# docs_fts_content

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=== Page 1 ===
OFFICIAL RECORD
Intake (Rev. 5-23-17)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Intake
Date: 08/03/2020
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Drafted By:
Date/Time Received: 08/03/2020 06:01 PM EDT
Details:
On 08/03/2020, at 5:11 P.M. Eastern Daylight Time,
date of birth
,
email address
address
, Los Lunas, NM 87031, cellular telephone number
,
Internet Protocol (IP) address
, which
resolves at Albuquerque, NM 87114, submitted an online tip to the FBI
National Threat Operations Center (NTOC) via tips.fbi.gov to report a
follow-up tip regarding being a victim of Jeffrey Epstein.
NOTE:
is real name and AKA name is
Date Submitted: 08/03/2020 05:11:11 PM ET
Transaction Number: 5914ABD0-1FE1-4719-9BFC-D0006B42A613
Threat To Life: False
Submitted Text:
I previously provided a tip about 3 weeks ago, maybe 4 weeks ago, under
an alias I have for myself,
-
All the other details of the
previous tip match all the information given in today's tip, except I am
giving my real name. A detective from NYPD FBI sex trafficking task force
called me a couple of weeks ago from a 212 area code number. I talked to
him for about 20 or 30 minutes about my being sex trafficked by my uncle
and Jeffrey Epstein in 1984 while I was 13 and pregnant. I told him some
other important information about other high profile individuals involved
in my sex trafficking and the murder and disposal of my newborn daughter
because I gave birth to her while in the middle of this sex trafficking
ordeal. I cannot remember the detective's name nor do I have a number
UNCLASSIFIED
EFTA00025010

=== Page 2 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/03/2020
where I can contact him. I would like to have his name and contact
information, and I would also like to know if there will be any further
follow up?
Violation: Other
Violation Questions
What was the exact crime that occurred?: child sex trafficking and
infanticide
When did the crime/incident occur? (Please provide an approximate date
and time) : May-Sep 1984
Where did the crime/incident occur? (Please provide the specific
location/address if possible) : Mostly from a yacht in Lake Michigan
originating from Mona Lake, MI
Complainant Information
First Name:
Middle Name:
Last Name:
Age:
DOB:
Additional Info:
Type: Cell
Phone:
Extension: 0
Account:
Type: Residential
Address:
City: Los Lunas
State: New Mexico
Zip: 87031
Country: United States
Subject Information
First Name: Jeffrey
Middle Name:
Last Name: Epstein
UNCLASSIFIED
2
EFTA00025011

=== Page 3 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/03/2020
Age: dec
DOB:
Additional Info: I am just wanting to reconnect with the original
detective that called me and I offered information about this.
How is Contact Known: He was orchestrating a deal, along with my uncle
where different men, and a few women and girls,
would come to a variety of boats and yachts and pay money to force me to
do
with them when I was 13 and pregnant.
Type: Other
Address:
City:
Zip:
Witness Information
First Name: Donald
Middle Name:
Last Name: Trump
Age: 70
DOB:
Additional Info: Again, just trying to find out the NYPD detective on the
FBI sex trafficking task force that called me a couple of weeks ago and
spoke to me about some of these issues.
How is Contact Known: He participated regularly in paying money to force
me to
with him and he was present when my uncle murdered
my newborn child and disposed of the body in Lake Michigan.
Type: Business
Address:
City: Washington DC
State: District of Columbia
Zip: 20500
Country: United States
Remote IP:
Remote Host: api.fbi.gov
Http Referrer: https://tips.fbi.gov/reported
User Browser: Mozilla/5.0 (Macintosh; Intel Mac OS X 10_15_5)
UNCLASSIFIED
3
EFTA00025012

=== Page 4 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/03/2020
AppleWebKit/605.1.15 (KHTML, like Gecko) Version/13.1.1 Safari/605.1.15
Latitude:
Longitude:
Country: US
Region: New Mexico
City: Albuquerque
Postal Code: 87114
Timezone: -06:00
UNCLASSIFIED
4
EFTA00025013


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
(USANYS)"
Bec:
"
Subject: RE: MCC discovery/notes
Date: Thu, 01 Oct 2020 15:10:23 +0000
Embedded: RE:_MCC_discovery_notes.msg
Sender:
Subject: RE: MCC discovery/notes
Message-Id:
<DM3P110MB05409C8E2C202236A5C92303ED300@DM3P110MB0540.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
EFTA00026564


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=== Page 1 ===
Event: Accepted: Call in Epstein FOIA
Start Date: 2021-04-13 17:30:00 +0000
End Date: 2021-04-13 18:00:00 +0000
Location:
to call
and
and merge calls
Class: X-PERSONAL
Comment:
Date Created: 2021-04-13 15:14:48 +0000
Date Modified: 2021-04-13 15:14:48 +0000
Priority: 5
DTSTAMP: 2021-04-13 14:58:19 +0000
Attendee:
(USANYS)
<
EFTA00026916


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=== Page 1 ===
From
To
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:24:28 +0000
Attachments: U.S._v._Ghislaine_Maxwell_Indictment.pdf, Ghislaine_Maxwell_Indictment_PR.pdf
Inline-Images: image001.png
Amazing work. Congrats!
From:
Sent: Thursday, July 02, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO UNITED DONIMINA VILLING
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
EFTA00024547

=== Page 2 ===
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
EFTA00024548

=== Page 3 ===
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00024549


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=== Page 1 ===
From:
"
(USANYS) [Contractor]"
To:
"
(USANYS)"
Cc:
(USANYS)"
Subject:
filings tonight
Date: Sat, 21 Dec 2019 00:26:06 +0000
Attachments: 127126085966.pdf; ATT00001.htm; 127126086038.pdf; ATT00002.htm; 127126085993.pdf;
ATT00003.htm; 127126086039.pdf; ATT00004.htm; 127126086040.pdf; ATT00005.htm;
127126086041.pdf; ATT00006.htm
EFTA00027033


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=== Page 1 ===
From:
To:
Subject: FW: Subscriber info for
Date: Tue, 25 Jun 2019 00:07:51 +0000
Importance: Normal
Attachments: SUB_Tibco_6464369784_6724923.xils
This is the number that was listed as
on a message pad in Epstein's Florida residence. I don't recognize
any of these subscribers.
Original Message
From:
Sent: Monday, June 24, 2019 4:17 PM
To:
Cc
Subject: Subscriber info for
See attached for subscriber info for
Special Agent
FBI New York
VCAC/Human Trafficking
EFTA00026673


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=== Page 1 ===
From:
"
)"
To: Christian Everdell
, "Mark S. Cohen"
Cc:
)"
>, , "
)"
=
Subject: RE: Hard Drive and Discovery
Date: Thu, 06 Aug 2020 01:26:51 +0000
Attachments: SDNY_GM_00000906-SDNY_GM_00000962.zip
Inline-Images: image001.png; image002.jpg
Counsel,
Further to our email below, attached please find the second .zip folder, containing four individual corrected documents.
Regards,
D
EFTA00023866

=== Page 2 ===
Duplicate
EFTA00023867

=== Page 3 ===
Duplicate
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:
EFTA00023868


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Order
Date: Sat, 15 May 2021 12:16:57 +0000
Thank you, Have a good weekend!
Staff Attorney
MDC Brooklyn
Original message
From:
(USANYS)"
Date: 5/14/21 5:18 PM (GMT-05:00)
To:
Cc:
Subject: FW: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Order
(USANYS)" 05/14/2021 17:18
Please see the attached Order from Judge Nathan.
Thank you,
From:NYSD_ECF_Pool@nysd.uscourts.gov <NYSD_ECF_Pool@nysd.uscourts.gov>
Sent: Friday, May 14, 2021 4:57 PM
To: CourtMail@nysd.uscourts.gov
Subject: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Order
This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-
mail because the mail box is unattended.
***NOTE TO PUBLIC ACCESS USERS*** There is no charge for viewing opinions.
U.S. District Court
Southern District of New York
Notice of Electronic Filing
The following transaction was entered on 5/14/2021 at 4:57 PM EDT and filed on 5/14/2021
EFTA00024708

=== Page 2 ===
Case Name:
USA V. Maxwell
Case Number:
1:20-cr-00330-AJN
Filer:
Document Number: 282
Docket Text:
ORDER as to Ghislaine Maxwell: On April 29, 2021, counsel for Ghislaine Maxwell wrote to the
Court requesting that the Court address her sleeping conditions, with particular emphasis on
counsel's representation, unsupported by affidavit or other factual showing, that guards are
shining a flashlight in Maxwell's eyes every 15 minutes at night. Dkt. No. 256. Defense counsel
claims that the flashlight surveillance in Maxwell's eyes is disrupting her sleep, which in turn is
impacting her ability to prepare for and withstand trial. The Court sought more information by
ordering the Government to confer with legal counsel for the Bureau of Prisons and to respond
to certain questions. Dkt. No. 257. In response, the Government states that MDC staff conduct
flashlight checks of all inmates as a matter of course. Dkt. No. 270. As reported by the
Government, inmates housed with cell mates in the Special Housing Unit are checked with
flashlights every 30 minutes. Inmates housed with others in the general population are
checked multiple times per night at regular intervals. The Government further reports that to
conduct the checks, flashlights are pointed at the ceiling of the cell to confirm that the inmate
is present, breathing, and not in distress. As the Government explains, there are a number of
neutral reasons why BOP's flashlight checks of Maxwell are relatively more frequent than those
of other inmates, including that Maxwell is housed alone, the nature of the charges, and the
potential stress for inmates that can arise in high-profile cases. The MDC has determined that
these factors necessitate more frequent safety and security checks. The Government also
indicates that the prohibition on eye masks is a generally applicable policy, but that Maxwell,
like other inmates, may use other noncontraband items to cover her eyes. To the extent that
Maxwell's April 29, 2021 letter asks the Court to override BOP's determination as to the
frequency of appropriate safety and security check procedures, that request is denied as
factually unsubstantiated and legally unsupported. Certainly nothing in the record plausibly
establishes that current protocols interfere with Maxwell's ability to prepare for her trial and
communicate with her lawyers. Defense counsel's May 7, 2021 letter, Dkt. No. 272, describes
generalized grievances but makes no additional specific and supported application for relief.
Nevertheless, the Court urges the MDC to consider whether sleep disruption for pretrial
detainees can be reduced. The Court also admonishes the MDC and the Government to
continue to ensure that Maxwell is subjected to only those security protocols that BOP
determines are necessary for her safety and security, based upon neutral and applicable
factors, and consistent with the treatment of similarly situated pre-trial detainees. The
Government shall provide a copy of this Order to the Warden and General Counsel for the
MDC. so ORDERED. (Signed by Judge Alison J. Nathan on 5/14/2021) (Inl)
1:20-cr-00330-AJN-1 Notice has been electronically mailed to:
David Boies, Il
Jeffrey S. Pagliuca
Laura A. Menninger
Bobbi C Sternheim
Christian R. Everdell
EFTA00024709

=== Page 3 ===
Mark Stewart Cohen
Sigrid S. McCawley
CaseView.ECF@usdoj.gov. USANYS.ECF@USDOJ.GOV
CaseView.ECF@usdoj.gov USANYS.ECF@USDOJ.GOV
CaseView.ECF@usdoj.gov. USANYS.ECF@USDOJ.GOV
CaseView.ECF@usdoj.gov. USANYS.ECF@USDOJ.GOV
caseview.ecf@usdoj.gov, usanys.ecf@usdoj.gov
1:20-cr-00330-AJN-1 Notice has been delivered by other means to:
The following document(s) are associated with this transaction:
Document description:Main Document
Original filename:n/a
Electronic document Stamp:
[STAMP dcecfStamp_ID=1008691343 [Date=5/14/2021] [FileNumber=25895804-
0] [63ff0bfb01f10bfc3d0e8d2bdeb02f59ed4d2bf8b47cd533ab0bf35151331f4a2
bc39021735fdaccd93fb8393b4940bd5771a6fac04662d94433fb4c5e38233]]
EFTA00024710


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=== Page 1 ===
EXHIBIT E
EFTA00025148

=== Page 2 ===
Case 1:18-cr-00492-PGG Document 8 Filed 07/16/18 Page 1 of 10
ORIGINAL
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
UNITED STATES OF AMERICA
:
:
INDICTMENT
- V. -
:
:
18 Cr.
CLAUDIUS ENGLISH,
:
a/k/a "Jay Barnes,"
:
18 CRIM 492
a/k/a "Brent English,"
:
:
Defendant.
:
X
COUNT ONE
(Conspiracy to Engage in Sex Trafficking of Minors)
The Grand Jury charges:
1. In or about 2013, in the Southern District of New
York and elsewhere, CLAUDIUS ENGLISH, a/k/a "Jay Barnes," a/k/a
"Brent English," the defendant, and others known and unknown,
conspired and agreed with each other to knowingly, in and affecting
interstate and foreign commerce, recruit, entice, harbor,
transport, provide, obtain, advertise, maintain, patronize, and
solicit by any means persons who had not attained the age of 18
years at the time (collectively, the "Minor Victims"), knowing,
having had a reasonable opportunity to observe, and in reckless
disregard of the fact that the Minor Victims had not attained the
age of 18 years, and knowing that the Minor Victims would be caused
to engage in commercial sex acts.
(Title 18, United States Code, Sections
1594 (c), 1591 (a) (1), (b) (1), and (b) (2) .)
EFTA00025149

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Case 1:18-cr-00492-PGG Document 8 Filed 07/16/18 Page 2 of 10
COUNT TWO
(Sex Trafficking of Minor Victim-1)
The Grand Jury further charges:
2. Between at least in or about March 2013 and at least
in or about April 2013, in the Southern District of New York and
elsewhere, CLAUDIUS ENGLISH, a/k/a "Jay Barnes," a/k/a "Brent
English," the defendant, in or affecting interstate and foreign
commerce, recruited, enticed, harbored, transported, provided,
obtained, advertised, maintained, patronized, and solicited a
person who had attained the age of 14 years but had not attained
the age of 18 years at the time ("Minor Victim-1"), knowing, having
had a reasonable opportunity to observe, and in reckless disregard
of the fact that Minor Victim-1 had not attained the age of 18
years, and knowing that Minor Victim-1 would be caused to engage
in commercial sex acts, to wit, ENGLISH recruited and enticed Minor
Victim-1, a seventeen-year-old girl, to travel from New Jersey to
the Bronx, New York, where ENGLISH took photographs of Minor
Victim-1, posted such photographs on an internet advertisement
website, and harbored and transported Minor Victim-1 for the
purpose of engaging in sexual acts with other men in exchange for
money, some of which ENGLISH kept for himself.
(Title 18, United States Code,
Sections 1591 (a) (1) and (b) (2), and 2.)
2
EFTA00025150

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Case 1:18-cr-00492-PGG Document 8 Filed 07/16/18 Page 3 of 10
COUNT THREE
(Sex Trafficking of Minor Victim-2)
The Grand Jury further charges:
3. Between at least in or about March 2013 and at least
in or about April 2013, in the Southern District of New York and
elsewhere, CLAUDIUS ENGLISH, a/k/a "Jay Barnes," a/k/a "Brent
English," the defendant, in or affecting interstate and foreign
commerce, recruited, enticed, harbored, transported, provided,
obtained, advertised, maintained, patronized, and solicited a
person who had attained the age of 14 years but had not attained
the age of 18 years at the time ("Minor Victim-2"), knowing, having
had a reasonable opportunity to observe, and in reckless disregard
of the fact that Minor Victim-2 had not attained the age of 18
years, and knowing that Minor Victim-1 would be caused to engage
in commercial sex acts, to wit, ENGLISH recruited and enticed Minor
Victim-2, a seventeen-year-old girl, to travel from New Jersey to
the Bronx, New York, where ENGLISH took photographs of Minor
Victim-2, posted such photographs on an internet advertisement
website, and harbored and transported Minor Victim-2 for the
purpose of engaging in sexual acts with other men in exchange for
money, some of which ENGLISH kept for himself.
(Title 18, United States Code,
Sections 1591 (a) (1) and (b) (2), and 2.)
3
EFTA00025151

=== Page 5 ===
Case 1:18-cr-00492-PGG Document 8 Filed 07/16/18 Page 4 of 10
COUNT FOUR
(Sex Trafficking of Minor Victim-3)
The Grand Jury further charges:
4. At least in or about November 2013, in the Southern
District of New York and elsewhere, CLAUDIUS ENGLISH, a/k/a "Jay
Barnes," a/k/a "Brent English," the defendant, in or affecting
interstate and foreign commerce, recruited, enticed, harbored,
transported, provided, obtained, advertised, maintained,
patronized, and solicited a person who had attained the age of 14
years but had not attained the age of 18 years at the time ("Minor
Victim-3"), knowing, having had a reasonable opportunity to
observe, and in reckless disregard of the fact that Minor Victim-
3 had not attained the age of 18 years, and knowing that Minor
Victim-3 would be caused to engage in commercial sex acts, to wit,
ENGLISH recruited and enticed Minor Victim-3, a sixteen-year-old
girl, to travel to the Bronx, New York, where ENGLISH took
photographs of Minor Victim-3, intending such photographs to be
posted on an internet advertisement website, and harbored Minor
Victim-3 for the purpose of engaging in sexual acts with other men
in exchange for money, some of which ENGLISH kept for himself.
(Title 18, United States Code,
Sections 1591 (a) (1) and (b) (2), and 2.)
4
EFTA00025152

=== Page 6 ===
Case 1:18-cr-00492-PGG Document 8 Filed 07/16/18 Page 5 of 10
COUNT FIVE
(Attempted Sex Trafficking of Minor Victim-4)
The Grand Jury further charges:
5. At least in or about September 2013, in the Southern
District of New York and elsewhere, CLAUDIUS ENGLISH, a/k/a "Jay
Barnes," a/k/a "Brent English," the defendant, in or affecting
interstate and foreign commerce, attempted to recruit, entice,
harbor, transport, provide, obtain, advertise, maintain,
patronize, and solicit a person who had not attained the age of 14
years at the time ("Minor Victim-4"), knowing, having had a
reasonable opportunity to observe, and in reckless disregard of
the fact that Minor Victim-4 had not attained the age of 14 years,
and knowing that Minor Victim-4 would be caused to engage in
commercial sex acts, to wit, ENGLISH attempted to recruit, entice,
transport, and obtain Minor Victim-4, an eleven-year-old
girl, to engage in sexual acts with at least one man in exchange
for money, some of which ENGLISH would keep for himself.
(Title 18, United States Code,
Sections 1594 (a), 1591 (a) (1) and (b) (1), and 2.)
COUNT SIX
(Attempted Sex Trafficking of Minor Victim-5)
The Grand Jury further charges:
6. At least in or about October 2013, in the Southern
District of New York and elsewhere, CLAUDIUS ENGLISH, a/k/a "Jay
Barnes," a/k/a "Brent English," the defendant, in or affecting
5
EFTA00025153

=== Page 7 ===
Case 1:18-cr-00492-PGG Document 8 Filed 07/16/18 Page 6 of 10
interstate and foreign commerce, attempted to recruit, entice,
harbor, transport, provide, obtain, advertise, maintain,
patronize, and solicit a person who had not attained the age of 14
years at the time ("Minor Victim-5"), knowing, having had a
reasonable opportunity to observe, and in reckless disregard of
the fact that Minor Victim-5 had not attained the age of 14 years,
and knowing that Minor Victim-5 would be caused to engage in
commercial sex acts, to wit, ENGLISH attempted to recruit, entice,
transport, and obtain Minor Victim-5, an eight-year-old girl, to
engage in sexual acts with at least one man in exchange for money,
some of which ENGLISH would keep for himself.
(Title 18, United States Code,
Sections 1594 (a), 1591 (a) (1) and (b) (1), and 2.)
COUNT SEVEN
(Attempted Sex Trafficking of Minor Victim-6)
The Grand Jury further charges:
7. At least in or about October 2013, in the Southern
District of New York and elsewhere, CLAUDIUS ENGLISH, a/k/a "Jay
Barnes," a/k/a "Brent English," the defendant, in or affecting
interstate and foreign commerce, attempted to recruit, entice,
harbor, transport, provide, obtain, advertise, maintain,
patronize, and solicit a person who had not attained the age of 14
years at the time ("Minor Victim-6"), knowing, having had a
reasonable opportunity to observe, and in reckless disregard of
6
EFTA00025154

=== Page 8 ===
Case 1:18-cr-00492-PGG Document 8 Filed 07/16/18 Page 7 of 10
the fact that Minor Victim-6 had not attained the age of 14 years,
and knowing that Minor Victim-6 would be caused to engage in
commercial sex acts, to wit, ENGLISH attempted to recruit, entice,
transport, and obtain Minor Victim-6, an thirteen-year-old girl,
to engage in sexual acts with at least one man in exchange for
money, some of which ENGLISH would keep for himself.
(Title 18, United States Code,
Sections 1594 (a), 1591 (a) (1) and (b) (1), and 2.)
COUNT EIGHT
(Sex Trafficking of Minor Victim-7)
The Grand Jury further charges:
8. At least in or about October and November 2013, in
the Southern District of New York and elsewhere, CLAUDIUS ENGLISH,
a/k/a "Jay Barnes," a/k/a "Brent English," the defendant, in or
affecting interstate and foreign commerce, recruited, enticed,
harbored, transported, provided, obtained, advertised, maintained,
patronized, and solicited a person who had attained the age of 14
years but had not attained the age of 18 years at the time ("Minor
Victim-7"), and attempted to do the same, knowing, having had a
reasonable opportunity to observe, and in reckless disregard of
the fact that Minor Victim-7 had not attained the age of 18 years,
and knowing that Minor Victim-7 would be caused to engage in
commercial sex acts, to wit, ENGLISH recruited and enticed Minor
Victim-7, a fourteen-year-old girl, to travel to the Bronx, New
7
EFTA00025155

=== Page 9 ===
Case 1:18-cr-00492-PGG Document 8 Filed 07/16/18 Page 8 of 10
York, where ENGLISH attempted to take photographs of her, harbor
her, and cause her to engage in sexual acts with at least one man
in exchange for money, some of which ENGLISH would keep for
himself.
(Title 18, United States Code,
Sections 1591(a) (1) and (b) (2), and 2.)
COUNT NINE
(Kidnapping of Minor Victim-7)
The Grand Jury further charges:
9. On or about November 16, 2013, in the Southern
District of New York and elsewhere, CLAUDIUS ENGLISH, a/k/a "Jay
Barnes," a/k/a "Brent English," having attained the age of eighteen
years, unlawfully, willfully, and knowingly seized, confined,
inveigled, decoyed, kidnapped, abducted, and carried away and held
for ransom and reward and otherwise Minor Victim-7, who had not
attained the age of eighteen years and who was not a familial
relation of ENGLISH's or under ENGLISH's legal custody, and in so
doing, ENGLISH willfully caused Minor Victim-7 to be transported
in interstate commerce, and used a mean, facility, and
instrumentality of interstate commerce in committing and in
furtherance of the commission of the offense, to wit, ENGLISH used
a cellphone to cause Minor Victim-7, a fourteen-year-old girl, to
8
EFTA00025156

=== Page 10 ===
Case 1:18-cr-00492-PGG Document 8 Filed 07/16/18 Page 9 of 10
travel from New Jersey to the Bronx, New York, where he held her
against her will inside his apartment.
(Title 18, United States Code,
Section 1201 (a) (1) and (g) (1).)
COUNT TEN
(Firearms Offense Related to Kidnapping)
The Grand Jury further charges:
10. On or about November 16, 2013, in the Southern
District of New York and elsewhere, CLAUDIUS ENGLISH, a/k/a "Jay
Barnes," a/k/a "Brent English," the defendant, knowingly, during
and in relation to a crime of violence for which he may be
prosecuted in a court of the United States, namely, the kidnapping
offense charged in Count Nine of this Indictment, did use and carry
a firearm, and, in furtherance of such crime, did possess a
firearm, which was brandished, to wit, ENGLISH brandished a firearm
at Minor Victim-7 in the course of kidnapping her, as charged in
Count Nine.
(Title 18, United States Code,
Section 924 (c) (1) (A) (i) and (ii) .)
Kon
FOREPERSON
GEOFFREY Deafrey BERMAN & Berman
United States Attorney
9
EFTA00025157

=== Page 11 ===
Case 1:18-cr-00492-PGG Document 8 Filed 07/16/18 Page 10 of 10
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
- V. -
CLAUDIUS ENGLISH,
a/k/a "Jay Barnes,"
a/k/a "Brent English,"
Defendant.
INDICTMENT
18 Cr.
(Title 18, United States Code, Sections
1591 (a) (1) and (b) (2), and 2.)
GEOFFREY S. BERMAN
United States Attorney.
KSn A TRUE BILL
Foreperson.
EFTA00025158


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
)"
Subject: Re: Epstein FOIA Atty Visit Logs and Count Slips
Date: Sat, 09 Jan 2021 17:51:12 +0000
Sure,
worked on some conditions of confinement stuff and recently
was added to handle
same
Deputy Chief, White Plains Division
O:
C:
On Jan 9, 2021, at 10:59,
(USANYS)
wrote:
Got it. Thanks,
If it's alright, I'm going to loop in
in Civ Div, who I understand has worked on some related
stuff.
On Jan 9, 2021, at 9:12 AM,
(USANYS)
wrote:
Hi
Defense counsel in Tartaglione has requested to see the attorney visit logs and count slips that have Tartaglione's name
on them. Those documents may be covered by the attached protective order, and so we have asked
who is firewall counsel in Tartaglione, to receive the documents from you for potential production to defense counsel
(so that
and I do not see them).
is going to review the protective order first and determine whether
she needs Judge Karas to modify the order to allow her to receive the documents, so please don't send them to
until she reaches out. Thanks for helping with this - we know it is a pain.
Deputy Chief, White Plains Division
United States Attorney's Office
Southern District of New York
300 Quarropas Street
White Plains, New York 10601
Tel:
Cell:
<127124560313.pdf>
EFTA00024998


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c0:
=== Page 1 ===
From:
(USANYS)"
To:
USANYS)
Cc:
(USANYS)"
(USANYS)"
USANYS)"
Subject: RE: Epstein FOIA - OCME Report of Autopsy
Date: Tue, 29 Jun 2021 22:46:20 +0000
Thanks,
Yes, we will ask BOP to redact that photo as well.
From:
(USANYS)
Sent: Tuesday, June 29, 2021 3:45 PM
To:
(USANYS)
Cc:
(USANYS)
(USANYS)
(USANYS)
Subject: RE: Epstein FOIA - OCME Report of Autopsy
and
I spoke with the GC of OCME, who appreciated the head's up. One note for you all: the photo of the hyoid bone on page
12 is in fact Epstein's hyoid bone. To the extent we're redacting the closeup photos from page 13, shouldn't we also
redact the entire photo on page 12?
Thanks,
From:
USANYS)
Sent: Monday, June 28, 2021 5:02 PM
To:
USANYS)
Cc:
(USANYS)
(USANYS)
(USANYS)
Subject: Epstein FOIA - OCME Report of Autopsy
Please find attached the OCME Report of Autopsy. The boxes show where there will be redactions.
Thanks,
Assistant United States Attorney
300 Quarropas Street
White Plains, NY 10601
EFTA00026518


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein OIG/FBI--Document Preservation
Date: Mon, 12 Aug 2019 21:12:56 +0000
Attachments: Jeffrey_Epstein_lit_hold_notice_form_08_12_2019.pdf
Dear all,
As
explained, we are instituting a formal litigation hold in connection with Mr. Epstein's death at MCC. You have
been identified as having done work on or supervised the Epstein matter, and thus as possibly having responsive records.
Please note and preserve whatever you have about Mr. Epstein, not limited to his death and to the earlier reported
incident in which he suffered physical injuries. In addition, to the extent possible, please avoid altering any relevant
records. If you need to use existing documents, please save what you're working off of as a new document so that the
version that now exists remains preserved and available.
I attach a formal litigation hold notice, which as required is on an EOUSA-provided form. Please review the notice, fill out
the form to indicate whether and where you have responsive records, and sign and return it to me. In particular, be sure
to let me know by USAO number if possible what records and share directories we have that are likely to include relevant
information.
I prefer scanned and emailed return of the forms, but you can also use interoffice mail if you prefer.
Please let me know if you think other USAO personnel may have relevant documents or evidence.
And please let me know if you have questions or want to discuss.
Finally, I am copying
to inform him of the new litigation hold, and to ask him to ensure that all responsive
information on our electronic record systems is preserved, including by suspending the routine maintenance email
deletions for recipients of this email.
Many thanks,
EFTA00023993

=== Page 2 ===
Deputy Chief, Civil Division, and Litigation Hold Coordinator
U.S. Attorney's Office, S.D.N.Y.
86 Chambers Street, Third Floor
New York, NY 10007
From:
Sent: Monday, August 12, 2019 4:46 PM
Subject: RE: Epstein OIG/FBI--Document Preservation
FYI, as a result of a preservation request Epstein's lawyers have made on behalf of the family, which indicates a
potential wrongful death case, you will shortly be receiving a formal litigation hold request from
our litigation hold coordinator.
From:
Sent: Monday, August 12, 2019 11:43 AM
Subject: FW: Epstein OIG/FBI--Document Preservation
All - Please see below and follow
instructions. Additionally, if you believe there are others at SDNY to whom this
email should be sent, please let me know immediately.
Thanks,
From:
Sent: Monday, August 12, 2019 11:35 AM
Subject: Epstein OIG/FBI--Document Preservation
Please forward this to everyone who might have any documents relating to the Epstein suicide, and cc me:
EFTA00023994

=== Page 3 ===
Please make sure to preserve any documents you may have relating to Epstein's conditions of confinement.
Your emails will be adequately preserved, for present purposes, by the regular three-year backup. But let
me know if you have any or not.
If you have any hard-copy notes, please scan them and send them to me. If you have none, let me know
that too.
Most particularly, please check to see if you have texted anything pertinent. If so let me know, one way
or the other. If you do have anything, we'll figure out how to preserve that.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
EFTA00023995


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=== Page 1 ===
From:
To:
Cc:
Subject: GM - Joint Letter Due Today
Date: Fri, 21 May 2021 19:36:40 +0000
Attachments: 2021.05.11, GM,_scheduling_order.pdf; 2021-05-
21_Joint_letter_re_proposed_GM_pretrial_schedule_v4.docx
Attached for your review is a draft joint letter regarding the pretrial schedule due today. Also attached is the order for
reference. The defense intends to insert their section into the version we send them. Happy to discuss.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel
EFTA00024811


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=== Page 1 ===
From:
(OIG)"
To:
(USANYS)"
(USANYS)"
Cc:
(OIG)"
Subject: RE: meeting with
Date: Tue, 08 Jun 2021 19:09:15 +0000
Attachments:
Warning_for_Employee_(Voluntary_Interview_Form).docx;
Kalkines_Warning_(Compelled_Interview_Form).docx
Good afternoon
and
I hope this email finds you well. I have attached the draft interview questions for
for your review. This is still a draft
and will certainly be edited prior to the interview. However, I wanted to give you both enough time to review the
questions so that you were able to make any edits and/or suggestions that you feel appropriate prior to the interview. I
only ask that you make your edits in track changes so that I am clear on what it is you have changed. I have also attached
the forms which we, as DOJ OIG agents, are required to provide to all employees at the start of their Subject interview.
Per our conversation, it is my understanding that we will be utilizing the Voluntary Interview Form, but I also wanted to
provide you with the Compelled Interview Form, in case you wanted to compare the two to be certain we are all of the
same understanding. Finally, we received guidance that we are required to record the interviews, so please let me know if
you know (or believe) this to be a problem so that we may address the issue prior to the interview(s).
Thanks very much in advance. I hope you're both having a nice day.
SSA
U.S. Department of Justice
OIG Boston Area Office
From:
(USANYS)
Sent: Tuesday, June 8, 2021 9:08 AM
To:
(OIG)
>;
(OIG)
Cc:
(USANYS)
Subject: FW: meeting with
See below. Does this work for you? We are still waiting on a update from
counsel, whom we spoke to last week. I
will let you know what we hear.
From: Montell Figgins, Esq.
Sent: Monday, June 7, 2021 9:53 AM
To:
(USANYS)
Subject: meeting with
Mr.
is available on June 17, 2021.
EFTA00025223

=== Page 2 ===
mf
Law Offices of Montell Figgins
www.figginslaw.com
EFTA00025224


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=== Page 1 ===
From:
To:
Cc: Arraignment NYSD <Arraignment@nysd.uscourts.gov>,
I
Subject: FW: Signed warrant
Date: Tue, 30 Jun 2020 15:57:31 +0000
Attachment
signed.pdf;
Inline-Images: image003.jpg
Good morning
Your Signed warrant and application is attached.
Have a great day
UNITED STATES DISTRIC COURT
Arraignment Unit Clerk
United States District Court
Southern District of New York
500 Pearl Street
DISTRICT OF
From:
Sent: Tuesday. June 30. 2020 1:50 AM
To
Subject: FW: Signed warrant
From:
Sent: Tuesdav. June 30. 2020 11:42 AM
To:
Cc:
is
Subject: FW: Signed warrant
Good morning,
Would it be possible to get stamped copies of this warrant reflecting the docket number, please?
Thanks very much,
EFTA00026491

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, June 29, 2020 5:58 PM
To:
is
Subject: FW: Signed warrant
From:
Sent: Monday, June 29, 2020 5:36 PM
To:
Subject: Fwd: Signed warrant
Get Outlook for iOS
From: IP_Warrants NYSD
Sent: Monday lune 29. 2020 5:31:08 PM
To
Cc
Subject: Fw: Signed warrant
From
Sent: Monday, June 29, 2020 8:56 PM
To
; Arraignment NYSD <Arraignment@nysd.uscourts.gov>
Cc:
>; KHP_Warrants NYSD
Subject: Signed warrant
Get Outlook for iOS
EFTA00026492


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c0:
=== Page 1 ===
From:
"
To:
(USANYS)"
(USANYS)"
Subject: Judge Berman letter
Date: Mon, 12 Aug 2019 18:05:46 +0000
Attachments: Aug_12_letter.pdf
EFTA00024002


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=== Page 1 ===
Event: Call with
counsel
Start Date: 2020-02-20 20:00:00 +0000
End Date: 2020-02-20 20:30:00 +0000
Organizer:
Location:
Class: X-PERSONAL
Date Created: 2020-02-24 18:19:00 +0000
Date Modified: 2020-02-24 18:19:00 +0000
Priority: 5
DTSTAMP: 2020-02-20 17:27:19 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00026786


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Date: Wed, 08 Jul 2020 16:14:31 +0000
Yes, will handle.
From:
Sent: Wednesday, July 8, 2020 11:43 AM
To:
>;
Subject: Fwd: Epstein investigation [FFW-DOCS.FID6003375]
Hi team- so sorry to ask, but IT has had my laptop all morning and I'm not sure when I'm getting it back.
Could one of you possibly set up the webex? Just want to make sure it's set up soon given the time zone
difference.
Thanks! Sorry about that.
Sent from my iPhone
Begin forwarded message:
From: Louise Scott
Date: July 8, 2020 at 4:32:14 AM EDT
To:
Cc:
)"
)"
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Hi
Many thanks for your email and yes that is fine if it is okay for you to set up from your side.
The participants will be Jill and Kyle and their email address are
and
If you need anything further, please do let me know.
Kind regards
Louise
Louise Scott
Executive Assistant
D:
Click here for information relating to Covid-19 business impacts
Fieldfisher Logo
<image8055be.PNG> <image4d07de.PNG>
EFTA00024774

=== Page 2 ===
From:
Sent: Tuesday, July 7, 2020 7:20 PM
To: Louise Scott
Cc:
in
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Hi Louise,
Thanks very much. Unfortunately, there are restrictions on the types of video conferencing platforms we are permitted
to use, but we would suggest a video conference over WebEx, which seems to work well. If that's okay with you, we can
send a WebEx video conference link, which should not require downloading any software. All we would need to set up
the conference would be the email addresses of anyone participating in the conference.
Thanks,
From: Louise Scott
Sent: Tuesday, July 7, 2020 10:51 AM
To:
Cc:
V.
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Hi
Many thanks for confirming.
Can this call please take place via BlueJeans? It is a video conferencing application that we are using and I will send
through an invite which will enable you to connect to the meeting.
Could I just confirm the attendees please -
and yousrselfqa ?
Kyle Philips another partner of the firm will also be in attendance for the call.
I look forward to hearing.
Kind regards
Louise
Louise Scott
Executive Assistant
D:
Click here for information relating to Covid-19 business impacts
<image001.jpg>
<image002.png><image003.png>
From:
Sent: Tuesday, July 7, 2020 3:01 PM
To: Louise Scott
Cc: Jill Greenfield
is
>;
EFTA00024775

=== Page 3 ===
Subject: Re: Epstein investigation [FFW-DOCS.FID6003375]
Louise,
Thanks very much, that time works for us. What is the best number to reach Jill at that time- or is there a
conference line she would prefer to use?
Thanks,
Sent from my iPhone
On Jul 7, 2020, at 7:57 AM, Louise Scott
wrote:
Dear
Many thanks for your email.
Jill would be free to speak on Thursday at 2pm (UK time) - would this be suitable for you all?
Kind regards
Louise
Louise Scott
Executive Assistant
D:
Click here for information relating to Covid-19 business impacts
<image001.jpg>
<image682813.PNG> <imageea0e95.PNG>
From:
Sent: Monday, July 6, 2020 11:50 PM
To: Jill Greenfield
Cc: Louise Scott
is
>;
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Hi Jill,
I hope you're doing well. We continue to be interested in speaking with your client in connection with our
investigation, and we think it would be helpful to check in and discuss how best to proceed in light of the pandemic.
Are you available for a call this week? We are generally available, so if you could please let us know what times would
work for you for a call, that would be great.
Thanks very much,
EFTA00024776

=== Page 4 ===
Assistant United States Attorney
Southern District of New York
From:
Sent: Wednesday, March 11, 2020 9:46 PM
To: Jill Greenfield
Cc: Louise Scott
is
y.
)
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Jill,
Following up on the below, given the development of the virus pandemic over the past week, any foreign travel for us
is completely shut down. We certainly will plan to come to the U.K. whenever we are permitted, but in the interim
this makes it even more valuable to get even a summary of what your client would expect to convey to us. Would it be
possible to set up a call for later this week or sometime next week? And profound apologies for the inconvenience in
changing plans, we certainly don't want to cause additional stress or anxiety to your client, the circumstances are just
completely beyond our control.
thank you,
From:
Sent: Thursday, March 05, 2020 13:13
To: Jill Greenfield
Cc: Louise Scott
is
is
)
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Jill,
Just to clarify, would it be possible for you to provide us even a very general or high-level summary of what she has
told you? We ordinarily don't go into interviews completely blind when witnesses have counsel - and the Weinstein
investigation had a great number of problems that we have been able to avoid. And separately, we'll of course keep
you updated on our approval process as well.
thanks again,
From: Jill Greenfield
Sent: Thursday, March 05, 2020 04:20
To:
)
Cc: Louise Scott
is
is
)
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Thanks
EFTA00024777

=== Page 5 ===
I am afraid that an attorney proffer will not be possible. I have been working with the DA in New York on the Weinstein
case and have simply offered up my clients to questions which has worked well.
I am of course happy to speak over the phone but it seems to me that you are better off getting the information first
hand. If you wish it may be sensible for you to initially have a call with my client?
My client has made a complaint to the Met police regarding a sexual assault by Jeffrey Epstein whilst in London and in
the employment of G Maxwell. Apart from the complaint itself, no further information has been provided to the police.
I appreciate the issue re coronavirus of course.
Kind regards,
Jill
Jill Greenfield
Partner
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
From:
Sent: Wednesday, March 4, 2020 5:04 PM
To: Jill Greenfield
Cc: Louise Scott
is
is
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
Jill,
That's great, thank you for letting us know, and we'll check on that right away and get back to you as soon as possible.
The only wrinkle, which unfortunately is completely beyond our control, is that there is now some talk of government
international travel being prevented due to the coronavirus situation, but we'll talk to the relevant people here
immediately.
One thing that would be extremely helpful for us in the near-term, including in terms of getting approvals here - and
we talked about this on the phone as well - would be to get an attorney proffer about your understanding of generally
what information you expect your client will convey on the subjects we've spoken about? We completely understand
that it's best to have her tell her story directly to us, but in terms of our preparation it's often very useful for both us
and the witness for us to have had a conversation with counsel in the first instance. Would it be possible to set up a
call to have that discussion? We could do as soon as tomorrow or Friday, or also next week.
Thanks very much,
From: Jill Greenfield
Sent: Wednesday, March 04, 2020 11:46
To:
Cc: Louise Scott
is
is
)
Subject: RE: Epstein investigation [FFW-DOCS.FID6003375]
EFTA00024778

=== Page 6 ===
Hi
There is the possibility of a meeting on the 19th March if you are able to come to London. Could you let me know
please?
Kind regards
Jill
Jill Greenfield
Partner
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
From:
Sent: Tuesday, March 3, 2020 11:17 PM
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
)
is
Subject: RE: Epstein investigation
Jill,
We wanted to quickly follow up since I think you and I last spoke a little over a week ago-understand if you are still
discussing with your client, just wanted to check in, and we're happy to provide any additional information that might
be useful, as always.
thank you,
From: Jill Greenfield
Sent: Saturday, February 22, 2020 17:09
To:
Cc: Kyle Phillips
>; Louise Scott
;
)
is
)
Subject: Re: Epstein investigation
Thanks
Understood
I will call tomorrow
Regards
Jill Greenfield
Partner
EFTA00024779

=== Page 7 ===
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
Sent from my iPhone
On 22 Feb 2020, at 21:51,
)
wrote:
Jill,
No problem at all, we understand this takes time, and we appreciate you getting back to us, and we're very grateful
that your client is open to speaking with us.
On your questions, we are certainly fine with the first two questions / requests - we're happy to meet with you and
your client in an initial conversation, during which we can do the kind of introductions and explanations we've done
with you (and that we do with all victim witnesses we meet), including answering any questions to the best of our
ability, and then to take a break and have a more substantive discussion later on.
Regarding the friend, does that individual also represent her as counsel? We aren't normally able to include
individuals in addition to the witness and counsel in an interview-what does sometimes work is for someone who is
providing support (a parent, friend, etc.) to be close by for any discussions, assistance, etc. anytime that a witness
wants to speak with that person, which would of course be totally fine in this instance. Or if he represents her in his
capacity as an attorney then he of course could be in the interview in that role (with the only caveat that we would
just want to confirm that he himself is not separately a witness of some sort in the case). We unfortunately are not
able to pay for third parties (including counsel) to travel in connection with witness interviews, though - if it's
preferable, we certainly could pay for your client's travel to the U.S. for the interview, including airfare and lodging, if
that makes it easier for the friend to be present? And we're happy to discuss any of this further by email or phone if
that's useful - l'll be at my desk for the next several hours and most of tomorrow, at
or we could
also set a time to chat, whatever would be helpful.
thank you,
From: Jill Greenfield
Sent: Saturday, February 22, 2020 13:55
To:
Cc: Kyle Phillips
>; Louise Scott
is
is
Subject: RE: Epstein investigation
Hello
Apologies for the slight delay. My client is willing to help but asks the following:
That there be a morning meeting at which introductions with a discussion as to the investigation and my
clients involvement. I appreciate that you have explained this to me but I think further verbal clarification
would assist.
In the afternoon and after a break, my client would be willing to answer questions, in so far as she can.
That a friend of hers be allowed to be present as well. However that friend is based in the US and would
need to be flown over to London. He is a US lawyer.
EFTA00024780

=== Page 8 ===
Perhaps you could let me know if this is possible?
Kind regards,
Jill
Jill Greenfield
Partner
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
From:
Sent: Saturday, February 15, 2020 7:08 PM
To: Jill Greenfield
>
Cc: Kyle Phillips
>; Louise Scott
is
in
Subject: RE: Epstein investigation
Understood - thanks very much.
From: Jill Greenfield
Sent: Saturday, February 15, 2020 07:22
To:
Cc: Kyle Phillips
>; Louise Scott
is
)
>;
)
Subject: Re: Epstein investigation
Thanks
This is helpful. I've gone back to my client with this. I will be back in touch shortly.
Regards
Jill
Jill Greenfield
Partner
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image003.jpg>
Sent from my iPhone
On 14 Feb 2020, at 21:43,
)
wrote:
EFTA00024781

=== Page 9 ===
Jill,
Following up on our phone call, thank you for talking with us again, and we wanted to get back to you regarding
some of the additional follow-up questions you asked, and to describe in more detail for your client how we would
expect to approach any discussion with your client if she were comfortable meeting with us.
The absolute most important thing is that any discussion would be entirely voluntary, and by that we mean the
decision to meet with us but also as to any topic or question-your client would be absolutely free to determine
what topics she felt comfortable discussing. There is absolutely no pressure on victim witnesses to address
anything that would make them uncomfortable at any time, and even if your client was willing to meet with us, we
would tell her, as we do for any witness, that if any topic comes up that she wants to skip, or discuss with you
privately, that is no problem at all.
In fact, if you and she would prefer, we would be happy to have a meeting where we simply introduced ourselves,
explained the status of our investigation, talked about how a discussion would proceed if your client ended up
being comfortable with that, and answered in person any questions she. We have done that previously, where we
do the talking rather than asking questions in an initial meeting, and that would of course be without any
requirement for anything additional if she preferred not to. As I mentioned on the phone, we have consistently
found that we are able to reassure individuals when we have the opportunity to meet in person so they can see
directly our interest in approaching these discussions with great sensitivity and care. As I also mentioned on the
phone, even if your client were willing to speak with us, there would be absolutely no need or requirement for her
to talk about any assault or victimization she experienced. We wrote in our first email that we would primarily be
interested in talking about topics such as the general scope of her employment, directions she received from
Epstein or Maxwell, etc., and as always we would be guided by her comfort level.
In terms of who would attend a meeting, we almost always work in pairs, so two prosecutors and two officers, and
that's not to have extra people, but rather because it helps us to be as efficient as we can, and so witnesses can
meet the people on the team. Our team is also majority female, and we always tell witnesses that if topics come
up in a discussion that they would prefer to speak about just with women, that's fine and we can be flexible in the
moment and are always guided by the comfort level of the victim. But I also want to stress that in terms of your
client in particular, we don't expect to initially address issues of a very personal or sexual nature, and we certainly
would tell you in advance if there came a time when we thought that might be important to address, and how we
could facilitate that. Who exactly from our team would be at any meeting would depend on schedules, but we can
assure you that every one of us has now spoken with dozens of victims in this case, and every one of us has
extensive experience more generally working with victims and working on cases involving sex offenses. We are
proud of how we have been able to work with victims in this case especially, given all of the circumstances, and we
absolutely would take the same sensitive approach with your client as we have with the many other victims in this
case who have spoken with us.
Again, if it would be helpful even for us to just come to the U.K. and introduce ourselves and explain in person how
our process works, and answer any questions your client has in person, we would absolutely be happy to do that
with no obligation at all from her. We also could do that with the possibility that if she felt comfortable, we could
just address the general subject of her employment, for example. But no obligation and no pressure. We continue
to appreciate your and her willingness to even broach the possibility of a discussion, and we hope this is helpful.
thank you very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00024782

=== Page 10 ===
From:
Sent: Saturday, February 08, 2020 14:25
To: Jill Greenfield
Cc: Kyle Phillips
>; Louise Scott
is
is
Subject: RE: Epstein investigation
Jill,
Thanks for circling back, and we'll do our best to answer these questions. In terms of who would be in the room,
the most likely answer is that it would be two of the prosecutors and the two law enforcement officers on the
case. The only reason I saw "most likely" rather than having a definitive answer is that when we're interviewing in
a foreign country, it sometimes is the case the local law enforcement also insists on having representatives
present. I don't believe that's required in the U.K., but we can check on it and give you a definitive answer in the
coming days if that's useful. (Also, if she preferred to be interviewed in the U.S., we certainly could guarantee that
the room would be just the case team, and we could arrange for travel and lodging for her. Let us know if that's the
case, but otherwise we're of course happy to travel to her.)
Regarding access to notes, it would principally be the investigative team-so again, the prosecutors and the FBI
team working on the case. Our respective supervisors also theoretically have access to our files, but the reports
are not generally widely disseminated. The basic logistics are that an agent takes notes during an interview, and
then types up those notes into a formal report (called an FBI Form 302). We don't ordinarily share notes with other
entities, but I can also check on that to see if I can make a more specific representation with respect to your client.
With respect to anonymity, I confess that I'm not familiar with the distinction you're referring to. In terms of our
investigation, we don't publicly disclose the names of individuals we meet with, and we don't disclose to any other
witnesses, for example, the identities of victims or witnesses we are meeting with. (And our policies on that don't
change even for individuals who are in the position of your client, who have been widely publicly reported to have
been connected to Epstein and/or his employees or associates). But if that doesn't answer your question, we're of
course happy to discuss further. Let me know if it might be useful to have a call? Or if not, also happy to address
any follow-up via email.
thanks,
From: Jill Greenfield
Sent: Saturday, February 08, 2020 13:17
To:
Cc: Kyle Phillips
>; Louise Scott
)
is
Subject: Re: Epstein investigation
Hi
Thanks for this. I've been asked who would be in the room and thereafter who would have access to any
notes made. Would her permission be sought before disclosing to any other parties or officials?
As you know there is a real difficulty in relation to her anonymity in the US versus the UK. Are you able
to provide any comfort on this?
Many thanks
Jill
EFTA00024783

=== Page 11 ===
Jill Greenfield
Partner
Personal Injury Team of the Year - Solicitors Journal Awards 2017
<image001.jpg>
Sent from my iPhone
On 6 Feb 2020, at 21:53,
)
wrote:
Ms. Greenfield,
Thank you again for speaking with us earlier today regarding our interest in talking with your client in connection
with our investigation into the conduct of Jeffrey Epstein.
As requested, we wanted to briefly memorialize our current views and understandings of your client, and also to
reiterate our interest in approaching any discussion with great care and sensitivity, particularly to avoid adding to
her trauma or causing re-victimization.
As we mentioned on the phone, your client is not a target of our investigation-it sounds like the analogue in the
U.K. may be the "suspect" category-and we currently do not have reason to believe that she has committed any
U.S. federal crime. As we discussed, our knowledge of your client specifically is somewhat limited, having never
spoken to her-and therefore knowing about her only through other witnesses and records-but it certainly has
been our experience that the overwhelming majority of young women and girls who were in the orbit of Jeffrey
Epstein during the relevant periods were subject to his abuse. It does not surprise us, nor do we have any trouble
believing, that your client was similarly a victim. I hope that is helpful in understanding the capacity in which we
hope to speak with her.
Separately, and as we also discussed, any discussion with our team would be entirely voluntary-and that extends
not just to whether she would be willing to meet with us at all, but also including her ability to decline to discuss
particular topics or even particular questions, and to talk with her counsel at any time, to take any breaks that
would be beneficial while we're meeting, etc.
In terms of topic areas, we would be hoping to learn about the general narrative of her interactions with Epstein
and his other associates and employees, including Ghislaine Maxwell, whom we understand she may have
worked directly for. That would broadly include how she came to be in contact with them, the nature and scope
of her employment, any instructions she was given relating to other women or girls, and just generally her
experiences and observations in interacting with them. We ordinarily would also be interested in understanding
the general nature of the abuse she was subjected to, but I want to emphasize that we would not need to discuss
with her the specifics if she weren't comfortable with that, and in particular we often don't even broach that
subject in a first meeting.
Please let us know if you have any additional questions, and in particular whether any other information from us
would be useful, and we look forward to speaking with you again soon.
Regards,
Assistant U.S. Attorney
EFTA00024784

=== Page 12 ===
Southern District of New York
Fieldfisher, Riverbank House, 2 Swan Lane, London EC4R 3TT.
www.fieldfisher.com
We do not intend to change our bank details. If you receive any communication that any of our bank details have changed, telephone us and speak to your
contact at our office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstances.
This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact
the sender immediately, destroy the email and any attachments and do not use, copy, store or disclose this email and any
attachments for any purpose. Fieldfisher does not accept service of documents by electronic means without express prior
agreement.
For details about what personal information we collect and why, please see our Privacy Notice on our website at
www.fieldfisher.com.
Fieldfisher is the trading name of Fieldfisher LLP, a limited liability partnership registered in England and Wales (registered number OC318472) and is authorised and
regulated by the Solicitors' Regulation Authority. A list of its members and their professional qualifications is available at its registered office, Riverbank House, 2 Swan
Lane, London EC4R 3TT. We use the term partner to refer to a member of Fieldfisher LLP or an employee or consultant with equivalent standing or qualifications.
EFTA00024785


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EFTA00025134


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c0:
=== Page 1 ===
From:
To:
Cc:
Bcc:
"
Subject: RE: Epstein-related files
Date: Mon, 12 Oct 2020 04:44:29 +0000
Embedded: RE:_Epstein-related_files.msg
Sender:
Subject: RE: Epstein-related files
Message-Id:
<SN5P110MB054220DC10F7E2102EEFB0B892070@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM
>
To:
EFTA00026832


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c0:
=== Page 1 ===
From: Sigrid McCawley
To:
)"
Subject: Filing
Date: Wed, 13 May 2020 22:22:52 +0000
Attachments: 2020-05-13_[00068-000]_LETTER_MOTION_for_Conference_addressed_to_Magistr..pdf
FYI - Maxwell is seeking a stay based on the investigation.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
EFTA00025555


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=== Page 1 ===
From:
)"
To:
(USANYS) 4"
(USANYS)"
Cc:
)"
)"
Subject: Question re T-Visa
Date: Fri, 22 May 2020 14:30:30 +0000
Hi
S attorneys have reached out to us to inquire about our office assisting her in obtaining a T-Visa. She is
currently legally in the U.S. on a work visa, but that expires when her passport expires in August of 2020. We've never
dealt with T-Visas before, so would appreciate any guidance you might be able to provide. Would
qualify for a T-
Visa? If so, what would the process be for sponsoring her?
Also happy to have a call if that's easier, or if there's someone else we should reach out to, please let me know.
Thanks,
EFTA00026608


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=== Page 1 ===
Event: Call with
(Epstein)
Start Date: 2019-03-01 18:30:00 +0000
End Date: 2019-03-01 19:00:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Date Created: 2019-03-01 16:42:12 +0000
Date Modified: 2019-03-01 16:42:12 +0000
Priority: 5
DTSTAMP: 2019-03-01 16:25:46 +0000
Attendee:
(USANYS)
Alarm: Display the following message 15m before start
Reminder
EFTA00027048


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 1 of 7
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
July 28, 2020
VIA 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 this letter with respect to the protective order to be
entered in the above-captioned case, and to respond to the defendant's letter and submission of
July 27, 2020 (the "Defendant Letter" or "Def. Ltr.") (Dkt. 29). The Government and defense
counsel have conferred regarding a protective order several times via telephone and email between
July 9, 2020, and today, including as recently as this morning. The Government and defense
counsel have come to an agreement on much of the proposed protective order. However, the
parties disagree as to two inclusions sought by the defendant which the Government objects to and
for which, as detailed herein, the Government submits there is no legal basis. Accordingly, the
Government respectfully requests that the Court enter its proposed protective order (the
"Government Proposed Order"), which is attached hereto as Exhibit A, and which differs from the
defendant's proposed order in those two respects, as further described below.
A. The Defendant's Request to be Permitted to Publicly Name and Identify Victims
As detailed herein, the Government seeks to protect the identities of victims, consistent
with their significant privacy interests and the well-established law in this Circuit, and proposes a
protective order consistent with those very significant interests. In contrast, the defendant insists
that the protective order be modified such that she and her counsel would be permitted to "publicly
referenc[e]" individuals, by name, who have "spoken on the public record to the media or in public
fora, or in litigation - criminal or otherwise - relating to Jeffrey Epstein or Ghislaine Maxwell."
1
Specifically, the defendant's proposed protective order differs from the Government's in that
it adds a sentence, in its paragraph 6 (which is paragraph 5 of the Government Proposed Order),
stating the following: "Nor does this Order prohibit Defense Counsel from publicly referencing
individuals who have spoken on the record to the media or in public fora, or in litigation - criminal
or otherwise - relating to Jeffrey Epstein or Ghislaine Maxwell." The defendant also either adds
EFTA00026750

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 2 of 7
The Honorable Alison J. Nathan
July 28, 2020
Page 2
The defendant's demand that she and her counsel be permitted to name any individuals who have
ever publicly identified themselves as a victim of either Epstein or the defendant in any "public
fora," and at any time, without limitation, is extraordinarily broad, unnecessary, and inappropriate,
and should be denied.
As an initial matter, there can be no serious question that there are significant privacy and
victim interests at issue here, which the Government Proposed Order seeks to protect. Particularly
in the context of victim witnesses, there are compelling reasons to limit public disclosure of victim
identities and other sensitive information. Indeed, the Crime Victims' Rights Act, 18 U.S.C. $
3771, requires district courts to implement procedures to ensure that crime victims are accorded,
among other rights, "[t]he right to be reasonably protected from the accused," in addition to "[t]he
right to be treated with fairness and with respect for the victim's dignity and privacy." Id. §§
(a)(1), (a)(8) (emphasis added). Moreover, "the public generally has a strong interest in protecting
the identities of victims so that other victims will not be deterred from reporting such crimes."
United States V. Paris, 2007 WL 1484974, at *2 (D. Conn. May 18, 2007).
Moreover, and consistent with those interests, courts in this Circuit have routinely
acknowledged the need to protect victim-witness identities. See, e.g., United States V. Corley,
13 Cr. 48 (AJN), 2016 WL 9022508, at *4 (S.D.N.Y. Jan. 15, 2016) ("Because Corley's minor
victims have significant privacy and safety interests at stake, while Corley's interests are minimal,
the Court finds good cause to modify the protective order in this case to prevent Corley from
learning the surnames of the minor victims."); United States V. Kelly, 07 Cr. 374 (SJ), 2008 WL
5068820, at *2 (E.D.N.Y. July 10, 2008) ("Given the potentially explicit nature of the government
witnesses' expected testimony, the government argues that it is necessary to conceal their identity
to protect them from public humiliation and embarrassment. This Court agrees. Thus, the parties
[. .] are hereby prohibited from releasing to anyone, including members of the press, the identity
or any identifying information of the government's witnesses."). It is similarly routine in this
District for parties in a criminal case to refer to witnesses by pseudonyms (such as "Victim-1" or
"Witness-1") to protect the privacy interests of third parties unless and until they testify publicly.
The Government's proposed order endeavors to protect those interests by generally
requiring the parties to abstain from identifying any victim by name in any public statement or
filing while also ensuring that the defendant and her counsel are fully able to prepare for trial.
Indeed, to facilitate the defendant's investigation and preparation for trial, the Government's
proposal makes clear that defense counsel and defense staff, including defense investigators,
should not be prohibited from referencing identities of individuals in conversations with
prospective witnesses, so long as those witnesses and their counsel abstain from further disclosing
or disseminating any such identities. See Government Proposed Order 1 5. The terms of the
Government's proposed order also would permit defense counsel to refer to any individual by
name in any filing under seal, merely requiring redaction of identifying information or the use of
a pseudonym in public filings. The Government further proposes that defense counsel not be
prohibited from publicly referencing individuals who have spoken-or who at some future time
or deletes language in furtherance of its desire to publicly reference victim identities in defense
paragraphs 7, 9, and 17 (which are Government Proposed Order paragraphs 6, 7, and 16).
EFTA00026751

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 3 of 7
The Honorable Alison J. Nathan
July 28, 2020
Page 3
speak-by name on the public record in this case, as one victim has already chosen to do, because
those victims, and only those victims, have affirmatively chosen to be publicly identified in
connection with this case. These proposals are reasonable, narrowly tailored, and not broader than
necessary to protect victims' privacy interests, safety, and well-being, to avoid potential
harassment of witnesses by the press and others, and to prevent undue embarrassment and other
adverse consequences. At this stage in the case, permitting defense counsel to refer to witnesses
by name in sealed filings, to refer to witnesses by name in the course of private conversations
during their investigation, and to refer by name to individuals who have made the affirmative
choice to be identified by name in connection with this criminal case is more than enough to enable
the defendant ability to vigorously pursue her defense.
The defendant has rejected this proposal because, as noted above, she believes that she and
her counsel should be permitted to "publicly referenc[e]" individuals, by name, who have "spoken
on the public record to the media or in public fora, or in litigation - criminal or otherwise - relating
to Jeffrey Epstein or Ghislaine Maxwell." In support of the defendant's application for such
sweeping ability to publicly name any such individuals, defense counsel provides only the
conclusory assertion that an inability to publicly reference the names of victims, in court
proceedings and beyond, will hinder their ability to investigate, prepare witnesses for trial, and
advocate on the defendant's behalf. The Government has repeatedly asked defense counsel to
explain how or why it would need to publicly name victims of sexual abuse to prepare for trial,
and the defense repeatedly has declined to do so, presumably because the argument borders on the
absurd.²
The Government's proposed protective order would do no such thing. As described above,
the Government's proposed order would permit defense counsel and defense staff to reference the
identities of individuals they believe may be relevant to the defense to potential witnesses and their
counsel (who then would be prohibited from further disclosing or disseminating such identifying
information). Government Proposed Order 9 5. It would further permit the defendant to publicly
identify individuals who have chosen to speak on the record on this case. Id. 6. And it would
permit the defendant to reference identifying information in filings made under seal. See id.
2
Despite the Government's requests for clarity on the need for the defendant's requested
modification, the sole additional reason provided by defense counsel for why it would be
appropriate or necessary to publicly name victims is that certain of these victims have obtained
what defense counsel described as the "benefit" of publicly identifying themselves as victims (and
thus, as the defendant presumably would have it, deserve whatever public identification and
scrutiny the defendant intends to invite upon them). Beyond the offensive notion that victims of
sexual abuse experience a "benefit" by making the incredibly difficult decision to share their
experience publicly, the suggestion that victims who receive this supposed "benefit" should
receive fewer protections than the law ordinarily offers to victims in criminal cases is alarming.
Permitting defense counsel to publicly identify witnesses who have not identified themselves on
the record in this case risks subjecting witnesses to harassment and intimidation, with no
conceivable benefit to the defense other than perhaps discouraging witnesses from cooperating
with the Government.
EFTA00026752

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 4 of 7
The Honorable Alison J. Nathan
July 28, 2020
Page 4
Moreover, the defendant is able, at any time, to apply to the Court for a modification of the
protective order should she be able to identify a particularized need to publicly name victims who
have not yet identified themselves on the record in this case-as opposed to redacting their names
from court filings, or referring to them in an anonymized fashion. As noted, to date, defense
counsel has declined to identify to the Court or to the Government any example of why doing so
would be necessary or helpful to the defense, or even under what circumstances the defense might
want to do so.
The defendant's proposal is also extraordinarily broad, and without any temporal or subject
matter limitation as to the phrase "public fora." Adopting the defendant's proposal would mean
that any individual who has ever self-identified as a victim of Jeffrey Epstein or Ghislaine Maxwell
publicly in any capacity would be subject to public identification by the defendant and her counsel
in connection with this case. This would include, as hypothetical examples, someone who spoke
to a journalist for a local story in 1997, or posted on a MySpace page followed by a handful of
friends in 2005, or made a statement on a small podcast in 2009, or posted on Twitter to a handful
of followers in 2013. But none of these examples of ventures into the "public fora" can possibly
be construed as efforts by hypothetical victims to consent or choose "to self-identify," Def. Ltr.
at 3, in a future criminal case against Ghislaine Maxwell subject to extraordinary public attention
and scrutiny.
Additionally, while some individuals have identified themselves as victims without
providing any details or additional information about their abuse, the defense contemplates no
limitation of publicly associating those individuals with the details of their abuse in public defense
statements or filings. In essence, the defendant's proposal seeks authorization to drag into the
public glare any victim who has ever made any type of public statement of victimization-no
matter how long ago or how brief-without that victim's knowing consent and without any
substantive justification. That is particularly troubling given that the Government expects to make
productions of discovery and 3500 materials well surpassing its obligations. Those productions
will necessarily include the identities of individuals whom the Government does not expect to call
as witnesses, and whose accounts-much less identities-will have no bearing on this case. But
the defendant's proposal would allow her and her counsel to publicly name them in any public
statement or filing at their sole discretion. This is plainly unnecessary for any investigative steps
or trial preparation, would be grossly inappropriate and unfair, and would be inconsistent with the
Crime Victims' Rights Act.
Conversely, the Government's submission proposes that the defendant and her counsel not
be precluded from discussing publicly individuals who identify themselves on the record in this
criminal prosecution, because any such individuals will have made a conscious and informed
choice to be associated publicly with this case. See Government Proposed Order 11 5, 6, 8. The
identity of any other individuals should be protected from public broadcast by the defendant and
her counsel.
The defendant argues that her proposed language is "nearly identical in all material
respects" to the protective order entered in United States V. Epstein, 19 Cr. 490 (RMB) (Dkt. 38).
Def. Ltr. at 3. In the first instance, that is false. The protective order in the Epstein case included
EFTA00026753

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 5 of 7
The Honorable Alison J. Nathan
July 28, 2020
Page 5
a provision stating that it did not prohibit defense counsel from publicly referencing individuals
who had spoken on the public record in litigation relating to Jeffrey Epstein. Id. 4. Here, defense
counsel seeks permission to publicly identify any individuals who have self-identified as victims
of either the defendant or Epstein "to the media or in public fora, or in litigation"-a vastly broader
allowance. Indeed, as a comparison, none of the hypothetical examples described above would
have been subject to public naming and identification under the Epstein protective order, but every
single one would be under the defendant's proposed order in this case.
Additionally, beyond the differences in the language itself, there are two significant
differences between the circumstances of the Epstein prosecution and this case. First, at the time
the Epstein protective order was entered, there were exceptionally few victims who had identified
themselves by name in litigation. Accordingly, the practical application of that provision was
extremely limited. Second, and related, in the time between when the Epstein protective order was
entered and the indictment in this case, many more victims have made public statements about
their victimization at the hands of Epstein, and the defendant, on their own terms and in their own
ways, including by exercising their rights under the Crime Victims' Rights Act in the context of
the dismissal of the indictment against Jeffrey Epstein following his suicide. Those victims could
not possibly have predicted, much less chosen, that their names would be publicly broadcast by
defense counsel in connection with a subsequent criminal case. Victims should be able to continue
to come forward, in the ways and in the venues they themselves choose, without fear of reprisal,
shaming, or other consequence arising from having their identities broadcast by defense counsel
in this case.
In sum, the requested modification to the Government's proposed order sought by the
defendant is contrary to precedent and the compelling privacy interests of victims. Moreover, it is
without basis in fact or law, and, despite the Government's repeated requests for clarity, the
defendant and defense counsel have offered no legitimate reason for their desire to be able to
publicly identify any number of victims, in the context of this criminal case and elsewhere, other
than a minimal, conclusory statement, without factual examples or legal support.³ At bottom, the
defendant and her counsel seek an unlimited ability to name victims and witnesses publicly, for no
discernible reason, and without justification or legal basis. The victims of Ghislaine Maxwell and
Jeffrey Epstein have suffered enough, and the Crime Victims' Rights Act, applicable law, and
common decency compel far more protection of their privacy interests here than the defense
proposal would afford.
B.
The Defendant's Demand that the Government Restrict Use of its Own Documents
The defendant and her counsel also ask the Court to impose restrictions upon the
Government in its use, through potential witnesses and their counsel, of documents it currently
possesses, beyond the already-extensive restrictions and protections applicable to the
3 To the extent defense counsel attempts to provide such examples or arguments for the first
time in a reply filing, the Government respectfully requests leave to reply to those examples or
arguments.
EFTA00026754

=== Page 6 ===
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 6 of 7
The Honorable Alison J. Nathan
July 28, 2020
Page 6
Government.4 The defendant cites not a single example in any district court in the country where
such a restriction has been imposed in a protective order. Indeed, it is nonsensical for a protective
order to require limitations of the Government in its use of material already in its possession so
that the Government may provide a defendant with discovery. The defendant's attempt to refuse
to agree to receive discovery unless the Government agrees to additional restrictions upon the use
of its own materials should be rejected.
As an initial matter, the Government's use of materials it has gathered through its
investigation, including through the grand jury process, search warrants, interviews, and voluntary
disclosures, is already subject to a wide range of restrictions, including Rule 6(e) of the Federal
Rules of Criminal Procedure, the Privacy Act of 1974, and other policies of the Department of
Justice and the U.S. Attorney's Office for the Southern District of New York. In this case,
consistent with the Government's customary practice, and as the Government has informed
defense counsel, the Government has no intention of providing witnesses, victims or their counsel
with the entirety of discovery produced to the defendant, nor anything even close to that. Indeed,
consistent with its standard practice, the Government rarely provides any third party, including a
witness, with any material they did not already possess. While the Government does more
commonly show a witness materials in connection with proffers or trial preparation, the
Government rarely if ever shows a witness material she has not already seen, does not have
personal knowledge of, or would not have some specific reason to opine upon. Practically
speaking, therefore, the concerns defense counsel raises about future use in civil litigation are not
likely to occur.
Nevertheless, a criminal protective order is not the appropriate forum for the defendant to
demand restrictions on the Government's use of its own materials. To the contrary, as noted above,
many of those restrictions are already established by rule and law-standards the defendant makes
no suggestion the Government has failed to adhere to in this case. Moreover, the Government as
a whole, including those beyond the prosecutors on this case, may have obligations that would
conflict with such language in a protective order. For example, the Government has obligations
under various statutory and regulatory regimes, including but not limited to the Freedom of
Information Act and Touhy V. Ragen, 340 U.S. 462 (1951), that cannot be bargained away through
a protective order. Indeed, the Government can represent that the Department of Justice has
received both FOIA and Touhy requests in connection with this investigation, requests to which
the Department has a legal obligation to respond appropriately. The Government respectfully
submits it would be inappropriate for the defendant to seek-or the Court to order-language in a
protective order that conflicts with or supersedes those obligations. Tellingly, the defendant cites
no authority or precedent for her request regarding this issue.
By contrast, to the extent the defendant intends to produce reciprocal discovery to the
Government, it may in that case be appropriate to limit the Government's use, or third parties' use,
4 Specifically, the defendant's proposed protective order differs from the Government's in that
it adds a paragraph, its paragraph 3, proposing restrictions upon the Government and its potential
witnesses, and their counsel, as well as adding language to its paragraph 5, which is Government
paragraph 4, further restricting potential government witnesses and their counsel.
EFTA00026755

=== Page 7 ===
Case 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 7 of 7
The Honorable Alison J. Nathan
July 28, 2020
Page 7
of such materials provided by the defendant to the Government. But there is no basis to add
additional restrictions upon the Government's use of materials gathered by the Government itself.
The defendant's only counter-argument, as noted-that this Court should put third parties
"on equal footing with the defense"-is both unlikely to be relevant given the Government's
standard practice, as described above, and, the Government submits, an irrelevant consideration in
the context of a criminal protective order. Indeed, the Government respectfully submits that
neither it nor this Court is well-positioned to, or should, become the arbiter of what is appropriate
or permissible in civil cases.
In sum, the defendant's attempt to restrict the Government and to restrict third parties in
this way appears to be unprecedented, and is without legal basis, and should be denied.
Accordingly, for the reasons set forth above, the Court should enter the Government's
proposed protective order, which is enclosed, and deny the defendant's motion.
Respectfully submitted,
AUDREY STRAUSS
By:
A Acting United States Attorney
Alex Rossmiller / Alison Moe / Maurene Comey
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2415
Cc:
All counsel of record (via ECF)
EFTA00026756

=== Page 8 ===
Case 1:20-cr-00330-AJN Document 33-1 Filed 07/28/20 Page 1 of 12
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
:
UNITED STATES OF AMERICA
[PROPOSED]
:
PROTECTIVE ORDER
:
- V. -
:
20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
:
:
Defendant.
:
:
X
ALISON J. NATHAN, United States District Judge:
WHEREAS the Government intends to produce to GHISLAINE
MAXWELL, the defendant, certain documents and materials that
(i) affect the privacy and confidentiality of individuals,
(ii) would impede, if prematurely disclosed, the Government's
ongoing investigation; (iii) would risk prejudicial pretrial
publicity if publicly disseminated, and (iv) is not authorized
to be disclosed to the public or disclosed beyond that which is
necessary for the defense of this action, and other materials
pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16")
and pursuant to any other disclosure obligations (collectively,
the "Discovery"), which contain sensitive, confidential, or
personal identifying information;
WHEREAS, the Government seeks to protect sensitive,
confidential, or personal identifying information contained in
the materials it produces consistent with Rule 16 or other
disclosure obligations;
1
EFTA00026757

=== Page 9 ===
Case 1:20-cr-00330-AJN Document 33-1 Filed 07/28/20 Page 2 of 12
WHEREAS the Government has applied for the entry of
this Order;
IT HEREBY IS ORDERED:
1.
The Discovery disclosed to the defendant
("Defendant") and/or to the defendant's criminal defense
attorneys ("Defense Counsel") during the course of proceedings
in this action:
a)
Shall be used by the Defendant or her
Defense Counsel solely for purposes of the defense of this
criminal action, and not for any civil proceeding or any purpose
other than the defense of this action;
b)
Shall not be copied or otherwise recorded or
transmitted by the Defendant, except to Defense Counsel, or
except as necessary for the Defendant to take notes, which are
not to be further transmitted to anyone other than Defense
Counsel;
c)
Shall not be disclosed or distributed in any
form by the Defendant or her counsel except as set forth in
paragraph 1 (d) below;
d)
May be disclosed only by Defense Counsel and
only to the following persons ("Designated Persons") :
i. investigative, secretarial, clerical,
or paralegal personnel employed full-time, part-time, or as
2
EFTA00026758

=== Page 10 ===
Case 1:20-cr-00330-AJN Document 33-1 Filed 07/28/20 Page 3 of 12
independent contractors by the defendant's counsel ("Defense
Staff");
ii. any expert or potential expert, legal
advisor, consultant, or any other individual retained or
employed by the Defendant and Defense Counsel for the purpose of
assisting in the defense of this case ("Defense
Experts/Advisors");
iii. such other persons as hereafter may be
authorized by Order of the Court ("Other Authorized Persons");
e) May be provided to prospective witnesses and
their counsel (collectively, "Potential Defense Witnesses"), to
the extent deemed necessary by defense counsel, for trial
preparation. To the extent Discovery materials are disclosed to
Potential Defense Witnesses, they agree that any such materials
will not be further copied, distributed, or otherwise
transmitted to individuals other than the recipient Potential
Defense Witnesses.
2.
The Defendant and Defense Counsel shall provide a
copy of this Order to any Designated Persons to whom they
disclose Discovery materials. Prior to disclosure of Discovery
materials to Designated Persons, any such Designated Person
shall agree to be subject to the terms of this Order by signing
a copy hereof and stating that they "Agree to be bound by the
terms herein," and providing such copy to Defense Counsel. All
3
EFTA00026759

=== Page 11 ===
Case 1:20-cr-00330-AJN Document 33-1 Filed 07/28/20 Page 4 of 12
such acknowledgments shall be retained by Defense Counsel and
shall be subject to in camera review by the Court if good cause
for review is demonstrated. The Defendant and her counsel need
not obtain signatures from any member of the defense team (i.e.,
attorneys, experts, consultants, paralegals, investigators,
support personnel, and secretarial staff involved in the
representation of the defendants in this case), all of whom are
nonetheless bound by this Protective Order.
3.
To the extent that Discovery is disseminated to
Defense Experts/Advisors, Other Authorized Persons, or Potential
Defense Witnesses, via means other than electronic mail, Defense
Counsel shall encrypt and/or password protect the Discovery.
4. The Government, the Defendant, Defense Counsel,
Defense Staff, Defense Experts/Advisors, Potential Defense
Witnesses and their counsel, and Other Authorized Persons are
prohibited from posting or causing to be posted any of the
Discovery or information contained in the Discovery on the
Internet, including any social media website or other publicly
available medium.
5.
The Government (other than in the discharge of
their professional obligations in this matter), the Defendant,
Defense Counsel, Defense Staff, Defense Experts/Advisors,
Potential Defense Witnesses and their counsel, and Other
Authorized Persons are strictly prohibited from publicly
4
EFTA00026760

=== Page 12 ===
Case 1:20-cr-00330-AJN Document 33-1 Filed 07/28/20 Page 5 of 12
disclosing or disseminating the identity of any victims or
witnesses referenced in the Discovery. This Order does not
prohibit Defense Counsel or Defense Staff from referencing the
identities of individuals they believe may be relevant to the
defense to Potential Defense Witnesses and their counsel during
the course of the investigation and preparation of the defense
case at trial. Any Potential Defense Witnesses and their
counsel who are provided identifying information by Defense
Counsel or Defense Staff are prohibited from further disclosing
or disseminating such identifying information. This Order does
not prohibit Defense Counsel from publicly referencing
individuals who have spoken by name on the public record in this
case.
6.
The Defendant, Defense Counsel, Defense Staff,
Defense Experts/Advisors, Potential Defense Witnesses, and Other
Authorized Persons are prohibited from filing publicly as an
attachment to a filing or excerpted within a filing the identity
of any victims or witnesses referenced in the Discovery, who
have not spoken by name on the public record in this case,
unless authorized by the Government in writing or by Order of
the Court. Any such filings must be filed under seal, unless
authorized by the Government in writing or by Order of the
Court.
5
EFTA00026761

=== Page 13 ===
Case 1:20-cr-00330-AJN Document 33-1 Filed 07/28/20 Page 6 of 12
7.
Copies of Discovery or other materials produced
by the Government in this action bearing "confidential" stamps,
or designated as "confidential" as described below, and/or
electronic Discovery materials designated as "confidential" by
the Government, including such materials marked as
"confidential" either on the documents or materials themselves,
or designated as "confidential" in a folder or document title,
are deemed "Confidential Information." The Government shall
clearly mark all pages or electronic materials containing
Confidential Information, or folder or document titles as
necessary, with "confidential" designations.
8.
Confidential Information may contain personal
identification information of victims, witnesses, or other
specific individuals who are not parties to this action, and
other confidential information; as well as information that
identifies, or could lead to the identification of, witnesses in
this matter. The identity of an alleged victim or witness who
has identified herself or himself publicly as such on the record
in this case shall not be treated as Confidential Information.
9.
Defense Counsel may, at any time, notify the
Government that Defense Counsel does not concur in the
designation of documents or other materials as Confidential
Information. If the Government does not agree to de-designate
such documents or materials, Defense Counsel may thereafter move
6
EFTA00026762

=== Page 14 ===
Case 1:20-cr-00330-AJN Document 33-1 Filed 07/28/20 Page 7 of 12
the Court for an Order de-designating such documents or
materials. The Government's designation of such documents and
materials as Confidential Information will be controlling absent
contrary order of the Court.
10. Confidential Information disclosed to the
defendant, or Defense Counsel, respectively, during the course
of proceedings in this action:
a)
Shall be used by the Defendant or her
Defense Counsel solely for purposes of the defense of this
criminal action, and not for any civil proceeding or any purpose
other than the defense of this action;
b)
Shall be maintained in a safe and secure
manner;
c)
Shall be reviewed and possessed by the
Defendant in hard copy solely in the presence of Defense
Counsel;
d)
Shall be possessed in electronic format only
by Defense Counsel and by appropriate officials of the Bureau of
Prisons ("BOP"), who shall provide the defendant with electronic
access to the Discovery, including Confidential Information,
consistent with the rules and regulations of the BOP, for the
Defendant's review;
7
EFTA00026763

=== Page 15 ===
Case 1:20-cr-00330-AJN Document 33-1 Filed 07/28/20 Page 8 of 12
e)
Shall be reviewed by the Defendant solely in
the presence of Defense Counsel or when provided access to
Discovery materials in electronic format by BOP officials;
f)
May be disclosed only by Defense Counsel and
only to Designated Persons;
g)
May be shown to, either in person, by
videoconference, or via a read-only document review platform,
but not disseminated to or provided copies of to, Potential
Defense Witnesses, to the extent deemed necessary by Defense
Counsel, for trial preparation, and after such individual (s)
have read and signed this Order acknowledging that such
individual (s) are bound by this Order.
11. Copies of Discovery or other materials produced
by the Government in this action bearing "highly confidential"
stamps or otherwise specifically designated as "highly
confidential," and/or electronic Discovery materials designated
as "highly confidential" by the Government, including such
materials marked as "highly confidential" either on the
documents or materials themselves, or designated as "highly
confidential" in an index, folder title, or document title, are
deemed "Highly Confidential Information." To the extent any
Highly Confidential Information is physically produced to the
Defendant and Defense Counsel, rather than being made available
to the Defendant and Defense Counsel for on-site - review, the
8
EFTA00026764

=== Page 16 ===
Case 1:20-cr-00330-AJN Document 33-1 Filed 07/28/20 Page 9 of 12
Government shall clearly mark all such pages or electronic
materials containing Highly Confidential Information with
"highly confidential" stamps on the documents or materials
themselves.
12. Highly Confidential Information contains nude,
partially-nude, or otherwise sexualized images, videos, or other
depictions of individuals.
13. Defense Counsel may, at any time, notify the
Government that Defense Counsel does not concur in the
designation of documents or other materials as Highly
Confidential Information. If the Government does not agree to
de-designate such documents or materials, Defense Counsel may
thereafter move the Court for an Order de-designating such
documents or materials. The Government's designation of such
documents and materials as Highly Confidential Information will
be controlling absent contrary order of the Court.
14. Highly Confidential Information disclosed to
Defense Counsel during the course of proceedings in this action:
a)
Shall be used by the Defendant or her
Defense Counsel solely for purposes of the defense of this
criminal action, and not for any civil proceeding or any purpose
other than the defense of this action;
9
EFTA00026765

=== Page 17 ===
Case 1:20-cr-00330-AJN Document 33-1 Filed 07/28/20 Page 10 of 12
b)
Shall not be disseminated, transmitted, or
otherwise copied and provided to Defense Counsel or the
Defendant;
c)
Shall be reviewed by the Defendant solely in
the presence of Defense Counsel;
d)
Shall not be possessed outside the presence
of Defense Counsel, or maintained, by the Defendant;
e)
Shall be made available for inspection by
Defense Counsel and the Defendant, under the protection of law
enforcement officers or employees; and
f)
Shall not be copied or otherwise duplicated
by Defense Counsel or the Defendant during such inspections.
15. The Defendant, Defense Counsel, Defense Staff,
Defense Experts/Advisors, Potential Defense Witnesses, and Other
Authorized Persons are prohibited from filing publicly as an
attachment to a filing or excerpted within a filing any
Confidential Information or Highly Confidential Information
referenced in the Discovery, unless authorized by the Government
in writing or by Order of the Court. Any such filings must be
filed under seal, unless authorized by the Government in writing
or by Order of the Court.
16. The provisions of this Order shall not be
construed as preventing disclosure of any information, with the
exception of victim or witness identifying information, that is
10
EFTA00026766

=== Page 18 ===
Case 1:20-cr-00330-AJN Document 33-1 Filed 07/28/20 Page 11 of 12
publicly available or obtained by the Defendant or her Defense
Counsel from a source other than the Government.
17. Except for Discovery that has been made part of
the record of this case, Defense Counsel shall return to the
Government or securely destroy or delete all Discovery,
including but not limited to Confidential Information, within 30
days of the expiration of the period for direct appeal from any
verdict in the above-captioned case; the period of direct appeal
from any order dismissing any of the charges in the above-
captioned case; the expiration of the period for a petition
pursuant to 28 U.S.C. $ 2255; any period of time required by the
federal or state ethics rules applicable to any attorney of
record in this case; or the granting of any motion made on
behalf of the Government dismissing any charges in the above-
captioned case, whichever date is later.
18. The foregoing provisions shall remain in effect
unless and until either (a) the Government and Defense Counsel
mutually agree in writing otherwise, or (b) this Order is
modified by further order of the Court.
19. The Government and Defense Counsel agree to meet
and confer in advance of any hearings or trial to discuss and
agree to any modifications necessary for the presentation of
evidence at those proceedings. In the absence of agreement,
11
EFTA00026767

=== Page 19 ===
Case 1:20-cr-00330-AJN Document 33-1 Filed 07/28/20 Page 12 of 12
Defense Counsel may make an appropriate application to the Court
for any such modifications.
SO ORDERED:
Dated:
New York, New York
, 2020
HONORABLE ALISON J. NATHAN
United States District Judge
12
EFTA00026768


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=== Page 1 ===
From:
To:
Subject: FW:
Date: Fri, 30 Nov 2018 21:01:52 +0000
Importance: Normal
From:
Sent: Tuesday, March 8, 2016 12:28 PM
To:
Cc:
Subject: RE:
If you haven't already seen it, the Post reported today on Jeffrey Epstein's continued relationships with young
women.
http://pagesix.com/2016/03/08/jeffrey-epsteins-east-side-mansion-houses-russian-playmates/
Best,
From:
Sent: Monday, February 29, 2016 10:13 PM
To:
Cc:
Subject: Re:
I am adding
to this email chain as well. As we mentioned earlier today,
is one of the lead attorneys on
the case and knows both
and the facts very well. Please include
in any follow-up that you may.
Best,
From:
Date: Monday, February 29, 2016 at 10:03 PM
To:
Cc:
Subject:
EFTA00026781

=== Page 2 ===
Thank you again for meeting with us today. We very much appreciate your time. I am attaching the following documents for
your review:
1. Complaint in the defamation case against Ghislaine Maxwell (just today, Judge Sweet denied Maxwell's motion to dismiss
today);
2. Declarations that
filed in the CVRA case;
3. The Rule 56.1 statement recently filed in the CVRA case;
4. The redacted 302
Please let us know what other information we can provide or if you have any further questions.
Best,
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1]
EFTA00026782


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=== Page 1 ===
From:
To:
Subject: Epstein FOIAs
Date: Tue, 10 Mar 2020 22:23:08 +0000
further to the little meeting we had a couple weeks ago, could you kindly pull together the Epstein press
releases and charges and anything else we made public? (I don't think you need to download everything from the
docket, tho.)
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
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=== Page 1 ===
FY 2020 Large Case-Related Expenses Request Form
District: Southern District of New York
Point of Contact:
Co-Chief, Money Laundering and Transational Criminal
Enterprises Unit,
Instructions: Please provide responses to the case specific questions below. Use a separate
form for each request. E-mail completed form to:
Funds may be available for expenses incurred in connection with the identification, seizure, and
forfeiture of assets in a pending judicial forfeiture case or USAO forfeiture matter. These
expenses include all litigation expenses associated with civil forfeiture cases, and those litigation
expenses associated with the forfeiture aspect of criminal forfeiture cases. Large case-related
expense requests should be limited to expenses that exceed the annual allocation the district
received from EOUSA for case-related expenses.
Before submitting this request, please confirm with your Budget Officer that the expense is
eligible for payment from the Assets Forfeiture Fund.
Case Name: In re Jeffrey Epstein
1. Case Number:
2. Estimated Amount of Request: $300,000
3. Specify Expense Type1 and Amount Associated with Case:
Expense Type: Litigation fees
Expense Amount: $200,000
Expense Type: Travel Expenses
Expense Amount: $100,000
4. Estimated Amount of Forfeited Assets: $100 million or more
Brief Synopsis of Case: This Office is investigating Jeffrey Epstein for possible
violations of 18 U.S.C. $ 1591 (sex trafficking of a minor), 18 U.S.C. § 2422 (coercion and
enticement), 18 U.S.C. $ 2423 (transportation and/or travel in interstate commerce for the
purpose of engaging in illicit sexual contact with minors), and conspiracy to commit those
I Allowable Expense Types include: Case specific travel, forfeiture related subpoena costs, litigation consultant
fees, discovery & deposition costs, transcription & translation fees, advertising & publication costs, lien & lis
pendens fees, financial records production/reproduction costs, and court appointed fiduciaries.
Expense Types Not Reimbursable from the AFF: Expert/witness testimony or travel related expenses (may be
allowed from FEW fund), office equipment, office supplies, salaries, or overtime.
Page 1 of 2
Executive Office for United States Attorneys
600 E Street, NW Washington, DC 20530
EFTA00026447

=== Page 2 ===
FY 2020 Large Case-Related Expenses Request Form
District: Southern District of New York
Point of Contact:
Co-Chief, Money Laundering and Transational Criminal
Enterprises Unit,
crimes, respectively. The investigation arises from conduct alleged to have occurred from in or
about the 1990s through at least in or about 2007.
Epstein is alleged to have engaged in a years-long pattern of enticing minor girls to
engage in sex acts, starting with massages and escalating to acts including sexual intercourse,
often in exchange for money. He has undertaken this conduct in at least New York, Florida, the
U.S. Virgin Islands, New Mexico, and certain cities abroad. Esptain was assisted by individuals,
including employees, girlfriends and friends, in the recruitment and enticement of the minors,
and he paid certain minors to recruit additional underage girls.
We estimate that there are at least 50 victims who were abused in New York, Florida and
elsewhere, and who currently live throughout the United States and abroad. Significant
investigative costs include frequent travel to interview victims and witnesses, and hiring a vendor
to process voluminous paper records and media, among other costs.
Page 2 of 2
Executive Office for United States Attorneys
600 E Street, NW Washington, DC 20530
EFTA00026448


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: June 25 Production in Epstein FOIA
Date: Sun, 13 Jun 2021 23:31:10 +0000
Hi
Just checking in-BOP - currently has a deadline of June 25 to produce documents without any redactions based on Noel in
the Epstein FOIA. Is everything on track in Noel for that date to still work? As in, all interviews or any other processes that
could support 7(A) withholdings will be wrapped up by June 25, right?
Thanks,
Assistant United States Attorney
300 Quarropas Street
White Plains, NY 10601
Telephone:
EFTA00025552


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=== Page 1 ===
From:
Subject: Re: CNN - Epstein
Date: Fri, 16 Aug 2019 20:15:30 +0000
It's hard to deny when they don't provide the name of the AUSA.
On Aug 16, 2019, at 4:11 PM,
wrote:
Hey guys,
CNN is pursuing a story about how
came to our Office in
2015/2016 to raise questions about the Epstein plea deal in Florida. Apparently through (with?) their attorney,
they talked to a sex trafficking or human trafficking AUSA (no name yet) about the issue. The reporter believes
that it was not raised to senior leadership at the time and it went nowhere.
CNN doesn't plan to run something immediately but knows that another reporter has similar information, so if
they feel their competition will go with the story, they will, too.
Any guidance or thoughts are welcome.
Public Affairs
U.S. Attorney's Office for the Southern District of New York
Facebook: https://www.facebook.com/usaosdny.
Follow us on Twitter: @SDNYnews
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=== Page 1 ===
SECURITY
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 28, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These materials are
stamped with control numbers SDNY_GM_02765768 through SDNY_GM_02767073.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. The Department of Justice directed this office to cease the dissemination of materials
marked with the word "confidential" in order to avoid potential confusion with markings reserved
for classified documents. Accordingly, in order to note the appropriate designation of this
production under the operative Protective Order in this case, the materials being produced today
are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,
8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective
Order that govern today's production.
An index of the materials contained in this production is below:
EFTA00024236

=== Page 2 ===
Page 2
Bates Start
Bates End
Summary Description
Confidential Designation
SDNY_GM_02765768
SDNY_GM_02765768
Scanned page of contact book
Confidential
SDNY_GM_02765769
SDNY_GM_02766967
Materials from Estate of Jeffrey Epstein¹
Confidential
SDNY GM 02766968
SDNY GM 02766974
Records from the United Kingdom
Confidential
Scan of 1 bound black address book marked
SDNY_GM_02766975
SDNY_GM_02767068
Government Exhibit 52, as referred to in
Confidential
SDNY GM 02753612
Scan of 2 stapled handwritten set of
SDNY_GM_02767069
SDNY_GM_02767073
documents on yellow legal pad paper, as
Confidential
referred to in SDNY GM 02753612
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by: s/
Assistant United States Attorneys
1 These materials appear to be largely duplicative of materials previously produced to you in
discovery.
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=== Page 1 ===
From:
)"
To: Sigrid McCawley
Cc:
)"
Subject: RE:
follow-up request
Date: Fri, 08 May 2020 15:02:07 +0000
I unfortunately was on trial during the previous interview, but I think somewhat less time than how long it went last time.
Ordinarily we try not to go longer than about 90 minutes in any event, so I think if she is able to block out that amount of
time, that would be great - and we'll try to be as efficient as possible and hopefully take less than that. If that sounds
alright?
thanks,
From: Sigrid McCawley
Sent: Thursday, May 07, 2020 18:57
To:
Cc:
Subject: RE:
follow-up request
Hello
I am sure
will be happy to help in any way she can. Let me find out what her patient schedule is like for next week
and find a time that works. How much time do you think she should allot for the interview - just so she can plan?
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Thursday, May 7, 2020 6:41 PM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
Hi Sigrid,
EFTA00025300

=== Page 2 ===
We wanted to follow up in connection with
- our supervisors have asked us to do an additional interview with her,
both to follow up on some specific aspects of her recollection but also do basically go through her experiences again. As
I'm sure you know, we have no doubts whatsoever, at all, about her candor and truthfulness in our previous interview,
which also was broadly consistent with what she has said in other interviews, but we are nevertheless hoping she might
be willing to speak with us sometime in the next week or two? Obviously due to the current situation we would plan to
do it via phone, and we would be happy to chat about logistics with you if that would be helpful, or to answer any
questions at all. And if
is willing to speak with us again, we're happy to work around her schedule, including talking
during an evening or weekend if that's easier for her than during the day-whatever you and she would prefer.
Please let us know if any questions, or if it would be useful to chat, and thanks very much.
From:
Sent: Thursday, January 16, 2020 14:35
To: Sigrid McCawley
Cc:
is
Subject: RE:
follow-up request
Got it, thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 2:29 PM
To:
Cc:
is
)
Subject: RE:
follow-up request
I checked back with
and she said that the last entry in her journal is in late February and she
went to New Mexico in April.
Thanks
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
EFTA00025301

=== Page 3 ===
www.bsfllp.com
Sent by Boxer
On January 16, 2020 at 1:05:54 PM EST,
)
wrote:
Thank you very much, Sigrid.
Just to confirm, does
have any journal entries regarding the time when she traveled to New Mexico? I
believe she told us during our interview that she does not have any entries from that time, but I just wanted to
make sure.
Thanks again,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 12:31 PM
To:
Cc:
i
)
Subject: RE:
follow-up request
Hello - attached are the pages
sent me to provide to you. Here is a bit of an explanation and I also
asked her to take a copy of the front and back of the journal book which she did. Hope this helps. Please let
me know if you need anything else:
"The shortest page and the one that is the hardest to read is the first entry from 12/95. It is written in colored
pencil and is fading. There are then two pages from 01/07/1996 where I talk about the highlights of my NY
trip and going to Epstein's house and then the next entry from 01/25/1996 is where I talk about going to the
movies with him."
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
EFTA00025302

=== Page 4 ===
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 4:01 PM
To: Sigrid McCawley
Cc:
)
i
)
Subject: RE:
follow-up request
Thanks very much, Sigrid. Yes, we received the photographs from
which we very much appreciate.
Anything else she is willing to share, including her journal entries, would be very helpful.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Friday, January 10, 2020 3:59 PM
To:
)
Cc:
)
Subject: RE:
follow-up request
Hello
,
Let me follow up with
about her journal. I know she shared some pictures with you from around the
time period when she was with Epstein/Maxwell. I will ask her about the journal ASAP and will get back to
you and will check with her to see if she has anything else that might be helpful to the investigation.
All my best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
EFTA00025303

=== Page 5 ===
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 3:30 PM
To: Sigrid McCawley
Cc:
)
)
Subject:
follow-up request
Hi Sigrid,
Hope you had a wonderful holiday season and very happy New Year. We wanted to follow up on a request we
made after interviewing
a few months ago. During her interview,
referred to several
entries in her journal that had helped refresh her recollection of the events involving Epstein and Maxwell. As
we mentioned at the end of the interview, it would be very helpful to our investigation if we could review
those journal entries, as well as any other records or documents
may have that relate to her experiences
with Epstein and Maxwell.
Would
be willing to share with us any relevant journal entries (or any other relevant documents she may
have) to assist in our investigation?
Happy to have a call to discuss if that would be helpful.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information
that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of
this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication
in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1
08201831BSF
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=== Page 1 ===
From:
)"
To:
)"
, "McGorty, Glen"
Cc: "Zelenko, Daniel"
^
"Giffuni, Danielle"
,
(USANYS)"
Subject: RE: Wednesday's WebEx
Date: Thu, 06 May 2021 16:50:04 +0000
Hi Glen,
Hope you're doing well. Do you have time for a quick call this afternoon or tomorrow?
Thanks very much,
From:
Sent: Wednesday, November 18, 2020 10:52 AM
To: McGorty, Glen
is
)
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
Subject: RE: Wednesday's WebEx
Glen,
Attached please find the fully executed proffer agreement with the agent's initials and my initials added.
Thanks,
Assistant United States Attorney
Southern District of New York
From:
Sent: Tuesday, November 17, 2020 9:30 PM
To: McGorty, Glen
is
)
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
Subject: RE: Wednesday's WebEx
Received, thank you very much, Glen.
Best,
EFTA00024932

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
From: McGorty, Glen
Sent: Tuesday, November 17, 2020 8:21 AM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
Subject: RE: Wednesday's WebEx
--- sorry for the delay. Here is the executed proffer agreement from our last meeting.
Best,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Wednesday, November 11, 2020 1:43 PM
To: McGorty, Glen
is
)
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Glen,
We will be joined by two FBI agents who are focusing on the CBP topics that we have previously discussed. I expect one
of those agents will take the lead on questioning Mr.
The topics we expect to cover include:
The identities of any CBP employees Mr.
recalls interacting with Jeffrey Epstein in the Virgin Islands.
Any steps Mr.
recalls any CBP employees in the Virgin Islands taking to help Epstein and those traveling with
Epstein to enter the country, including any steps that allowed Epstein or those traveling with him to avoid
processing that travelers would normally undergo.
Any favors Mr.
recalls Epstein doing for CBP employees in the Virgin Islands, such as trips to Epstein's island.
EFTA00024933

=== Page 3 ===
Thanks,
Assistant United States Attorney
Southern District of New York
From: McGorty, Glen
Sent: Tuesday, November 10, 2020 1:16 PM
To:
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
Subject: RE: Wednesday's WebEx
just wanted to circle back with you in advance of Thursday's meeting. We want
to be fully prepared, so
if there is any more granularity on this topic (or any additional topic or topics), please let us know.
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
)
Sent: Monday, October 26, 2020 6:19 PM
To: McGorty, Glen
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
is
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Thanks very much, Glen. Let's plan for 1pm on Thursday, 11/12. I will circulate a WebEx invitation shortly.
We expect to ask Mr.
about his interactions with
the U.S. Customs and Border Protection
employee who worked in Saint Thomas and who had Mr.
listed as a contact in his phone. I expect we will ask for
an approximate timeline of when Mr.
met and interacted with
the nature of those interactions, and any
interactions
may have had with Epstein (to the best of Mr.
knowledge).
EFTA00024934

=== Page 4 ===
Best,
Assistant United States Attorney
Southern District of New York
From: McGorty, Glen
Sent: Monday, October 26, 2020 11:58 AM
To:
)
is
Cc: Zelenko, Daniel
>; Giffuni, Danielle
>;
(USANYS)
Subject: RE: Wednesday's WebEx
-
Sorry for the delay. Looks like we can do between 11 a.m. and 2 p.m. on Tuesday, 11/10, or any time on Thursday, 11/12.
Let us know if anything in that range will work.
So as to make sure Mr.
S prepared, can you give us an overview of what you expect to cover?
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Thursday, October 22, 2020 10:33 AM
To:
>; ; McGorty, Glen
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Glen,
EFTA00024935

=== Page 5 ===
As I believe we mentioned when we last spoke, we would like to schedule time for a second interview with Mr.
via
WebEx. Are there any days the week of November 9th when your team and Mr.
would be available? We would
expect this proffer to be much shorter than our first, and certainly no more than two hours at most.
Thanks,
Assistant United States Attorney
Southern District of New York
From:
Sent: Friday, October 9, 2020 4:42 PM
To: McGorty, Glen
Cc: Zelenko, Daniel
>; Giffuni, Danielle
(USANYS)
is
Subject: RE: Wednesday's WebEx
Hi Glen,
Thanks very much. I'm attaching the fully executed copy.
Thanks,
From: McGorty, Glen
Sent: Thursday, October 8, 2020 9:31 AM
To:
Cc: Zelenko, Daniel
>; Giffuni, Danielle
i
(USANYS)
is
Subject: RE: Wednesday's WebEx
Hi all.
Attached please find the signed proffer agreement. It was nice seeing everyone yesterday.
Thanks,
Glen
Glen G. McGorty I Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
I
Web Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
EFTA00024936

=== Page 6 ===
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Monday, October 5, 2020 4:14 PM
To: McGorty, Glen
Cc: Zelenko, Daniel
>; Giffuni, Danielle
>;
(USANYS)
is
)
Subject: RE: Wednesday's WebEx
External Email
Hi Glen,
Not a problem at all -- I've added everyone to the calendar invitation. Please let us know if any other tech issues crop up,
and we'd be happy to work through them.
Thanks,
From: McGorty, Glen
Sent: Monday, October 5, 2020 12:48 PM
To:
is
is
(USANYS)
Cc: Zelenko, Daniel
is
>; Giffuni, Danielle
in
Morrissey, Josh
Subject: Wednesday's WebEx
Thanks for sending the WebEx invitation for Wednesday's meeting to me. For whatever reason, the system is not
permitting me to forward the invite, so I would ask that you separately invite those copied on this e-mail: Dan, Danielle
and Mr.
but also Josh Morrissey who is in our IT group and will make sure we are good to go for our meeting.
Thanks,
Glen
Glen G. McGorty Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
EFTA00024937


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=== Page 1 ===
From:
Dabbs
To:
)"
N
"Roberta Kaplan"
Conlon
>, Alexandra Elenowitz-
Hess
Cc:
)"
)"
Subject: Re: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Date: Thu, 11 Jul 2019 04:28:37 +0000
Hey
:
I think your conversation with Robbie earlier this evening covers things from our perspective. Thank you for
always making yourself available. As I know you know, we won't be shy if we need to connect on anything further.
And we will be rooting for you on Monday.
Best,
Get Outlook for iOS
From:
)
Sent: Wednesday, July 10, 2019 10:08:08 PM
To: Roberta Kaplan;
Conlon;
Dabbs; Alexandra Elenowitz-Hess
Cc:
);
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Or can dial into your conference number if that's preferable.
From:
Sent: Wednesday, July 10, 2019 22:07
To: 'Roberta Kaplan'
is
Conlon
is
Dabbs
>; Alexandra Elenowitz-Hess
Cc:
is
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Sure, I'm at my desk -
From: Roberta Kaplan
Sent: Wednesday, July 10, 2019 22:06
To:
>;
Conlon
is
Dabbs
>; Alexandra Elenowitz-Hess
EFTA00026674

=== Page 2 ===
Cc:
;
Subject: Re: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Can you talk?
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
New York, New York 10118
From:
Sent: Wednesday, July 10, 2019 5:56:39 PM
To:
Conlon; Roberta Kaplan;
Dabbs; Alexandra Elenowitz-Hess
Cc:
);
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Hi all,
As you may already know, pursuant to the Crime Victims' Rights Act, specifically 18 U.S.C. 3771(a)(4), a crime victim has the
right to be reasonably heard at certain public proceedings in the district court, including proceedings involving release.
Accordingly, we wanted to be in touch consistent with our responsibilities and obligations-and your client's rights-under
that statute, to see whether your client would like to be heard in any fashion, whether through a submission, a
representation that we can include in our bail submission due Friday, or some other form. Of course no requirement or
obligation, but we would be happy to discuss it if that would be useful.
To the extent this information is useful in your consideration, I can say that while I don't want to prejudge the
Would it make sense to set up a brief call sometime tomorrow, if any of you want to discuss? I should be able to make myself
available whenever is convenient for you (and likely will be just me, as the remainder of the team will be traveling).
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00026675

=== Page 3 ===
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify the
sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify the
sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00026676


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=== Page 1 ===
Case 1:19-cv-03377-LAP Document 99 Filed 12/20/19 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
,
Plaintiff,
V.
ALAN DERSHOWITZ,
Civil Action No. 1:19-cv-3377 (LAP)
Defendant.
ALAN DERSHOWITZ,
Oral Argument Requested
Counterclaim Plaintiff,
V.
,
Counterclaim Defendant.
NOTICE OF MOTION FOR LEAVE TO
FILE AN AMENDED COMPLAINT
PLEASE TAKE NOTICE that upon the Declaration of Haley N. Proctor, dated December
20, 2019, together with the exhibits annexed thereto, and the accompanying memorandum of law,
the undersigned will move this Court, before the Honorable Loretta A. Preska, United States
District Judge for the Southern District of New York, at the United States Courthouse, 500 Pearl
Street, New York, New York 10003, at a date and time to be determined by the Court, for an order
under Rule 15(a) granting Plaintiff leave to file an amended complaint.
PLEASE TAKE FURTHER NOTICE that any response or objection to the motion should
be made on or before January 17, 2020, in accordance with the Stipulation and Order dated
EFTA00027034

=== Page 2 ===
Case 1:19-cv-03377-LAP Document 99 Filed 12/20/19 Page 2 of 3
November 26, 2019, Doc. No. 95. Any reply should be filed on or before January 24, 2020, in
accordance with Local Rule 6.1(b).
Dated: December 20, 2019
/s/ Charles J. Cooper
Charles J. Cooper*
Michael W. Kirk*
Nicole J. Moss*
Haley N. Proctor*
COOPER & KIRK PLLC
1523 New Hampshire Ave. NW
Washington, DC 74008
(202) 220-9600
*Admitted PHV
Attorney for Plaintiff
2
EFTA00027035

=== Page 3 ===
Case 1:19-cv-03377-LAP Document 99 Filed 12/20/19 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on December 20, 2019, I electronically filed the foregoing with the
Clerk of the Court using the CM/ECF system, and I hereby certify that the foregoing was served
upon all counsel of record using the CM/ECF system.
/s/ Charles J. Cooper
Charles J. Cooper*
COOPER & KIRK PLLC
1523 New Hampshire Ave. NW
Washington, DC 74008
(202) 220-9600
*Admitted PHV
Attorney for Plaintiff
3
EFTA00027036


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=== Page 1 ===
From: White Collar Law360 <news@law360.com>
To:
Subject: 2nd Circ. Rejects Immediate Stay In Trump Tax Subpoena Suit
Date: Mon, 24 Aug 2020 07:54:45 +0000
Law360 White
Collar
WHITE COLLAR
Monday, August 24, 2020
Follow Law360
TOP NEWS
Law360 Rising Stars
2nd Circ. Rejects Immediate Stay In Trump Tax Subpoena Suit
The Second Circuit said Friday that it will consider President Donald Trump's
request to pause a decision allowing a Manhattan grand jury to subpoena his
tax records pending an appeal, but the court denied his request for an
immediate stay.
4 documents attached Read full article
Loughlin Gets 2 Mos., Husband 5 Mos. In 'Varsity Blues' Case
Actress Lori Loughlin and her fashion-designer husband Mossimo Giannulli
were sentenced Friday to two months and five months in prison, respectively,
for their roles in the "Varsity Blues" college admissions scandal after
admitting to paying bribes to get their two daughters into the University of
Southern California as fake rowing recruits.
Read full article
LAW FIRMS
Adam Leitman
Feds Want Accused Chinese Spy Held As 'Extreme Flight Risk'
Akin Gump
U.S. attorneys in Hawaii endeavored to convince a federal judge to deny bail
Arnold & Porter
to an ex-CIA agent accused of spying for China in a filing released Thursday,
citing a "war chest of damning evidence" and calling him "an extreme flight
Baker Botts
risk."
Beach Cowdrey
Memorandum attached Read full article
Becker & Poliakoff
Bernstein Liebhard
Feds Say Maxwell Can't Use Criminal Discovery In Civil Suits
Bervar & Jones
Federal prosecutors urged a New York federal judge on Friday to deny a
Blank Rome
request by Ghislaine Maxwell to let her file certain criminal discovery
Cadwalader Wickersham
materials under seal in unspecified civil suits against her, arguing that
Calfee Halter
Maxwell is attempting to "blur the lines between the criminal discovery
process and civil litigation."
Carella Byrne
Letter attached Read full article
Clark Hill
Cohen & Gresser
LA Blast That Injured Firefighters Sparks Criminal Charges
Consovoy McCarthy
An explosion at a commercial property in downtown Los Angeles that injured
Cozen O'Connor
a dozen firefighters earlier this year has sparked criminal charges against the
Donnelly Conroy
building's owners and managers, the city attorney's office announced Friday.
Ericksen Arbuthnot
4 documents attached Read full article
Fenwick & West
Fish & Richardson
COMPLIANCE
Flachsbart & Greenspoon
Feds Stress Risk Focus For 'Politically Exposed' Bank Clients
Foley & Lardner
Fox Rothschild
EFTA00025258

=== Page 2 ===
The Financial Crimes Enforcement Network and federal banking regulators
Franklin Soto LLP
said Friday that banks should make sure their "politically exposed" clients
Fried Frank
receive customer due diligence that matches their risk levels but don't need
Gibson Dunn
to subject these clients to special extra scrutiny.
Statement attached Read full article
Glancy Prongay
SECURITIES
Haddon Morgan
Hogan Lovells
Traders Sue Scotiabank After $127M Spoofing Deal With DOJ
Jones Day
A pair of commodities traders sued Scotiabank on Friday after the Toronto-
K&L Gates
based bank admitted in a $127 million settlement with the U.S. government
King & Spalding
to an eight-year scheme to manipulate the market for precious metals futures
Kirkland & Ellis
contracts.
Latham & Watkins
Complaint attached
Read full article
Law Offices of Alan S. Futerfas
Fiat Chrysler Aims To Dump Investor Suit Over UAW Bribes
Levi & Korsinsky
Fiat Chrysler on Friday urged a New York federal court to ditch a stock-drop
Lewis Brisbois
suit accusing the automaker of concealing a scheme to bribe officials at the
Lowenstein Sandler
United Automobile Workers, insisting that none of its executives was aware of
Manatt Phelps
the bribery scheme and its financial disclosures therefore weren't misleading
Mark Beck Law
or inaccurate.
Marshall Gerstein
Motion attached Read full article
Miller Canfield
SEC Says There's 'No Dispute' Biotech Brass Broke Law
Morgan Lewis
The U.S. Securities and Exchange Commission on Friday sought partial
Mukasey Frenchman
judgments against the chief executive officer and chief financial officer of
Munger Tolles
biotechnology company Osiris Therapeutics Inc., telling a Maryland federal
Nussbaum Law Group PC
judge that there was no good faith argument to be made that the men didn't
Patterson & Sheridan
violate federal securities law by scheming to cook the company's books.
2 documents attached Read full article
Paul Hastings
Paul Weiss
SEC Sues Ex-Brokers For Role In $22M Belize Airport Ponzi
Quinn Emanuel
The U.S. Securities and Exchange Commission targeted two former brokers
Reed Smith
in New York federal court on Friday for the unregistered sale of securities to
Ropes & Gray
about half of the investor victims in a $22 million Ponzi scheme fronted by a
Rosen Law Firm PA
purported airport project in Belize.
Scheper Kim
Complaint attached Read full article
Selendy & Gay
CFTC Seeks $572M From Vanished Crypto Fraud Suspect
Sheppard Mullin
The U.S. Commodity Futures Trading Commission is seeking a default
Sidley Austin
judgment against apparent U.K. resident Benjamin Reynolds that would put
Squire Patton Boggs
him on the hook for $572 million after the agency alleged he stole 22,858
Stoel Rives
bitcoins in a Ponzi scheme-like fraud and failed to appear in the case.
Sullivan & Cromwell
2 documents attached Read full article
Swanson Martin
Investor Claims Ohio Utility Played Role In $60M Bribery Plot
Vogl Meredith
White & Case
American Electric Power Co. Inc. is facing a proposed class action from an
investor who says the utility's stock lost value after an Ohio newspaper ran
WilmerHale
an investigative report implicating AEP in a more than $60 million corruption
Wilson Elser
plot.
Complaint attached
Read full article
COMPANIES
Amazon.com Inc.
LEGAL ETHICS
American Airlines Group Inc.
American Bar Association
Dallas Atty Hit With 6-Month Suspension For Misconduct
American Electric Power Co. Inc.
A three-judge panel of the Northern District of Texas has suspended a Dallas
Appaloosa Management LP
criminal defense attorney from practicing before the court for six months,
finding she violated a judge's order to stop communicating with an ex-client
Apple Inc.
and lied to prosecutors.
Association of Corporate Counsel
EFTA00025259

=== Page 3 ===
Order attached
Read full article
Center for Justice
HEALTH
Cisco Systems Inc.
Dealogic LLC
NextHealth Marketer Charged In $60M Kickback Scheme
Deutsche Bank AG
A pharmacy marketer has been charged in a $60 million health care kickback
Eli Lilly & Co.
scheme, accused of helping a pharmacy and laboratory services company
FCA US LLC
recruit physicians, according to the U.S. Department of Justice.
Read full article
Federalist Society
Fiat Chrysler Automobiles NV
III. Doctors With Same Name Agree To End Trademark Fight
Financial Industry Regulatory
An Illinois federal judge on Friday permanently dismissed a case between a
Authority Inc.
doctor and another physician of the same name, the latter of whom was
FirstEnergy Corp.
accused of capitalizing off their similar names to run an opioid "pill mill" and
Fred Alger & Co. Inc.
tarnish the plaintiff's professional standing.
1 document attached Read full article
Google Inc.
Humana Inc.
Fla. Telemedicine Schemers Cost Humana Millions, Suit Says
Janus Henderson Group PLC
Humana Insurance Co. sued a Florida telemedicine company on Thursday
Liberty Mutual Insurance Group
for allegedly preying upon Humana members through a telemedicine scheme
Mazars LLP
that billed the insurer for millions of dollars' worth of unnecessary prescription
Michelin Group
creams.
Microsoft Corp.
Complaint attached Read full article
National Futures Association
IMMIGRATION
Osiris Therapeutics Inc.
Skype Technologies SA
Feds Arrest Va. Man Over Alleged $21M H-1B Scam
Spotify Technology SA
A Virginia information technology business owner was arrested Thursday on
The Bank of Nova Scotia
charges of orchestrating a $21 million immigration fraud scheme that saw
The Boeing Co.
him using his companies to fraudulently obtain H-1B visas for foreign tech
The Clorox Co.
workers.
The Lawyers' Committee for Civil
Read full article
Rights Under Law
CONSUMER PROTECTION
Trump Organization Inc.
U.S. Chamber of Commerce
Pa. AG Hits Amazon Seller With Sanitizer Price-Gouging Suit
United Auto Workers
Pennsylvania's attorney general is seeking $1 million in penalties against a
University of Southern California
Philadelphia-based company accused of illegally jacking up the price of hand
YouTube Inc.
sanitizer it sold on Amazon.com as the coronavirus pandemic took hold in
March.
GOVERNMENT AGENCIES
Complaint attached
Read full article
Central Intelligence Agency
Commodity Futures Trading
EXPERT ANALYSIS
Commission
Congressional Research Service
Opinion
Pandemic Is No Excuse To Limit Defendants' Trial Rights
Equal Employment Opportunity
Commission
Chicago federal prosecutors' recent argument that the pandemic compels
two ex-Deutsche Bank traders to choose between their right to a speedy trial
European Union
and the right to confront witnesses in person is not only inconsistent with
Executive Office of the President
current law but fundamentally unfair, say John Richter and Christina Kung at
Federal Bureau of Investigation
King & Spalding.
Federal Deposit Insurance Corp.
Read full article
Federal Judicial Center
Why Remote Depositions Are Likely Here To Stay
Federal Reserve System
As attorneys and their clients realize it is possible to conduct video
Financial Crimes Enforcement
depositions just as smoothly as in-person sessions while eliminating travel,
Network
catering and other costs, they will likely demand that remote procedures
Florida Supreme Court
remain in place even after the pandemic is contained, says Darren Goldman
Library of Congress
at Becker & Poliakoff.
EFTA00025260

=== Page 4 ===
Read full article
Massachusetts Supreme Judicial
LEGAL INDUSTRY
Court
National Credit Union
Legend In Law: Liberty Mutual Insurance's James Kelleher
Administration
Kelleher, chief legal officer for one of the largest U.S. insurers, has been
National Labor Relations Board
named a Burton Awards Legend in Law, a distinction reserved for the top
Office of the Comptroller of the
general counsel in the nation.
Currency
Read full article
Ohio House of Representatives
U.S. Attorney's Office
BigLaw And The Ballot: The Pro Bono Fight For Mail-In Voting
U.S. Court of Appeals for the
With the U.S. presidential election looming and the coronavirus pandemic still
Eleventh Circuit
raging, pro bono attorneys at BigLaw firms are increasingly jumping into court
battles over mail-in voting that are moving at unprecedented speed.
U.S. Court of Appeals for the First
Circuit
Read full article
U.S. Court of Appeals for the
Second Circuit
33-Year-Old Trump Judicial Pick Attacked Over Experience
Liberal advocates are lambasting President Donald Trump's youthful pick for
U.S. Department of Homeland
a Florida federal judgeship, questioning the trial experience of a Jones Day
Security
associate who graduated law school in 2012 and would be the youngest
U.S. Department of Justice
federal judge in over 30 years.
U.S. District Court for the District of
Read full article
Hawaii
U.S. District Court for the District of
Stoel Rives Walks Back COVID-19 Cuts But Will Remain Wary
Maryland
Stoel Rives LLP has announced that it will partly roll back the salary
U.S. District Court for the District of
reductions it implemented in the spring due to the COVID-19 pandemic,
Massachusetts
although the firm said that it will continue to "operate cautiously."
U.S. District Court for the District of
Read full article
New Jersey
U.S. District Court for the Eastern
Lowenstein Securities Chair Forms New Firm With Colleagues
District of New York
Lawrence Rolnick, the chair of Lowenstein Sandler LLP's securities litigation
U.S. District Court for the Eastern
practice, is taking nine of his colleagues with him to start a new firm catering
District of Virginia
to the investment management industry, he told Law360 on Friday.
U.S. District Court for the Northern
Read full article
District of California
Calif. Atty Says Lewis Brisbois Cheated Him Of $1M Fee Award
U.S. District Court for the Northern
District of Illinois
A California attorney has filed a fraud suit against Lewis Brisbois Bisgaard &
Smith LLP, one of its partners and several other firms and attorneys who
U.S. District Court for the Northern
allegedly cheated him out of over $1 million in attorney fees from a
District of Texas
settlement in a personal injury lawsuit.
U.S. District Court for the Southern
Read full article
District of Florida
U.S. District Court for the Southern
GC Cheat Sheet: The Hottest Corporate News Of The Week
District of New York
The U.S. Equal Employment Opportunity Commission came closer to a
U.S. Patent and Trademark Office
proposed rule that modifies its presuit conciliation process for settling bias
U.S. Postal Service
claims against employers, and a new survey found that staff changes have
affected a majority of in-house attorneys' workload. These are some of the
U.S. Securities and Exchange
Commission
stories in corporate legal news you may have missed in the past week.
Read full article
U.S. Supreme Court
United States District Court for the
In Case You Missed It: Hottest Firms And Stories On Law360
Southern District of Ohio
For those who missed out, here's a look back at the law firms, stories and
expert analyses that generated the most buzz on Law360 last week.
Read full article
Podcast
Law360's Pro Say: The Artistry Of The Courtroom Sketch
The courtroom sketch artist has one of the legal world's most fascinating
professions and, so long as television access to court proceedings remains
limited, maybe one of the most important.
EFTA00025261

=== Page 5 ===
Read full article »
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=== Page 1 ===
From:
"
(NY) (FBI)"
To:
)"
)"
Cc:
Subject: Fwd: Travel for Epstein vic for hearing
Date: Fri, 23 Aug 2019 00:53:15 +0000
FYI
-
Forwarded message
From:
(NY) (FBI)"
Date: Aug 22, 2019 8:42 PM
Subject: Travel for Epstein vic for hearing
To:
(USANYS)"
Cc:
Hi
Just got another call from one of the victims from LA. She is represented by Brad Edwards. Her name is
She would like to come out for the hearing on Tuesday. She also expressed meeting with us. She plans to reach
out to you. Her number is
Thanks,
EFTA00024418


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=== Page 1 ===
From:
)"
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
,
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Date: Wed, 12 Feb 2020 21:10:12 +0000
Attachments: 020-02-10,_NDO_&_subpoena_to_Interlochen_(for_student_records)_docx.pdf
Jeff,
As discussed, attached please find a second subpoena with an accompanying non-disclosure order. Please feel free to
give me a call with any questions.
Thanks,
Maurene
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
Cc:
is
Subject: Re: Subpoena to Interlochen Center for the Arts
Maurene -
Receipt confirmed.
Thanks,
Jeff
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.
EFTA00026849

=== Page 2 ===
From:
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
"
i
)
"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey Epstein and
Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Maurene
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00026850


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=== Page 1 ===
90A-NY-3151227 Serial 6
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Evidence
Date: 08/14/2019
NYC023580
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) MCC-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Evidence NYC023580: One (1) Seagate Barracuda 500GB
HDD, ST500DM002, S/N Z3T6CF5X, from MCC Nice Vision DVR2 Surveillance
System (3 of 18).
Item Type
Description
1B Digital
(U) NYC023580: One (1) Seagate Barracuda 500GB HDD,
ST500DM002, S/N Z3T6CF5X, from MCC Nice Vision DVR2
Surveillance System (3 of 18).
Collected On: 08/10/2019 04:30 PM EDT
Seizing Individual:
Located By:
Device Type: Hard Drive
Designation: Original
Number of Devices Collected: 1
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00023970


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=== Page 1 ===
From: "Kate L. Doniger"
To:
(USANYS)"
Cc:
)"
N
Alexandra Conlon
, Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Date: Thu, 30 Apr 2020 16:44:53 +0000
Thanks,
That works for us. Speak to you then.
Kate L. Doniger Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Thursday, April 30, 2020 12:27 PM
To: Kate L. Doniger
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Kate,
I hope you are keeping well also. Would a call at 1:45 on Monday, 05/04, work? Please call me at
,
or I can
circulate a dial-in if helpful.
Thanks,
From: Kate L. Doniger
Sent: Thursday, April 30, 2020 11:15 AM
To:
(USANYS)
Cc:
>; Alexandra Conlon
is
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Hope you are keeping well. Thank you very much for this production. We have a few questions for you-are you available
tomorrow or next week to discuss? Please let us know what would be convenient for you. Thanks again,
Kate
Kate L. Doniger I Kaplan Hecker & Fink LLP
EFTA00025349

=== Page 2 ===
From:
(USANYS)
Sent: Tuesday, April 21, 2020 10:55 PM
To: Kate L. Doniger
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: [Not Virus Scanned] RE: Request for Information Relating to Jeffrey Epstein
This message has not been virus scanned because it contains encrypted or otherwise protected data. Please ensure you
know who the message is coming from and that it is virus scanned by your desktop antivirus software.
Kate,
Per our conversation earlier today, please find attached a letter responding to your request for information relating to
Jeffrey Epstein, as well as the set of documents identified in the letter. I will send the password for the document file
separately.
Thank you,
From: Kate L. Doniger
Sent: Wednesday, April 15, 2020 9:09 AM
To:
(USANYS)
Cc:
>; Alexandra Conlon
is
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Thanks very much,
Kate L. Doniger I Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Wednesday, April 15, 2020 12:10 AM
To: Kate L. Doniger
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Kate,
Thank you for checking in. I hope you are keeping well also. I do not think we need any additional information from you at
this time. I hope to be able to provide an update early next week.
Thanks,
From: Kate L. Doniger
Sent: Tuesday, April 14, 2020 3:01 PM
To:
(USANYS)
Cc:
>; Alexandra Conlon
is
EFTA00025350

=== Page 3 ===
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
We hope that you are keeping well in this very challenging time.
We completely understand that all things are in flux these days, but we just wanted to check in with you about our
request and whether there is any other information you need from us. If it would be helpful to set up a call to discuss, we
are available at your convenience.
Best,
Kate
Kate L. Doniger I Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Thursday, February 27, 2020 7:23 PM
To: Alexandra Conlon
>; Roberta Kaplan
Cc: Kate L. Doniger
is
Subject: RE: Request for Information Relating to Jeffrey Epstein
Alexandra and Robbie,
Thank you for this. I will contact you regarding the request.
Thanks,
From: Alexandra Conlon
Sent: Tuesday, February 25, 2020 7:54 PM
To:
(USANYS)
>; Roberta Kaplan
Cc: Kate L. Doniger
>;
Subject: RE: Request for Information Relating to Jeffrey Epstein
SENT ON BEHALF OF ROBERTA KAPLAN
AUSA
Thank you for contacting us. Attached please find a Touhy letter and supporting exhibit requesting documents from the
Department of Justice in connection with our pending litigation against Jeffrey Epstein's estate.
We are happy to schedule a time to talk if it would be helpful to discuss our request.
Best Regards,
Robbie
EFTA00025351

=== Page 4 ===
Alexandra Conlon Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Monday, January 6, 2020 6:59 PM
To: Roberta Kaplan
Cc: Kate L. Doniger
>; Alex Conlon
Subject: Request for Information Relating to Jeffrey Epstein
Dear Ms. Kaplan,
Please find attached a letter regarding the request you discussed with AUSA
for certain information
relating to Jeffrey Epstein. As stated in the letter, please contact me once you have had a chance to review the letter if you
would like to discuss the issues therein further.
Thanks
Assistant United States Attorney
Southern District of New York
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00025352


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024509.pdf
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c0:
=== Page 1 ===
From:
To:
Subject: Final Voucher
)
approved by
,
now awaiting further approval
Date: Fri, 20 Dec 2019 17:55:30 +0000
Importance: Normal
Dear
Final voucher
) has been approved by
, now awaiting further approval.
Trip ID:
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13257 - U.S. V. Epstein - Witness Interviews
Destination: Santa Monica, CA, United States
Dates: 2019-12-15 - 2019-12-17
Current status: Pending Voucher Approval
Voucher total expenses: 1400.38
Estimated trip cost: 1907.95
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
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Reference ID# V0010
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00024509


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025398.pdf
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=== Page 1 ===
From:
(OPR)"
To:
)"
Cc:
)"
)"
Subject: RE: OPR Matter (following up on our recent conversation)
Date: Tue, 07 Apr 2020 12:44:55 +0000
We will certainly do so,
in all respects.
Thank you.
And best wishes to you all for safety and health.
Regards,
From:
Sent: Monday, April 06, 2020 11:00 PM
To:
(OPR)
Cc:
;
Subject: RE: OPR Matter (following up on our recent conversation)
We're glad that information is helpful, and we appreciate you checking in with us on this - thank you. We do not believe
that asking victims about their past contacts with the USAO-SDFL and FBI-MIA in or about 2005-2008 would present any
issues for our office, we would just respectfully ask that any such discussions avoid addressing the substance of the
underlying criminal scheme (including the victims' personal experiences and interactions with Epstein or his associates).
And if those topics unavoidably arise despite not having been raised by OPR, we'd ask that you please let us know so we
can incorporate any such witness statements as 3500 material as appropriate and required. But please let us know if that
poses any issues on your end.
thanks again,
Assistant U.S. Attorney
Southern District of New York
From:
(OPR)
Sent: Monday, April 06, 2020 15:32
To:
Subject: RE: OPR Matter (following up on our recent conversation)
Thank you,
This is sufficient; no need for you to do anything further.
I want to assure you that in reaching out to and possibly interviewing the victims regarding their past contacts with the
USAO-SDFL and FBI-MIA, OPR wishes to in no way interfere with anything your office may be doing currently or
anticipates doing in the future. Please confirm that our doing so does not present any issues for your office. If you have
any concerns in that regard, please let me know so we can discuss the matter. I hope I might hear back from you by
midday Wednesday if possible.
Best regards,
From:
Sent: Friday, April 03, 2020 7:48 PM
To:
(OPR)
Cc:
Subject: RE: OPR Matter (following up on our recent conversation)
EFTA00025398

=== Page 2 ===
Thanks for following up, and as discussed we are able to advise OPR regarding the individuals on your list whom we
understand to be represented by counsel. I'm happy to speak with you via phone at your convenience, but in the first
instance, because the overwhelming majority of the individuals on your list are represented by counsel, attached is a
spreadsheet with the relevant information. The spreadsheet represents our best and current understanding-i it is of
course possible that individuals have changed their counsel very recently, but this should hopefully at least get you
started.
As reflected in the spreadsheet, of the 32 individuals you listed, 22 are represented by Brad Edwards, of Edwards Pottinger
LLC; two are represented by Jack Scarola, of Searcy Law; one is represented by Sigrid McCawley, of Boies Schiller; one is
represented by Rita Glavin, of Seward & Kissel LLP, and one is represented by Gloria Allred, of Allred, Maroko & Goldberg.
Of the remaining five, four we have been unable to connect with (at least at the AUSA level), and one we believe is
deceased. The contact information for the attorneys is the following:
Brad Edwards
Jack Scarola
Sigrid McCawley
Rita Glavin
Gloria Allred
Please let me know if it would be helpful to chat, and thanks as always.
best,
From:
(OPR)
Sent: Thursday, April 02, 2020 14:04
To:
Subject: OPR Matter (following up on our recent conversation)
AUSA
USAO-SDNY
As you and I have briefly discussed OPR wishes to conduct brief interviews, on very limited and historical matters, with a
number of individuals who may be involved in matters you have under investigation, who are listed below. You offered to
advise us which of the individuals you know to be currently represented by counsel, and who those counsel are. For
efficiency's sake, I would like to schedule a phone call with you for that purpose. Please let me know when you might be
available.
As are so many of us, I'm teleworking, but available to speak at pretty much any time of the workday.
With regards,
Counsel
Office of Professional Responsibility
U.S. Department of Justice - Suite 3266
950 Pennsylvania Avenue NW
Washington DC 20530
EFTA00025399

=== Page 3 ===


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=== Page 1 ===
From:
To:
Subject: epstein foia question
Date: Tue, 05 Jan 2021 21:43:39 +0000
MCC Regs/Training - investigative reason for SHU staff name redactions back to 8/4
Counsel to the Acting U.S. Attorney
United States Attorney's Office
Southern District of New York
EFTA00026958


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=== Page 1 ===
From:
To:
Subject: RE: Epstein investigation
(
)
Date: Tue, 25 Feb 2020 16:33:05 +0000
That works, thanks.
From:
Sent: Tuesday, February 25, 2020 11:33 AM
To:
)
Cc:
Subject: Re: Epstein investigation
(
That works for me.
, good for you?
Sent from my iPhone
On Feb 25, 2020, at 09:29,
)
wrote:
I have a conference in the
in White Plains at that exact time, so I'll have to miss this. You guy should go
ahead without me if that works for you, though.
From: Sigrid McCawley
Sent: Tuesday, February 25, 2020 9:03 AM
To:
Cc:
is
)
Subject: RE: Epstein investigation
(
Hello
I spoke to
and she and I can meet with you on Wednesday, March 4th at 2:00 p.m. Please confirm that works
for your team. Can you also please send me the street address for your building so I can get that to
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
From:
Sent: Monday, February 24, 2020 4:45 PM
To: Sigrid McCawley
EFTA00026800

=== Page 2 ===
Cc:
is
Subject: RE: Epstein investigation
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
Sigrid,
Thank you again for speaking with us this afternoon, we appreciate it. As discussed, we wanted to follow up with you
via email about a possible meeting with Ms.
-it sounded like it might be convenient to do a meeting next
week while you're in New York, if that would work for her? If so, if you could give us the dates and time ranges that
might be possible, we can coordinate on scheduling on our end as well. And of course as always we're happy to address
any questions that you or she might have in advance.
thanks very much,
Assistant U.S. Attorney
Southern District of New York
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information
that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1
08201831BSF
EFTA00026801


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=== Page 1 ===
MASSEUSES
EFTA00024797

=== Page 2 ===
EFTA00024798

=== Page 3 ===

=== Page 4 ===
EFTA00024800

=== Page 5 ===
EFTA00024801

=== Page 6 ===
EFTA00024802

=== Page 7 ===
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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)
[Contractor]"
Subject: RE: Maxwell Review
Date: Wed, 17 Mar 2021 19:29:26 +0000
Great, thanks.
From:
(USANYS)
Sent: Wednesday, March 17, 2021 3:27 PM
To:
)
is
(USANYS) [Contractor]
Subject: FW: Maxwell Review
FYI. No pushback from
From: Tyrrell, Edward (USANYS)
Sent: Wednesday, March 17, 2021 3:26 PM
To:
(USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Maxwell Review
Got it.
From:
(USANYS)
Sent: Wednesday, March 17, 2021 3:20 PM
To: Tyrrell, Edward (USANYS)
is
(USANYS)
Cc:
(USANYS)
Subject: Maxwell Review
Hi
and
Just want to put an issue on your radar. As you may recall, we paid a vendor to scan the SDFL Epstein file in October, and
we are hopeful that it will be loaded into Relativity by the end of March (the delay was unfortunate, but we're hopeful
PAE can make it happen soon). In order to meet pretrial disclosure deadlines, we need to review the file (which we
understand to be 30k documents) to determine what has already been produced. We have recruited 4 paralegals and an
intern in PC to help conduct this review, and have requested an additional 3-4 paralegals from Darcy to assist. The
deadline is the end of April, so the team has about a month to complete the review.
Happy to discuss any further if you have any questions.
Thanks very much,
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
Desk
Cell
EFTA00024030


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=== Page 1 ===
From:
"
(USANYS)"
To:
"
(USANYS)"
Subject: Accepted: Epstein/Maxwell FOIA
Date: Wed, 10 Mar 2021 20:31:56 +0000
Importance: Normal
Attachments: unnamed
EFTA00025211


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=== Page 1 ===
From:
"
To:
"
"
Cc:
11
"
"
"
Subject: Modification to 15JA5418F00000299
Date: Thu, 11 Jul 2019 13:10:36 +0000
Importance: Normal
Attachments: P00005.pdf
Inline-Images: image001.jpg; image003.jpg
Hi
Attached is modification P00005 (additional task order/funds added) to the referenced order for your files. Thanks.
DEPARTMENT OF JUSTICE
Contract Specialist (FAC-C/COR III)
U.S. Attorney's Office, Southern District of New York
T
F
E-Mail:
EFTA00024823


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10643456-2 has received final approval
Date: Mon, 30 Sep 2019 15:09:10 +0000
Importance: Normal
Dear
Travel authorization 10643456-2 has received final approval.
Trip ID: 10643456-2
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews
Destination: Santa Monica, CA, United States
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.
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Reference ID# T0006
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.
EFTA00025335


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=== Page 1 ===
From:
To:
Bcc: "USAHUB-USAJournal111"
Subject: RE: CVRA notice
Date: Tue, 08 Dec 2020 23:20:20 +0000
Embedded: RE:_CVRA_notice.msg
Sender:
Subject: RE: CVRA notice
Message-Id:
<SN5P110MB0542558377667A54292E552392CD0@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM>
To:
To:
EFTA00025492


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
(USANYS)"
)"
Subject: RE: U.S. V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) -- Response to Government's Letter re:
Birth Certificates
Date: Sun, 21 Nov 2021 13:29:43 +0000
Inline-Images: image001.gif; image002.jpg
Nice work!
From:
Sent: Saturday, November 20, 2021 9:40 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
(USANYS)
>;
Subject: FW: U.S. V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) -- Response to Government's Letter re: Birth Certificates
Attached is the defense response on birth certificates. They have conceded.
From: Christian Everdell CEverdell@CohenGresser.com
Sent: Saturday, November 20, 2021 9:31 PM
To: Nathan NYSD Chambers
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Laura Menninger <lmenninger@hmflaw.com>; bcsternheim@mac.com;
in
is
(USANYS)
is
Subject: [EXTERNAL] U.S. V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) -- Response to Government's Letter re: Birth
Certificates
Dear Chambers -
Attached please find Ms. Maxwell's response to the government's letter, dated November 11, 2021, regarding the self-
authentication of birth certificates of the alleged Minor Victims. Pursuant to our established protocol, we are submitting
the letter to the Court under temporary seal to allow the government to propose any redactions it deems necessary.
Respectfully submitted,
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 707 7268
ceverdell@cohengresser.com
view bio
www.cohengresser.com
New York Paris Washington DC London
EFTA00024907

=== Page 2 ===
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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
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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.
EFTA00024908


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=== Page 1 ===
From:
"
To:
Subject: Declined: Epstein FOIA Next Steps - Noel Team
Date: Tue, 13 Apr 2021 17:10:20 +0000
Importance: Normal
Attachments: unnamed
EFTA00026924


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=== Page 1 ===
From: The Washington Post <email@washingtonpost.com>
To:
Subject: The Daily 202: As a baseball season like no other begins, escaping coronavirus proves
impossible
Date: Thu, 23 Jul 2020 17:45:53 +0000
Sign up for this newsletter
Read online
The Washington Post
The Daily 202
Intelligence for leaders.
Presented by American Cancer Society Cancer Action Network
Jame
By James Hohmann
S
with Mariana Alfaro
Hohma
Email
As a baseball season like no other begins,
escaping coronavirus proves impossible
A reporter approached Sen. Mitt Romney in the Capitol on Wednesday
afternoon to ask: "Do you have confidence in the president's handling of
this crisis right now?"
"Which? There are so many crises going on," replied Romney (R-Utah).
"I'm not sure which."
Mitt Romney arrives for this week's Senate Republican lunch. (Stefani
Reynolds/Bloomberg)
Mitt Romney arrives for this week's Senate Republican lunch. (Stefani Reynolds/Bloomberg)
The 2012 GOP presidential nominee was not trying to be flip and lamented
President Trump's response to the novel coronavirus when the reporter
clarified. But our nation faces cascading crises: the worst civil unrest since
EFTA00025443

=== Page 2 ===
1968, the worst economic upheaval since 1933 and the worst public health
emergency since 1918. This morning's jobs report shows another 1.4
million workers filed for unemployment benefits last week, the 18th
straight week that more than a million Americans have filed claims.
Other ongoing crises get less attention because of the contagion, but that
does not mean they have been solved. There is an opioid crisis causing
deaths of despair, the climate crisis that imperils the future of the planet, a
looming sovereign debt crisis that most political leaders seem nonchalant
about, rising great-power conflict with China, including a new space race,
and fresh complications overnight in Afghanistan as America struggles to
exit her longest war.
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Professional sports offer a comfortable getaway from the challenges of life
and the burdens of reality. For a few hours, and a few bucks, you can go to
the ballpark and escape. That has always been part of the joy that comes
with the price of admission.
On this Opening Day of the Major League Baseball season, delayed by
nearly four months because of the coronavirus, such escapism is
impossible. Largely, this is because no one is safe from covid-19. To wit, the
Kansas City Royals revealed Wednesday that Hunter Dozier, who hit 26
home runs last season, tested positive and will be placed on the injured list.
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This abridged 60-game season, instead of the usual 162, will not be
baseball as we know it; it might better be described as covidball. First off,
there will be no spectators allowed in the stands, so all of us will be
watching on television and fake crowd noise will be piped into the
ballparks.
There is supposed to be social distancing - and mask wearing - in the
dugout. Players have been told not to give high-fives. Or spit. Or chew
sunflower seeds. Coaches have been told they are not allowed to touch their
faces.
Tradition-bound Major League Baseball has made rule changes that would
have been considered sacrilege not long ago, including introducing
designated hitters in the National League and starting extra innings with
an automatic runner on second base.
Historically and culturally, baseball has been far less political and polarized
than professional football and basketball. Players have tended to be less
outspoken than their counterparts in other sports. (I touched on this in
2017 after completing a personal quest to watch games at all 30 major
league stadiums.)
But times are changing. The sport has not been immune to the national
reckoning on racial injustice. San Francisco Giants manager Gabe Kapler
and several of his players knelt during the national anthem earlier this
week before an exhibition game, provoking an attack by Trump. "Looking
forward to live sports," he tweeted on Tuesday, "but any time I witness a
player kneeling during the National Anthem, a sign of great disrespect for
our Country and our Flag, the game is over for me!"
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In a show of solidarity, "Black Lives Matter" will be stenciled on several
mounds across the league this weekend, including in Washington. The
league has also given players the option to wear patches on their jerseys
that use the phrase.
The topsy-turvy process that got us to Opening Day has itself been a
metaphor for the country's broader struggle to control the virus. Baseball is
the first of the big four sports to play a regular season game since March.
The United States has lagged Europe and Asia in restarting professional
sports. Players are being tested regularly now, but there have been long
delays in turning around results - just like for the rest of society - that
limit the values of the tests.
So often, it has felt like America just cannot catch a break these past few
months. It is perhaps apt that the forecast calls for scattered
thunderstorms to linger in Washington into the evening before tapering off
after sunset.
Tony Fauci, director of the National Institute of Allergy and Infectious Diseases,
adjusts his face mask during a Senate health committee hearing on June 30. (Al
Drago/Reuters)
Tony Fauci, director of the National Institute of Allergy and Infectious Diseases, adjusts his face mask
during a Senate health committee hearing on June 30. (Al Drago/Reuters)
Tony Fauci, the government's top infectious-disease expert, will throw the
ceremonial first pitch of the first game at 7 p.m. Eastern in Washington as
the Nationals take on the New York Yankees. ESPN will broadcast it live. In
a video released Wednesday by the Nationals, the 79-year-old Fauci said he
was nervous about getting the ball past home plate. Washington star Ryan
Zimmerman told him not to worry. "If you bounce it, there's nobody there
to boo you," he quipped.
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I will never forget flying to Houston last October to watch the Nationals
win in the World Series with my dad. But it feels hard to believe that
incredible playoff run was just nine months ago. It feels like nine years.
The season opener is a doubleheader: The Dodgers will play the Giants
tonight in Los Angeles after the Nationals-Yankees game. But San
Francisco's star catcher Buster Posey will not play. He has opted to sit out
the season because he and his wife adopted identical twin girls who were
born prematurely, and he doesn't want to put them at risk. Among the
dozen or so other stars skipping this season are Zimmerman, Atlanta's
Nick Markakis, Los Angeles's David Price and Colorado's Ian Desmond.
The members of my fantasy baseball league normally gather in the
basement of a Capitol Hill bar for an annual draft. This year, we gathered
virtually to respect social distancing protocols. We also waited to hold our
draft until late last night because so many players kept announcing that
they wouldn't play this season. None of us wanted to pay for pitchers and
hitters who will not generate any stats for our teams.
(For those who care about the game, the roster for "The 202s" includes
Gerrit Cole, Francisco Lindor, Clayton Kershaw, Nelson Cruz, Javier Baez,
Jose Altuve, Matt Olson, Eddie Rosario and Kyle Schwarber. Picking Cole
as one of my starting pitchers creates a somewhat awkward dynamic
tonight because I will be cheering for the Nationals as the new Yankees ace
starts against them. So it goes.)
Everything comes with some risks amid the pandemic. The first road game
for the Nationals will be against the Toronto Blue Jays. But no one knows
where that game will take place because Canada is not allowing its sole
MLB team to play in the country. On Wednesday, the state of Pennsylvania
told the Blue Jays that they will not be allowed to play their home games
this season at PNC Park in Pittsburgh, as they had hoped to do.
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"In recent weeks, we have seen a significant increase in the number of
COVID-19 cases in southwestern Pennsylvania," said Rachel Levine,
secretary of the state Department of Health, in a statement. "To add
travelers to this region for any reason, including for professional sports
events, risks residents, visitors and members of both teams. We know that
this virus does not discriminate and can even make professional athletes
very sick. We are committed to protecting the health and well-being of all
Pennsylvanians."
More team coverage:
Thomas Boswell: "This MLB season will be weird and not without
risk. I can't wait."
Jesse Dougherty: "This was not the Opening Day the Nationals had
planned, but at least it's here."
Dave Sheinin: "The baseball season starts Thursday. How it ends is
anyone's guess."
Jerry Brewer: "Sports are doing what they can to remain viable, just
like the rest of us."
Scott Allen: "Shut out from Nationals Park, fans look for other ways to
make Opening Day memorable."
George Will created his annual baseball trivia quiz for Opening Day.
(You can take it here.)
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The coronavirus
Sophie Cunningham, seen here on the right after a win in last year's NCAA
women's college basketball tournament, believes she has had the coronavirus twice.
(Charlie Neibergall/AP)
Sophie Cunningham, seen here on the right after a win in last year's NCAA women's college basketball
tournament, believes she has had the coronavirus twice. (Charlie Neibergall/AP)
Anecdotal evidence is mounting that you can get covid-19
twice, but doctors remain unsure.
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"When Sophie Cunningham, a guard for the WNBA's Phoenix Mercury,
returned to training last week after a bout with covid-19, she said she
believed she had been infected twice - once in March and then again in
June or July," Carolyn Johnson and Ariana Eunjung Cha report. "Daniel
Griffin, an infectious diseases doctor and researcher at Columbia
University Medical Center, said that with every virus - including
chickenpox, for which antibodies are supposed to last a lifetime - there are
cases of people who become sick again after recovering from the initial
illness. When it comes to Ebola, American doctor Ian Crozier was declared
free of the virus but then doctors found it lurking in his eye. In HIV/AIDS,
a baby in Mississippi born to an HIV-positive mother was thought to be
cured but then the virus reemerged 27 months after therapy was stopped.
So in a world where 14.5 million people have had the coronavirus, a small
number with resurgent sickness should not be cause for alarm.
"At the University of Pennsylvania, there was the pregnant woman infected
in March who was fine for two months and then became so sick during
childbirth she had to be put on a ventilator. At Cleveland Clinic, there was a
patient with very mild symptoms in February - just a loss of smell and
taste - who was well for two months, but then needed to be hospitalized in
early May and was confirmed to have the virus again. And at ProHealth
Care in Long Island, there was a man infected at the end of March who was
never sick enough to be hospitalized. He showed up again in July, this time
very ill. 'He thought he had an immunity shield, so he took care of his son
when he got covid,' Griffin said. "Two weeks later, he was in the ER.' The
man, who had a very high antibody response the first time and donated his
plasma so it could be used to treat other coronavirus patients, had barely
any when doctors recently tested his blood in the hospital."
There are conflicting explanations for what's going on. "For severe acute
respiratory syndrome, or SARS, and Middle East respiratory syndrome
(MERS), the antibodies seem to last for a year or longer. But other
coronaviruses, such as the four that cause the common cold, act differently.
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People seem to be able to get them each season, over and over again,"
Carolyn and Ariana report. "Last week, a British study posted to a preprint
server added to the body of evidence that virus-fighting antibodies drop off
steeply two to three months after infection It was quickly followed
by
another study, also not peer-reviewed, of antibodies in nearly 20,000 New
Yorkers with mild or moderate covid-19 symptoms. After retesting 120 of
those people three months later, researchers at Mount Sinai Health System
found virus-fighting antibodies were largely stable and had even increased
in people that started with lower levels right after their infections."
The Senate GOP scrapped Trump's demand for a payroll
tax cut.
Senate Republicans have cast aside one of Trump's key demands in their
emerging coronavirus stimulus package, refusing to include a payroll tax
cut in their opening offer to Democrats, which Senate Majority Leader
Mitch McConnell (R-Ky.) is aiming to announce later today. "The
development came amid a frantic GOP effort to try and salvage other parts
of the package, though the entire process remained fluid and there was
confusion among Republican aides about when a deal might be reached,"
per Erica Werner, Seung Min Kim and Jeff Stein.
Ascena Retail Group, the conglomerate behind women's apparel
brands Ann Taylor, Lane Bryant and Catherines, filed for bankruptcy
and said it would close some of its 2,800 stores. (Abha Bhattarai)
LinkedIn, which is laying off 960 staff, joins a growing group of
employers announcing layoffs for white-collar jobs, as coronavirus
losses continue to ripple beyond low-wage work to better-paying jobs
in auto manufacturing, technology and consulting. "Economists and
human resources experts said the job cuts at LinkedIn were further
evidence that hiring for white-collar jobs has stalled and did not bode
well for a short-term recovery," Jena McGregor reports.
The top executives of biotechnology company Novavax stand to collect
millions even if their vaccine never makes it to the market. The stock
options earmarked for CEO Stanley Erck and three other executives
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=== Page 9 ===
are worth more than $100 million. They're contingent on the vaccine
making it to a Phase 2 trial, which is said to be imminent. (Hamza
Shaban)
The U.S. will soon surpass 4 million confirmed cases.
"Trump painted a wishful view Wednesday of the U.S. response to the
coronavirus pandemic, in which existing treatments can almost cure
patients flooding hospitals, all schools will safely reopen this fall, and the
country's soaring cases are confined to a handful of states," William Wan
and Jacqueline Dupree report. "The rosy assessment he issued at a White
House news briefing was undermined by the alarming reality that on
Wednesday, almost every metric showed just how badly America is losing
its fight against the virus. The number of daily deaths on
Wednesday surpassed 1,100, the first time that mark had been reached
since May 29. And total deaths in the United States since the start of the
pandemic increased to more than 140,000. California on Wednesday
passed New York in the number of total confirmed coronavirus cases
"With transmission rapidly spiking in many areas, governors in
Indiana, Minnesota and Ohio joined the growing number of
states mandating face coverings statewide. More than 30 states
require people to wear masks. [Trump] declined to press for a
nationwide mandate for masks, despite the near-universal urgings of
public health experts. On Wednesday, an influential model created by
the Institute for Health Metrics and Evaluation said wider mask-wearing
by Americans had caused the institute to revise projections on how many
people will die of covid-19 by Nov. 1. Earlier, it had forecast 224,500 deaths
by that date. Now, it estimates 219,900 deaths by Nov. 1 - a decrease of
about 5,000 deaths. If 95 percent of Americans wore masks when leaving
their homes, that number would drop further to 185,900, IHME
researchers said."
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A Texas county is storing bodies in trucks because so
many residents are dying.
"Texas, which reported 197 deaths and 10,893 hospitalizations, has been
one of the states hardest hit by the resurgent coronavirus. Hidalgo County,
at the southern tip of the state on the U.S. border with Mexico, has seen
cases rise 60 percent in the last week with deaths doubling to more than
360," Reuters reports. "Crematoriums in the Hidalgo area have a wait list
of two weeks forcing the county to use five refrigerated trucks that can
hold 50 bodies each. Hidalgo's top medical official, Dr. Ivan Melendez,
partly blamed (Republican Gov. Greg) Abbott's move to override local
officials for the spike in coronavirus infections, which he said has jammed
the local medical system at every level."
Banks face a unique coronavirus problem: Robbers in
masks.
Financial regulators and banks fear masks could double as handy disguises
for would-be bank robbers, and there have been a few mask-involved
attempted robberies. "In one case, a man walked into a Houston bank with
a bandanna covering his face and handed a teller a note: 'I didn't get a
stimulus or that 10k loan. I lost my business to Covid so please make this
easy and comply," Renae Merle reports. "Another would-be robber in
Florida, entered a Wells Fargo branch wearing sunglasses, gloves and a
white cone-like mask over his face. He approached a teller's window
demanding money, according to the arrest warrant. But the bank employee
had trouble hearing the robber's demands - through the mask. "The male
got upset and repeated himself several times' and eventually left empty-
handed, according to the arrest warrant. Despite the robbery attempt,
Wells Fargo began requiring customers to wear masks July 13. They are
also required by Bank of America. JPMorgan Chase said its employees are
required to wear masks but they would comply with local ordinances when
it comes to their customers."
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D.C. imposed one of the most stringent mask requirements
in the country.
"Mayor Muriel E. Bowser said her order requires people older than 2 to
wear a mask when they leave the house and are likely to come into contact
with others. It's one of the strictest mask ordinances in the country - and
came on the same day the city recorded 102 new coronavirus cases, the
highest daily number since early June," Julie Zauzmer, Ovetta Wiggins,
Dana Hedgpeth and Rachel Chason report. "John Falcicchio, the mayor's
chief of staff, said D.C. police will be empowered to fine people not wearing
a mask, although the city expects such fines to be limited. As the city's case
counts rise, Health Director LaQuandra Nesbitt said Wednesday that an
increasing proportion of those newly diagnosed infections involve younger
people."
The virus could push 250,000 into hunger in the D.C. region,
according to a report by the Capital Area Food Bank. About half of the
food bank's 450 partner groups and food pantries are still closed
because of the pandemic. (Kyle Swenson)
Southwest Airlines said it will no longer let travelers fly without
masks, thus enacting the strictest mask policy among U.S. airlines.
(Lori Aratani)
Trump attended a fundraiser at his D.C. hotel without a mask. The
city sent an investigator to inspect the hotel. (Fenit Nirappil and Julie
Zauzmer)
Two cafeterias used by staff in the White House complex were closed
after an employee tested positive. (NYT)
Colleges are creating special quarantine housing for
students who get infected or exposed.
Michigan State University will quarantine sick students in a 500-person
"isolation dorm." Penn State will quarantine sick students at an on-campus
hotel, while the University of North Carolina at Chapel Hill will convert two
dorms - one for students who have been exposed to the virus and another
for those confirmed to have it. (Teo Armus)
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Education Secretary Betsy DeVos said children are "stoppers" of the
virus. While there is evidence that younger children especially may
not transmit the virus as easily, claiming that children may stop the
spread of the disease shows a stunning lack of due diligence, writes
Post fact checker Glenn Kessler.
A new poll shows 60 percent of parents with school-age children say
they'd rather wait for schools to reopen later to minimize infection
risks, even if their kids miss out on academics, according the Kaiser
Family Foundation.
Trump said he would be comfortable sending his son and
grandchildren back to school. (Colby Itkowitz)
Teachers across Arizona protested against reopening schools in
"motor marches." (Arizona Republic)
Florida Gov. Ron DeSantis (R) reiterated his plan to let parents
choose between sending their kids back to school or educating them
online. (Miami Herald)
Quote of the day
"This is everything I was trying to warn people about," said Rebekah
Jones, a Florida Department of Health employee who created the
state's coronavirus dashboard and was fired by DeSantis after being
labeled an "alarmist" for predicting that the state would suffer 4,000
covid-19 deaths. (Yahoo News)
Divided America
Portland, Ore., Mayor Ted Wheeler joins protests in his city. (Jonathan
Maus/Bikeportland via Reuters)
Portland, Ore., Mayor Ted Wheeler joins protests in his city. (Jonathan Maus/Bikeportland via Reuters)
Portland Mayor Ted Wheeler got tear-gassed by federal
agents.
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"Wheeler choked on tear gas late Wednesday as he stood outside the
federal courthouse in downtown Portland, where federal agents set off
explosives and fired chemicals into a crowd of hundreds," Marissa Lang
reports. "The Democratic mayor had strapped on lab goggles to help
protect his eyes, but still, the mayor said, his face burned and eyes watered.
'It's hard to breathe - it's a little harder to breathe than I thought,'
Wheeler told The Washington Post while a man with a leaf blower turned
the nozzle on the mayor to clear away any gas still hanging in the air. "This
is abhorrent. This is beneath us.' As Wheeler stood at the fence, he was
heckled and insulted. For hours before Wheeler's brush with chemical
irritants, the mayor made a contentious and, at times, tense attempt to talk
with protesters. On the wall of the justice center behind him, activists had
displayed a list of demands. The last demand on the list, which included
defunding the Portland Police Bureau by 50 percent and expelling federal
forces from the city, was for Wheeler to resign. After nearly an hour,
Wheeler had enough. A thick cloud of gas hung over the place where he
stood as he and two security officers pushed through the crowd and away
from the federal building."
The House voted to remove Confederate statues from the
Capitol.
The chamber also voted to "replace the bust of Roger B. Taney, the U.S.
chief justice who wrote the Supreme Court decision that said people of
African descent are not U.S. citizens," Felicia Sonmez and Donna Cassata
report. "The vote was 305 to 113 for the bill that would replace the bust of
Taney, which sits outside the old Supreme Court chamber on the first floor
of the Capitol, with one of Thurgood Marshall, the first black member of
the Supreme Court. Democrats were unified in backing the measure; all
the no votes came from Republicans, who were divided with 72 GOP
lawmakers voting for the bill and 113 opposed."
The GOP-controlled Senate is poised to defy Trump's veto threat and
force the renaming of 10 military bases that honor Confederate
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=== Page 14 ===
generals. The name changes are included in the $740 billion military
spending bill, a final version of which the Senate has yet to pass. But
the chamber voted yesterday to end the debate period for
amendments without taking up a measure from Sen. Josh Hawley (R-
Mo.) that sought to strip the legislation's requirement to rename the
bases. (Karoun Demirjian)
George Washington University will consider retiring the school's
"Colonials" moniker and renaming the campus's community center.
The center is named after Cloyd Heck Marvin, a former university
president credited with expanding the school but also known for being
a segregationist who resisted admitting black students. (Lauren
Lumpkin)
Trump announced a surge of federal law enforcement into
Chicago and Albuquerque.
"Appearing at an event with top federal law enforcement officials and the
family members of crime victims, Trump delivered fiery talking points that
took direct aim at those who have advocated redirecting funding from law
enforcement to other endeavors. He blamed the recent increases in
violence in some cities on leaders who have endorsed such steps and said
he planned to increase federal law enforcement's presence to reduce
crime," Matt Zapotosky reports. "Soon after he finished speaking,
Chicago's mayor accused Trump of seeking to distract from his handling of
the coronavirus pandemic. The deployments, at least at first, will be
focused in Chicago and Albuquerque, where Attorney General William P.
Barr said the Justice Department will roll out a program it launched earlier
this month in Kansas City, Mo., to increase the number of agents from the
FBI, the U.S. Marshals Service, the Drug Enforcement Administration and
the Bureau of Alcohol, Tobacco, Firearms and Explosives. The program
was named 'Operation Legend' to honor 4-year-old LeGend Taliferro, who
was shot and killed in Kansas City last month."
Barr falsely claimed that federal agents have already arrested 200
people in K.C. as part of "Operation Legend." A Justice Department
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=== Page 15 ===
later tried to clarify that his number included arrests dating back to
last year and included state and FBI arrests in other joint operations.
(Kansas City Star)
Philadelphia District Attorney Larry Krasner (D) said he's prepared to
arrest federal agents if they bring the tactics they've used in Portland
to his city. "Anyone, including federal law enforcement, who
unlawfully assaults and kidnaps people will face criminal charges
from my office," he said. (Bloomberg News)
The number of people trying to buy guns who are not legally allowed
to own them has more than doubled this spring, according to internal
FBI data. A year ago, in March, the FBI's National Instant Criminal
Background Check System ran background checks on 823,273
attempted gun buys, blocking about 9,500 people from buying guns.
This March, the system processed more than 1.4 million background
checks and blocked 23,692 gun sales. (Politico)
The fired Minneapolis police officer who put his knee on George
Floyd's neck was charged with felony tax evasion. Authorities allege
that Derek Chauvin failed to claim more than $460,000 in income -
at least $96,000 of that in his off-duty security work. (Star Tribune)
A Canadian court said sending asylum seekers back to the U.S.
violates their rights. The court "threw out a long-standing deal that
has allowed the country to send asylum seekers back to the United
States, saying it violates their rights by exposing them to likely
detention and possible removal on the U.S. side," Amanda Coletta
reports.
Charles Evers, brother of slain civil rights activist Medgar Evers, died
at 97. Charles picked up his brother's mantle by leading black voter
registration efforts in Mississippi in the 1960s. He was elected the first
black mayor of a mixed-race Mississippi town since Reconstruction.
(Olesia Plokhil)
The elections
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At least 76 percent of American voters can cast ballots by
mail this fall.
"As of now, nearly 180 million Americans who are eligible to vote would be
able to cast a ballot by mail. Of those, 22 million live in states that will
accept fear of the coronavirus as an excuse to vote absentee, or have
switched to become 'no excuse' states," Kate Rabinowitz and Brittany
Renee Mayes report. "Thirty-four states and the District of Columbia
already allowed anyone to vote absentee. But many of these places are
making the process easier. California will start proactively mailing ballots
to registered voters, joining universal vote-by-mail states such as Colorado.
Many states will send every registered voter an absentee-ballot application.
These types of statewide expansions affect another 63 million eligible
voters. In some states like Nebraska, individual counties are planning to
send mail-in voting applications in the absence of a statewide directive. For
voters in nine states - Connecticut, New York, Indiana, Kentucky,
Louisiana, Mississippi, South Carolina, Texas and West Virginia - in-
person voting remains the only option unless they can provide an approved
reason not related to fear of the coronavirus. Traditional absentee excuses
include military deployments or illness."
Republican lawmakers are privately having conversations
about what happens if Trump refuses to relinquish power.
"Most legal experts said it is hard to envision that Trump would actually try
to remain in office after a clear defeat by Biden, considering the uproar that
would follow," Elise Viebeck and Robert Costa report. "But his
unwillingness to commit to a smooth transition of power has forced
academics and political leaders - including, privately, some GOP
lawmakers - to contemplate possible scenarios. Among the possibilities:
Trump could claim victory before the vote in key states is fully counted - a
process that could take days or even weeks this year because of the
expected avalanche of absentee ballots. He could also spend weeks refusing
to concede amid a legal war over which votes are valid and should be
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=== Page 17 ===
included in the tally Or he could simply refuse to leave on Jan. 20.
This year, the president has attacked the security of voting by mail at least
50 times There is no evidence that mail voting leads to the kind of
massive fraud Trump has described.
"In GOP circles, private talk about Trump's assertions veers
from alarm to shrugging off his comments as simply incendiary
political salvos. One moderate Republican House member, who spoke
on the condition of anonymity to comment candidly and avoid Trump's
wrath, said he expects Trump to 'leave quickly' if it is a blowout defeat. But
he said he worries about a narrow election and whether Trump would go to
extreme lengths to 'protect his personal brand.' 'It's something we'd all
rather not think about, but it's there,' he said. The president is being
backed by a bustling Republican operation in 15 states to monitor voting
locations and ensure a heavy GOP presence at polling sites. Trump's
reelection campaign and the RNC are working together to
recruit 50,000 volunteers to serve as 'poll watchers,' according to
advisers to both groups, with $20 million set aside for courtroom fights
Democrats and voting rights advocates, meanwhile, are mustering their
own legal effort to make it easier to cast ballots by mail, filing more than 50
lawsuits in 25 states."
A new Quinnipiac University poll finds Biden leading Trump by one
point in Texas, 45 percent to 44 percent. Voters there say they like
Trump better, but they're seriously considering breaking for the
former vice president. (Aaron Blake)
Biden claimed that Trump is America's "first" racist president. That's
not correct: A dozen presidents owned slaves. Others like Woodrow
Wilson used racist language. And many others, think Andrew
Jackson, enacted racist policies. Trump's spokeswoman also insists
that he is not racist. (Colby Itkowitz and John Wagner)
Trump keeps bragging about passing a cognitive test, but it
doesn't mean what he thinks it does.
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"In another Fox News interview [last night], Trump couldn't resist
revisiting what he said was the hardest part of the test - repeating five
words, in order. Trump said he was first asked to repeat a set of words -
'person,' "woman," 'man,' 'camera,' "TV,' he said, offering a hypothetical
example - and then, later in the assessment after some time had elapsed,
he was again asked whether he remembered those same words, in order,"
Ashley Parker and William Wan report. "And they say... 'Go back to that
question, and repeat them. Can you do it?" Trump said, mimicking the
doctors administering the exam. 'And you go, 'Person, woman, man,
camera, TV.' They say, "That's amazing. How did you do that?' I do it
because I have, like, a good memory, because I'm cognitively there.'
Experts say the president's fixation on the Montreal Cognitive Assessment
is particularly puzzling because the test is normally administered
only if someone is concerned that they or their loved ones may
be experiencing dementia or other cognitive decline. Getting a perfect
score - as Trump has repeatedly claimed he did - merely signifies that the
test-taker probably does not have a cognitive impairment as measured by
the exam."
Senate primaries are exposing growing fissures inside the
GOP.
The Senate Leadership Fund formally took a side Wednesday in a
contested GOP primary for a candidate to succeed retiring Kansas Sen. Pat
Roberts (R). The super PAC's aim is to stifle the chances of former Kansas
secretary of state Kris Kobach. Kobach choked in a very winnable
governor's race two years ago. SLF, which is closely aligned with
McConnell and run by his former chief of staff, will launch a $1.2 million
ad campaign promoting Rep. Roger Marshall (R-Kan.) in the primary. The
primary in Tennessee to replace retiring Sen. Lamar Alexander is also
becoming nastier: The Trump-endorsed candidate, former U.S.
ambassador to Japan Bill Hagerty, launched attack ads this week against
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=== Page 19 ===
his main competitor, Manny Sethi, an orthopedic surgeon whom Ted Cruz
endorsed. (Seung Min Kim and Rachael Bade)
Trump's company applied to trademark the word "telerally."
Then Trump held one.
In an application to the trademark office, a subsidiary of the organization
said the word will be used for "organizing events in the field of politics and
political campaigning." The trademark application could mark a shift in the
company's business model, which has always stayed one step away from
politics and doesn't market itself as a political company. By filing it,
trademark experts said, the company is saying it intends to enter this
business soon. (David Fahrenthold and Colby Itkowitz)
Following weeks of erratic behavior by Kanye West, his
wife addressed his bipolar disorder.
Kim Kardashian West issued a statement requesting "compassion and
empathy" from the public, as the rapper claims that he's running for
president. "We as a society talk about giving grace to the issue of mental
health as a whole," the reality TV star wrote, "however we should also give
it to the individuals who are living with it in times when they need it most."
West held what was billed as a campaign rally in North Charleston, S.C., on
Sunday, during which he attacked abolitionist Harriet Tubman and
revealed that he and Kardashian had seriously considered terminating
their first pregnancy. "For the following two nights, West sent - and, in
most cases, deleted - tweets detailing a strained relationship with his
family," Sonia Rao reports. "He also stated that Kardashian tried to get him
medical attention and, later on, claimed he has been trying to divorce her."
Social media speed read
EFTA00025461

=== Page 20 ===
The president joined his eldest son in attacking Rep. Liz Cheney (R-Wyo.),
the No. 3 member of House GOP leadership and the highest-ranking
conservative woman in Congress:
The newest branch of the military had a meta message:
Trump's description of the coordinator of his coronavirus task force was
magical:
Videos of the day
Stephen Colbert was confused by Trump's message to Ghislaine Maxwell:
Seth Meyers said Trump is trying to convince America that he suddenly
cares about the virus:
The Congressional Black Caucus hosted a special session on the House
floor for members to remember the late Rep. John Lewis (D-Ga.):
EFTA00025462

=== Page 21 ===
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EFTA00025463


c1: EFTA00026690
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026690.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: "Avraham C. Moskowitz"
Subject: RE: congrats!
Date: Fri, 12 Jul 2019 00:24:32 +0000
Importance: Normal
Thanks very much, Avi © 0
From: Avraham C. Moskowitz
Sent: Thursday, July 11, 2019 5:59 PM
To:
Subject: congrats!
Heard you are handling the Epstein case. I know you will do a great job. Go get em, tiger. Save all of your
sympathy for my poor, misunderstood clients.
Avraham C. Moskowitz
Moskowitz & Book, LLP
345 Seventh Avenue
21st Floor
New York, N.Y. 10001
EFTA00026690


c1: EFTA00024662
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024662.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Subject: FW: GM supplemental pretrial motions
Date: Mon, 10 May 2021 13:19:19 +0000
Attachments: 2021-5-10_Gov't_Letter_re_Proposed_Trial_Date_v2_-_TAM.docx
Here are my edits (which are all just questions, since there may be obvious answers to these things that I just don't know).
From:
(USANYS)
Sent: Sunday, May 9, 2021 10:07 PM
To:
)
>;
Cc:
(USANYS)
>;
(USANYS)
is
is
Subject: RE: GM supplemental pretrial motions
Chiefs,
Attached for your review is a draft of the letter regarding the trial date, as well as the relevant orders.
Thanks,
From:
Sent: Saturday, May 8, 2021 2:42 PM
To:
Cc:
(USANYS)
is
(USANYS)
>;
i
(USANYS)
V.
Subject: Re: GM supplemental pretrial motions
Thanks
For planning purposes, we anticipate
would like to see our letter regarding the trial date on Monday before it's due,
so if you could get us a draft tomorrow evening or Monday morning that would be helpful. Thanks very much.
On May 8, 2021, at 1:44 PM,
)
wrote:
,
The defendant's supplemental pretrial motions (regarding the superseder) were filed yesterday, and I'm attaching the
brief here. The team is reviewing this weekend and will reach out early next week about our game plan for responding.
Our opposition is due on May 21ˢᵗ.
Thanks,
EFTA00024662

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
<!Memo ISO Supplemental Pretrial Motions.pdf>
EFTA00024663


c1: EFTA00026646
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026646.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Epstein bail hearing
Start Date: 2019-07-15 14:00:00 +0000
End Date: 2019-07-15 14:30:00 +0000
Organizer:
)
Location: 17B (Berman)
Class: X-PERSONAL
Date Created: 2019-07-08 20:52:55 +0000
Date Modified: 2019-07-08 20:52:55 +0000
Priority: 5
DTSTAMP: 2019-07-08 20:41:19 +0000
Attendee:
i
Alarm: Display the following message 15m before start
Reminder
EFTA00026646


c1: EFTA00025495
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025495.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "Kate L. Doniger"
To:
(USANYS)"
Cc:
)"
Alexandra Conlon
, Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Date: Thu, 30 Apr 2020 15:14:39 +0000
Hope you are keeping well. Thank you very much for this production. We have a few questions for you-are you available
tomorrow or next week to discuss? Please let us know what would be convenient for you. Thanks again,
Kate
Kate L. Doniger Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Tuesday, April 21, 2020 10:55 PM
To: Kate L. Doniger
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: [Not Virus Scanned] RE: Request for Information Relating to Jeffrey Epstein
This message has not been virus scanned because it contains encrypted or otherwise protected data. Please ensure you
know who the message is coming from and that it is virus scanned by your desktop antivirus software.
Kate,
Per our conversation earlier today, please find attached a letter responding to your request for information relating to
Jeffrey Epstein, as well as the set of documents identified in the letter. I will send the password for the document file
separately.
Thank you,
From: Kate L. Doniger
Sent: Wednesday, April 15, 2020 9:09 AM
To:
(USANYS)
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Thanks very much,
Kate L. Doniger Kaplan Hecker & Fink LLP
EFTA00025495

=== Page 2 ===
From:
(USANYS)
Sent: Wednesday, April 15, 2020 12:10 AM
To: Kate L. Doniger
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Kate,
Thank you for checking in. I hope you are keeping well also. I do not think we need any additional information from you at
this time. I hope to be able to provide an update early next week.
Thanks,
From: Kate L. Doniger
Sent: Tuesday, April 14, 2020 3:01 PM
To:
(USANYS)
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
We hope that you are keeping well in this very challenging time.
We completely understand that all things are in flux these days, but we just wanted to check in with you about our
request and whether there is any other information you need from us. If it would be helpful to set up a call to discuss, we
are available at your convenience.
Best,
Kate
Kate L. Doniger I Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Thursday, February 27, 2020 7:23 PM
To: Alexandra Conlon
>; Roberta Kaplan
Cc: Kate L. Doniger
is
Subject: RE: Request for Information Relating to Jeffrey Epstein
Alexandra and Robbie,
Thank you for this. I will contact you regarding the request.
EFTA00025496

=== Page 3 ===
Thanks,
From: Alexandra Conlon
Sent: Tuesday, February 25, 2020 7:54 PM
To:
(USANYS)
>; Roberta Kaplan
Cc: Kate L. Doniger
is
Subject: RE: Request for Information Relating to Jeffrey Epstein
SENT ON BEHALF OF ROBERTA KAPLAN
AUSA
Thank you for contacting us. Attached please find a Touhy letter and supporting exhibit requesting documents from the
Department of Justice in connection with our pending litigation against Jeffrey Epstein's estate.
We are happy to schedule a time to talk if it would be helpful to discuss our request.
Best Regards,
Robbie
Alexandra Conlon Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Monday, January 6, 2020 6:59 PM
To: Roberta Kaplan
Cc: Kate L. Doniger
>; Alex Conlon
Subject: Request for Information Relating to Jeffrey Epstein
Dear Ms. Kaplan,
Please find attached a letter regarding the request you discussed with AUSA
for certain information
relating to Jeffrey Epstein. As stated in the letter, please contact me once you have had a chance to review the letter if you
would like to discuss the issues therein further.
Thanks,
Assistant United States Attorney
Southern District of New York
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00025497

=== Page 4 ===
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00025498


c1: EFTA00026580
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026580.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Accepted: Call w/ DOJ re. Epstein SDNY Investigation
Date: Mon, 05 Oct 2020 14:20:46 +0000
Importance: Normal
Attachments: unnamed
EFTA00026580


c1: EFTA00023977
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023977.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
90A-NY-3151227 Serial 7
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Evidence
Date: 08/14/2019
NYC023581
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) MCC-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Evidence NYC023581: One (1) Seagate Barracuda 500GB
HDD, ST3500320NS, S/N 9QM8MT9P, from MCC Nice Vision DVR2 Surveillance
System (4 of 18).
Item Type
Description
1B Digital
(U) NYC023581: One (1) Seagate Barracuda 500GB HDD,
ST3500320NS, S/N 9QM8MT9P, from MCC Nice Vision DVR2
Surveillance System (4 of 18).
Collected On: 08/10/2019 04:30 PM EDT
Seizing Individual:
Located By:
Device Type: Hard Drive
Designation: Original
Number of Devices Collected: 1
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00023977


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023505.pdf
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c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
)"
Subject: FW: Maxwell testifying witness folder
Date: Wed, 07 Jul 2021 02:59:49 +0000
Attachments: 2007-08-
10_INVESTIGATIVE_CASE_MANAGEMENT_COLLECTED_ITEMS_FOR_A_CASE_0
8_10_2007.pdf; 2006-09-
06_DESCRIPTION_OF_PROPERTY_LOG_REGARDING_EPSTEIN,_JEFFREY
.pdf
We already produced these in Rule 16 discovery, but I figure it makes sense to pull these and produce them as part of
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:
is
(USANYS)
is
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,
EFTA00023505


c1: EFTA00025059
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025059.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Nicole Simmons
To: 'Nathan NYSD Chambers'
Cc: Jeff Pagliuca
,
Laura Menninger
"
"
'''
"
Subject: [EXTERNAL] U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Response to
Government's Omnibus Motions in Limine]
Date: Tue, 26 Oct 2021 03:49:44 +0000
Attachments: 2021.10.25_Maxwell's_Respons_to_Government's_Omnibus_Motions_in_Limine.zip
Inline-Images: image001.jpg
Dear Judge Nathan:
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Response to the Government's Omnibus Motions in
Limine and supporting documents.
Regards,
Nicole Simmons
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
Denver, Colorado
www.hmflaw.com
EFTA00025059


c1: EFTA00024487
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024487.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Epstein - travel approval form
Date: Fri, 06 Mar 2020 15:30:33 +0000
My chiefs talked with me yesterday about the status of this and I was wondering if I could stop by very briefly when you
have a free moment, just to complete the loop? Thanks!
From:
Sent: Tuesday, February 04, 2020 14:13
To:
Subject: RE: Epstein -- travel approval form
Totally understand - no worries and we'll link up when you're able.
From:
Sent: Tuesday, February 04, 2020 14:12
To:
Subject: Re: Epstein -- travel approval form
Got it. I'm so sorry - tied up with Geoff.
Sent from my iPhone
On Feb 4, 2020, at 2:10 PM,
wrote:
I'm going to make some calls so if I don't pick up when you call, that's why, but I'm here and will get off the phone
and come down whenever you're available.
thanks,
From:
)
Sent: Tuesday, February 04, 2020 13:02
To:
Subject: Re: Epstein -- travel approval form
No problem, I'm around whenever you're back.
On Feb 4, 2020, at 12:44,
wrote:
I may run late. Don't come till I call!
Sent from my iPhone
EFTA00024487

=== Page 2 ===
On Feb 3, 2020, at 5:45 PM,
wrote:
That works, thanks - just let me know if your schedule changes, otherwise l'll come by at 1:00 tomorrow. Thanks
again and looking forward to it.
From:
Sent: Monday, February 03, 2020 16:07
To:
Subject: RE: Epstein -- travel approval form
Right now 1 p.m. looks open.
From:
Sent: Monday, February 3, 2020 1:33 PM
To:
Subject: RE: Epstein -- travel approval form
No problem at all, and I'm very flexible tomorrow afternoon - whatever time is good for you I can make work, so just
let me know and l'll put it in the calendar.
From:
Sent: Monday, February 03, 2020 13:31
To:
Subject: RE: Epstein -- travel approval form
So sorry for the delay. Maybe tomorrow? I have time in the afternoon.
From:
Sent: Friday, January 31, 2020 1:09 PM
To:
Subject: RE: Epstein -- travel approval form
Totally understand, and next week would be fine - let me know if it's helpful to set a time, and otherwise l'll touch
base midweek if we haven't connected by then.
And thanks very much re: the memo.
From:
Sent: Friday, January 31, 2020 12:53
To:
Cc:
Subject: RE: Epstein -- travel approval form
Already signed and sent upstairs
I will do my best to ensure signature immediately.
EFTA00024488

=== Page 3 ===
Re: this afternoon: it may be best to kick it to next week. If some time develops before 3, I'll let you know, but right
now it is iffy.
From:
Sent: Friday, January 31, 2020 12:21 PM
To:
Cc:
Subject: Epstein -- travel approval form
We dropped off the Sweden travel memo for you - we were unexpectedly significantly delayed in getting OIA
approval, but it finally came this morning, so with apologies for the short turnaround, hoping to get Office and final
DOJ approval this afternoon. Thank you!
And separately, if you still wanted to meet up today, I'll be around until about 3:00, but I'm also flexible next week if
that's easier.
thanks again,
Assistant
Attorney
Southern District of New York
EFTA00024489


c1: EFTA00024741
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024741.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
Cc:
"
Bcc: "USAHUB-USAJournal111"
Subject: Re: United States V. Maxwell
Date: Tue, 27 Oct 2020 01:40:57 +0000
Embedded: Re:_United_States_v_Maxwell.msg
Sender:
Subject: Re: United States V. Maxwell
Message-Id: <1D4D5972-F131-497C-85D7-507D045D0B35@usa.doj.gov>
To:
Cc:
EFTA00024741


c1: EFTA00025101
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025101.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject
proffer (re abuse)
Date: Wed, 27 Nov 2019 16:35:47 +0000
Importance: Normal
Attachments: unnamed
EFTA00025101


c1: EFTA00024824
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024824.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
15JA5418F00000299/P00005 Page 1 of 4
1. CONTRACT ID CODE
AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT
GS-25F-0131M
2. AMENDMENT/MODIFICATION NUMBER
3. EFFECTIVE DATE
4. REQUISITION/PURCHASE REQUISITION NUMBER
5. PROJECT NUMBER (If
P00005
applicable)
07/11/2019
See Lines
6. ISSUED BY
CODE
15JA54
7. ADMINISTERED BY (If other than Item 6)
CODE
U.S. Attorneys Office Southern District of New York
8. NAME AND ADDRESS OF CONTRACTOR (Number, street, country, state and ZIP Code)
(X)
9A. AMENDMENT OF SOLICITATION NUMBER
CACI, INC. - COMMERCIAL
ATTN CONTRACTS ADMIN. SAM ONLY
9B. DATED (SEE ITEM 11)
10A. MODIFICATION OF CONTRACT/ORDER
DUNS: 030261817
NUMBER
15JA5418F00000299
10B. DATED (SEE ITEM 13)
X
CODE 541008297
FACILITY CODE 030261817
09/10/2018
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS
The above numbered solicitation is amended as set forth in Item 14. The hour and date specified for receipt of Offers
is extended,
is not extended
Offers must acknowledge receipt of this amendment prior to the hour and date specified in the solicitation or as amended, by one of the following methods: (a)
By completing items 8 and 15, and returning
copies of the amendment; (b) By acknowledging receipt of this amendment on each copy of the
offer submitted: or (c) By separate letter or electronic communication which includes a reference to the solicitation and amendment numbers. FAILURE OF YOUR
ACKNOWLEDGMENT TO BE RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY
RESULT IN REJECTION OF YOUR OFFER. If by virtue of this amendment you desire to change an offer already submitted, such change may be made by letter or
electronic communication, provided each letter or electronic communication makes reference to the solicitation and this amendment, and is received prior to the opening
hour and date specified.
12. ACCOUNTING AND APPROPRIATION DATA (If required)
USA-2018-0322ADIR-JC2-NYS-USA-DIR-25107-2598-2018
13. THIS ITEM APPLIES ONLY TO MODIFICATIONS OF CONTRACTS/ORDERS.
IT MODIFIES THE CONTRACT/ORDER NUMBER AS DESCRIBED IN ITEM 14.
CHECK ONE
A. THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT
ORDER NUMBER IN ITEM 10A.
B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes in paying office,
appropriation date, etc.) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b).
C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF:
D. OTHER (Specify type of modification and authority)
X
FAR 52.232-7, Payments under Time-and Materials and Labor-Hour
E. IMPORTANT: Contractor
X
is not,
is required to sign this document and return copies to the issuing office.
14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, including solicitation/contract subject matter where feasible.)
R19NYS18006 / R18NYS17044
PDF file management services to the USAO, SDNY
Modification to add additional task request and add funds of
See Statement of Work for details
Original Contract Obligation: $
Increase Obligation:
Net Contract Obligation
Except as provided herein, all terms and conditions of the document referenced in Item 9A or 10A, as heretofore changed, remains unchanged and in full force and effect.
15A. NAME AND TITLE OF SIGNER (Type or print)
16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
Nick Siu
15B. CONTRACTOR/OFFEROR
15C. DATE SIGNED
16B. UNITED STATES OF AMERICA
16C. DATE SIGNED
(Signature of person authorized to sign)
By
(Signature or Contracting Officer)
07/11/2019
Previous edition unusable
STANDARD FORM 30 (REV. 11/2016)
Prescribed by GSA FAR (48 CFR) 53.243
EFTA00024824

=== Page 2 ===
15JA5418F00000299/P00005 Page 2 of 4
Section 2 - Commodity or Services Schedule
R18NYS17044 / R19NYS18006
Period of Performance: 9/10/2018 - 9/9/2019
See Statement of Work
Regan Anderson, CACI Contracts Administrator
SCHEDULE OF SUPPLIES/SERVICES
CONTINUATION SHEET
ITEM NO.
SUPPLIES/SERVICES
QUANTITY
UNIT
UNIT PRICE
AMOUNT
0001
AS
JB
0002
JB
0003
JB
0004
JB
0005
IT
JB
0006
U.S. V. Epstein, PDF file management project AUSA
Previous:
Previous:
Previous: $0.00
19-CR-00490 / 2018R01618
0.000000
$0.0000
Change: $
Line Period of Performance: 09/10/2018 - 09/09/2019
EFTA00024825

=== Page 3 ===
15JA5418F00000299/P00005 Page 3 of 4
Change: 1.000000
Change:
Current: $
Current: 1.000000
$
Current:
$
PREVIOUS TOTAL
CHANGE
CURRENT TOTAL
FUNDING DETAILS:
ITEM
FUNDING LINE
OBLIGATED AMOUNT
ACCOUNTING CODES
NO.
N/A
1
N/A
2
2-3 Specifications/Work Statement
EFTA00024826

=== Page 4 ===
15JA5418F00000299/P00005 Page 4 of 4
For the rest of the documents, separate the documents based on logical document determination. Name each
document in a format to be provided by the USAO.
Place the 66 folders with their associated documents and index on contractor FTP site for retrieval by the
USAO-SDNY.
EFTA00024827


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Subject: Accepted: Call re Epstein FOIA case
Date: Fri, 04 Jun 2021 12:52:39 +0000
Importance: Normal
Attachments: unnamed
EFTA00025216


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c3: VOL00008
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=== Page 1 ===
Event: Accepted: Gov't reply to Epstein bail motion due
Start Date: 2019-07-12 21:00:00 +0000
End Date: 2019-07-12 21:30:00 +0000
Organizer:
)
Location: Berman
Class: X-PERSONAL
Comment:
Date Created: 2019-07-10 05:55:53 +0000
Date Modified: 2019-07-10 05:55:53 +0000
Priority: 5
DTSTAMP: 2019-07-10 05:49:57 +0000
EFTA00026648


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c3: VOL00008
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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: Revised letter
Date: Tue, 12 Oct 2021 23:22:49 +0000
Attachments: Joint_proposed_Maxwell_Trial_Length_Letter_-_Revised.docx
I know you have your 7:30 call. If you have a moment to look before then, l'll send this to the chiefs and then to the
defense in the meantime.
EFTA00026699


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Epstein update
Date: Sat, 10 Aug 2019 16:31:48 +0000
Hi all,
Who is his lead counsel? The Warden is preparing the formal letter for the Court, in which your office, the USMS, USPO, and
lead counsel are cc'ed. Do you have an email address for him/her?
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
New York, New York 10007
>>>
>
8/10/2019 11:30 AM >>>
It is frankly unbelievable to me that BOP is issuing public press releases on this before telling us basic information so that we
can relay it to his attorneys who can relay it to his family. When can we expect to get either some sort of statement we can
pass along to counsel as accurate and reliable or have a call with someone?
I understand from the Marshals that they have been unsuccessful in reaching anyone with authority at BOP, and given the
BOP press release that was just put out I assume we need to speak with someone there. Please advise.
Thank you.
On Aug 10, 2019, at 10:43,
> wrote:
As you might imagine, we are getting increasingly frantic calls from defense counsel who continue to be seeing information
in the press that we-the U.S. Attorney's Office-haven't yet received. We need to know as soon as possible the very basic
facts, such as time and cause of death at the absolute minimum. It has now been hours since this was reported publicly.
Please advise when we can expect to receive either a written report on those basic facts or when we can have a call to get
that information to relay to his counsel. It is extraordinarily frustrating to have to tell them that we have less information
than the press. Please advise.
Thank you,
EFTA00024352

=== Page 2 ===
On Aug 10, 2019, at 08:46,
> wrote:
Passed away. We are completing a significant incident report for HQ for Death of a Federal Inmatehowever, I do not
have any specifics from the BOP yet.
From:
Sent: Saturday, August 10, 2019 8:44 AM
To:
>
Cc:
is
Subject: Re: Automatic reply: Epstein update
Thank you for telling us. What do you mean by "passed"?
Thanks,
Sent from my iPhone
On Aug 10, 2019, at 8:18 AM,
wrote:
BOP just provided another update- Epstein has passed. I have no additional info. I will push out updates as we
receive.
From:
)
Sent: Saturday, August 10, 2019 7:52 AM
To:
Subject: Re: Automatic reply: Epstein update
FYI:
The BOP just informed us that Epstein is being taken by ambulance to the hospital from another apparent suicide
attempt- no other information was provided.
They will update us as more info becomes available.
On Aug 10, 2019, at 7:26 AM,
wrote:
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses
may be delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
at
or
EFTA00024353


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=== Page 1 ===
From:
To:
BOBBI C STERNHEIM
,
Cc: Christian Everdell
>, , "Mark S. Cohen"
Bcc:
Subject: Re: Ghislaine Maxwell 02879-509
Date: Thu, 07 Jan 2021 17:05:43 +0000
Embedded: Re:_Ghislaine_Maxwell_02879-509.msg
Sender:
Subject: Re: Ghislaine Maxwell 02879-509
Message-Id: <5FF73F5D020000920008C205@SMTP1.BOP.GOV>
Recipient:
EFTA00024887


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=== Page 1 ===
Event: Call w/ SDNY re: discovery, Epstein investigation
Start Date: 2020-10-23 15:00:00 +0000
End Date: 2020-10-23 15:30:00 +0000
Organizer:
)
Location:
Class: X-PERSONAL
Date Created: 2020-10-22 16:53:21 +0000
Date Modified: 2020-10-22 16:53:21 +0000
Priority: 5
DTSTAMP: 2020-10-22 16:34:21 +0000
Attendee:
i
(USANYS)
i
(NYPD)
i
(NY)
(FBI)
Alarm: Display the following message 15m before start
Reminder
EFTA00025512


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Re: Tartaglione Taint Team Question
Date: Wed, 21 Apr 2021 23:51:33 +0000
Sent from my iPhone
On Apr 21, 2021, at 7:04 PM,
(USANYS)
wrote:
Thanks,
Assistant United States Attorney
300 Quarropas Street
White Plains, NY 10601
Telephone:
<US V Tartaglione, ECF 119.pdf>
EFTA00025173


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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein Image/Video File Review Protocol
Date: Mon, 19 Oct 2020 22:07:25 +0000
Importance: Normal
Attachments: unnamed
EFTA00024733


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=== Page 1 ===
From:
"
To:
Subject: FW: reminder -- monthly updates
Date: Thu, 03 Sep 2020 16:33:15 +0000
Attachments: PC_Unit__Short_Form_Update.9.4.20.docx
Attached, no need to take a look, but giving you the option!
From:
Sent: Thursday, September 3, 2020 11:35 AM
To:
Cc:
Subject: reminder -- monthly updates
Tomorrow is the first Friday of September. That means, updates are due to
Thanks, as always.
Chief, Criminal Division
United States Attorney's Office, SDNY
EFTA00026710


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=== Page 1 ===
"I"
JIIUS
"ill
July 16 2019
out
cellie Centire time)
Regular
Gaunds in SHU
Moming - "G"
would know by face
M/W/F showers 3 only would
any other time would have to yell to get
something
they do counts when wanted - not
regular counts like who he knew frompast
to set into as would have to call to
be let in
laundry mat
described what he remembered about
layat of SHU and MCC
96 people in SHU /48 cells
checks
aften=incident"
tribuing hirse
remamber/wake up when
midnight /3am /5am
don't remember them actualleing
Guards
EFTA00025264

=== Page 2 ===
don't know name act knows in news
peple/imates would yell things
about him
CO
would make fun of him -
bey freedom
always would be wl lowyer -
so would hold up other inmates
to see attorney
collnate of guy
used to be P.O.
incident 1:30a/1:30a no check
a
midnight
reading book
hear 00
guiscell everyone/inmates mate - screamine/bane,ing for CO.
could see guys door - right accross
but couldn't see
C.
hase than 5 min to come to area
had no Key
went to Get Key
came back
down will
2 C.O.s
6'3"
260/270
Black
EFTA00025265

=== Page 3 ===
yes
prex
heard a theemp like something hit floor
could see hends stretched out
CO.S pulled out of cell/face-down
looked blue -looked dead
no CPR - COs just lookine him -
doctor
put on floor and pickeds geel 1
dropped gew and hit ground on stretcher
all inmates start screaming + nitting
cloars when dropped
on his face
had to flip him over
dropped on again nis gleed
only wearing underwear
took him away
+ Lt.
COs then talked about camel back
took &
A
and deared cell
with Campra off(0) leacefter takente had out may again
turned
6
Lt. had the videamera
2 sodes t towel -tied together
orange one
started f.lmine/carrin after cleaned
out cell
cell mate was sleeping said thought died -tried to
hargenladder of bed
killself
EFTA00025266

=== Page 4 ===
afferidat
inging
brought phone to make call - didn't have to
wait
would flashlights start doing more checks Wl
buards
4 12 5
5
would usually
be asleep during
2 guy hea has
3am check
Suicide watch
Tues well ed Fri 20th
119 m Tier
123 - incident
heard gargeling
app 120a/130 incident
cancemera wr
2:10/2:10
shown
pictures
I — No washere
# 2 - worked in SHU but notthere that night
EFTA00025267


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 10621156(1) approved by
now awaiting further approval
Date: Wed, 25 Sep 2019 18:49:26 +0000
Importance: Normal
Dear
Final voucher 10621156(1) has been approved by
now awaiting further approval.
Trip ID: 10621156
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R19NYS13832 - U.S. V. Epstein (2018R0618) - Victim Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-09-09 - 2019-09-10
Current status: Pending Voucher Approval
Voucher total expenses: 720.32
Estimated trip cost: 910.73
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0010
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00025340


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=== Page 1 ===
From:
)"
To:
)"
Subject: FW: Epstein NY property
Date: Thu, 16 Jul 2020 14:05:02 +0000
works for me
From: Weinstein, Marc A.
Sent: Thursday, July 16, 2020 10:04
To:
is
)
>;
Cc:
Subject: Epstein NY property
Would you have time for a call today for an update on the NY property? If so, would something between 1:00-1:45 work?
Thanks,
Marc
Marc A. Weinstein Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
I
New York, NY 10004-1482
Office
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
EFTA00024500


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=== Page 1 ===
From:
(OAG)"
To: "Berman, Geoffrey (USANYS)"
Subject: Senate letter
Date: Sun, 11 Aug 2019 13:26:42 +0000
Attachments: 08-10-2019--sasse-letter-to-ag-barr-re-epstein-suicide.pdf; ATT00001.htm
Geoff: Please see question 4 in the attached letter. I'm not sure exactly what he's asking but can you please
provide a preliminary response to Question 4.
Thanks.
EFTA00023979


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=== Page 1 ===
Mod AO 442 (09/13) Arrest Warrant AUSA Name & Telno:
UNITED STATES DISTRICT COURT
for the
Southern District of New York
United States of America
V.
)
)
Case No.
)
)
)
Ghislaine Maxwell
)
Defendant
ARREST WARRANT
To:
Any authorized law enforcement officer
YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
(name of person to be arrested) Ghislaine Maxwell
,
who is accused of an offense or violation based on the following document filed with the court:
Indictment
Superseding Indictment
Information
Superseding Information
Complaint
Probation Violation Petition
Supervised Release Violation Petition
Violation Notice
Order of the Court
This offense is briefly described as follows:
Title 18, United States Code, Section 371 (conspiracy to entice minors)
Title 18, United States Code, Sections 2422 and 2 (enticement of a minor)
Title 18, United States Code, Section 371 (conspiracy to transport minors)
Title 18, United States Code, Sections 2423(a) and 2 (transportation of a minor)
Title 18, United States Code, Section 1623 (perjury)
Lisa Margaret Sun
Date:
06/29/2020
Issuing officer's signature
City and state:
White Plains, NY
Hon. Lisa Margaret Smith, U.S. Magistrate Judge
Printed name and title
Return
This warrant was received on (date)
, and the person was arrested on (date)
at (city and state)
Date:
Arresting officer's signature
Printed name and title
EFTA00026523


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=== Page 1 ===
From:
To:
Cc:
Subject: US V. Maxwell, 20 Cr. 330 (AJN)
Date: Tue, 26 Oct 2021 02:31:11 +0000
Attachments:2021.10.25_Maxwell_Discovery_Letterpdf,202110.25_Maxwell_Cover_Letter_Final.pdf;
2021.10.25_U.S._v_Ghislaine_Maxwell_3500_Index_(Defense_Copy).pdf
2021.10.25_U.S._v_Ghislaine_Maxwell_Non-
Testifying_Witness_Material_(Defense_Copy).pdf
Counsel,
We have an additional discovery production ready to send to you. Attached please find the accompanying cover letter.
The production will be made via USAfx.
In additional, a supplemental production of testifying witness and non-testifying witness material is also ready to send to
you. Attached please find the accompanying cover letter and indices. The production will be made via USAfx.
We will send a CD with the materials to the MDC for Ms. Maxwell. If you would prefer that she receive the production on
a drive, we can either request that the MDC send us one of the drives back to load with the production, or we can load a
new drive if you would like to provide us with one.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00025057


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=== Page 1 ===
From: AAG Legal Request For Information <LegalRFI@alaskaair.com>
Sent: Thursday. February 13, 2020 9:04 PM
To:
(NY) (FBI)
Subject: Fed GJ SBP 2020-01-23- Maxwell-
SA
Please be advise that Alaska Airlines has no responsive records for the above mentioned subpoena,
for the specific time frame requested.
Best regards,
AS Legal RFI Team
EFTA00023821


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=== Page 1 ===
From:
(USANYS)"
To:
BOBBI C STERNHEIM
, Laura Menninger
, Jeff Pagliuca
Cc:
)"
)"
)"
Subject: US V. Maxwell - Government Letter Due Today
Date: Mon, 07 Jun 2021 21:19:58 +0000
Attachments: 2021-06-07_GM_letter_update_re_MDC_conditions_final.pdf
Counsel,
Our update letter to the Court regarding MDC conditions is due today. Can you please let us know by 8:30 pm if you
intend to seek any redactions to the attached letter? If so, we will plan to send the letter by email to the Court to give you
an opportunity to propose and justify any redactions.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00025218


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: Re: Epstein catch up
Date: Sun, 17 Nov 2019 17:42:35 +0000
I have to head up to CLS at 530 on Monday, so unfortunately it doesn't look like any of those times work for the
team.
Sent from my iPhone
On Nov 17, 2019, at 12:25 PM,
)
wrote:
I'm in White Plains all day Wednesday. Monday 5:30 would work for me.
On Nov 17, 2019, at 11:47 AM,
)
wrote:
Wednesday morning okay for you both?
Sent from my iPhone
Begin forwarded message:
From:
(USANYS)"
Date: November 16, 2019 at 21:18:48 EST
To:
)"
)"
)"
Cc:
(USANYS)"
Subject: Epstein catch up
Can we find a time in the near future to catch up on a few things, including hearing more about your
interview last week? Unfortunately both
and I have to be out portions of Monday/Tuesday. Would
Monday at 530 work for you guys? If not, can we aim for Wednesday morning. Thanks
Sent from my iPhone
EFTA00025081


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 172 Filed 03/24/21 Page 1 of 3
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 3/24/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
On March 5, 2021, Defendant Ghislaine Maxwell submitted to the Court an application
for an order authorizing a subpoena pursuant to Rule 17(c)(3) of the Federal Rules of Criminal
Procedure. The proposed subpoena was directed at a law firm that represents alleged victims of
the Defendant. As is standard for Rule 17(c) subpoenas, the application was made ex parte and
under seal on the ground that it reveals defense strategy. See e.g., United States V. Skelos, No.
15-CR-317 (KMW), 2018 WL 2254538, at *8 (S.D.N.Y. May 17, 2018), aff'd 988 F.3d 645 (2d
Cir. 2021); United States V. Wey, 252 F. Supp. 3d 237, 243 (S.D.N.Y. 2017); United States V.
Earls, No. 03-CR-0364 (NRB), 2004 WL 350725, at *6 (S.D.N.Y. Feb. 25, 2004); United States
V. Reyes, 162 F.R.D. 468, 470 (S.D.N.Y. 1995).
Rule 17(c)(3) provides that "[a]fter [an indictment] is filed, a subpoena requiring the
production of personal or confidential information about a victim may be served on a third party
only by court order," but "before entering the order and unless there are exceptional
circumstances, the court must require giving notice to the victim so that the victim can move to
quash or modify the subpoena or otherwise object." Fed. R. Crim. P. 17(c)(3). Consistent with
the Rule, on March 12, 2021, in a sealed ex parte Order, the Court required defense counsel to
provide notice to alleged victims whose personal or confidential information may be disclosed
1
EFTA00024166

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 172 Filed 03/24/21 Page 2 of 3
by the proposed subpoena. The Court also gave the alleged victims an opportunity to object to or
request modifications of the subpoena as required by Rule 17(c)(3).
On March 19, 2021, the Court received a letter from the law firm indicating that it can
provide notice to alleged victims whose personal or confidential information may be elicited by
the subpoena. The law firm shall provide notice to any such alleged victims it represents.
In that letter, the law firm also interposed substantial objections on behalf of the law firm
and the alleged victims it represents. Those objections are functionally the equivalent of a
motion to quash, even though the subpoena has not yet issued. So that the Court can receive
adversarial briefing on the proposed subpoena comparable to a motion to quash, the law firm
shall enter an appearance and file its objections on the public docket. See United States V. Ray,
No. 20-CR-110 (LJL), 2020 WL 6939677, at *10 (S.D.N.Y. Nov. 25, 2020) ("[I]f the Court
determines that the subpoena calls for personal or confidential information about a victim, it
requires the requesting party have given notice to the victim before it permits the service of the
subpoena. If the victim objects, the Court will then determine whether to modify or quash the
subpoena, including on grounds that Nixon was not satisfied.").
In advance of noticing an appearance and filing, the law firm shall meet and confer with
defense counsel to see if any issues can be narrowed before formal briefing. Moreover, prior to
filing, the law firm shall confer with defense counsel as to any proposed, necessary, and tailored
redactions to the objections. The law firm's objections with any proposed redactions shall be
filed on or before March 26, 2021. Any redactions must be justified consistent with Lugosch V.
Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Within one week of the filing of
objections, defense counsel may respond to the subpoena objections. The law firm may reply
2
EFTA00024167

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 172 Filed 03/24/21 Page 3 of 3
within three days of the Defendant's response.¹ Counsel shall confer regarding any proposed
redactions for all briefing.
so ORDERED.
Alim D. Netto
Dated: March 24, 2021
New York, New York
ALISON J. NATHAN
United States District Judge
I All filings must be double-spaced and in 12-point font with 1-inch margins.
3
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=== Page 1 ===
From:
To:
Subject: Re: JE estate meeting
Date: Sat, 21 Dec 2019 00:52:36 +0000
: )
Sent from my iPhone
On Dec 20, 2019, at 19:43,
wrote:
Ah, sorry, just saw this.
On Dec 20, 2019, at 5:22 PM,
wrote:
I'm sorry - my colleagues remind me that this is inaccurate, defense counsel returned and/or destroyed
discovery materials, pursuant to the protective order, following Epstein's suicide. So they won't be able to provide
discovery materials. However, I believe they should separately have copies of the search warrant inventories which
were of course provided separate from the protective order; if they don't, please let us know, and again we'll continue
to try to figure out what if any obligations / restrictions we are subject to on the copies of inventory records that we
have. Apologies for the confusion.
From:
Sent: Friday, December 20, 2019 17:17
To:
Cc:
Subject: RE: JE estate meeting
We're not yet exactly sure what our ability is to provide to the Trustees what is effectively discovery in a now-defunct
criminal case against Epstein himself; that said, I can convey that we did produce to defense counsel detailed search
warrant returns in connection with the New York property. Perhaps you would be able to obtain those from Epstein's
criminal defense counsel? In particular I believe what you're looking for would be especially at USAO_4381-4445, but
potentially also USAO_2662-4380 (though I note that a handful of those pages were marked as Confidential under a
protective order, as set forth in the discovery letter sent to counsel on July 31, 2019). We will also review the status of
the search warrant return with respect to the island property (and we have not searched the New Mexico property),
and I hope this is useful in the interim.
Separately, I've conveyed your request for a meeting to discuss the possibility of resolving the Government's potential
forfeiture claims, and I haven't yet gotten a response to relay but will let you know as soon as I do (and will also
provide these dates in connection with your request).
thanks,
EFTA00024507

=== Page 2 ===
From:
Sent: Thursday, December 19, 2019 19:09
To:
Cc:
Subject: JE estate meeting
To follow up on our call, can you please send us the search warrant returns/inventories and, if possible, any additional
detail regarding the items that were seized in the two searches of the New York property and the search of the New
Mexico property.
With respect to a next meeting with you and the Chief of the Criminal Division and, of course, any other colleagues
you wish to attend, the following dates in early January would be good for us:
January 3, 6 (before 2:00), 7, 8 (1:00 or later), 9 (after 11:00), or 10
Happy and Healthy New Year from Andy and me.
Partner
Co-Chair, White Collar Defense
New York, NY 10004-1482
Office
Cell
Fax
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this
e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of
this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
EFTA00024508


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=== Page 1 ===
From:
To:
Cc:
Subject: Amended Application for Second Warrant
Date: Tue, 30 Jun 2020 20:39:23 +0000
Attachments: Application for Second Warrant & Order (Maxwell Exhibit_C
2020.06.29_Application_for_Maxwell_GPS_Combo.pdf;Exhibit D -
_2020.06.29_Maxwell_GPS_Combo_Warrant.pdf; Exhibit -
Maxwell_signed_indictment.pdf;_Exhibit_B_-_Maxwell_arrest_warrant_signed.pdf
Dear Judge Parker,
Attached for the Court's consideration, please find an amended application and amended affidavit in support of a second
warrant and order. As detailed in the amended application and amended affidavit, this afternoon,
realized
that she had inadvertently included two errors in the affidavit submitted to Your Honor yesterday. Accordingly, the
Government respectfully submits these amended materials and requests the issuance of a second warrant and order.
If at all possible, we would be extremely grateful if the agent could please swear out this warrant today. I can be reached
at
,
and the agent can be available at any time convenient for the Court. We apologize for the error and the
inconvenience.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00026524


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=== Page 1 ===
90A-NY-3151227 Serial 33
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Derivative
Date: 08/16/2019
Evidence NYC027706
Approved By: SSA
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S);
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) CART-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Derivative Evidence NYC027706: One (1) Seagate
Barracuda 1000GB Hard Drive, model ST1000DM003, S/N W1D48YH6, containing
the Clone Copy of 1B7 hard drive (Seagate Constellation ES 500GB,
ST500NM0011, S/N Z1M1PZPE), collected via Tableau TD3-B, S/N 11D350F0-
1525. Request ID 112048. Derivative Copy.
Item Type
Description
1B Digital
(U) NYC027706: One (1) Seagate Barracuda 1000GB Hard
Drive, model ST1000DM003, S/N W1D48YH6, containing the
Clone Copy of 1B7 hard drive (Seagate Constellation ES
500GB, ST500NM0011, S/N Z1M1PZPE), collected via Tableau
TD3-B, S/N 11D350F0-1525. Request ID 112048. Derivative
Copy.
Collected On: 08/12/2019 07:00 PM EDT
Seizing Individual:
Collected By:
Device Type: Hard Drive
Designation: Derivative
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00025431

=== Page 2 ===
90A-NY-3151227 Serial 33
UNCLASSIFIED
Title: (U) Submission of CART Derivative Evidence NYC027706
Re: 90A-NY-3151227, 08/16/2019
Number of Devices Collected: 1
UNCLASSIFIED
2
EFTA00025432


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=== Page 1 ===
From:
To:
Subject: RE:
)
- Epstein
Date: Mon, 17 May 2021 23:26:17 +0000
Attachments:
5.14.21.docx
Signed.
From:
Sent: Friday, May 14, 2021 3:27 PM
To:
(NY) (FBI)
Subject: [EXTERNAL EMAIL] - FW:
- Epstein
Hi
When you have a chance, could you please initial the proffer agreement and send it back to me? Thanks!
From: Joe Nascimento
Sent: Friday, May 14, 2021 2:56 PM
To:
Cc:
(USANYS)
is
Subject: Re:
)
- Epstein
Hi
Thanks again for your time today. Attached, please find a copy of the proffer agreement with updated initials.
Have a nice weekend,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
EFTA00024748


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=== Page 1 ===
From: Nicole Simmons
To: Nathan NYSD Chambers
Cc: Jeff Pagliuca
Laura Menninger
"
"
Subject: [EXTERNAL] U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Motn for Order re.
Fed. R. Crim. P. 17(c) Sub Prpsd Redctns]
Date: Sun, 21 Nov 2021 19:35:10 +0000
Attachments: 2021.11.14 Mtn _for_Order_Auth_a_Sub_Pursnt_to_F.R.Crim.P_17(c)
(4)_re.
[redactions].pdf;,2021.11.14_Ex._1_[redactions].pdf
Inline-Images: image001.jpg
Dear Judge Nathan:
At the request of Jeffrey Pagliuca, please see attached the Proposed Redactions to Ms. Maxwell's Motion for an Order
Authorizing a Subpoena Pursuant to Fed. R. Crim. P 17(c)(3), the redacted version will be filed on the public docket today.
Regards,
Nicole
From: Nicole Simmons
Sent: Sunday, November 14, 2021 9:57 PM
To: 'Nathan NYSD Chambers'
Cc: Jeff Pagliuca
>; Laura Menninger
>; 'CEverdell@CohenGresser.com
is
>;
is
;
Subject: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Motn for Order re. Fed. R. Crim. P. 17(c) Sub]
Dear Judge Nathan:
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Motion for an Order Authorizing a Subpoena
Pursuant to Fed. R. Crim. P 17(c)(3). Pursuant to our established protocol, we are submitting the Motion and Exhibit to
the Court under temporary seal to allow the government to propose any redactions it deems necessary.
Regards,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
Denver, Colorado
80203
EFTA00024909

=== Page 2 ===
PH
FX
DIRECT:
www.hmflaw.com
EFTA00024910


c1: EFTA00026872
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=== Page 1 ===
From: Christian Everdell <CEverdell@CohenGresser.com>
To:
)"
N
Laura Menninger
<lmenninger@hmflaw.com>,
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Mon, 12 Apr 2021 05:50:05 +0000
Inline-Images: image001.jpg
-
Thanks for your email. We appreciate the extra time. The complete list of people who will be at the evidence views is
below. All of us except Camille will be there on Tuesday for the first day, but will likely rotate the remaining days.
Chris Everdell
Jeffrey Pagliuca
Laura Menninger
Bobbi Sternheim
Jim Harkins (investigator)
Simek Shropshire (paralegal)
Camille Delgado (paralegal)
Thanks,
Chris
From:
)
[mailto:
Sent: Friday, April 09, 2021 12:01 PM
To: Laura Menninger;
);
(USANYS)
Cc: Jeff Pagliuca; Christian Everdell; 'BOBBI C STERNHEIM'
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
Today the Marshals and the FBI informed me that they are able to arrange for your client and the evidence to be at 500
Pearl in time for the review to start as early as 8am each morning of the review period. The review can still continue until
4:30pm each day. In order to take advantage of the extra time, I would propose planning to begin each review day at
8:30am. You would also be welcome to arrive as early at 8am, and if the Marshals and FBI are ready to begin before 8:30,
then we can do so. I will plan to be at 500 Pearl by 8am each morning.
Also, the CSOs have asked for a list of everyone from the defense team who should be granted access into the proffer area
on the fifth floor of 500 Pearl for the review. Would you please send me a list of the names of everyone who you expect
to attend the review?
Thank you,
EFTA00026872

=== Page 2 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Thursday, April 8, 2021 10:05 PM
To: Laura Menninger <lmenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
Below please find responses to the issues you raised:
We are confirmed for the review at the Bronx warehouse on April 12, 2021 from 11am to 4:30pm.
During the April 12th review, your team can see the evidence for yourselves and let me know if you need any of the
items you are not permitted to photograph to be brought to 500 Pearl. Depending on the size of the item(s), we
may need to figure out whether they can be brought later in the week once you have already reviewed several
boxes, which would free up space in the FBI vehicle for the larger items. I'm confident we will be able to reach a
reasonable agreement about those items.
For the bulky photos, you will not be permitted to photograph any that feature nudity. As referenced above, once
your team has seen those photos for yourselves, you can let me know if you will need any to be brought to 500
Pearl.
As I mentioned previously and is indicated in the spreadsheet, we are preparing a letter to defense counsel
explaining why you will not be permitted to review those 16 discs. We expect to send you that letter tomorrow,
after which I will be happy to discuss the matter further.
The blue-ray discs referenced in the spreadsheet are what the FBI burned in order to provide the USAO SDNY with
a copy of electronic data to produce to you in discovery. The discs are not evidence themselves. The data is the
evidence, and it was produced to you already. You are correct, however, that the 4/24/07 file is a data file that was
copied from a VHS tape, which is currently located in the FBI's ELSUR office in Florida. We have asked that the
original tape be shipped to New York, and it should arrive on Tuesday, April 13th. We will make it available for you
to review once we have received it. We also plan to produce the digital file of that same recording to you as part of
our productions of non-testifying witness statements.
The shredded paper is currently being analyzed by the FBI lab. We have asked the case agent to inquire with the
lab regarding its anticipated timeline for analysis and will let you know when we expect it will be possible to have
the shredded paper returned to New York for you to review. It will not, however, be available next week.
The "Missing from Assigned Box" items are items 1B130 and 1B110. Those items were migrated within the FBI
evidence system from the Florida case to the New York case and incorporated into New York evidence item
EFTA00026873

=== Page 3 ===
numbers 1B127, 1B128, & 1B137. So these items will be available for your review under those New York evidence
numbers.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Wednesday, April 7, 2021 4:23 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
My apologies, I meant to include in my previous email that we could have the Bronx view on Monday, April 12. Thank you
for the logistics.
Regarding the spreadsheets you provided, I have several issues.
First, there are a couple of items that you have noted for the Bronx Warehouse but will in fact need to be brought to 500
Pearl for review because you labeled them as "Highly Confidential" and not "bulky." These appear to include:
NY Evidence List
Items 1B127-130 (4 boxes).
Item 1B13 (1 box)
Florida Evidence List
Item 1, Subitem 26 - one large framed photo from Master Bedroom.
Second, with regard to the "Bulky" photos (Florida Items 1, Subitems 8, 15a, 15b and 15c), are we permitted to
photograph those or not? If not, we will need them transported to 500 Pearl.
Third, Florida Item 8, Subitem 8, says it is Sixteen DVD-R Discs from PBSO but you do not indicate that we can review
those. Why? We need to address with the Court promptly any issues related to our request to view all evidence.
Fourth, Electronic surveillance - Your email yesterday stated that these were all "electronic files" with no corresponding
physical item. However, for several, the chart indicates "Blu-Ray Disks;" is there a reason we cannot inspect these?
Another Florida item is listed as "one original recording of an interview dated 4/24/07"; I am suspicious that "one original
recording of an interview" is not truly only an "electronic" file? I was practicing law in 2007 and do not recall "electronic
files" being the standard then. Can you please confirm? I know that Chris has written separately about the many files for
EFTA00026874

=== Page 4 ===
which the metadata has apparently been stripped, so we will have to address purely electronic information at another
date.
Shredded Paper - Yes, we need to review that as well.
"Missing from Assigned Box" items - can you please provide more of an explanation for all "missing items"?
I will let you know any other issues as I see them. However, now that we have made travel plans in reliance on your
agreement to produce all evidence items, I am hoping that you can promptly answer these questions so that we can
resolve any of them as needed this week.
Thank you,
-Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Wednesday, April 7, 2021 1:44 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Hi Laura,
The Bronx warehouse is located at 2350 Lafayette Ave, Bronx, NY. There is plenty of street parking outside of the
building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the
attorney, investigator, and paralegal at the warehouse to escort them into the building to the evidence review room. The
AUSA will remain present at the warehouse to answer any questions that may arise.
The FBI has informed me that they can make the evidence available for review at the warehouse any day next week or the
week of April 19th. Please just let me know what day you prefer, and we will coordinate with the FBI to arrange for the
review.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00026875

=== Page 5 ===
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Wednesday, April 7, 2021 3:30 PM
To:
>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for the updated spreadsheets and the information regarding the timing of the review at 500 Pearl.
I believe we will be able to have an attorney, investigator and paralegal present at the Bronx warehouse to take photos of
the "excluded from transportation" items. Please let us know the particulars for that visit when you have a moment.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Wednesday, April 7, 2021 10:06 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
Attached please find the revised spreadsheets, which reflect designations under the Protective Order for the three mini-
VHS tapes that I referenced below.
I learned this morning that the Marshals intend to bring Ms. Maxwell back to the MDC each review day at 4:30pm. So we
can plan for the review to take place at 500 Pearl Street from 9:30am to 4:30pm each day beginning on April 13th.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00026876

=== Page 6 ===
From:
Sent: Wednesday, April 7, 2021 12:09 AM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: 'Jeff Pagliuca' <jpagliuca@hmflaw.com>; 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good evening,
Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day
thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street
at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer rooms on the 5th floor of
the 500 Pearl Street courthouse beginning at 9:30am on April 13th. I will plan to be present and to continue assisting with
logistics. If any questions or concerns arise, please feel free to call my cellphone at
To assist in preparing for this review, attached please find annotated versions of the three evidence spreadsheets I
previously emailed to you: (1) a spreadsheet of New York evidence; (2) a spreadsheet of Florida evidence; and (3) a more
detailed spreadsheet of the sub-items contained in the Florida evidence spreadsheet. A couple things to note:
These spreadsheets now indicate the Protective Order designation, if any, for each item to be reviewed. As you will
see, there are three mini-VHS tapes that I need to double check before assigning a final designation. I expect to be
able to access a mini-VHS cassette player later this week, at which point I will be able to provide an updated
spreadsheet with a confirmed designation for those three items. Additionally, please note that there is one item
about which we plan to provide you with a letter later this week.
These spreadsheets also indicate where each item will be made available for the defense to review. As you will see,
we have now learned that one item (consisting of shredded paper) is currently at FBI headquarters and will not be
available for review next week. Please let me know if you believe you need to review that item, and I will inquire as
to whether and how it can be relocated to New York. Additionally, all 1D items consist of electronic data (as
opposed to 1B items, which are physical items). As is noted in the spreadsheets, the electronic data that constitute
the 1D items in this case have either already been produced to you in discovery (e.g., pen register data, GPS data,
and aerial footage), or are digital recordings of interviews that will be produced as non-testifying witness
statements. Because these 1D items are data files stored in the FBI system, there is no corresponding physical item
to produce for you to review.
Please let me know when you would like to schedule a time for a smaller group from the defense team to review evidence
at the Bronx warehouse.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
)
Sent: Monday, April 5, 2021 10:48 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
EFTA00026877

=== Page 7 ===
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
Thank you for your email and for your understanding as we work through the logistics of arranging this review. Your
modifications and clarifications are acceptable to us. Below I address each specifically:
The FBI can arrange for a lawyer, investigator, and paralegal to inspect and photograph the precluded items at the
Bronx warehouse either next week or the week after. Please let us know what day you would like to arrange for
that inspection, and I will coordinate with the FBI accordingly. I would suggest trying to schedule this visit early
next week if possible so that if there are items that you believe need to be produced to 500 Pearl Street, we will
have time to do so during a subsequent day of review at 500 Pearl if the FBI agrees to transport the item(s).
Tomorrow, I will send you evidence spreadsheets with annotations of which items the FBI will not be producing to
500 Pearl Street, and which items we are designating under the Protective Order. Please note that certain items
will be designated "Confidential," in which case they may be photographed, but the photographs should be treated
as Confidential under the Protective Order. Other items will be designated "Highly Confidential," in which case they
may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to
photograph this latter category because some Highly Confidential evidence items include both nude and non-nude
portions, in which case we would permit photography of the non-nude portions.
In light of our decision to produce non-testifying witness statements beginning on April 12, 2021, we are no longer
segregating any electronic media that contain witness statements during this review. This is because all of the
witness statements on the electronic media in the FBI's possession are from witnesses whom the Government does
not expect to call at trial in this case. Please note that we intend to produce digital audio files to you containing the
contents of the electronic media with these non-testifying witness statements, but you are of course welcome to
review the original recordings themselves.
In terms of space, I have been informed that we will not be permitted to conduct this review in a courtroom and
will instead be required to do so in the proffer rooms. I have reserved the two largest proffer rooms available at
500 Pearl. We can use the largest proffer room for evidence review, and the slightly smaller proffer room as a
private meeting space for the defense team.
Confirmed, I will ask the FBI to bring all electronic highly confidential images to 500 Pearl Street, including the
2,100 that were not previously reviewed and the electronic images that were previously provided for review at the
MDC.
Confirmed, I will ask the FBI to bring the 7 hard-copy highly confidential materials to 500 Pearl Street.
As I mentioned earlier today in a separate email, the FBI and AUSAs are prepared to facilitate this review beginning April
13th and continuing every day thereafter until your review is complete. I have also formally requested that the Marshals
produce Ms. Maxwell to 500 Pearl Street on April 13th and every day thereafter until the review is complete. The
Marshals previously confirmed their willingness to produce Ms. Maxwell for such a review in general, but they have not
yet confirmed their ability to do so on any particular dates. I will let you know as soon as the Marshals inform me
whether they can accommodate these specific dates.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00026878

=== Page 8 ===
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Friday, April 2, 2021 5:36 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for your email. Your proposal is largely acceptable to us, with the following modifications and clarifications.
For the items that you propose below to exclude from the evidence transported to 500 Pearl Street (with the
exception of the cash held at 26 Federal Plaza), we will need to have access for a lawyer, investigator and paralegal
to inspect and photograph those items at the Bronx warehouse. This seems to include the bulky items, electronic
devices and "fragile" items.
Once they are photographed and shared with the team and our client, we can decide whether a separate
inspection by our client and/or any expert is necessary at a later time. To be clear, the government's photos
of these same items are insufficient.
If there are any items we are not permitted to photograph (and perhaps you will be able to tell us by April 5
which those are), we likely will need to have those transported because there is no way for our client to
inspect the evidence. We can wait to finalize this issue until you have finished deciding what items you
consider non-photographable, and if we can't agree, then discuss next steps.
Please let us know when these "non-transportable" items can be inspected and photographed at the Bronx
warehouse. It makes sense that it would be done soon so that we can raise any issues as necessary with the
Court.
For playing any of the electronic media, we will obtain the necessary equipment to play at 500 Pearl Street and
seek permission to bring those devices into the Courthouse. You can segregate out the section of recordings that
contain "witness statements" and advise us then which ones cannot be played, but we still need to inspect the
outside of those recordings.
As far as space, can you please advise whether the largest proffer room will be available for review of evidence? It
is my understanding that it can accommodate a large number of the team members at one time. If not, is a locked
courtroom available for us to review the evidence? The agents could bring out a limited number of boxes at a time
for inspection.
We understand that the evidence will not be taken outside of the monitoring of the agents or your staff and
appreciate that you will have a separate room for us to consult with our client privately (without the evidence).
We understand that all of the highly confidential materials, including not only the 2,100 images not previously
disclosed as well as the electronic images that were only shown to NY counsel and the client at the MDC, will be
available for review on a singular laptop at 500 Pearl Street.
We also understand the 7 hard-copy highly confidential materials will also be available for inspection at 500 Pearl
Street.
Please let me know if you have any questions or disagree with my understanding. If you agree, we can then proceed as
scheduled on April 12 and continue day to day until we are finished, with a break if necessary for the arraignment.
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
EFTA00026879

=== Page 9 ===
From:
Sent: Saturday, March 27, 2021 4:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with
arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will
also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12th.
Physical Evidence
It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are
certainly willing to work with you to ensure that your client can review any physical items that are material to the
preparation of her defense.
We would propose excluding the below items from production to 500 Pearl:
We appreciate your note that the massage tables are not needed, which will certainly help with the logistics
of transport.
We also appreciate your indication that the cash items from 26 Federal Plaza do not need to be produced.
Those are the only items not located in the Bronx warehouse.
The FBI has seized dozens of electronic devices, including desktop computers, servers, and laptops, from
Jeffrey Epstein's residences in 2019. Photographs of those devices were produced in our August 2020
productions as part of the search warrant photographs, and you have received copies of the data that was
seized from those devices pursuant to a warrant. The production of these devices would be very
cumbersome, and we do not see any value in looking at an electronic device that cannot be turned on.
The framed pictures are bulky and cumbersome to transport. These are also very delicate and are difficult
to transport. Photographs of those seized images were already provided to you as part of the photographs
from the searches of Epstein's residences.
Certain items seized from the New York residence are bulky, fragile, and/or difficult to transport. These
include plaster busts of female torsos and a stuffed dog. Photographs of these items were already provided
to you from the search of the New York residence.
The remaining physical items of evidence would fit into approximately 15 to 20 boxes. The FBI has indicated that it
would be feasible to transport those boxes to 500 Pearl Street.
Regarding your request for equipment that can play the recordings, we believe they would require a VCR, a cassette
player, a CD player, an adapter for a micro VHS tape, and a microcassette player. If you wish to play these
recordings at 500 Pearl, you will need to provide that equipment. We have asked the FBI whether any other
equipment would be necessary and will let you know if that is the case prior to the date of your review. It is our
understanding that any recordings that are not witness statements and that are not highly confidential have been
produced to you in discovery. We are not aware of any discoverable, non-highly confidential, recordings that were
not produced to you as part of the Government's discovery productions in the fall. To confirm that understanding,
we are working with the FBI to physically doublecheck each recording. If we identify any discoverable recordings
that have not already been produced, we will promptly provide them to you.
The segregation of highly confidential material will require the FBI and an AUSA to physically review each item to
confirm the item's status. We will endeavor to do so by your requested date of April 5, 2021.
EFTA00026880

=== Page 10 ===
We can confirm that neither the AUSA(s) nor the agent(s) will record or attempt to record any part of the evidence
review or conversations among the defense team or with the defendant during this review. Although the evidence
cannot be left outside of the presence of an agent, we will ensure that a room is available for the defense team and
the defendant to confer privately away from the agent(s) and the AUSA(s) without monitoring.
As for your request for a space large enough to fit 8 members of the defense team, the defendant, an agent, an
AUSA, and the evidence, my office cannot control the space that the Marshals allow us to use at 500 Pearl outside
of the proffer rooms. We will certainly request as large a space as possible, but if we are required to use the
proffer rooms, then members of the defense team may need to rotate in and out of the room. I know members of
the defense team have been in those proffer rooms before, and they can hopefully provide some thoughts on how
we might use the proffer room space effectively for your purposes. If the Court grants authorization for the
defense to bring electronic devices into 500 Pearl, that is certainly fine with the Government, and you may note our
consent in your request to Judge Nathan for such authorization.
Highly Confidential Electronic Images
The 2,100 electronic images were recovered during the responsiveness review of images and videos seized from
Jeffrey Epstein's devices, which review was not complete until early November 2020. We indicated on page 4 the
cover letter to our November 9, 2020 production, which included all other images and videos from those devices,
that "the Federal Bureau of Investigation ('FBI') seized multiple nude and partially nude images from several for the
above-listed electronic devices. All such images have been designated Highly Confidential. The FBI will make these
images available for review by the defense upon request." We did not receive a request from the defense to review
these images until your March 8, 2021 letter, which requested to "view and inspect all materials designated by your
office as 'Highly Confidential' under the terms of the Protective Order".
We did not ask the FBI to bring the 7 hard copy images to the MDC in the fall because we did not understand you to
be requesting a review of physical, non-electronic evidence during those meetings. Our understanding of the
defense request at that time was to review the electronic highly confidential images that were recovered from CDs
from Epstein's residence. We will ensure that the 7 hard copy images are available to you for review at 500 Pearl.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 22, 2021 5:19 PM
To:
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
We have considered your proposal. Unfortunately, it does not permit us an adequate ability to review the evidence in the
case and does not permit our client to meaningfully participate in her own defense.
EFTA00026881

=== Page 11 ===
First, we are unable to meaningfully review the evidence without the benefit of our laptops and other electronic devices
which are needed to take notes of our review. We also need access to our devices during the review to compare the
physical evidence with the electronic discovery and with our work product.
Second, we need to provide our client the ability to review all discovery, including any recordings, in order to assist in her
own defense. Presuming that she will not be taken to the FBI downtown office, then your proposal offers no means by
which she can both inspect a recording in its physical form and listen to the recording at the same time.
In order to address the deficiencies in your proposal, we believe the following are necessary:
Physical Evidence
All of the physical evidence currently located in the FBI Bronx warehouse will be transported to 500 Pearl Street
and made available during the week of April 12, with our client present, in a room sufficiently large to
accommodate 8 attorneys and investigators.
We do not need the "bulky" massage tables transported; if there are any other extremely large evidence
pieces, let us know what they are and we can consider whether we can have someone review and
photograph those at the Bronx warehouse at an earlier time.
From your email, it appears that only two items are not located at the Bronx warehouse - both envelopes
with cash. Please confirm this. We do not need the two "cash" evidence items transported to 500 Pearl.
If there are other evidence items housed somewhere other than the Bronx, please let us know what they are
and where they are.
We will be permitted to bring our laptops, and a camera, into 500 Pearl Street; we are happy to seek permission
from Judge Nathan to do so.
Either the FBI can provide the equipment necessary to listen to any of the recordings at 500 Pearl Street or we can
bring the necessary equipment. If we are to provide the equipment, we will need to know in advance the formats
of each recording so that we can be prepared. You can note that on your Excel spreadsheet by the item number by
March 29 to give us adequate time to secure the necessary equipment.
The FBI can segregate any physical evidence that you deem "highly confidential." You can identify any "highly
confidential" physical evidence items on your Excel spreadsheets by April 5 (one week before the evidence view). If
we need to photograph or reproduce any such item for expert evaluation, we will seek leave of court. Otherwise,
we will not photograph any such items during the review during the week of April 12. This will ensure the evidence
review proceeds smoothly and there will not be any need to ask permission to photograph on an item by item
basis.
The FBI also can segregate any recordings which we will be able to inspect, but not listen to, during the evidence
view the week of April 12. You can note such designation on your Excel spreadsheet. If we disagree, we can seek
leave of the Court in advance.
We understand that an FBI Agent and/or AUSA may be present during our physical evidence review at 500 Pearl
Street but of course must ensure that no recordings are made of our conversations and also ensure that there is a
separate, secure room in which we can confer with our client during the evidence view without monitoring by the
government.
Please confirm whether all electronic recordings (other than the highly-confidential images and videos described
below) have previously been produced to us, and if not, please explain which ones were not produced by the
discovery deadlines last fall and why.
Highly Confidential Electronic Evidence
Can you please explain why 2,100 + 7 "highly confidential" images have not been shared with us yet? It was our
understanding that you previously provided all "highly confidential" images to our client - and to defense counsel -
for review at the MDC in November. We are confused about where these previously undisclosed items were
located and why they have not yet been made available for inspection and review.
During the week of April 19, Ms. Maxwell should be produced to 500 Pearl Street to review (with counsel and a
defense staff member, on the 1 laptop provided) all of the 5,507 electronic images and video marked "highly
confidential". These should be segregated into the three categories you describe (never-before produced,
previously produced, and the 7 hard-copy images).
EFTA00026882

=== Page 12 ===
Please let us know if you will not agree to any of these steps so that we can address the issues with the Court.
Thank you.
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
)
Sent: Tuesday, March 16, 2021 4:40 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding
discovery cover letter. We are sending a copy of these files to the MDC for your client as well.
In response to your questions, the FBI has informed me of the following:
Regarding the Highly Confidential nude/partially nudge images to be reviewed at 500 Pearl:
There are three categories of these images:
Approximately 2,100 electronic images and videos seized from Epstein's electronic devices (which have not
been previously provided to you)
Approximately 3,400 electronic images from discs seized from Epstein's residences in 2019 (which have
previously been provided to you and your client for review at the MDC)
Approximately 7 hard copy nude images located in the file from the FBI Florida office's investigation of
Epstein (which have not been previously provided to you)
The FBI will make all three of those categories available to you. The electronic files will be provided on hard drives,
and the FBI will provide you with the hard copy images for review as well.
All electronic images should be viewable as thumbnails, except those seized from Apple devices, which must
be viewed using Cellebrite.
The Cellebrite software will be provided on the drive for your review of images and videos seized from Apple
devices.
The electronic files have the same metadata on the hard drive that was available when the FBI seized each
image. For images that were carved or deleted, no metadata was recovered, so none is viewable. For all
other images, the metadata recovered should be viewable on the hard drive.
The approximately 2,100 electronic images and videos seized from Epstein's devices are separated by folder
to indicate which device each image was seized from.
Because these images are considered obscene material, the FBI is not permitted to make duplicates of them, and
there is a limited number of clean laptops on which these images can be reviewed. As a result, the FBI is only able
to provide a single laptop for review of these images.
Regarding the physical evidence:
Attached are two lists of all physical items in the FBI's custody relating to this case. The first list relates to items
associated with the FBI Florida office's investigation of Epstein. The second list relates to items associated with the
FBI New York office's current investigation.
The vast majority of physical evidence in the FBI's custody is located at the FBI's warehouse in the Bronx. Two
items (1B 77 & 1B 79) are located at 26 Federal Plaza, but the case agents can check those items out from 26
EFTA00026883

=== Page 13 ===
Federal Plaza and bring them to the Bronx warehouse on whatever day you choose to conduct your review so that
you will have all evidence in one place.
The FBI is able to arrange for the defense team to review all physical evidence at the Bronx warehouse under the
following conditions:
The warehouse requires at least two weeks' notice in order to pull all of the items for the entire case and
place them in a location where a large group of people can view them.
The warehouse is open during normal business hours between 9am and 5pm on weekdays.
At least two FBI agents and an AUSA will be present at the Bronx warehouse to assist and answer questions.
The evidence will be placed in a loading dock at the warehouse to provide additional space for the review.
To ensure that there is sufficient space, please let me know how many members of the defense team intend
to be physically present for this review.
Electronic devices such as cellphones and laptops are not permitted in the warehouse. The defense team
may bring a digital camera that is not connected to the Internet or a cellular network into the warehouse. If
the defense team wishes to photograph an item of evidence, the defense will need to inform the agents who
are present, so that they may confirm that the photographed item is not Highly Confidential based on the
presence of nudity.
Electronic media such as VHS tapes, cassette tapes, and CDs will not be playable at the warehouse.
To the extent the defense requests that the FBI bring any physical items to 500 Pearl Street for your client to review,
the FBI is prepared to bring items that are reasonably sized to 500 Pearl Street. With respect to bulky or large
items, the defense team should be able to photograph those for your client to review, unless they are deemed
Highly Confidential, in which case the FBI can make arrangements to transport the item to 500 Pearl Street if
necessary.
The FBI is in the process of confirming that it can provide devices to play all of the electronic media in the case in a
single location at the FBI's offices in downtown Manhattan. We are also double-checking to confirm that all media
that does not contain witness statements have already been produced to you and your client in discovery. The FBI
anticipates that we can arrange for you to review all non-witness statement electronic media at the FBI's office in
downtown Manhattan in approximately three weeks.
To the extent you wish to review all of the discs containing photographs, which were seized from Epstein's
residences in 2019, we note that all of those images have already been produced to you in discovery. For
your awareness, the FBI has informed me that it took their team several weeks to review all of the images on
all of those discs.
Please let me know how you wish to proceed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, March 15, 2021 6:00 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
EFTA00026884

=== Page 14 ===
Laura,
I expect to be able to answer all of your questions about the evidence review by tomorrow.
We have been looking into the discovery request you made last week, and we hope to have a response ready to provide
to you by next week.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 15, 2021 3:01 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of
when you would have answers, it could help me answer your question.
At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the
attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their
evidence when they seized it from NY and LSJ, so I don't think we need to wait for them to now prepare an inventory
before we start reviewing evidence.
Also, when do you believe you will have a response regarding the discovery I requested last Monday?
Thanks,
Laura
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
EFTA00026885

=== Page 15 ===
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00026886

=== Page 16 ===
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 3:44 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you. Is that the only index of physical evidence available?
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00026887

=== Page 17 ===
From:
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
Code:
Best,
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
is
V.
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
Thank you,
EFTA00026888

=== Page 18 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00026889


c1: EFTA00025515
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025515.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Subject: Epstein Passport Photos
Date: Wed, 17 Jul 2019 18:48:01 +0000
Attachments: 20190717_132040.jpg; 20190717_132050.jpg; 20190717_132056.jpg
Please let me know if there are issues opening and I can resend. Due to size, had to send multiple emails.
Thanks,
FBI New York - C20
VCAC/Human Trafficking
EFTA00025515


c1: EFTA00024734
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024734.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Epstein Image/Video File Review Protocol
Start Date: 2020-10-20 17:00:00 +0000
End Date: 2020-10-20 17:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-10-19 22:19:58 +0000
Date Modified: 2020-10-19 22:19:58 +0000
Priority: 5
DTSTAMP: 2020-10-19 22:07:21 +0000
Attendee:
EFTA00024734


c1: EFTA00025174
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025174.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
(USANYS)"
Subject: FW: US V. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
Date: Thu, 22 Apr 2021 16:14:06 +0000
Attachments: 2021.04.22_Defts_Letter_for_Adjournment.pdf
FYI. Our response is due at 5 today.
From: Laura Menninger
Sent: Thursday, April 22, 2021 11:22 AM
To:
Cc:
is
is
(USANYS)
is
)
>; ; Jeff Pagliuca
is
>; 'Bobbi Sternheim
(
)'
>; Nicole Simmons
Subject: US V. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
Judge Nathan -
Pursuant to this Court's Order of April 20, 2021 (Dkt. 221), attached please find counsel's Letter Motion for an
Adjournment of the trial.
Counsel for Ms. Maxwell request redaction of their other clients' names and case numbers from this Letter Motion
pursuant to Rule of Professional Conduct 1.6 which prohibits lawyers from revealing confidential information related to a
client even where that information is publicly available. See In Re. Anonymous, 654 N.E. 2.d. 1128 (Ind. 1995) (lawyer
violated Rule 1.6 by disclosing information relating to representation of client, even though information "was readily
available from public sources and not confidential in nature"); In re Bryan, 61 P.3d 641 (Kan. 2003) (lawyer violated Rule
1.6 by disclosing, in court documents, existence of defamation suit against former client); State ex rel. Okla. Bar Ass'n V.
McGee, 48 P.3d 787, 791 (Okla. 2002) (a lawyer's duty of confidentiality attaches "to all information relating to the
representation, whatever its source").
Upon direction of the Court, counsel will file either the redacted or unredacted version of this letter on the public docket.
Best regards,
Laura Menninger
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
EFTA00025174


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=== Page 1 ===
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR J.E
FOR
J.E.
DATE
9/19/05
TIME 8:30 A.M. P.M
DATE
9/19/05
TIME 2:30 AM P.M.
M
M
G.M.
OF
OF
PHONE/
PHONE/
MOBILE
MOBILE
TELEPHONED
X
PLEASE CALL
X
TELEPHONED
X
PLEASE CALL
X
CAME TO SEE YOU
WILL CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
MESSAGE
MESSAGE
SIGNED J.
1184
SIGNED J.
a
1184
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR
J.E.
FOR J.E.
DATE
9/20/05
TIME 1:20
AM.
P.M.
DATE 9/19/05
TIME 8:20a AM P.M.
M
M
OF
OF
PHONE/
PHONE/
MOBILE
MOBILE
TELEPHONED
PLEASE CALL
X
TELEPHONED
X
PLEASE CALL
CAME TO SEE YOU
WILL/CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
MESSAGE
MESSAGE
I would like to know
what time I should
be tommorow
SIGNED J.
a
1184
SIGNED I.
a
1184
EFTA00026717

=== Page 2 ===
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR
J.E.
FOR
J.E.
DATE
9/30/05
TIME 6:30 A.M. P.M.
DATE
9/20/05
TIME 4:55 P.M A.M.
M
G. M.
M
OF
OF
PHONE/
PHONE/
MOBILE
MOBILE
TELEPHONED
PLEASE CALL
TELEPHONED
PLEASE CALL
X
CAME TO SEE YOU
WILL CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
MESSAGE
MESSAGE
a
SIGNED
1184
SIGNED J
1184
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR J.E.
FOR Mr. . Epstein
DATE
9/30/05
TIME 6:30AM P.M
DATE Sept. 21,05 TIME 10:00 P.M. A.M.
M
G.M.
M
OF
OF
PHONE/
PHONE/
MOBILE
MOBILE
TELEPHONED
X
PLEASE CALL
TELEPHONED
PLEASE CALL
CAME TO SEE YOU
WILL CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
MESSAGE
MESSAGE
SIGNED J.
1184
SIGNED L
a
1184
EFTA00026718

=== Page 3 ===
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR
J.E.
FOR
J.E
DATE 10/1/05
TIME 2:50 A.M. P.M.
DATE
10/1/05
TIME g:50AM A.M. P.M.
M
M
OF
OF
PHONE/
PHONE/
MOBILE
MOBILE
TELEPHONED
X
PLEASE CALL
TELEPHONED
PLEASE CALL
CAME TO SEE YOU
WILL CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
MESSAGE
MESSAGE
confirmal
at 11 nn
and
- 4 POT
SIGNED I
1184
SIGNED J.
a
1184
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR J.E.
FOR
J.E.
DATE
10/1/05
AM
TIME 7:10
P.M
DATE 10/1/05
TIME 10:15 P.M. A.M.
M John Brockman
M
OF
OF
PHONE
PHONE/
MOBILE
MOBILE
TELEPHONED
X
PLEASE CALL
TELEPHONED
X
PLEASE CALL
CAME TO SEE YOU
WILL CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
MESSAGE
MESSAGE
SIGNED J.
a
1184
SIGNED J.
1184
EFTA00026719

=== Page 4 ===
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR J. E.
FOR
J.E.
DATE
10/2/05
TIME 10:40 A.M. P.M.
10/1/05
A.M.
DATE
TIME 7:20
P.M.
M
M Jerry Goldsmith
OF
OF
PHONE/
PHONE/
MOBILE
MOBILE
TELEPHONED
PLEASE CALL
TELEPHONED
X
PLEASE CALL
CAME TO SEE YOU
WILL CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
is seek
MESSAGE
MESSAGE
and she can't
come today
SIGNED J.
a
1184
SIGNED J.
1184
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR mr. J. Epstein
FOR
J.E.
DATE Oct 2.05
TIME 12:30 A.M. P.M.
DATE
10/2/05
TIME 10:20 A.M P.M.
M
M
OF
OF
PHONE/
PHONE/
MOBILE
MOBILE
TELEPHONED
PLEASE CALL
TELEPHONED
X
PLEASE CALL
CAME TO SEE YOU
WILL CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
MESSAGE
MESSAGE
(561)
SIGNED L
a
1184
SIGNED J.
a
1184
EFTA00026720

=== Page 5 ===
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR J.E.
FOR
J.E.
DATE
10/3/05
TIME 2:50 A.M. P.M.
DATE 10/2/05
TIME 9:05 P.M. AM:
M
M Sandy Berger
OF
OF
PHONE/
PHONE/
MOBILE
MOBILE
TELEPHONED
X
PLEASE CALL
TELEPHONED
PLEASE CALL
CAME TO SEE YOU
WILL CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
MESSAGE
MESSAGE
Canyon call him
at this # between
30 PM
SIGNED J.
a
1184
SIGNED J.
1184
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR
J.E.
FOR Mr. J. Epstein
DATE
10/3/05
TIME 4:10
A.M.
P.M.
10-2-05
DATE
TIME 12:30 A.M. P.M.
M
M
OF
OF
PHONE/
PHONE/
MOBILE
MOBILE
TELEPHONED
PLEASE CALL
TELEPHONED
PLEASE CALL
CAME TO SEE YOU
WILL CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
MESSAGE
will be
MESSAGE
1/2 hour late
SIGNED J
SIGNED L
a
1184
1184
EFTA00026721

=== Page 6 ===
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR
FOR
J.E.
A.M.
DATE
TIME
P.M.
DATE
10/3/05
TIME 6:20 A.M. P.M.
M
M
OF
OF
PHONE/
PHONE/
MOBILE
MOBILE
TELEPHONED
PLEASE CALL
TELEPHONED
PLEASE CALL
CAME TO SEE YOU
WILL CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
MESSAGE
MESSAGE
can not be of
8 he is outoy town
He will beback on
Thursday.
is asking it you
want Swedish guy
SIGNED
SIGNED I
a
1184
1184
IMPORTANT MESSAGE
IMPORTANT MESSAGE
FOR
FOR
A.M.
A.M.
DATE
TIME
P.M.
DATE
TIME
P.M.
M
M
OF
OF
PHONE/
PHONE/
MOBILE
MOBILE
TELEPHONED
PLEASE CALL
TELEPHONED
PLEASE CALL
CAME TO SEE YOU
WILL CALL AGAIN
CAME TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
RUSH
WANTS TO SEE YOU
RUSH
RETURNED YOUR CALL
SPECIAL ATTENTION
RETURNED YOUR CALL
SPECIAL ATTENTION
MESSAGE
MESSAGE
a
SIGNED
1184
SIGNED
1184
EFTA00026722


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=== Page 1 ===
From:
To:
Subject: RE: Re:
Date: Fri, 25 Sep 2020 14:00:01 +0000
Sure!
>>>
(USANYS)" 9/25/2020 9:48 AM >>>
Thanks
!
Do you have two minutes for me to give you a ring today?
From:
Sent: Thursday, September 24, 2020 5:22 PM
To:
(USANYS)
Subject: Re:
Good evening,
It will be tomorrow! You can follow up with
at MCC New York in the interim. There will hopefully be a new attorney
on board (and even two!) at MDC Brooklyn in the very near future.
Thank you so much - I really appreciate it. If you need anything this evening, or tomorrow, please let me know. And even thereafter, I'll
only be a phone call or email away if you need.
Best,
>>>"
(USANYS)"
9/24/2020 5:19 PM >>>
- was today your last day or is it tomorrow? Do you know who I can be following up with re Ghislaine Maxwell?
I wish you the best in your next endeavor, and thank you for all of your service!
Counsel to the Acting U.S. Attorney
United States Attorney's Office
Southern District of New York
EFTA00025263


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=== Page 1 ===
From:
<
To:
Cc:
>,
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509)
Date: Fri, 10 Jul 2020 14:29:41 +0000
I just missed a call from her case manager. I'm on a court conference that's not going particularly well, so I'm not sure when
I'll be off it. I'm asking my staff to look into it.
Thanks
>>>
)" <
7/10/2020 10:26 AM >>>
Defense counsel for Maxwell communicated to us a few minutes ago that they haven't gotten a call yet this morning. Do you
know if that has gone through in the past five or ten minutes? They are looking to speak with her before her interview with
pretrial this afternoon.
I'm reachable at
if it's useful to chat in real time.
thanks,
On Jul 7, 2020, at 19:50,
<
> wrote:
You're welcome. We will do our best to provide a call at 10:00 AM every day this week to Mr. Everdell at the number he has
previously provided. We will also provide a call on Monday 7/13/20.
The EDNY and SDNY created a joint protocol whereby counsel may request legal calls to be placed in the afternoon at the
MDC. Requests should be sent to
Truly urgent requests can be sent to me, but unless there is a last minute, imminent court deadline, counsel really should
send the requests to the federal defenders, as outlined in the protocol. We want to ensure inmates get equitable access. If
they anticipate needing several calls in a week, they should make requests in advance and note whether and when calls
would be preferred. Generally, calls are for 30 minutes in duration. If a longer call is desired, that should be explained as
well.
If you need anything else, please let me know.
Thank you,
>>>
)" <
> 7/7/2020 5:00 PM>>>
Thank you so much,
A 10am standing legal call every day before the arraignment on Tuesday 7/14 would be perfect if that's something you
would be able to accommodate. Defense counsel will be available at that time, and they are very grateful for the time.
EFTA00024788

=== Page 2 ===
We have also conveyed to defense counsel that they will need to follow the same protocols as other inmates' counsel
following the arraignment. Thank you for letting us know about the lack of requests from defense counsel thus far. There
appears to be some confusion on their end about how to submit requests to schedule legal calls. Would you be able to
please share with us the procedure that they should follow, so that we can make sure they understand what steps to take
going forward?
Thank you again for all of your help-we really appreciate it.
Best,
From:
Sent: Tuesday, July 7, 2020 4:23 PM
To:
Cc:
y
Subject: RE: Ghislaine Maxwell (USMS No. 02879-509)
You're welcome.
Would 10 am work as a standing legal call through the end of this week (and Monday, if you think that's a good idea), in
advance of the arraignment on Tuesday? However, after this, defense counsel should be required to follow the same
protocols as all other inmates' counsel with respect to requesting legal calls.
I also just want to make clear that defense counsel sent no requests yesterday that I am aware of, and we were able to
facilitate a call yesterday evening following a request from your office, and today, I received one request, about mid-day,
that we were again able to accommodate. So, I do not think it is fair at all to categorize this as defense counsel having
difficulty scheduling legal calls.
Thank you,
>>>
)"
>
7/7/2020 2:37 PM >>>
Thanks,
This is about the legal call today. In addition, because defense counsel his having difficulty scheduling legal
calls, it would be helpful if MDC could schedule standing calls for the rest of this week to address this issue. Thanks very
much.
From:
Sent: Tuesday, July 7, 2020 2:36 PM
To:
Cc:
is
Subject: Re: Ghislaine Maxwell (USMS No. 02879-509)
Hi
I just saw this now. Is this about the legal call issue or something separate? If it's about the legal call, I am working on it.
Thanks,
>>>
)"
> 7/7/2020 1:27 PM >>>
Hi
Thanks for your help with this. Are you available now for a call? We are having a time sensitive issue with this.
Thanks,
Sent from my iPhone
On Jul 6, 2020, at 7:59 PM,
<
> wrote:
Hi
For future reference, there is a protocol in place for defense counsel to reques legal calls. If counsel is unaware of it, I can
provide the details.
However, I understand that she just came into custody today and there is a more urgent deadline. If you can please
provide the name and phone number of counsel, I will do my best.
Thanks,
EFTA00024789

=== Page 3 ===
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
)"
>
Date: 7/6/20 7:48 PM (GMT-05:00)
To:
Cc:
>,
>
Subject: Ghislaine Maxwell (USMS No. 02879-509)
>>>
)" 07/06/2020 19:48 >>>
Hi
Hope you're doing well. This evening, Judge Nathan directed the parties in the US V. Ghislaine Maxwell case to file a
letter by 9pm today. Defense counsel need to speak with Ms. Maxwell this evening about the letter, but they have not
been able to reach her. Would it be possible to allow Ms. Maxwell to make a legal call to her lawyers this evening,
please?
Thank you very much for your help.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00024790


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=== Page 1 ===
From: Gary Bloxsome
To:
)"
Cc: Daniel Cundy
Jennifer Richardson
)"
,
)"
Subject: Re: Sensitive correspondence
Date: Sun, 26 Jul 2020 20:17:27 +0000
Inline-Images: image001.jpg; image002.jpg; image410762.jpg; image217207.jpg
1. Dial-in number(s):
2. Enter Guest PIN:
Thank you
Gary Bloxsome
I
Partner
RANKED IN
Chambers
UK
500
2020
TOP TIER
Leading Firm
2020
COVID-19 - Please see our websiteherefor our updated position in relation to Coronavirus.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in ourPrivacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 24 Jul 2020, at 16:59,
) wrote:
External email: is it safe to open attachments and links?
Gary,
Please feel free to send your conference number, and we'll look forward to speaking with you on Monday.
thank you,
EFTA00023783

=== Page 2 ===
From: Gary Bloxsome
Sent: Friday, July 24, 2020 05:47
To:
)
Cc: Daniel Cundy ; Jennifer Richardson ;
);
)
Subject: Re: Sensitive correspondence
Dear
Thank you for your email.
We look forward to speaking to you at 4pm (LDN time) on Monday 27th July 2020.
Due to lockdown we will be calling from different parts of the UK.Do you have dial in details we could use or we can
send to you our conference call number?
Kind regards
Gary
Gary Bloxsome Partner
COVID-19 - Please see our websitehere for our updated position in relation to Coronavirus.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 22 Jul 2020, at 22:05,
)
wrote:
External email: is it safe to open attachments and links?
Gary,
To your concern, we point you to the second listed term, which provides that both parties agree that "the fact of the
Negotiation Period, as well as any communications made during the Negotiation Period, shall be treated as confidential,
and shall not be the subject of any public comments."
Subject to all of the terms we outlined in our email of July 14, 2020, we are available for a call on Monday, July 27 at
4:00 p.m. GMT+1 or anytime thereafter on that date.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Wednesday, July 22, 2020 03:13
To:
Cc: Daniel Cundy
>; Jennifer Richardson
Subject: Re: Sensitive correspondence
Dear
EFTA00023784

=== Page 3 ===
Thank you for your email, we assume that it is implicit from point 4 of your email below, that you won't disclose the
fact of this negotiation or the contents of any discussions which take place, including in the event of any inability to
reach an agreement, other than to the UKCA.
On that basis can we arrange a call for Monday 27th July? Please suggest a time that would be convenient for
yourselves.
Regards
Gary
Gary Bloxsome Partner
COVID-19 - Please see our websiteherefor our updated position in relation to Coronavirus.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 14 Jul 2020, at 15:59,
)
wrote:
External email: is it safe to open attachments and links?
Gary,
In response to your July 13 email, we are prepared to enter into a limited period of confidential negotiations regarding
a voluntary interview of your client, subject to the following conditions:
1. The confidential negotiation period shall last no more than two weeks, starting today, and ending at the end of the
day on July 28, 2020 (the "Negotiation Period");
2. Both sides agree that the fact of the Negotiation Period, as well as any communications made during the
Negotiation Period, shall be treated as confidential, and shall not be the subject of any public comments;
3. If, as the result of negotiations conducted during the Negotiation Period, your client completes a voluntary
interview with U.S. authorities, either side may publicly confirm that your client met with United States law
enforcement authorities and answered questions about matters under investigation. Neither party, or their
representatives, shall comment further on the circumstances or substance of the interview.
4. Alternatively, if, at the end of the Negotiation Period, no agreement is reached, the parties will jointly inform the
appropriate authorities in the UK and US that the parties are not able to reach agreement on a voluntary interview
and accordingly a voluntary interview will not occur.
We believe these conditions directly address your stated concerns while allowing us to satisfy ourselves that all sides
are endeavoring in good faith to either expeditiously reach agreement on a voluntary interview or reach agreement
that no such interview will occur.
Please inform us as soon as possible if you are amenable to this proposal. If so, we are prepared to schedule a call at
your earliest convenience to discuss arrangements for the interview.
Regards,
EFTA00023785

=== Page 4 ===
From: Gary Bloxsome
Sent: Monday, July 13, 2020 11:49
To:
)
Cc: Daniel Cundy
>; Jennifer Richardson
)
Subject: Re: Sensitive correspondence
Dear
Geoffrey Berman and Audrey Strauss have persistently commented about the prospects and purpose of
interviewing the Duke of York, prompting widespread media coverage. We regard that commentary as
improper. Your offer to refrain from publicly commenting on the substance of any witness interview and
general assurances about your standard practice are clearly insufficient to prevent the DoJ and the SDNY
from encouraging a media circus around the process of arranging for and the Duke attending any interview.
All we are asking for at this stage is an undertaking of confidentiality in relation to the discussion of dates,
concerns and arrangements in relation to any interview. This is no more than would be good practice in the
UK and we invite you provide an assurance in this regard.
Regards
Gary
Gary Bloxsome Partner
Coronavirus - COVID-19 - A message to our clients and fellow professionals
All of the partners of the firm are still working and their contact details can be found on our website at
www.blackfords.com. In addition we have a team of key workers supporting us across all offices. We
continue to take instructions from existing and new clients.
As a consequence of the coronavirus pandemic and the need to ensure the safety of our staff, the firm
will be operated by a limited number of key personnel.
Family Court hearings and proceedings - these are operating through video and telephone hearings.
Our family team is operating as normal.
Criminal and Regulatory hearings - most court and tribunal hearings are being adjourned but you
must please stay in contact with us to check hearing dates and deadlines until we have confirmation
that they have been moved or extended. For individuals held in custody, cases are being dealt with
where social distancing measures or electronic hearings can be implemented.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
EFTA00023786

=== Page 5 ===
On 10 Jul 2020, at 00:51,
)
wrote:
External email: is it safe to open attachments and links?
Gary,
While we do not think it would be productive to rehash the history of our communications, we have always been and
remain open to a voluntary interview in lieu of one compelled under U.K. law. However, your client has neither
offered nor agreed to sit for a voluntary interview. That has left us no choice but to pursue a compelled interview.
You have asked about the confidentiality of any witness interview. We have previously told you, by email dated
February 4, 2020, and reiterate here, that it is our standard practice to refrain from publicly commenting on the
substance of any witness interview, and we intend to abide by that practice in this case. It is also our standard
practice to disclose information provided during a witness interview only in connection with an ongoing criminal
investigation or proceeding, any related civil or forfeiture proceeding initiated by this Office, or as otherwise
authorized under U.S. law. We do not voluntarily share information with the press or civil litigants or members of
the public, and it is entirely unclear why you believe we might do so here.
Give us a commitment that your client will sit for a voluntary interview with us, give us a date or dates that work for
you and your client, and we will be happy to schedule a call to discuss any additional arrangements or particular
concerns you may have. But until we have a commitment from your client to sit for a voluntary interview - and to
do so on a timeline that reflects the urgency of our ongoing investigation - we will continue to pursue a compelled
interview through all available legal channels.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Monday, July 06, 2020 09:15
To:
Cc: Daniel Cundy
Jennifer Richardson
Subject: Re: Sensitive correspondence
Dear
Thank you for your email of 2 July 2020, sent late in the evening UK time.
It appears that there may be cultural differences between UK and US legal practice that are causing
problems in our communications. Normally in UK practice, any written communication is acknowledged
promptly and any differences between the parties are identified in that correspondence. Following our
emails of 3 and 8 June 2020, I had expected the DOJ to at least acknowledge our email of 8 June 2020. I
did not expect to have to chase for an acknowledgment, let alone a response, on 1 July 2020.
I remain very keen to discuss a path for the Duke's voluntary cooperation, without necessity for compelled
process under the MLAT. I believe that through a cooperative agreement which could be reached, the Duke
would be able to provide answers to any relevant questions you may have.
I am disappointed that your email response of 2 July 2020 seems to suggest that the DOJ has no interest in
discussing the practical arrangements that obviously need to made to allow us to advise the Duke of York
that he should agree a process under which he provides witness evidence to you. For that discussion to
take place I would invite you to indicate what protections might be available to ensure that this process is
fair and does not turn into a media circus.
Insofar as you complain about our public statement on 8 June 2020, this solitary public comment was
made in response to what I believe have been highly unusual public statements and persistent and
deliberate leaks to the press by the DOJ, including the latest leak of the fact that there had been a mutual
legal assistance request.
However, I acknowledge that both sides appear to have quite different views as to how we have reached
this position and who is in the right. May I therefore suggest that we start afresh, and both make a good
EFTA00023787

=== Page 6 ===
faith attempt to reach an agreement which will allow the Duke of York to provide the potential evidence
you seek.
I do not believe that this agreement can be achieved by the DOJ unilaterally insisting that the Duke must
commit to a voluntary cooperation without any guarantee that he would have even the limited protection
that he would be given in the context of a request for mutual legal assistance. In the mutual legal assistance
process in the UK, for example, he could only be required to answer questions and provide evidence that
are demonstrably relevant to a US criminal trial. Whatever evidence he provides may only be used for the
US criminal proceedings and cannot be given to the press or deployed by civil claimants' lawyers. The
overall confidentiality of the evidence taking process is supervised by a judge.
In those circumstances I do urge you to agree that we should at least attempt to iron out the cultural
differences and practical issues between us by speaking on a call in the very near future.
I look forward to hearing from you regarding a time you might be available to speak by telephone.
Kind regards
Gary
Gary Bloxsome Partner
Coronavirus - COVID-19 - A message to our clients and fellow professionals
All of the partners of the firm are still working and their contact details can be found on our website at
www.blackfords.com In addition we have a team of key workers supporting us across all offices. We
continue to take instructions from existing and new clients.
As a consequence of the coronavirus pandemic and the need to ensure the safety of our staff, the firm
will be operated by a limited number of key personnel.
Family Court hearings and proceedings - these are operating through video and telephone hearings.
Our family team is operating as normal.
Criminal and Regulatory hearings - most court and tribunal hearings are being adjourned but you
must please stay in contact with us to check hearing dates and deadlines until we have confirmation
that they have been moved or extended. For individuals held in custody, cases are being dealt with
where social distancing measures or electronic hearings can be implemented.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 2 Jul 2020, at 22:07,
)
wrote:
EFTA00023788

=== Page 7 ===
External email: is it safe to open attachments and links?
Gary,
There is nothing under active consideration because you have not proposed anything for consideration. To the
contrary, in your email of June 8, you stated: "we cannot commit to a particular form of cooperation until we are
properly informed and assured as to what protections, including as to confidentiality and use, are to pertain." We
note that notwithstanding your professed interest in confidentiality, that email was followed almost immediately by
a public release issued in your name that contained any number of false and misleading characterizations of your
dealings with our Office and your client's purported interest in cooperation.
If and when you are prepared to arrange a date for your client to sit for an interview with our Office, we assume
you will let us know, and we will be happy to discuss the particulars of such an interview. Until such an interview
is arranged, we will continue to report to the authorities in the UK, through the appropriate channels, that there has
been no offer of a voluntary interview, nor any likelihood of one being scheduled, and that we will therefore have
no alternative but to pursue a compelled interview via formal request.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Wednesday, July 01, 2020 12:28
To:
)
Cc: Daniel Cundy
>; Jennifer Richardson
Subject: Sensitive correspondence
Dear
I refer to our email dated 8th June 2020. We have not received any response from you. We assume it is still under
active consideration by your department. If it would assist we would welcome a telephone conference to discuss
the matter further.
Kind regards
Gary
Coronavirus - COVID-19 - A message to our clients and fellow professionals
All of the partners of the firm are still working and their contact details can be found on our website at
www.blackfords.com. In addition we have a team of key workers supporting us across all offices. We
continue to take instructions from existing and new clients.
As a consequence of the coronavirus pandemic and the need to ensure the safety of our staff, the firm
will be operated by a limited number of key personnel.
Family Court hearings and proceedings - these are operating through video and telephone hearings.
Our family team is operating as normal.
Criminal and Regulatory hearings - most court and tribunal hearings are being adjourned but you
EFTA00023789

=== Page 8 ===
must please stay in contact with us to check hearing dates and deadlines until we have confirmation
that they have been moved or extended. For individuals held in custody, cases are being dealt with
where social distancing measures or electronic hearings can be implemented.
In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling
where we will respond to the messages in the order they are received or by emailing your
enquiry to
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in ourPrivacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
RANKED IN
Chambers
UK
2020
Leading Firm
LEGAL
500
UNITED
KINGDOM
TOP TIER
2020
EFTA00023790


c1: EFTA00025420
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025420.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
MCC NEW YORK
Saturday August 10, 2019
NEW YORK, NY
Page 1
Daily Assignment Roster
6 07:00 15:00
9 12:00- 20:00
3 06:00 14:00
8 08:00 16:00
10 14:00- 22:00
12
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oT
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oT
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****Special Assignments****
10/2019 10:46:54 AM
EFTA00025420

=== Page 2 ===
Saturday August 10, 2019
Page 2
PHONE RM
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COP
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Ret
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8
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[SWAP]
$J 7/30 20:22
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11 SOUTH #2
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[Sick / Annual]
<Unassigned>
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[Removed]
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10/2019 10:46:56 AM
EFTA00025421

=== Page 3 ===
Saturday August 10, 2019
Page 3
Relieved Officer's
Relieving Officer's
Ret
Post
Splt Shft Officer
New Status
Relleving Officer
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SHU #3
3 <Unassigned>
-
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Y RW 8/5 08:43
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-
OT 08:00 14:00
UNIT 3
[
CONTROL #2
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Y
RW 8/5 08:45
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Staff
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L
OT
Day Off
L
8 <Unassigned>
12 10 SOUTH #1
Y
RW 8/5 08:46
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Staff
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OT
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RW 8/5 08:58
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[Inserted]
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Y
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10/2019 10:46:57 AM
EFTA00025422

=== Page 4 ===
Saturday August 10, 2019
Page 4
Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
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12 <Unassigned>
$
[Sick / Annual]
SJ 8/6 20:15
[Sick / Annual]
$
[Removed]
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2
$
[Sick / Annual]
<Unassigned>
RW 8/7 08:30
7 SOUTH
2
<Unassigned>
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2
<Unassigned>
$
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Y RW 8/7 08:31
Shift
Staff
OT/CT Start End
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$
OT
OSP #1
$
$
[Sick/Annual]
RW 8/7 08:36
[Inserted NCS]
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<Unassigned>
$
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RW 8/7 08:36
SHU #2
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$
2 INTERNAL
Y RW 8/7 10:07
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Staff
OT/CT Start End
SHU #2
$
OT
INTERNAL
$
[Sick / Annual]
[Removed]
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2
[Sick / Annual]
<Unassigned>
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[Inserted NCS]
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oT
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OT
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Staff
OT/CT Start End
SHU #1
oT
SHU #1
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10/2019 10:46:57 AM
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=== Page 5 ===
Saturday August 10, 2019
Page 5
Relieved Officer's
Relieving Officer's
Ret
New Status
Relieving Officer
Previous Status
Shft Changed By
Post
Spit Shft Officer
8 <Unassigned>
F
12 11 NORTH
Y
GA 8/9 22:09
5 SOUTH
Shift
Staff
OT/CT Start End
5 SOUTH
R
OT
11 NORTH
R
GA 8/9 22:28
[Inserted NCS]
0
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(sp)LOBBY #2
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Shift
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OT
7 SOUTH
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Shift
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[Sick / Annual]
<Unassigned>
SJ 8/10 06:04
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Shift
Staff
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OT
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OT
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[Sick / Annual]
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10/2019 10:46:57 AM
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=== Page 6 ===
Saturday August 10, 2019
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Relieved Officer's
Relleving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
5 NORTH
8
<Unassigned>
8 SEARCH OFFICER
SJ
8/10 06:23
CONTROL #1
8
<Unassigned>
8 UNIT 3
SJ
8/10 06:27
UNIT 3
8
<Unassigned>
2 UNIT 3
Y SJ
8/10 06:27
Shift
Staff
OT/CT Start End
UNIT 3
0
OT
UNIT 3
ACT LT
10
[Sick / Annual]
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SJ
8/10 06:44
[Sick / Annual]
[Removed]
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8/10 06:44
ACT LT
10
<Unassigned>
$
3 ACT LT
SJ
8/10 06:44
ACT LT
3
<Unassigned>
$
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SJ
8/10 08:31
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Y SJ
8/10 10:28
Shift
Staff
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OT
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Y
SJ
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Shift
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OT
SHU #2
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[Inserted NCS]
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<Unassigned>
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SJ
8/10 10:32
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[Time Change]
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8/10 10:33
Shift
Staff
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OT
08:00
16:00
SHU #2
8
$
[Sick / Annual]
<Unassigned>
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8/10 10:33
[Sick / Annual]
$
[Removed]
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8/10 10:33
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<Unassigned>
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8/10 10:33
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8
<Unassigned>
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OT
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QT
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[Sick / Annual]
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8/10 10:34
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8/10 10:35
INTERNAL
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[Sick / Annual]
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SJ
8/10 10:35
[Inserted NCS]
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8/10 10:36
INTERNAL
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<Unassigned>
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8/10 10:37
10/2019 10:46:58 AM
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=== Page 7 ===
Saturday August 10, 2019
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Relieved Officer's
Relieving Officer's
Ret
Post
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
10 SOUTH #2
3 <Unassigned>
[Sick / Annual]
SJ 8/10 10:38
10 SOUTH #2
3
[Time Change)
SJ 8/10 10:38
Shift
Staff
OT/CT Start End
10 SOUTH #2
oT
08:00 14:00
SHU #1
8
[Sick / Annual]
<Unassigned>
SJ 8/10 10:38
[Sick / Annual]
[Removed]
SJ 8/10 10:38
SHU #1
8
<Unassigned>
$
8 VISIT #1
SJ 8/10 10:38
UNIT 3
8
[Sick / Annual]
<Unassigned>
SJ 8/10 10:39
[Sick / Annual]
[Removed]
SJ 8/10 10:39
UNIT 3
8
<Unassigned>
12 10 SOUTH #1
Y SJ 8/10 10:39
Shift
Staff
OT/CT Start End
UNIT 3
OT
10 SOUTH #1
[Sick / Annual]
$
[Removed]
SJ 8/10 10:40
VISIT #2
8
$
[Sick / Annual]
<Unassigned>
SJ 8/10 10:40
[Sick / Annual]
[Removed]
SJ 8/10 10:40
VISIT #3
8
[Sick / Annual]
<Unassigned>
SJ 8/10 10:40
5 SOUTH
12
Sick Leave
<Unassigned>
SJ 8/10 10:41
SHU #1
12
Sick Leave
<Unassigned>
SJ 8/10 10:41
***Recapitulation****
Morning Watch
8
AM Watch
1
Day Watch
10
PM Watch
3
Evening Watch
12
**Back Page Categories**
Day Off
64
Sick Leave
11
Annual Leave
5
COP
2
Total Correctional Svcs. Staff: 116
Non Correctional Svcs. Staff: 7
Overtime Occurrences: 25
Comptime Occurrences: 0
Ops Lt. Evening Watch Signature:
Captain's Signature:
10/2019 10:46:58 AM
EFTA00025426


c1: EFTA00025041
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025041.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Date: Mon, 25 Oct 2021 23:00:33 +0000
Attachments: GX-744.pdf; GX-741.pdf; GX-742.pdf; GX-743.pdf
Jeff,
Thanks for speaking earlier. Attached are the exhibits we discussed. If possible, it would be helpful to know by the end of
the week which custodian we should be speaking with.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Monday, October 25, 2021 1:07 PM
To:
Subject: [EXTERNAL] Re: Subpoena to Interlochen Center for the Arts
Hi
- I'm ready to talk anytime.
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 22, 2021 at 2:45 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Thanks very much. Let's plan to talk at 1 p.m. on Monday, if that works.
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 22, 2021 1:55 PM
To:
Subject: [EXTERNAL] Re: Subpoena to Interlochen Center for the Arts
Monday afternoon works. Today is shot.
EFTA00025041

=== Page 2 ===
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 22, 2021 at 1:25 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. Are you available for a call today or Monday to follow up on our conversation about a records
custodian testifying at trial?
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, May 14, 2021 10:50 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
I just reached out to Interlochen and they do not have a color version.
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, May 14, 2021 at 10:38 AM
EFTA00025042

=== Page 3 ===
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>, "
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Received, thanks very much Jeff. Do you have a color copy of the photograph on page 87?
Best,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, May 13, 2021 4:41 PM
To:
Cc:
)
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Attached is what went in the mail today.
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: Wednesday, May 12, 2021 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on this.
Thanks,
EFTA00025043

=== Page 4 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Monday, April 26, 2021 10:32 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
I'm working on it and hope to have it complete and ready in the next couple of days.
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: Monday, April 26, 2021 at 9:28 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Could you please let us know when you expect to produce these materials?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, March 26, 2021 5:33 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Alison-
Just confirming receipt. Also, I'm hopeful that we can have everything gathered by April 12th. However, l'll be out of the
office for the next week so it might be delayed. Will that be a problem?
EFTA00025044

=== Page 5 ===
In addition, and just for confirmation's sake, you are ok that we will make reasonable efforts to notify the
parents/students of the subpoena prior to compliance with the subpoena correct?
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, March 26, 2021 at 3:37 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
Thanks again for taking the time to speak with me this morning. As we discussed, I'm attaching a subpoena for additional
student records.
Thank you,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Sounds good. Yes, that is the best number.
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
EFTA00025045

=== Page 6 ===
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, March 25, 2021 at 4:40 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Thanks so much-let's plan to talk at 9:30 tomorrow morning, if that works for you. Is this the best number to reach you
then: 231-947-0400
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:32 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm available between 9am and 10am, and then again after 11am.
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, March 25, 2021 at 3:41 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
EFTA00025046

=== Page 7 ===
Hi Jeff,
Hope you're doing well. Are you available for a quick call tomorrow morning?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, January 7, 2021 11:10 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
231-947-0400
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, January 7, 2021 at 10:37 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff- what is the best number to reach you this morning? Thanks.
Sent from my iPhone
On Jan 5, 2021, at 3:21 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me.
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
EFTA00025047

=== Page 8 ===
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 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
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,
EFTA00025048

=== Page 9 ===
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
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:
)"
i
(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:
is
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
EFTA00025049

=== Page 10 ===
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,
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:
II
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(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
EFTA00025050

=== Page 11 ===
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
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
EFTA00025051

=== Page 12 ===
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still
be grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or
determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com>, "Donnini, George B." <donnini@butzel.com>
EFTA00025052

=== Page 13 ===
Cc:
)"
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would
you please confirm that your production included all records of any tuition payments that Epstein (or his entities)
made for any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow
and will have limited availability this week, but my colleagues
and
(both cc'd) should be
able to coordinate with you as needed.
Best,
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.
EFTA00025053

=== Page 14 ===
From:
II
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>, II
)"
:
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
EFTA00025054


c1: EFTA00026622
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026622.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
[Type text]
A. Public Corruption Unit
The Public Corruption Unit, consisting of about 20 AUSAs, including two supervisors, had
a busy year focusing on both traditional corruption offenses and abuses of power by both local and
national in scope. The Unit charged numerous law enforcement and correctional officers in the
New York City area with various abuses of power, including an excessive force prosecution
involving a mentally disturbed homeless victim, and multiple federal correctional officers,
including one who has since pled guilty to sexually assaulting numerous female inmates under his
watch. The Unit also brought charges of national significance, including campaign finance and
related charges against Lev Parnas and Igor Fruman, among others; extortion and fraud charges
against attorney Michael Avenatti, and sex trafficking charges against former financier Jeffrey
Epstein.
At the local level, the Unit successfully prosecuted both local and federal officials,
including a former NYPD Detective who used his position to facilitate a scheme to steal tens of
thousands of dollars from dozens of New York victims. U.S. V. Bonanno, 18 Cr. 427 (PGG). The
Unit also brought charges against a sitting Brooklyn Supreme Court Justice for obstructing a
federal investigation into fraud and corruption at the Municipal Credit Unit ("MCU") whose board
she chaired. U.S. V. Ash, 19 Cr. 780 (LAK). Finally, the Unit brought charges against three federal
correctional officers at the MCC, one for abusing his position to sexually assault numerous female
inmates under his watch over a multi-year period, U.S. V. Akparanta, 19 Cr. 363 (LGS), and two
for falsifying records intended to conceal their failure to conduct routine rounds and checks on the
night Jeffrey Epstein, then an inmate at the MCC, committed suicide. U.S. V. Noel et al., 19 Cr.
830 (AT).
At the national level, the unit brought campaign finance and related charges against four
defendants, including Lev Parnas and Igor Fruman, based on their participation in a scheme to
funnel money to political candidates and committees in the hope of gaining access and influence,
including with respect to their efforts to cause the removal of the then-U.S. Ambassador to
Ukraine. U.S. V. Parnas, 19 Cr. 725 (JPO). The unit also successfully prosecuted the operator of
a fraudulent political action committee ("PAC") for defrauding tens of thousands of victims into
making what they believed to be political or cause-specific contributions under false pretenses,
obtaining over $1.5 million in restitution and forfeiture for victims at sentencing. U.S. V. Tierney,
18 Cr. 804 (JMF).
The Unit's work in 2019 extended beyond the traditional realm of public officials. In early
2019, the Unit brought novel extortion charges against attorney Michael Avenatti for attempting
to extort tens of millions of dollars from the athletic apparel company, Nike. U.S. V. Avenatti, 19
Cr. 373 (PGG). Avenatti was also charged in a separate scheme to defraud his former client
Stephanie Clifford a/k/a "Stormy Daniels," U.S. V. Avenatti, 19 Cr. 374 (JMF). In July 2019, the
unit brought sex trafficking charges against the former financier Jeffrey Epstein who over a multi-
year period abused dozens of minor victims in New York, Florida and other locations. U.S. V.
Epstein, 19 Cr. 490 (RMB). While Epstein committed suicide while awaiting trial, at a unique
hearing held in connection with the entry of an order of nolle prosequi, dozens of Epstein's victims
were afforded an opportunity to address the Court and publicly confront their abuser. Finally, in
2019, the Unit successfully completed its prosecution of three cases stemming from corruption in
EFTA00026622

=== Page 2 ===
State of the Office 2018
Page 2
the world of college basketball, including trying to verdict bribery charges against two defendants
for making cash payments to university coaches. U.S. V. Evans, 17 Cr. 684 (ER), U.S. V. Person,
17 Cr. 683 (LAP).
EFTA00026623


c1: EFTA00025090
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025090.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Travel Authorization 11061344 approved by
, now awaiting further
approval
Date: Fri, 21 Feb 2020 18:39:52 +0000
Importance: Normal
Dear
Travel authorization 11061344 has been approved by
, now awaiting further approval.
Trip ID: 11061344
Traveler name:
Purpose: R20NYS13402 - Epstein Investigation - Witness interview
Destination: Los Angeles, CA, United States
Dates: 2020-02-26 - 2020-02-29
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
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EFTA00025090


c1: EFTA00024516
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024516.pdf
c6: pdf
c7: images
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=== Page 1 ===
From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:38:39 +0000
Inline-Images: image001.png
Thanks so much,
From
Sent: Thursday, July 2, 2020 2:38 PM
To
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Huge congrats.
From
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA JUSTITIA OF OFFICE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
EFTA00024516

=== Page 2 ===
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00024517

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
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[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00024518


