DEPARTMENT OF TRANSPORTATION - FEDERAL AVIATION ADMINISTRATION
RESULT IN CANCELLATION OF REGISTRATION
AIRCRAFT REGISTRATION RENEWAL APPLICATION
AND REGISTRATION NUMBER ASSIGNMENT
(See 14 C.F.R. §§ 47.15(i), 47.40 and 47.41)
AIRCRAFT REGISTRATION NUMBER
SERIAL NUMBER
N 401HB
5173
MANUFACTURER
MODEL
GULFSTREAM AEROSPACE
GV-SP (G550)
DATE OF ISSUANCE
DATE OF EXPIRATION
TYPE OF REGISTRATION
04/02/2008
04/30/2017
CORPORATION
ENTER REGISTERED OWNER(S) & ADDRESS FROM FAA FILE
HELPFUL INFORMATION
(Owner 1) CHEVRON U S A INC
Review Aircraft Registration File Information for this aircraft
at: http://registry.faa.gov/aircraftinquiry.
(Owner 2)
Note: Enter any additional owner names on page two.
Assistance may be obtained
at our web page: http://registry.faa.gov/renewregistration,
(Address)
by e-mail at:
faa.aircraft.registry@faa.gov.or
(Address)
by telephone at:: (866) 762 9434 (toll free), or
City OAKLAND
State CA Zip 94621-4543
When mailing fees, please use a check or money order made
Country UNITED STATES
payable to the Federal Aviation Administration
Physical Address: Required when mailing address is a P.O. Box or mail drop.
Signature and Title Requirements for Common Registration Types:
(Address)
Individual
owner must sign, title would be "owner".
- Partnership
general partner signs showing "general partner" as
(Address)
title.
City
State
Zip
- Corporation
corporate officer or manager signs, showing full title.
Country
- Limited Liability Co
authorized member, manager, or officer identified in
the LLC organization document signs, showing full title.
TO RENEW REGISTRATION: REVIEW aircraft registration information,
Co-owner
each co-owner must sign; showing "co-owner" as title.
- Government
authorized person must sign and show their full title.
SELECT the appropriate statement, ENTER any change in address in the
spaces below, SIGN. DATE & SEND form with the $5 renewal fee to the:
Note: All signatures must be in ink, or other permanent media.
FAA Aircraft Registry,
Oklahoma City OK 73125-0504, or
To correct entries: Draw a single line through error. Make correct entry in
by courier to:
Oklahoma City OK 73169-6937
remaining space, or complete the form on-line. An application form will be
rejected if any entry is covered by correction tape or similarly obscured.
I (WE) CERTIFY, THE NAME(S) AND ADDRESSES FROM THE FAA FILES
TO CANCEL THE REGISTRATION FOR THIS AIRCRAFT:
FOR THE OWNER(S) OF THIS AIRCRAFT ARE CORRECT, OWNERSHIP
MEETS CITIZENSHIP REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS
CHECK All applicable block(s) below, COMPLETE SIGN. DATE & MAIL
NOT REGISTERED UNDER THE LAWS OF ANY FOREIGN COUNTRY.
this form with any fees to the: FAA Aircraft Registry,
Oklahoma City, OK, 73125-0504, or by courier to:
UPDATE THE MAILING / PHYSICAL ADDRESS AS SHOWN BELOW.
Oklahoma City OK 73169-6937
I (WE) CERTIFY THE: NAME(S) SHOWN ABOVE FOR THE OWNER(S) OF
THIS AIRCRAFT IS CORRECT, OWNERSHIP MEETS THE CITIZENSHIP
CANCELLATION OF REGISTRATION IS REQUESTED.
REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS NOT REGISTERED
THE AIRCRAFT WAS SOLD TO:
UNDER THE LAWS OF ANY FOREIGN COUNTRY.
(Show purchaser's name and address.)
NEW MAILING ADDRESS
THE AIRCRAFT IS DESTROYED OR SCRAPPED.
NEW PHYSICAL ADDRESS: complete if physical address has changed, or
THE AIRCRAFT WAS EXPORTED TO:
the new mailing address is a PO Box or Mail Drop.
OTHER, Specify
PLEASE RESERVE N-NUMBER IN THE OWNER'S NAME
AND ADDRESS. The $10 reservation fee is enclosed.
SIGNATURE OF OWNER 1 (required field)
PRINTED NAME OF SIGNER
(required field)
TITLE
(required field)
DATE
Electronically Certified by Registered Owners
12/4/2013
SIGNATURE OF OWNER 2
PRINTED NAME OF SIGNER
TITLE
DATE
Use page 2 for additional signatures.
Fee paid: $5 (201312041628370511NB)
AC Form 8050-1B (04/12)
EFTA00010666

=== Page 48 ===
EFTA00010667

=== Page 49 ===
OMB Control Number 2120-0729
Expires 2/29/15
Note: Twelve (12) owner names may be entered on this page. If you require more, enter the first 12 names and then print
this page by pressing the 'Print Page 2' button below. Next click the 'Reset' button to clear the data fields (from page 2
only) to add more names. Repeat action as needed.
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
NAME OF OWNER
DATE
SIGNATURE
PRINTED NAME OF SIGNER
TITLE
AC Form 8050-1B (04/12)
REF N-NUM: 401HB
EFTA00010668

=== Page 50 ===
EFTA00010669

=== Page 51 ===
PRINT PAGE 1
PRIVACY ACT STATEMENT
OMB Control Number 2120-0729
Expires 2/29/2012
Paperwork Reduction Act Statement: The information collected on this form is necessary to obtain aircraft re-registration. We estimate that it will take approximately 30
minutes to complete the form. Please note that any agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays
a valid OMB control number. Form Approved, OMB No. 2120-0729
"Comments concerning the accuracy of this burden and suggestions for reducing the burden should be directed to the FAA at: 800 Independence Avenue SW. Washington, DC
20591. ATTN: Information Collection Clearance Officer, AES-200"
Accepted LT Apr/12/2011
DEPARTMENT OF TRANSPORTATION-FEDERAL AVIATION ADMINISTRATION
FAILURE TO RE-REGISTER WILL RESULT
IN CANCELLATION OF REGISTRATION
AIRCRAFT RE-REGISTRATION APPLICATION
AND REGISTRATION NUMBER ASSIGNMENT
(See 14 C.F.R. 95 47.15(i). 47.40 and 47.41)
AIRCRAFT REGISTRATION NUMBER
SERIAL NUMBER
N 401HB
5173
MANUFACTURER
MODEL
GULFSTREAM AEROSPACE
GV-SP (G550)
DATE OF ISSUANCE
DATE OF EXPIRATION
TYPE OF REGISTRATION
APRIL 02, 2008
JUNE 30, 2011
CORPORATION
NAME AND MAILING ADDRESS OF REGISTERED OWNER
INFORMATION FOR COMPLETION
(If individual, give last name, first name and middle initial)
(Owner 1) CHEVRON USA INC
Additional information may be obtained at our web page
http://registry.faa.gov/renewregistration or by phone at 866-762-9434
(Owner 2)
Aircraft Registration Information may be reviewed at:
Note: Enter any additional owner names on page two of this document.
http://registry.faa.gov/aircraftinguiry
(Address)
Please pay fees with a check or money order payable to the
(Address)
Federal Aviation Administration
City SAN RAMON
State CA Zip 94583-2324
Signature Requirements for Listed Registration Types:
Country UNITED STATES
Individual
owner must sign.
PHYSICAL ADDRESS (REQUIRED WHEN MAILING ADDRESS IS A P.O. BOX
Partnership
a general partner must sign.
OR MAIL DROP)
Corporation
a corporate officer or managing official must sign.
Limited Liability Co.
a member, manager, or officer who is authorized to
(Address)
manage the LLC must sign.
(Address)
Co-owner
each co-owner must sign, continuing as necessary.
on page number two.
City
State
Zip
Government
any authorized person may sign.
Country
Note: All signatures must be In Ink.
TO RE-REGISTER AIRCRAFT: REVIEW REGISTRATION INFORMATION,
TO CANCEL THE REGISTRATION FOR THIS AIRCRAFT:
ENTER CORRECTIONS IN BLANKS PROVIDED, CHECK APPLICABLE
THE LAST REGISTERED OWNER MUST: MARK THE APPLICABLE
BLOCK BELOW. SIGN. DATE. & MAIL WITH THE $5 FEE. To: The FAA
BLOCK(S). COMPLETE SIGN, DATE & Mail with any fees to: The
Aircraft Registration Branch,
Oklahoma City. OK, 73125-0504.
FAA Aircraft Registration Branch,
Oklahoma City, OK,
73125-0504.
I (WE) CERTIFY THE: NAME(S) AND MAILING ADDRESS SHOWN ABOVE
FOR THE OWNER(S) OF THIS AIRCRAFT ARE CORRECT, OWNERSHIP
MEETS CITIZENSHIP REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS
CANCELLATION OF REGISTRATION IS REQUESTED FOR THE
NOT REGISTERED UNDER THE LAWS OF ANY FOREIGN COUNTRY.
REASON MARKED BELOW,
UPDATE THE MAILING / PHYSICAL ADDRESS AS SHOWN BELOW. I
1. THE AIRCRAFT WAS SOLD TO:
(WE) CERTIFY THE: NAME(S) SHOWN ABOVE FOR THE OWNER(S) OF
(Show purchaser's name and address)
THIS AIRCRAFT IS CORRECT. OWNERSHIP MEETS THE CITIZENSHIP
REQUIREMENTS OF 14 CFR $47.3. AIRCRAFT IS NOT REGISTERED
UNDER THE LAWS OF ANY FOREIGN COUNTRY.
MAILING ADDRESS
OAKLAND, CA 94621
2. THE AIRCRAFT IS DESTROYED OR SCRAPPED.
3. THE AIRCRAFT WAS EXPORTED TO:
PHYSICAL ADDRESS: COMPLETE IF PHYSICAL ADDRESS HAS
CHANGED. OR NEW MAILING ADDRESS IS A PO BOX OR MAIL
DROP.
4. OTHER, Specify
UPON CANCELLATION, PLEASE RESERVE THE N-NUMBER
IN OWNERS' NAME. The $10 check or money order for the N-
number reservation fee is enclosed.
TITLE
DATE
Assistant Secretary
2/8/2011
SIGNATURE OF OWNER 2
PRINTED NAME OF SIGNER
TITLE
DATE
110660826086
AC Form 8050-1A (10/10)
$5.00 03/07/2011
EFTA00010670

=== Page 52 ===
EFTA00010671
AIRCRAFT REGISTRATION
BR
2011 MAR 7 AM 8 34
OKLAHOMA CITY
OKLAHOMA

=== Page 53 ===
DOCUMENT LEVEL ANNOTATIONS FOR DOCUMENT ARE002412672
REV/DOI - 4/2/2008
EFTA00010672

=== Page 54 ===
EFTA00010673

=== Page 55 ===
U.S. Department
Flight Standards Service
of Transportation
Aircraft Registration Branch,
Oklahoma City, Oklahoma 73125-0504
AFS-750
Federal Aviation
Toll Free:
Administration
WEB Address:
Date of Issue: April 2, 2008
CHEVRON USAINC
SAN RAMON, CA 94583-2324
HAND DELIVERED TO ARTC IN THE PD ROOM
T082390
This facsimile must be carried in the Aircraft as a Temporary Certificate of
Registration for
N401HB GULFSTREAM AEROSPACE GV-SP (G550) Serial 5173 and is valid until May
02, 2008.
This is not an airworthiness certificate. For airworthiness information, contact the nearest
Federal Aviation Administration Flight Standards District Office.
Manager, FAA Aircraft Registry, AFS-750
Federal Aviation Administration
AFS-750-FAX-4 (10/05)
EFTA00010674

=== Page 56 ===
EFTA00010675

=== Page 57 ===
ASSIGNMENT OF SPECIAL REGISTRATION NUMBERS
Special Registration Number
N
Aircraft Make and Model
401HB
U.S. Department
GULFSTREAM AEROSPACE
GV-SP (6550)
of Transportation
Present Registration Number
Federal Aviation
Serial Number
Administration
5173
3960203
N
673GA
Issue Date:
ICAO AIRCRAFT ADDRESS CODE
NOVEMBER 14, 2007
FOR N401HB = 51130411
This is your authority to change the United States registra-
tion number on the above described aircraft to the special
GULFSTREAM AEROSPACE CORP
registration number shown.
SAVANNAH GA 31408-9643
Carry duplicate of this form in the aircraft together with the
old registration certificate as interim authority to operate the
aircraft pending receipt of revised certificate of registration.
Obtain a revised certificate of airworthiness from your near-
est Flight Standards District Office.
The latest FAA Form 8130-6, Application
NUMBER CHANGED TO
401HB
For Airworthiness on file is dated:
DATE
18 FEB 05 2008
The airworthiness classification and category:
INSTRUCTIONS:
SIGN AND RETURN THE ORIGINAL of this form to the Civil Aviation Registry, AFS-750, within 5 days after the special registration number is
placed on the aircraft. A revised certificate will then be issued.
The authority to use the special number expires:
NOVEMBER 14, 2008
CERTIFICATION: I certify that the special registration number was placed on the
RETURN FORM TO:
aircraft described above:
Civil Aviation Registry, AFS-750
Signature of Ow
Oklahoma City, Oklahoma 73125-0504
Title of Owner:
Contract Administrator
Date Placed on Aircraft:
1/23/08
AC Form 8050-64
(5/2005) Supersedes Previous Edition
EFTA00010676

=== Page 58 ===
theirs
MIREILED WITH FAA
AIRCRAFT REGISTRATION BR
2008 JAN 23 . PM 3 19
OKLAHOMA CITY
OKLAHOMA

=== Page 59 ===
AIRCRAFT TITLE SEARCHES
Aero Records & Title Co./N
RECORDING SERVICES
its
AIRMEN RECORD INFORMATION
ARICO
Oklahoma City, OK 73144
October 25, 2007
Hand Delivered
To:
FAA
Oklahoma City, Oklahoma
401HB
Attention:
Central Records
-64 673GA
Gentlemen:
18 NOV 14 2007
On behalf of our client:
GULFSTREAM AEROSPACE CORP.
Savannah, GA 31407
Please initiate the following action:
1. Please RESERVE the following special registration number:
N401HB
PLEASE HAND THE CONFIRMATION OF RESERVATION LETTER TO
ARTC IN THE PUBLIC DOCUMENTS ROOM.
2. Please ASSIGN N401HB to the following described aircraft which
is registered to our client above:
GULFSTREAM AEROSPACE GV-SP (G550)
SERIAL NUMBER 5173
CURRENTLY N673GA
PLEASE HAND THE ORIGINAL FORM 8050-64 TO ARTC IN THE PUBLIC
DOCUMENTS ROOM.
Thank you.
072981539402
$10.00 10/25/2007
X
PLEASE HAND CONFIRMATION OF RESERVATION LETTER TO ARTC - PUBLIC DOCUMENTS ROOM.
X
PLEASE HAND ORIGINAL FORM 8050-64 TO ARTC - PUBLIC DOCUMENTS ROOM.
Thank you,
AERO
0
By:
Special Services
Fee Attached: $ 10.00
CC:
Gulfstream Aerospace Corp.
EFTA00010678

=== Page 60 ===
EFTA00010679
FILED WITHFAA
AIROPANT RECISTR ATSH DR
'07 OCT 25 PM 3 28
OKLAHOMA CITY
CKLAHOMA

=== Page 61 ===
DECLARATION
OF
INTERNATIONAL OPERATIONS
Accepted PH Apr/02/2008
The undersigned owner of aircraft N401HB, Manufacturer Gulfstream Aerospace
Corporation Model No. GV-SP (G550) Serial No. 5173 declares that this aircraft is
scheduled to make an international flight on April 14, 2008 departing Oakland,
California, USA, with a destination of London, England, United Kingdom.
Expedited registration in support of this international flight is requested this 27th day of
March, 2008 with knowledge that:
Whoever, in any matter within the jurisdiction of the executive branch of
the Government of the United States, knowingly and willfully makes or
uses any false writing or document knowing the same to contain any
materially false, fictitious or fraudulent statement or representation shall
be fined under Title 18 United States Code or imprisoned not more than 5
years, or both. 18 U.S.C. 1001(a).
Name of Owner:
Chevron U.S.A. Inc.
Typed Name and
Manager Flight Operations
Signature:
Comments:
Filed by: AERO RECORDS & TITLE CO.
(telephone number)
EFTA00010680

=== Page 62 ===
EFTA0001068
FILED WITHFAA
AIRCR FT T REGISTRATION BR
2008 MAR 27 PM 1 25
OKLAHOMA CITY
OKLAHOMA

=== Page 63 ===
FORM APPROVED
OMB No. 2120-0042
UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION-MEKE MONRONEY AERONAUTICAL CENTER
AIRCRAFT REGISTRATION APPLICATION
CERT. ISSUE DATE
UNITED STATES
REGISTRATION NUMBER
N
401
HB
AIRCRAFT MANUFACTURER & MODEL
GULFSTREAM AEROSPACE GV-SP (G550)
AIRCRAFT SERIAL No.
5173
FOR FAA USE ONLY
Accepted PH Apr/02/2008
TYPE OF REGISTRATION (Check one box)
1. Individual
2. Partnership
X
3. Corporation
4. Co-owner
5. Gov't.
8. Non-Citizen
Corporation
NAME OF APPLICANT (Person(s) shown on evidence of ownership. If individual, give last name, first name, and middle initial.)
CHEVRON U.S.A. INC.
TELEPHONE NUMBER: (
ADDRESS (Permanent mailing address for first applicant listed.) (If P.O. BOX is used, physical address must also be shown.)
Number and street:
r
a
Rural Route:
P.O. Box:
CITY
STATE
ZIP CODE
SAN RAMON
CA
94583
CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS
ATTENTION! Read the following statement before signing this application.
This portion MUST be completed.
A false or dishonest answer to any question in this application may be grounds for punishment by fine and / or imprisonment
(U.S. Code, Title 18, Sec. 1001).
CERTIFICATION
I/WE CERTIFY:
(1) That the above aircraft is owned by the undersigned applicant, who is a citizen (including corporations)
of the United States.
(For voting trust, give name of trustee:
). or:
CHECK ONE AS APPROPRIATE:
a.
A resident alien, with alien registration (Form 1-151 or Form 1-551) No.
b.
A non-citizen corporation organized and doing business under the laws of (state)
and said aircraft is based and primarily used in the United States. Records or flight hours are available for
inspection at
(2) That the aircraft is not registered under the laws of any foreign country: and
(3) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration
NOTE: If executed for co-ownership all applicants must sign. Use reverse side if necessary.
TYP
-TITLE
DATE
ASST. SECRETARY
3/19/2008
EACH PART OF THIS
APPLICATION MUST
BE SIGNED IN INK.
SIGNATURE
TITLE
DATE:
3-27-08
SIGNATURE
TITLE
DATE
NOTE Pending receipt of the Certificate of Aircraft Registration, the aircraft may be operated for a period not in excess of 90
days, during which time the PINK copy of this application must be carried in the aircraft.
AC Form 8050-1 (5/03) (0052-00-628-9007)
EFTA00010682

=== Page 64 ===
EFTA00010683
AIRCRAFT REGISTRATION BR
FILED WITHFAA
2008 MAR 27 PM 1 25
OKLAHOMA.CITY

=== Page 65 ===
FORM APPROVED
OMB NO. 2120-0042
UNITED STATES OF AMERICA
U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION
AIRCRAFT BILL OF SALE
FOR AND IN CONSIDERATION OF $1.00 & OVC THE
UNDERSIGNED OWNER(S) OF THE FULL LEGAL
AND BENEFICIAL TITLE OF THE AIRCRAFT
DESCRIBED AS FOLLOWS:
UNITED STATES
REGISTRATION NUMBER N 401HB
AIRCRAFT MANUFACTURER & MODEL
Gulfstream Aerospace GV-SP (G550)
AIRCRAFT SERIAL NO.
5173
DOES THIS 27th DAY OF march 2008,
PH000007 Conveyance Recorded Apr/02/2008 08:11 AM FAA
HEREBY SELL, GRANT, TRANSFER AND
DELIVER ALL RIGHTS, TITLE, AND INTERESTS
IN AND TO SUCH AIRCRAFT UNTO:
Do Not Write In This Block
FOR FAA USE ONLY
NAME AND ADDRESS
(IF INDIVIDUAL (S), GIVE LAST NAME, FIRST NAME, AND MIDDLE INITIAL.)
PURCHASER
Chevron U.S.A. Inc.
San Ramon, CA 94583
DEALER CERTIFICATE NUMBER
AND TO ITS SUCCESSORS, EXECUTORS, ADMINISTRATORS, AND ASSIGNS TO HAVE AND TO HOLD
SINGULARLY THE SAID AIRCRAFT FOREVER, AND WARRANTS THE TITLE THEREOF.
IN TESTIMONY WHEREOF WE HAVE SET OUR HAND AND SEAL THIS 274h DAY OF march 2008.
NAME (S) OF SELLER
SIGNATURE (S)
TITLE
(TYPED OR PRINTED)
(TYPED OR PRINTED)
SELLER
Gulfstream Aerospace Corporation
Manager
ACKNOWLEDGEMENT (NOT REQUIRED FOR PURPOSES OF FAA RECORDING: HOWEVER, MAY BE REQUIRED
BY LOCAL LAW FOR VALIDITY OF THE INSTRUMENT.)
ORIGINAL: TO FAA
AC Form 8050-2 (9/92) (NSN 0052-00-629-0003) Supersedes Previous Edition
080871324467
$5.00 03/27/2008
EFTA00010684

=== Page 66 ===
EFTA00010685
FILED
AIRCRAFT REGISTRATION BR
2008 MAR 27 PM 1 25
OKLAHOMA
OKLAHOMATY

=== Page 67 ===
U.S. Department
Flight Standards Service
of Transportation
Aircraft Registration Branch, AFS-750
Oklahoma City, Oklahoma 73125-0504
Federal Aviation
Toll Free:
Administration
WEB Address:
March 1, 2007
GULFSTREAM AEROSPACE CORP
SAVANNAH GA 31408
Dear Sirs:
United States identification mark N673GA has been assigned to Gulfstream Aerospace GV-SP
(G550), serial number 5173, Mode S Transponder Code 52163564 as requested by you. This
manufacturer's assignment of special registration number cannot be used as an authorization for a
number change.
If we may be of further assistance, please contact the Aircraft Registration Branch at
or toll free
Sincerely,
Legal Instruments Examiner
Aircraft Registration Branch
AFS-750-SUPPORT-5 (04/06)
EFTA00010686

=== Page 68 ===

=== Page 69 ===
Gulfstream
AGENT RAI
A 6736A
O6 FEB 26 2007
February 15 ) 2007
Federal Aviation Administration
FAA Aircraft Registry
Oklahoma City, OK 73125
ATTENTION: CENTRAL RECORDS DIVISION
Dear Madam/Sir:
Please reserve and assign the enclosed special registration numbers for
Gulfstream Aerospace Corporation
Once these numbers have been reserved and assigned in the name of
Gulfstream Aerospace Corporation, please hand confirmations to ARTC in the
PD Room. If the above requested numbers are not available, please contact
Lisa homas at ARTC immediately.
Thank you for your assistance with this request.
Very truly yours.
Enclosure
070471458332
$420.00 02/16/2007
EFTA00010688

=== Page 70 ===
EFTA00010689
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2007 FEB 16 PM 2 53
OKLAHOMA CITY
OKLAHOMA

=== Page 71 ===
Reserve:
Assign to:
TEBID#
1.
N
494
GA
Gulfstream Model GIV-X (G350)
S/N
4094
2.
N
495 GA
Gulfstream Model GIV-X (G450)
S/N
4095
3.
N
496 GA
Gulfstream Model GIV-X (G450)
S/N
4096
4.
N
397
GA
Gulfstream Model GIV-X (G450)
S/N
4097
5.
N
398
GA
Gulfstream Model GIV-X (G450)
S/N
4098
6.
N
199 GA
Gulfstream Model GIV-X (G450)
S/N
4199
7.
N
120 GA
Gulfstream Model GIV-X (G450)
S/N
4100
8.
N
401
GA
Gulfstream Model GIV-X (G450)
S/N
4101
9.
N
702
GA
Gulfstream Model GIV-X (G450)
S/N
4102
10.
N
603
GA
Gulfstream Model GIV-X (G450)
S/N
4103
11.
N
704
GA
Gulfstream Model GIV-X (G450)
S/N
4104
12.
N
405 GA
Gulfstream Model GIV-X (G450)
S/N
4105
13.
N
606
GA
Gulfstream Model GIV-X (G450)
S/N
4106
14.
N
607
GA
Gulfstream Model GIV-X (G450)
S/N
4107
15.
N
608
GA
Gulfstream Model GIV-X (G450)
S/N
4108
16.
N
609
GA
Gulfstream Model GIV-X (G450)
S/N
4109
17.
N
610
GA
Gulfstream Model GIV-X (G450)
S/N
4110
18.
N
131
GA
Gulfstream Model GIV-X (G350)
S/N
4111
19.
N
612
GA
Gulfstream Model GIV-X (G450)
S/N
4112
20.
N
913
GA
Gulfstream Model GIV-X (G450)
S/N
4113
21.
N
614 GA
Gulfstream Model GIV-X (G450)
S/N
4114
815 GA
Gulfstream Model GIV-X (G450)
S/N
4115
22.
N
23.
N
764
GA
Gulfstream Model GV-SP (G550)
S/N
5164
24.
N
965 GA
Gulfstream Model GV-SP (G550)
S/N
5165
25.
N
966
GA
Gulfstream Model GV-SP (G550)
S/N
5166
26.
N
967
GA
Gulfstream Model GV-SP (G550)
S/N
5167
27.
N
668
GA
Gulfstream Model GV-SP (G550)
S/N
5168
28.
N
569
GA
Gulfstream Model GV-SP (G550)
S/N
5169
29.
N
770
GA
Gulfstream Model GV-SP (G550)
S/N
5170
30.
N
971
GA
Gulfstream Model GV-SP (G550)
S/N
5171
31.
N
972
GA
Gulfstream Model GV-SP (G550)
S/N
5172
32.
N
673
GA
Gulfstream Model GV-SP (G550)
33.
N
974
GA
Gulfstream Model GV-SP (G550)
Gulfstream Model GV-SP I (G550)
S/N
5173
S/N
5174
34.
N
GA
Gulfstream Model GV-SP (G550)
S/N
5175
975
35.
N
476
Gulfstream Model GV-SP (G550)
S/N
5176
GA
36.
Gulfstream Model GV-SP (G550)
S/N
5177
N
977
GA
37.
N
978
GA
Gulfstream Model GV-SP (G550)
S/N
5178
Gulfstream Model GV-SP (G550)
S/N
5179
38.
N
979
GA
39.
N
980
GA
Gulfstream Model GV-SP (G550)
S/N
5180
S/N
5181
40.
N
181
GA
41.
N
GA
Gulfstream Model GV-SP (G550)
S/N
5182
782
42.
N
983
GA
Gulfstream Model GV-SP (G550)
S/N
5183
EFTA00010690

=== Page 72 ===
EFTA00010691
FILED WITH FAA
AIRCRAF I REGISTRATION BR
2007 FEB 16 PM 2 53
OKLAHOMA CITY
OKLAHOMA

=== Page 73 ===
Aero Records & Title Co.
799138
Post Office Box 19246, Oklahoma City, OK 73144
Phone
.
Fax:
AR
Escrow Toll Free:
February 16, 2007
REQUEST
FOR
MANUFACTURER
N#
Aircraft Title Searches
ASSIGNMENTS
Professional Escrow and Closing
Services
Recording Services
Federal Aviation Administration
Reservation and Assignment of
Civil Aviation Registry
Special Registration Numbers
Aircraft Title Insurance
Aircraft Registration Branch
$1031 Like-Kind Exchange Services
Attention: Central Records
Reference: (42) Registration Number Assignments
Gentlemen/Ladies:
On behalf of our client:
GULFSTREAM AEROSPACE CORPORATION
Physical address for
courier deliveries:
SAVANNAH, GA 31407
Oklahoma City, OK 73179
Please reserve & assign forty-two (42) special
registration numbers as listed on Gulfstream's
enclosed letter. Please issue 8050-7 forms to
Gulfstream at the address shown above. PLEASE
HAND COPIES OF THE ASSIGNMENT LETTERS
TO ARTC IN THE P.D. ROOM.
www.aerorecords.com
The necessary $420.00 fee for reservation of the
special registration numbers is enclosed.
Aero Records & Title Co. is
Special Services Administrator
a subsidiary of Fidelity National
/lg
Title Insurance Company
a member of the
Enclosures: letter by Gulfstream & check for $420.
Fidelity National Financial, Inc.
family of companies.
CC: Carol Rowley /Gulfstream
EFTA00010692

=== Page 74 ===
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FILED WITH FAA
AIRCRAFT REGISTRATION BR
2007 FEB 16 PM 2 53
OKLAHOMA CITY
OKLAHOMA


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=== Page 1 ===
From: BOBBI C STERNHEIM
To: BRO-LegalVisit-S
@bop.gov> Achal Fernando-Peiris
NYS MDCemail
Cc:
>, BRO/Exec Assistant~
@bop.gov>,
)"
Subject: URGENT REQUEST-GHISLAINE MAXWELL 02879-509
Date: Fri, 20 Nov 2020 19:36:44 +0000
My client -Ghislaine Maxwell 02879-509- has been placed in quarantine
due to contact with a corrections officer who became infected with COVID.
I have not received notification that my scheduled legal visits-
for tomorrow 11/21 and next Saturday 11/28 from 12:30 pm - 3:00 pm-
but I assume they are cancelled.
IN LIEU OF THE LEGAL VISITS - I AM REQUESTING LEGAL CALLS
FOR TOMORROW AND NEXT SATURDAY FROM 12:30 -3:00 PM.
There are time sensitive matters to be discussed.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Main:
Cell:
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
On Nov 17, 2020, at 9:27 AM, BRO-LegalVisit-S
@bop.gov> wrote:
You are scheduled as follows
November 21, 2020
12:30 pm to 3:00 pm
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November 28, 2020
12:30 pm to 3:00 pm
Asia
>>> BOBBI C STERNHEIM
<
>
11/14/2020 6:09 PM >>>
Good afternoon-
I am counsel for
Ghislaine Maxwell 02879-509.
I am requesting a legal visit for:
Saturday 11/21 @ 12:30 - 3:00
and
Saturday 11/29 @ 12:30 - 3:00.
I possess a NYS Secure Pass.
Please contact me with any questions.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
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.
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=== Page 1 ===
From:
(USAFLS)"
To:
(USAFLS)"
Bcc:
(USAFLS)"
Subject: RE: Don't know if you saw
Date: Tue, 01 Jul 2008 21:04:05 +0000
Importance: Normal
Thank you,
I hope you are feeling better.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
From:
(USAFLS)
Sent: Tuesday, July 01, 2008 4:15 PM
To:
(USAFLS)
Subject: RE: Don't know if you saw
Alex told me this morning that Epstein had pled. That is wonderful. I never thought we'd see the day. You
deserve all the credit for this. If it had not been for you, he would have gotten away with it.
From:
(USAFLS)
Sent: Tuesday, July 01, 2008 11:31 AM
To:
(USAFLS)
Subject: Don't know if you saw
But my nemesis Mr. Epstein finally pled. The first article is my favorite. Thank you, as always, for your help
and support. I am still in a state of shock.
« File: News Briefings 07 01 08.pdf
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax
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=== Page 1 ===
Event: Accepted: Call w/ DOJ re. Epstein SDNY Investigation
Start Date: 2020-10-05 19:00:00 +0000
End Date: 2020-10-05 19:30:00 +0000
Location:
4279915#
Class: X-PERSONAL
Comment:
Date Created: 2020-10-02 16:40:02 +0000
Date Modified: 2020-10-02 16:40:02 +0000
Priority: 5
DTSTAMP: 2020-10-02 16:17:58 +0000
Attendee: Singer, Linda
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=== Page 1 ===
From
To
Cc: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>, "USANYS-
CRIMINAL PARALEGALS" <USANYS-CRIMINALPARALEGALS@usa.doj.gov>, USANYS-
INVESTIGATORS <USANYS-INVESTIGATORS@usa.doj.gov>.
Subject: Re: United States V. Ghislaine Maxwell
opens
Date: Mon, 29 Nov 2021 19:03:04 +0000
About to start
Sent from my iPhone
On Nov 29, 2021, at 12:58 PM
wrote:
We (finally!) have our jury. Preliminary instructions are happening now, and
will open after lunch, around
1:45. Come support!
Sent from my iPhone
On Nov 28, 2021, at 9:59 AM,
wrote:
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took
place in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors
will do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine
Maxwell sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her
accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions
and opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
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=== Page 1 ===
Case 9:08-cv-80119-KAM Document 65-3 Entered on FLSD Docket 03/25/2009 Page 1 of 3
AFFIDAVIT OF JACK A. GOLDBERGER, ESQUIRE
STATE OF FLORIDA
) SS
COUNTY OF PALM BEACH
)
BEFORE ME, the undersigned authority, personally appeared
having personal knowledge and being duly sworn, deposes and says:
1.
I, Jack A. Goldberger, have personal knowledge of the matters set
forth herein. I am an attorney licensed to practice in the State of Florida since
1978. I am a partner with the law firm of Atterbury Goldberger & Weiss, P.A.,
located at One Clearlake Centre, Suite 1400, 250 Australian Avenue South, West
Palm Beach, FL 33401.
2.
My practice includes and specializes in the defense of criminal
matters. I am board certified in criminal law. I have been and currently am the
criminal defense attorney for JEFFREY EPSTEIN.
3.
I represented Mr. EPSTEIN in the negotiation of and entering into a
Non-Prosecution Agreement with the United States Attorney's Office (USAO) for
the Federal Southern District of Florida. The terms and conditions of the Non-
Prosecution Agreement also entailed the entering of a Plea Agreement with the
State Attorney's Office, Palm Beach County, State of Florida. (The Non-
Prosecution Agreement shall hereinafter be referred to as the "NPA").
4.
By its terms, the NPA took effect on June 30, 2008. Also, pursuant
to the terms of the NPA, any criminal prosecution against EPSTEIN is deferred
as long as the terms and conditions of the NPA are fulfilled by EPSTEIN.
EXHIBIT "B"
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Case 9:08-cv-80119-KAM Document 65-3 Entered on FLSD Docket 03/25/2009 Page 2 of 3
5.
The criminal matters against EPSTEIN remain ongoing until the
NPA expires by its terms in late 2010, and as long as the USAO determines
EPSTEIN has complied with those terms and conditions. The threat of criminal
prosecution against EPSTEIN by USAO in the Southern District of Florida
continues presently and through late 2010.
6.
Pursuant to the terms of the NPA, the USAO possesses the right to
declare that the agreement has been breached, give EPSTEIN's counsel notice,
and attempt to move forward with a prosecution. As of the date of this Affidavit,
the USAO has taken the position on a number of occasions that it might consider
the following actions by EPSTEIN to be a breach of the NPA.
Investigation by EPSTEIN (by and through his attorneys) of this Plaintiff
and the other Plaintiffs in other pending civil cases for purposes of
defending the civil actions;
EPSTEIN's contesting damages in this action and other civil actions.
EPSTEIN or his legal representatives making statements to the press
about this Plaintiff or the other Plaintiffs.
Using the word "jail" instead of "imprisonment" in the plea agreement with
the Palm Beach County State Attorney's Office.
7.
EPSTEIN, through counsel, submitted a Freedom of Information
Act request to the Federal Bureau of Investigation (FBI) for documents relating to
this and the other cases; the FBI denied the request stating the materials are at
this time exempt from disclosure because they are in an investigative file, i.e. the
matter is still an ongoing criminal investigation.
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Case 9:08-cv-80119-KAM Document 65-3 Entered on FLSD Docket 03/25/2009 Page 3 of 3
8.
The NPA expires in late 2010.
FURTHER THE AFFIANT SAYETH NAUGHT
Mr Jack A. Goldberger, Esq.
STATE OF FLORIDA
COUNTY OF PALM BEACH
I hereby Certify that on this day, before me, an officer duly authorized to
administer oaths and take acknowledgments, personally appeared
Jack A. Goldberger, Esquire, known to me to be the person described in and who
executed the foregoing Affidavit, who acknowledged before me that he/she
executed the same, that I relied upon the following form of identification of the
above named person: known Personally
, and that an oath was/was
not taken.
WITNESS my hand and official seal in the County and State last aforesaid
this 19th day of February
, 2009.
would
SUBLIC
Notary Public State of Florida
Kim E Rosin
PRINT NAME:
Kin E Rosin
(SEAL)
My Commission DD489790
NOTARY PUBLIC/STATE OF FLORIDA
Expires 11/13/2009
COMMISSION NO.: DD 489790
MY COMMISSION EXPIRES: 11/13/2009
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