# docs_fts_content

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=== Page 1 ===
From:
)"
To:
Subject: RE: EMail 1 of 2: EPSTEIN -
, signed application/affidavit
Date: Thu, 29 Oct 2020 17:48:31 +0000
Inline-Images: image001.jpg; image002.jpg
Great, thank you so much.
Best,
Assistant United States Attorney
Southern District of New York
New York NY 10007
From:
Sent: Thursday, October 29, 2020 1:48 PM
To:
is
Subject: RE: EMail 1 of 2: EPSTEIN
signed application/affidavit
I've included them.
Have a great night.
COURT
Arraignment Unit Clerk
United States District Court
Southern District of New York
New York, NY 10007
5
DISTRICT
0
From:
Sent: Thursday, October 29, 2020 1:31 PM
To:
Subject: RE: EMail 1 of 2: EPSTEIN
,
signed application/affidavit
CAUTION - EXTERNAL:
Received, thank you very much,
I noticed that the affidavit does not have the exhibits attached. To make sure they are maintained in the court's file,
attached are the four exhibits that we submitted with the affidavit.
EFTA00018402

=== Page 2 ===
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Thursday, October 29, 2020 11:51 AM
To:
Cc:
Subject: FW: EMail 1 of 2: EPSTEIN
signed application/affidavit
Good Morning
Your signed Warrants are attached.
UNTER STATES COURT
Arraignment Unit Clerk
United States District Court
Southern District of New York
New York NY 10007
0
From:
Sent: Wednesday, October 28, 2020 7:18 PM
To:
Cc:
K
Subject: FW: EMail 1 of 2: EPSTEIN -
signed application/affidavit
From:
Sent: Tuesday, October 27, 2020 7:18 PM
To:
Subject: EMail 1 of 2: EPSTEIN -
signed application/affidavit
USDC-SDNY
EFTA00018403

=== Page 3 ===
Sent from my mobile device
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening
attachments or clicking on links.
EFTA00018404


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=== Page 1 ===
From:
To:
Cc:
Subject: Investigators scrutinizing video outside Epstein's cell find some footage unusable, according to
people familiar with the inquiry
Date: Tue, 27 Aug 2019 17:54:36 +0000
Investigators scrutinizing video outside Epstein's cell find some footage unusable, according to people
familiar with the inquiry
Washington Post
By Carol D. Leonnig and Matt Zapotosky
8/26/19
At least one camera in the hallway outside the cell where authorities say registered sex offender Jeffrey Epstein
hanged himself earlier this month had footage that is unusable, although other, clearer footage was captured in
the area, according to three people briefed on the evidence gathered earlier this month.
It was not immediately clear why some video footage outside Epstein's cell is too flawed for investigators to use
or what is visible in the usable footage. The incident is being investigated by the FBI and the Justice
Department's inspector general's office, which are attempting to determine what happened and how to assess
whether any policies were violated or crimes committed.
The footage is considered critical to those inquiries, and the revelation of an unusable recording is yet another of
the apparent failures inside the Metropolitan Correctional Center, the short-staffed Bureau of Prisons facility in
downtown Manhattan that held Epstein.
It's unclear whether the flaw in the taping affected a limited duration of the footage or whether it was a chronic
problem in the beleaguered Manhattan facility.
A Bureau of Prisons spokesman declined to comment, as did spokespeople for the FBI, the Justice Department
and the U.S. attorney's office in Manhattan.
The people who spoke about the footage did so on the condition of anonymity, citing the ongoing probe.
Epstein, a well-connected financier, had been charged in early July with sexually abusing dozens of young girls
in the early 2000s and ordered held without bond. The arrest brought a sense of long-awaited justice to those
who alleged Epstein abused them and who had earlier been dismayed by a 2008 plea deal he received to resolve
similar allegations that was widely criticized as too lenient.
That deal allowed Epstein to plead guilty to two state charges and spend just 13 months in jail, with work release
privileges. The new charges could have resulted in a prison term of as much as 45 years.
But on Aug. 10, the 66-year-old was found hanging in his cell. He was taken to a hospital, where he was later
pronounced dead. His death was ruled a suicide.
Prosecutors have since moved to drop the charges against Epstein - although they continue to investigate those
who might have conspired with him. A federal judge has scheduled a hearing for Tuesday to consider the matter
and has indicated that those who say Epstein victimized them will be allowed to speak in court.
EFTA00018870

=== Page 2 ===
Meanwhile, there has been intense scrutiny of the federal facility where he was held, which did not follow its
protocol in the handling of Epstein in several ways, officials have said.
Epstein should have been checked on every 30 minutes in the jail's special housing unit, though it had been
several hours since the last check when he was discovered as staff members delivered breakfast. Investigators are
exploring whether logs were falsified to indicate checks had occurred when they had not, a person familiar with
the matter said.
The two officers on duty when Epstein apparently hanged himself were both working overtime - one forced,
the other voluntarily, officials have said. One did not normally work as a corrections officer, though he had in the
past and was allowed to do so, officials have said.
Epstein also was supposed to have a roommate, following a July 23 incident in which he was found on the floor
of his cell with marks on his neck. Authorities suspected he had attempted suicide; Epstein said he believed he
had been attacked.
He was placed on suicide watch for about a week after that - meaning he was monitored 24-7. He was placed
back in the jail's special housing unit late in the month and, for a time, had a new roommate.
But that person was transferred the day before Epstein's death, and a new roommate was not assigned - despite
the fact that at least eight jail officials knew Epstein was not to be left alone in his cell.
New York's chief medical examiner, Barbara Sampson, ruled Epstein's cause of death a suicide on Aug. 16. The
ruling came five days after the medical examiner's office conducted an autopsy and classified the cause of death
as pending while seeking additional information.
The pathologist's autopsy found Epstein suffered fractures in his neck bones, according to two people familiar
with the findings. Among the breaks in Epstein's neck was the hyoid bone, which in men is near the Adam's
apple. Such breaks can occur in those who hang themselves, according to forensics experts and studies on the
subject. But they are typical in victims of homicide by strangulation, experts told The Post. Experts also caution
that such a break must be viewed in the context of the findings of a full autopsy to draw a conclusion about a
cause of death.
The hyoid bone becomes more brittle and is easier to break as people age. Epstein was 66.
Law enforcement officials have said they believe Epstein killed himself.
Lawyers for Epstein and his family had questioned Sampson's ruling of suicide and the thoroughness of the
investigation into Epstein's death.
"The defense team fully intends to conduct its own independent and complete investigation into the
circumstances and cause of Mr. Epstein's death including if necessary legal action to view the pivotal videos -
if they exist as they should - of the area proximate to Mr. Epstein's cell during the time period leading to his
death," the lawyers said in an Aug. 16 statement. "We are not satisfied with the conclusions of the medical
examiner."
EFTA00018871


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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: following up
Date: Wed, 16 Dec 2020 20:43:06 +0000
Embedded: RE: _following_up.msg
Sender:
Subject: RE: following up
Message-Id:
<MN2PR14MB2512B8851F6F662646AA1EEBDFC50@MN2PR14MB2512.namprd14.prod.outlook.com>
Recipient:
EFTA00019242


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=== Page 1 ===
Event: Accepted: Call re: Epstein FOIA
Start Date: 2021-03-19 13:00:00 +0000
End Date: 2021-03-19 13:30:00 +0000
Location:
133318#
Class: X-PERSONAL
Comment:
Date Created: 2021-03-11 21:10:42 +0000
Date Modified: 2021-03-11 21:10:42 +0000
Priority: 5
DTSTAMP: 2021-03-11 20:29:33 +0000
Attendee:
)
EFTA00017902


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=== Page 1 ===
Event: Accepted: Epstein Oral Argument-- Second Circuit
Start Date: 2019-02-06 15:00:00 +0000
End Date: 2019-02-06 17:00:00 +0000
Organizer:
)
Class: X-PERSONAL
Comment:
Date Created: 2019-01-09 23:30:03 +0000
Date Modified: 2019-01-09 23:30:03 +0000
Priority: 5
DTSTAMP: 2019-01-09 19:18:49 +0000
EFTA00019534


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=== Page 1 ===
/
P.Skinner
2/29/16
Brad Edwards
Stan Pottinger
A. Kramer (notes)
Re:
BE- rep-
SP - rep.
long history of litigation
BE
Int. INV. into Jetrey Epstern was donety local Palm
Beach PD 2005
- randed up app. 24 girls molasted by JC
- represented about 10 girls
-JES mo - w/ adults they'd tell B yr. old got "Came to
rich guy's house to give paid massage JE naked-
(if you want $, do x) After paid 200/300 r
Starts as massage extationate demand of sex aels
there offered DOD- 300 finders fee Victims recensted
other victims. Mother comp bined + involved PD
t
PD turned case over to FBI + USAO Must of
Issued GJ subpoenas Epstein + 4 named cb-conspirations
girls Cappr. 40+) in FL. No flight logs.
+
Entered into a non pros ul guilty plea to state ct. to
2001-2007 procery minor for prost. & immunity
from fed. pros. for SIX crimes comm. in FL
b/w 2001 r 2007
- Jery Letcart, Jay Letcowitz, Ken Stair, Roy Black,> cansel Easters
Martin Weinberg Gry Lewis - never Jerry shorgel
#
SDFL: - at of Palm Beach
t
Limited to FL in pris.
EFTA00019071

=== Page 2 ===
2
- US Attorney has said cald be prosecuted elsenhere
- Agmt. under 2255 if ictions elect to proceed
mder 2255 + forfect cin] remedres Epstein must
pay stat. min. 50K at 150k At least 12
proceeded under that proisizer
Named
- adult recriter
- recruted as minor, become recember
- naciones
-asst. in NY - -recriters
Ghislaine Mapwell - daughter of Robert Moywell-
head recenter
- Evidence = 2000
- her case unlaws
P
time)
- NO END?
,
Oreof Epstein's bf; Jean LUC Banel, has helpdget
cooperate day inv. Was served for dep. any
girls. He is wanty to ccoperate Waldnt
Cirl case 14 two to he no -showed In 2015
14 Bund wed JE for obstruction of pustice - Ford
him not to go to depostion He says lawyer and
by Epsteia duped him into missing dep.
still
Bunel hired Joe Titane in Miami for lawsit Titane
represents
contacted Brad Edwards + two of them met. Bond ufr
Stan to Titme Titane says his client has photographe
entence. Doesnt know ages of girls maybe yourself
and that Banel took photos w/o ensire dag If
subjects. There doesnt know hav to handle this
Banel wants Epstein prosecited twint 8.
EFTA00019072

=== Page 3 ===
3
- Bnnel doesnt want to amplicate Gimself.
- recently denied photos to Stan Boies Schiller office - Epsteins is there. alty
Bunel told friend Alan LNU that he has photos -
made yrs ago.
lives in Paris
may
Titane said Bund has friend named Michale Kadorh
in MIami - friend to rabbi - said to Titme Bnnd told
me he has photos.
- Kadosh spoke w/ alty in Pans for Bund who advised him
that if he has photos he should destroy them @ are
- Bund mt Stan Boies together few days later t
offered to show computer Then he cancelot
went bade to Paris + then to Asia an business
- Hope firm- to go to Paris + have computer coneged by pnf
Bnnel is afraid of being prosecited.
victimized summer DOVO 16 (8/9/93) -abut
to two 17
- taken to NY for training by MarwelltEpstein-haw to
sence men
- in (in) case, got records carr. her as his plane
- She gues to private island Little St. James - -USUI
- few miles off to Am
-
- 2000-2002 was live in 898 slave -suc Epseir &
said that in attidant -sametry happen
others.
- Primised educ. in mags. then
EFTA00019073

=== Page 4 ===
4
r
2
18 told by Epstem too old
-
turny. 19 went to Thouland to get underage girl
+ fled to Australia where lised for - decade
- filed cent busent in 2015 - detamation sult
- she want public by patty declaration in FL suit
against Maxwell
- FL sut - pn beno- crime ultims rights agt -
against Airls USAO b/c they didn't interview
-
moved to poin those suits
- in 2011 a British reporter fundher + interviewed her
about Prince Andrew Also said met Bill Claim
-said was Epstein Slc slave
-2011 was first atoy of her.
- FBI went + interviewed
-FL FBI-
302 FBI FL wants to pursue INV.
-was lung w/ parents
- dad worked @ Maralago
-dad dropped her off @ Epstein 5 house
- family under her to lave
- in 2000 Enstein was appr. 40s -50
- Dad abvid
+ lent her at to dads bfs. Two men
- may have sold her
swapped daughters
@
d
age 7. Ended after a
few years.
Sent to family member (aint) in CA @ B
- she ran away to SF
- lived w/ parents + ran away again
EFTA00019074

=== Page 5 ===
is
- long sen'es of events on street in miami
- sugar daddy boyfriends as min away
- B/W 13 + 16, picked up in 1998 by Ron
Eppinger 1/11/99, police (RBI paterial home,
fund her, arrested her, he went put for
any Contrat.
Cristo
- Nothy since 2007 other their FBI Art
- 2010 - civil depos. A Epstem firmer Litter
Bel. Eashn to Morwell were
gay to cill him Dannloaded their blade book.
Brad went to FBI, made controlled calls, they
arrested has + he went to prison For obsendin
Pled to cap. aigmt + blew deal b/c
triedto sell Balk explained have it all under
he was selly AK-475
in recorded mtgs. FBI agent
died in pait.
- Agent filed attadant in abstruction can.
- Epstein's lawyers said his property
1997-2005 flight logs manifess
CP -
- Have been told Epstein had phetos in hase in PB+NYL
USVI
CP?
(
- One photo is a photo of
w/ another girl - naked
+ in sexual pose - on his wall artistic - misible
genitals
EFTA00019075

=== Page 6 ===
6
- Photos of halad girls on Mouvells comp.
\
SW executed an PB house. Collage of photos included
nude girls incl. clients. Epstern tipped off. All compter
were gare.
says camens all over NY house. She believes
they were used for extertor or bm by Epstein. When leat
art 6 other men had to repat buek
- Videos recordy in bathom recarly? security ?
- Maxwell to Bunel twk sexually expluit photos of her
Moxwell regularly gave photo to Epstein for bday @ age 16.
- Pheto hng in are of the homes
- Savedar computers.
- Sibp. issued fr computers
Registered as sex offends in PL
USMS
level 3
Registered in NY
Repay by mule jet
1
Sex acts an planes-
Marhattan
EFTA00019076

=== Page 7 ===
7
Highly credible wtness - Hollywood adress
- abused by Epstem since
age13 In FL + an planes.
Now pregnant
Chns Armenta -aky or LA - says she wants
to be not in public about part.
wants prosecution Now has chidren thats oblig. to do
V Somety about it.
From 2014/2015. she believed it was Summer 1999
As it turns at, it was summer of two
She has lawsist against Moxevell.fo detaination Inth
is defease
She wants settlement/ing. into nonprofit to help girls
in same situation
Her father regatiated a settlement w/ Epstein tshe
- of or ney
around 2009
has a confidentiality provision limity amount
Epstein's attaneys rached at + reg. Settlement
Dd FBI search his planes? Did they find hidden
cameras?
Cancern active pedaphile.
Pitch to other projectors? no
Bar deal? not now
- 20/20 interview last spring > ABC killed it - lawyers pulled it
Bill anton "Hwo women not under age @ osn.
but they still
have it
Have purtians of diang
EFTA00019077

=== Page 8 ===
8
\ Scotland Yard investigation -all about Prince
Andrew situation - - will seed me contact into
-ACTIVE- They audio-recarded intensev.
- They will send me attrouts reporting
- Blond, part. size shape
-Wanted to have baby of her -
- same MO uf one other untim - 17yr. old -emads w/her
-As - yang as 12 but yander the better.
emailed Epstein
/ haland- mm charges handwritten note wf nameof
given - unter by Mat well.
EFTA00019078

=== Page 9 ===
Brad Edwards
Trial Attorney
roi
Farmer, Jaffe, Weissing,
Edwards, Fistos & Lehrman, P.L.
Mass Torts
425 N. Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
Class Action
Personal Injury
Wrongful Death
Whistleblower Cases
WWW.PATHTOJUSTICE.COM
STAN POTTINGER
J. STANLEY POTTINGER PLLC
0+2
EFTA00019079


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=== Page 1 ===
From:
(NY) (FBI)"
To:
(USANYS)"
Subject: Accepted: Update Conference Call - Epstein
Date: Tue, 13 Aug 2019 13:28:54 +0000
Importance: Normal
Attachments: unnamed
EFTA00019862


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=== Page 1 ===
From:
To:
Subject: https://app.criticalmention.com/app/#/report/13bd706a-5524-427c-ae46-57c34473e775
Date: Fri, 10 Jan 2020 19:58:30 +0000
Truth and Lies: Jeffrey Epstein got about 3.5 million viewers last night. Report attached.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
EFTA00018250


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=== Page 1 ===
From:
)"
To:
Subject: Read: RE: Question re Epstein Relativity
Date: Mon, 15 Mar 2021 18:13:18 +0000
EFTA00018985


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
Subject: RE: Subpoenas to Serve
Date: Mon, 19 Aug 2019 14:01:37 +0000
Doing so right now. Just going to change the dates and then proceed to send them.
From:
(USANYS)
Sent: Saturday, August 17, 2019 3:55 PM
To:
(USANYS) [Contractor]
Subject: Subpoenas to Serve
Can you send all of these out? All Epstein related. To each of them can you attach the OB211 form at the end, which I've
also attached. 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:
EFTA00018954


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=== Page 1 ===
From:
To:
Subject: Fwd: Daughter of former FBI director Comey revealed to be part of prosecution team in sex
trafficking case against billionaire Jeffrey Epstein: Shimon Prokupecz, Reporter via Twitter.
Date: Sun, 07 Jul 2019 23:50:03 +0000
Importance: Normal
FYI - can we please make sure the case agents accompany
and other AUSAs to/from court.
URGENT UPDATE
10:37pm July 06, 2019 EDT REPORTER
Daughter of former FBI director Comey revealed to be
part of prosecution team in sex trafficking case
against billionaire Jeffrey Epstein: Shimon
Prokupecz, Reporter via Twitter.
ORIGINAL PUBLIC TWEET (10:37pm July 06, 2019 EDT)
the daughter of former FBI director James Comey, is one of
the prosecutors, according to a source with knowledge of the case.
Shimon Prokupecz @ShimonPro
ESTIMATED EVENT LOCATION:
New York, NY, USA
EFTA00018147

=== Page 2 ===
ALERT VERIFICATION :
REPORTER @SHIMONPRO
Account Created: 08.13.2009
Public Tweets 16,247 I Followers 80,826
Journalist insta: @shimonpro
Track Story
Open in First Alert
EVENT TIMELINE CAPTIONS
Billionaire Jeffrey Epstein expected to be charged in a sex trafficking
scheme allegedly involving "dozens" of victims after being arrested in
Teterboro, New Jersey: News Outlet via NBC News.
Billionaire Jeffrey Epstein arrested for allegedly sex trafficking dozens
of minors and will appear in court in New York: News Outlet via The
Daily Beast.
EVENT TIMELINE DETAIL
10:27pm July 06, 2019 EDT
EFTA00018148

=== Page 3 ===
New York, NY, USA
Billionaire Jeffrey Epstein expected to be charged in a sex trafficking scheme
allegedly involving "dozens" of victims after being arrested in Teterboro, New Jersey:
News Outlet via NBC News.
OPEN IN First Alert I VIEW POST VIA NBC NEWS
New York, NY, USA
07:57pm July 06, 2019 EDT
Billionaire Jeffrey Epstein arrested for allegedly sex trafficking dozens of minors and
will appear in court in New York: News Outlet via The Daily Beast.
OPEN IN First Alert I VIEW POST VIA THE DAILY BEAST
Lists: NYC AOR
Topics: Public Safety - Legal Action
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EFTA00018149


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=== Page 1 ===
From:
To:
Subject: Accepted: Meet re Epstein
Date: Thu, 25 Apr 2019 13:26:35 +0000
Importance: Normal
Attachments: unnamed
EFTA00017792


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
March 29, 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:
We write in response to your March 8, 2021 letter, which requests the disclosure of:
(1) documents produced to Radar Online in the matter of Radar Online V. FBI, 17 Civ. 3956
(PGG); (2) "any other FOIA requests that have produced documents pertaining to any investigation
of Jeffrey Epstein or Ghislaine Maxwell"; and (3) "any materials that reflect the involvement of
the FBI-New York Office in the USAO-SDFL investigation." We address each request in turn
below.
First, you have requested that we produce to you all materials that were produced to Radar
Online pursuant to the Freedom of Information Act ("FOIA") in connection with the civil lawsuit
Radar Online V. FBI, 17 Civ. 3956 (PGG). As an initial matter, your letter fails to articulate any
legal basis for that request under Rule 16, or any other law governing criminal discovery.
Moreover, to the extent that you assert that you need to know when information received by Radar
Online through FOIA may have been published by the media, any information about the date of
publication would presumably be publicly available and, in any event, not information within the
Government's possession, custody or control.
EFTA00019599

=== Page 2 ===
Page 2
Notwithstanding the above, we have been informed by an attorney in the General Counsel's
Office of the Federal Bureau of Investigation that all materials produced pursuant to the FOIA
request made in connection with Radar Online V. FBI, 17 Civ. 3956 (PGG) are publicly available
on the FBI's website: https://vault.fbi.gov. Furthermore, and without conceding any obligation to
do so, as a courtesy, we will provide you with the cover letters that accompanied the productions
to Radar Online. The Government is providing materials stamped with control numbers
SDNY_GM_02743189 through SDNY_GM_02743292 under separate cover.
Second, you have requested that we search the files of the prosecution team¹ for "any other
FOIA requests that have produced documents pertaining to any investigation of Jeffrey Epstein or
Ghislaine Maxwell and produce to us the documents made public through the FOIA requests, the
dates the documents were produced and the identity of the recipient of the documents." Your letter
offers no legal basis for this request, and in the absence of further explanation for your request, we
see none. FOIA concerns public disclosure of agency records; it has no bearing on whether
information is subject to discovery in criminal or civil cases. See, e.g., NLRB V. Sears, Roebuck &
Co., 421 U.S. 132, 143 n. 10 (1975) ("The Act is fundamentally designed to inform the public
about agency action and not to benefit private litigants."). In particular, to the extent this request
seeks the identity of any individual or entity who made a FOIA request, along with corresponding
information about how the Government acted on such a request, we are unaware of any basis in
law for such a request, and we invite you to point us to such authority. To the extent this request
seeks materials produced in response to any FOIA request pertaining to any investigation of
Epstein, we are similarly unaware of any basis in law for such a broad request. Our discovery
obligations are not governed by FOIA but instead by Rule 16 and rules applicable to criminal
discovery, all of which we have complied with and intend to continue complying with fully.
Accordingly, we are not producing materials in response to your request at this juncture.
Third, you have requested that the Government "produce any materials that reflect the
involvement of the FBI-New York Office in the USAO-SDFL investigation." In response, the
Government is providing materials stamped with control numbers SDNY_GM_02743143 through
SDNY_GM_02743188 in response to this request as a courtesy. This production should not be
taken to indicate that the Government believes it has any obligation, under Rule 16 or otherwise,
to do so; rather, we make this production as a courtesy in response to your request.
1
Your letter erroneously asserts that the FBI's Florida office is part of the prosecution team in this
case. We would direct you to our October 7, 2020 letter to the Court, in which we detailed the
entities that are part of this prosecution team.
EFTA00019600

=== Page 3 ===
Page 3
Finally, we have considered the concern you have raised regarding the language in our
October 7, 2020 letter and have filed a letter with the Court addressing the matter.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
/s
Assistant United States Attorneys
EFTA00019601


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=== Page 1 ===
From:
)"
To:
)"
Cc:
(USANYS)"
Subject: Re: Epstein Estate update
Date: Mon, 09 Nov 2020 15:09:30 +0000
Thanks, I can join a call this afternoon, as long as you're ok taking the lead. I'll be continuing to review images
at a snail's pace during all of my calls today.
On Nov 9, 2020, at 9:55 AM,
)
wrote:
Given that today is the deadline, I would be fine pushing this call to tomorrow to make more time today. Or if
you'd prefer I can just deal with this call alone this afternoon.
Sent from my iPhone
Begin forwarded message:
From: "Weinstein, Marc A."
Date: November 9, 2020 at 9:49:47 AM EST
To:
)"
)"
Cc: Andrew Tomback
Subject: Epstein Estate update
and
Would you have time for a call this afternoon to give you an update on a new development?
Thanks,
Marc
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
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.
EFTA00019129


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Language to include
Date: Thu, 02 Jul 2020 01:37:07 +0000
Attachments: contact_list_only_31E-NY-3027571_6.26.2020.xlsx
Good Evening,
SA
has identified each of these names on the attached spreadsheet as victims in the original case
against Jeffrey Epstein. Included in the attached document is victim contact information as well as attorney
information regarding representation and contact information. This is a comprehensive list.
Lastly, would you be able to send your draft language for the VNS notifications?
Thank you,
Program Manager
FBI Victim Services Division
From:
Sent: Monday, June 29, 2020 9:05 AM
To:
Cc:
Subject: Language to include
Good Morning,
I hope each of you had a good weekend. Please find language below that has been approved by FBI NY, VSD
executive management and our OGC rep. I'm more than happy to have a call if you would like to discuss.
The FBI's Victim Services Division (VSD) is committed to providing services and support to victims of crimes
committed by Jeffrey Epstein. Though this particular indictment is focused on specific individuals, you are still
entitled to your rights, resources, and referrals as a federal victim independent of this indictment. An overview
of these services is available at www.fbi.gov/resources/victim-services If you would like to speak with a Victim
EFTA00020233

=== Page 2 ===
Specialist, or if you have any questions regarding your rights to victim services and referrals, please email
victimservices@fbi.gov.
Thank you,
Program Manager
FBI Victim Services Division
EFTA00020234


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
(USANYS)"
Subject: RE: laptop for MDC
Date: Thu, 29 Oct 2020 14:23:05 +0000
Hi
Thanks for your help with this. We spoke with
at BOP legal this morning, and she highlighted three
specific requirements for the laptop:
It must be disabled for all communications, including wifi/bluetooth
All games and entertainment programs must be disabled/uninstalled
All audio and video recording capabilities must be disabled
is conferring with the Warden in the next few days to determine whether our laptop request will be approved. If
the request is approved, we are aiming to deliver the laptop to MDC on November 16th, if at all possible. We would need
time to load the laptop with files before it goes to MDC.
Thanks so much,
From:
(USANYS)
Sent: Wednesday, October 28, 2020 2:44 PM
To:
Subject: Re: laptop for MDC
It sure we will research one tonight and place the order tomorrow. It depends on availability and delivery. Do we have a
copy of the data that goes with the drive?
Also with the ever changing policies in BOP, can you confirm that they will allow her to have a laptop. Not sure the rules at
MDC.
Sent from my iPhone
On Oct 28, 2020, at 2:22 PM,
wrote:
Perfect, thanks so much. How long would you estimate that will take?
From:
(USANYS)
Sent: Wednesday, October 28, 2020 2:20 PM
To:
Cc:
)
>;
(USANYS)
Subject: RE: laptop for MDC
We will spec out a laptop to purchase for this case.
EFTA00018257

=== Page 2 ===
From:
Sent: Wednesday, October 28, 2020 2:09 PM
To:
(USANYS)
Cc:
is
(USANYS)
Subject: RE: laptop for MDC
Thanks so much.
From:
(USANYS)
Sent: Wednesday, October 28, 2020 2:06 PM
To:
Cc:
is
(USANYS)
Subject: RE: laptop for MDC
Let me discuss with
the best options. get back to you shortly.
From:
Sent: Wednesday, October 28, 2020 1:58 PM
To:
(USANYS)
Cc:
)
is
(USANYS)
Subject: laptop for MDC
Hi
I hope you're doing well. Because of some discovery accessibility issues we're having in the Ghislaine Maxwell case, we
would like to provide a clean laptop to Maxwell in MDC for discovery review purposes. The laptop need only permit
review of standard files - word, pdf, .tif, .xls, etc. All other capabilities and programs can be disabled. I understand we
did something similar in the Avenatti case, and we'd like to do the same here. Would that be possible? It would be a
huge help to us if you could possibly prep and provide us with a laptop for this purpose.
Thanks so much-
EFTA00018258


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=== Page 1 ===
From:
To:
(USANYS) [Contractor]"
Cc:
(USANYS)"
)"
Subject: [EXTERNAL] US V Maxwell VOir Dire 11/18/21
Date: Thu, 18 Nov 2021 19:54:17 +0000
Attachments: XLBI1MAXVDF.pdf
EFTA00019417


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=== Page 1 ===
OFFICIAL RECORD
FD-1057 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Electronic Communication
Title: (U) EC for submission of Administrative
Date: 07/12/2013
Subpoena returns to case file.
From: MIAMI
MM-PB3
Contact:
Approved By: A/SSA
Drafted By:
Case ID #:
(U) EPSTEIN, JEFFREY
Synopsis: (U) To submit Administrative Subpoena returns to case file.
Full Investigation Initiated: 07/25/2006
Enclosure (s) : Enclosed are the following items:
1.
(U) Palm Beach County Health Department - Certificate of Birth for
2. (U) Metro PCS
- Subscriber Information
3. (U) Bell South
- Subscriber and Toll Information
4. (U) At&t
- Subscriber and Toll Information
5. (U) T-Mobile USA, Inc.
- Subscriber Information
Details:
The following is a list of the Administrative Subpoenas and the
associated returns which are being submitted to the case file:
Palm Beach County Health Department - Certificate of Birth for
Metro PCS
- Subscriber Information
Bell South
- Subscriber and Toll Information
At&t
- Subscriber and Toll Information
T-Mobile USA, Inc.
Subscriber Information
UNCLASSIFIED
461
EFTA00019865


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: Probate Petition and Will_pdf
Date: Sun, 18 Aug 2019 18:35:31 +0000
Attachments: Probate_Petition_and_Will_.pdf;ATT00001.htm
FYI
From:
Sent: Sunday, August 18, 2019 9:16 AM
To:
Cc:
Subject: Probate Petition and Will_.pdf
Epstein's will is attached. Lest there be any lingering doubt in your minds about what happened, Epstein
apparently either created or meaningfully amended his will on...August 8, 2019.
EFTA00018953


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=== Page 1 ===
From:
To:
Subject: discovery/brady letter
Date: Tue, 27 Oct 2020 18:54:59 +0000
Attachments: 2020-10-27_Discovery_Letter_Draft_v4.docx
I went through the comments/edits. Updated draft is attached. Can we discuss the few remaining comments briefly
(perhaps after our call with Richards)?
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00018286


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=== Page 1 ===
ase 1:20-cr-00330-AJN Document 76 Filed 11/24/20 Page 1 of 2
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100
Main
33 West 19th Street 4th Floor
917-306-6666
Cell
New York, New York 10011
888-587-4737
Fax
bc@sternheimlaw.com
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
November 24, 2020
DATE FILED: 11/24/20
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States V. Ghislaine Maxwell
20 Cr. 330 (AJN)
Dear Judge Nathan:
As counsel for Ghislaine Maxwell, I write in response to the government's letter, dated
November 23, 2020 (see Dkt 74), reporting Ms. Maxwell's conditions of detention and
confirming that she is currently in quarantine due to contact with a staff member, assigned to her
isolation pod, who tested positive for COVID-19.
The government recites a variety of allowances given Ms. Maxwell, including being
permitted out of her cell three times a week during quarantine for a maximum of 30 minutes, the
total time allotted for showering, making personal calls, and using the CorrLinks email system to
communicate with family and counsel. However, the letter presents an incomplete picture of
Ms. Maxwell's conditions of confinement.
The government fails to mention a variety of issues brought to the attention of the MDC,
including but not limited to the fact: that all email correspondence between Ms. Maxwell and
counsel was deleted in advance of the 180-day period, when deletion is expected to occur; that
after being administered two nasal swab tests, under threat of 21-day quarantine if she declined
to be tested, Ms. Maxwell was ordered to remove her COVID-protection mask for an in-mouth
inspection, further risking exposure to the virus; that Ms. Maxwell was initially quarantined
without soap or a toothbrush; that medical and psychology staff, who checked on Ms. Maxwell
daily pre-quarantine, have ceased doing so daily since quarantine and have neither informed her
of results of the COVID tests nor provided information in response to her inquiry regarding what
she should do if she becomes symptomatic.
The letter omits the fact that while staff are not supposed to enter Ms. Maxwell's
isolation cell during quarantine, an unidentified man entered to take photographs and a guard
entered to search. Further, while counsel assumed that an in-person legal visit scheduled for
Saturday, November 21, would be canceled as a result of Ms. Maxwell's quarantine status, no
notification was provided; and a request for a substituted legal call was not accommodated.
EFTA00017821

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 76 Filed 11/24/20 Page 2 of 2
LAW OFFICES OF BOBBI C. STERNHEIM
The government highlights what Ms. Maxwell is permitted but not what she is denied:
equal treatment accorded other inmates in general population. Ms. Maxwell has spent the
entirely of her pretrial detention in de facto solitary confinement under the most restrictive
conditions where she is excessively and invasively searched and is monitored 24 hours per day.
In addition to camera surveillance in her cell, a supplemental camera follows her movement
when she is permitted to leave her isolation cell and is focused on Ms. Maxwell and counsel
during in-person legal visits. And despite non-stop in-cell camera surveillance, Ms. Maxwell's
sleep is disrupted every 15-minutes when she is awakened by a flashlight to ascertain whether
she is breathing.
Ms. Maxwell is a non-violent, exemplary pretrial detainee with no criminal history, no
history of violence, no history of mental health issues or suicidal ideation. She is overmanaged
under conditions more restrictive than inmates housed in 10South, the most restrictive unit in the
MCC; or individuals convicted of terrorism and capital murder and incarcerated at FCI Florence
ADMAX, the most restrictive facility operated by the BOP. The MDC concedes that it is unable
to place her in general population for her safety and the security of the institution but fails to
explain why she is deprived of all other opportunities provided to general population inmates.
Stating that Ms. Maxwell "continues to have more time to review her discovery than any
other inmate at the MDC, even while in quarantine" gives the unfair impression that she is being
given a perquisite. However, given the voluminous discovery in this case, the most recent
production alone being 1.2 million documents, the time accorded Ms. Maxwell remains
inadequate for her to review and prepare the defense of her life.
Due to the failure of MDC's Warden and Legal Department to respond to recurring
problems and complaints, counsel have reached out to the government. While we appreciate any
assistance provided by government counsel, it has done little to redress the many concerns
regarding the disparate treatment of Ms. Maxwell.
Rather than receive second-hand information from counsel, the defense requests that the
Court summon Warden Heriberto Tellez to report directly to the Court and counsel on Ms.
Maxwell's conditions of detention.
Your consideration is greatly appreciated.
Very truly yours,
Bobbi C. Sternbeim
BOBBI C. STERNHEIM
cc: All Counsel
so ORDERED. 11/24/20
The parties are hereby ORDERED to meet
Alim D. Netto
and confer regarding Defendant's request
that Warden Heriberto Tellez directly
address Defendant's concerns regarding
Alison J. Nathan, U.S.D.J.
the conditions of her detention. The
2
parties shall jointly submit a status update
within one week of this Order.
SO ORDERED.
EFTA00017822


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=== Page 1 ===
From:
To:
)"
Cc:
"
)"
)"
Subject: Re: Epstein accounts
Date: Thu, 06 Aug 2020 18:50:54 +0000
Never mind, USVI AG not USAO. Will still forward what I got.
Sent from my iPhone
On Aug 6, 2020, at 2:31 PM,
)
wrote:
Refreshing this - please let us know? Or happy to discuss if necessary. Thanks.
On Aug 3, 2020, at 18:56,
)
wrote:
FYI, below - the AG's office at USVI is basically just trying to copy our investigation. Do we care if DB provides our
subpoenas, what they produced to us, to USVI AG?
From: Moyne, Parvin
Sent: Monday, August 03, 2020 12:12
To:
Cc: DiPiero, Joseph
Moyer, Thomas
is
Subject: RE: Epstein accounts
I hope you are well and getting some time "off" this summer. I'm reaching out via email as it may be the most efficient
way to tee-up the inquiry we have received, but we can circulate a dial-in at a convenient time for you if you'd like to
discuss anything.
Deutsche Bank has received a third-party subpoena from the Attorney General's Office of the U.S. Virgin Islands in
connection with a pending civil suit they have filed against Jeffrey Epstein's estate, the executors of the estate, and
others. One of the requests is for a copy of any government subpoenas received by the Bank relating to Epstein, and a
copy of any productions made pursuant to the subpoenas. Do we have your permission to disclose your subpoena and
our production to you to the U.S.V.I. AG? Would you prefer us to refer the office to you directly or provide you with
contact information? I'm happy to send you a copy of the U.S.V.I. AG subpoena if helpful in evaluating the request.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
Direct:
Internal:
EFTA00017795

=== Page 2 ===
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by
e-mail, and delete the original message.
EFTA00017796


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)
(USANYS)"
Bcc:
Subject: FW: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Motion to Suppress
Date: Fri, 05 Feb 2021 00:13:06 +0000
Embedded: FW:_Activity_in_Case_1:20-cr-00330-AJN_USA_v_Maxwell_Motion_to_Suppress.msg
Sender:
Subject: FW: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Motion to Suppress
Message-Id: <18ed51f7d16d473194a79f26e7a9b517@SN1P110MB0222.NAMP110.PROD.OUTLOOK.COM>
To:
To:
To:
EFTA00018018


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein
Date: Fri, 30 Nov 2018 14:38:55 +0000
Importance: Normal
Attachments: Plaintiffs_Motion_08_Civ_80736.pdf
Here's the motion for summary judgment, for example.
Original Message
Sent: Friday, November 30, 2018 9:33 AM
Subject: Re: Epstein
Thanks. And in either the state or federal action, has there been motion practice in which deposition transcripts
have been filed? Motion for summary judgement, for example?
Sent from my iPhone
> On Nov 30, 2018, at 9:28 AM,
wrote:
>
> It's in Palm Beach County Circuit Court. It's not the lawsuit the victims filed against the government to
invalidate the NPA. And it's not one of the suits the victims filed against Epstein. It's a lawsuit that an attorney
who represented multiple victims filed against Epstein for malicious prosecution. Sort of a complicated
background: previously Epstein sued the lawyer, claiming that the lawyer was involved in an unrelated fraud that
the lawyer's law partner was convicted of-- the fraud related to an Epstein business. The lawyer is now suing
Epstein for malicious prosecution, claiming that he wrongfully filed the old lawsuit in retaliation for representing
Epstein's victims.
Original Message
V V V V V V V V V V
Subject: Epstein
The December 4 trial - is that the one against DOJ or against Epstein? State or federal court?
> Sent from my iPhone
EFTA00019658


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=== Page 1 ===
From: "Stoddart, Allison"
To:
)"
"Sahni, Anjan"
Cc:
)"
i
)"
Subject: RE:
entities subpoenas
Date: Mon, 23 Sep 2019 13:09:53 +0000
Thanks,
That works for us.
Allison
From:
Sent: Saturday, September 21, 2019 3:15 PM
To: Stoddart, Allison
Sahni, Anjan
Cc:
is
Subject: RE:
entities subpoenas
EXTERNAL SENDER
Allison,
Thanks for checking in. Regarding the production format for the wire information, unless it's burdensome or the materials
are very voluminous, we'd like to receive both the Excel and PDF versions. Let us know, though, if that's an issue. For the
second question, why don't you produce the information as it's currently organized in the first instance, and we can get a
sense of the volume, structure, searchability, etc. If we then think it would be useful to receive the information by
account (which I think ordinarily is easiest for us, though may not be necessary here), we can circle back, if that all sounds
alright to you?
thanks,
From: Stoddart, Allison
Sent: Friday, September 20, 2019 14:10
To:
>; Sahni, Anjan
Cc:
is
Subject: RE:
entities subpoenas
We are preparing to produce account lists early next week. We have also started to receive certain wire information, but
wanted to discuss the format of that data with you before producing it.
First, the wire information is available in two formats that contain identical information: PDF and Excel. For each
transaction, the PDF version has a two-page summary of date, amount, sender, recipient, and other related information.
The two-page summaries are compiled chronologically into a single multi-page PDF across all of the individual's accounts.
The Excel version includes all of the same information, but each transaction is reflected in a single row. The Excel format
is more easily accessible on our end, and we assume that it is more useful for you. Therefore, we would propose to
produce only the Excel version, but please let us know if you would like the PDF compilations as well.
EFTA00019689

=== Page 2 ===
Second, the wire information is pulled by client name and is organized chronologically across all of that individual's
accounts. (Note that pulling by name also pulls in instances where the individual's name is mentioned only in the
payment details, even where the individual is neither sending nor receiving the money.) The account information for
sender and recipient is visible for each transaction, but because the account may be in the "Order," "Debit," or "Credit"
Party fields, it is not easily sortable by account number. In light of your request below, please let us know if you would like
us to organize the data by account before production. This will take a little work for the Excel format, but is feasible.
Given the volume of transactions, it would be incredibly time-consuming to reorganize the PDF compilations.
Happy to discuss further.
Thanks and have a great weekend,
Allison
Allison Stoddart I WilmerHale
250 Greenwich Street
New York, NY 10007 USA
From:
Sent: Tuesday, September 17, 2019 10:11 AM
To: Sahni, Anjan
; Stoddart, Allison
Cc:
is
Subject: RE:
entities subpoenas
EXTERNAL SENDER
Anjan,
Thanks, and this all makes sense. We're happy to get wire information on a rolling basis, and other than that I think it
probably will be most efficient for us to receive the priority categories together (as to any individual account) unless there
will be a significant time lag due to any particular type of record, which we're happy to be in touch about as you get your
arms around the materials. And as always we can be in touch as the process progresses to refine the approach as useful.
thanks,
From: Sahni, Anjan
Sent: Monday, September 16, 2019 23:44
To:
>; Stoddart, Allison
Cc:
is
Subject: RE:
entities subpoenas
Thanks,
We're aiming to provide a list of accounts (along with account types) for each of Epstein,
and
Maxwell by the end of this week or early next week.
We are prioritizing the collection of
and Maxwell documents, and will also prioritize Butterfly Trust documents.
We will do our best to organize the documents in a way that's easily digestible and will certainly provide indices. As you
EFTA00019690

=== Page 3 ===
noted, some information may be available to us sooner (e.g., wire information) than others (e.g., account statements).
Assuming that you'd prefer that we provide information quickly, we'll plan to produce such account information on a
rolling basis, but we are happy to hold off until we have collected all of the priority categories - account statements, wire
records, account opening documents, and KYC materials - for a given account. Let us know your preference.
Thanks,
Anjan
From:
Sent: Sunday, September 15, 2019 5:42 PM
To: Sahni, Anjan
Stoddart, Allison
Cc:
is
Subject: RE:
entities subpoenas
EXTERNAL SENDER
Anjan, Allison,
Following up on our discussion earlier this week, wanted to provide some additional information and to confirm some of
what we spoke about. We had talked about the likely usefulness of an index-or other description or list-of the number
and type of accounts that would be covered by the requests in each of the subpoenas; we certainly understand that may
take time, but do you have an estimate of approximately when that information would be available?
As we discussed, although the investigation continues to move forward quickly in all aspects, to the extent the pending
subpoenas are being processed in some serial order, the subpoenas relating to Ghislaine Maxwell and
dated August 16 and September 3, respectively, are more time-sensitive for us than the subpoenas relating
to Jeffrey Epstein, dated August 11. (Please note that there is a typo in the September 3 subpoena-in the "NAME" field,
the second name should say
rather than
please let us know if we need to serve a
corrected version of the subpoena for your records.)
For the Maxwell and
subpoenas, we are especially interested in incoming check and wire information, as well as
account statements, in the first instance. And as we also talked about, more generally we are prepared to receive
productions on a rolling basis, with account statements, wire records, account opening documents, and KYC materials
being prioritized in particular. And if you're able to keep us posted on the likely scope of responsive documents, we'll use
that information to further focus and target our requests.
In terms of logistics, I think I neglected to mention this on the phone, but wanted to also note that we sometimes receive
entity subpoena responses that are unusually disorganized-either not separated by account, or that only include
account statements and not other associated requested materials, or unaccompanied by an index or other way to discern
what materials are reflected in thousands or tens of thousands of pages in a production, etc. My recollection from prior
fights with
is that this is in significant part due to the fact that their records still need to be individually printed and
scanned for production (and that a fully-electronic review and production system, while in progress, is still a year or two
away). We're of course very heartened that these particular productions will go through you, which I imagine will
mitigate those issues, but we do want to formally request that any productions be organized by account, produced in
electronic format, and accompanied by indices linked to production numbers so we can make sense of what we receive.
Finally, with respect to areas of particular focus, we would like to request expedited production of any records relating to
accounts in the name of, or for the benefit of, "Butterfly Trust," in connection with the Epstein subpoenas.
Please let us know if any additional information would be useful, thanks again for talking with us last week, and we look
forward to being in touch again soon.
EFTA00019691

=== Page 4 ===
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Monday, September 09, 2019 09:04
To: Sahni, Anjan
Cc:
is
>; Stoddart, Allison
Subject: Re:
entities subpoenas
Sure, give us a call at 10:15. Talk with you then.
On Sep 9, 2019, at 09:00, Sahni, Anjan
wrote:
Thanks
We can call you at the number below. If it's possible to do 10:15, that would be great.
Best,
Anjan
On Sep 6, 2019, at 7:24 PM,
)
wrote:
EXTERNAL SENDER
That works for us. Please let us know if there's a number we should call you at, otherwise we'll be reachable then at
thanks,
From: Sahni, Anjan
Sent: Friday, September 06, 2019 19:16
To:
Cc:
is
>; Stoddart,
Allison
Subject: Re:
entities subpoenas
Thanks
10am on Monday?
On Sep 6, 2019, at 2:34 PM,
wrote:
EXTERNAL SENDER
Anjan,
EFTA00019692

=== Page 5 ===
We unfortunately have a meeting starting imminently that we expect may go a couple hours. We could do anytime
before noon on Monday, though, if there's a time then that works for you?
thanks,
From: Sahni, Anjan
Sent: Friday, September 06, 2019 12:00
To:
Cc:
is
>; Stoddart,
Allison
Subject: RE:
entities subpoenas
Many thanks, Alex. Would later this afternoon work for a call? Might 3pm or 4pm work?
Thanks,
Anjan
From:
)
Sent: Wednesday, September 4, 2019 7:47 PM
To: Sahni, Anjan
Cc:
is
Subject: RE:
entities subpoenas
EXTERNAL SENDER
Anjan,
Very good to hear from you, and I apologize for the delay in replying to your voicemail from Friday - I was on trial last
week so have spent the past couple days digging out from under piles of emails and voicemails. But we'd be happy
to speak with you regarding the subpoenas to the JPMorgan entities in connection with the Epstein investigation.
We had been in touch with Steve D'Allessandro, who was very helpful, but he also mentioned that they might bring
in outside counsel.
If you let us know a couple times that would work for you tomorrow or Friday-and I'm copying my colleagues
and
who are also working on the case-we'll get a quorum on our side and finalize a time. And please let
us know if any other information would be useful in the interim.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00019693


c1: EFTA00019819
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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
(USANYS) [Contractor]"
Cc:
)"
)"
Subject: FW: Interview notes (document management project)
Date: Fri 16 Aug 2019 04:19:50 +0000
Attachments:
Hey
I'm not sure why we got sent these in this format, but could we ask you to please separate these docs out and save them
in the relevant folders? They can go in folders here:
Please save each interview notes with the format: YYYY-MM-DD, [First name Last name], interview notes
For anyone we already have folders for, the notes can be added to the existing ones; for anybody who we don't yet have
folders, please create new subfolders in that overall one.
And of course please let us know if any questions, issues, etc - and thank you!
From:
Sent: Thursday, August 15, 2019 17:27
To:
(NY) (FBI)
is
>;
>;
Subject: Re: Interview notes
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
(NY) (FBI)
Sent: Thursday, August 15, 2019 4:25:26 PM
To:
is
)
>;
Cc:
Subject: Interview notes
EFTA00019819

=== Page 2 ===
FBI New York
VCAC/HT
C:
O:


c1: EFTA00020310
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00020310.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
1144-2081-6
Page:
1 of 9
FedEx Tax ID: 71-0427007
JEFFREY E EPSTEIN
Billing Account Shipping Address:
Invoice Questions?
IFFEREY E EPSTEIN
Contact FedEx Revenue Services
Phone:
(800) 622-1147 M-F 7-6 (CST)
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Internet: www.fedex.com
Invoice Summary Oct 27, 2003
FedEx Express Services
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602.65
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-63.90
Special Handling Charges
56.24
Total Charges
USD.$
594.99
TOTAL THIS INVOICE
USD $
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You saved $63.90 in discounts this period!
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Your payment is due by Nov 11, 2003
4-923-30001
USD $ 594.99
114420814923300018300005949948
SP 01 000001 97702 A 1 ASNGLP
FEEREY E EPSTEIN
FedEx
P.O. Box 1140
Memphis TN 38101-1140
EFTA00020310

=== Page 2 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
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Account Number:
1144-2081-6
Page:
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Adjustment Request
FAX TO (800) 548-3020
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EFTA00020311

=== Page 3 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
1144-2081-6
Page:
3 of 9
FedEx Express Shipment Summary by Payor Type
Original
Shipper
Number of Shipments
11
Transportation Charges
458.15
Base Discount
-49.45
Special Handling Charges
50.39
TOTAL
USD $
459.09
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11
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1
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144.50
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-14.45
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5.85
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1
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USD $
135.90
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12
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USD $
594.99
EFTA00020312

=== Page 4 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
1144-2081-6
Page:
4 of 9
FedEx Express Shipment Detail By Payor Type (Original)
Picked up: Oct 15, 2003
Payor: Shipper
Reference: NO REFERENCE INFORMATION
Fuel Surcharge FedEx has applied a fuel surcharge of 4.50% to this shipment.
Distance Based Pricing. Zone 8
Package sent from: 10021 zip code
Tracking ID
Sender
Recipient
Service Type FedEx Priority Overnight
G MAXWELL
Package Type FedEx Box
JEFFREY E EPSTEIN
Zone
8
Packages
1
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55.0 lbs, 25.0 kgs
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Oct 16, 2003 10:29
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153.00
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A1
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-15.30
Signed by
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6.20
FedEx Use
288221490/01618/
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0.00
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USD $
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Payor: Shipper
Reference: NO REFERENCE INFORMATION
Fuel Surcharge - FedEx has applied a fuel surcharge of 4.50% to this shipment.
Distance Based Pricing. Zone 8
1st attempt Oct 17. 2003 at 12:44 PM.
Weather delay Thunderstorm.
Tracking ID
Sender
Recipient
Service Type FedEx Standard Overnight
JEFFREY EPSTEIN
Package Type FedEx Envelope
JEFFREY E EPSTEIN
Zone
8
Packages
1
Weight
1.0 lbs, 0.5 kgs
Delivered
Oct 20. 2003 12:36
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16.00
Svc Area
A2
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-2.56
Signed by
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0.60
FedEx Use
289210380/00266
Residential Delivery
1.40
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USD $
15.44
Picked up: Oct 17, 2003
Payor: Shipper
Reference: LESLEY
Fuel Surcharge FedEx has applied a fuel surcharge of 4.50% to this shipment.
Distance Based Pricing. Zone 6
FedEx has audited this shipment for correct packages, weight, and service. Any changes made are reflected in the invoice amount.
Release signature on file.
InternetShip
Sender
Recipient
Tracking ID
JEFFREY EPSTEIN
Service Type
FedEx Priority Overnight
JEFFREY E EPSTEIN
Package Type FedEx Pak
Zone
6
Packages
1
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4.0 lbs, 1.8 kgs
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34.75
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Discount
-3.48
Svc Area
AA
Saturday Delivery
12.50
Signed by
E.PSTEIN
Fuel Surcharge
1.41
FedEx Use
522453140/01574/02
Residential Delivery
1.40
Total Charge
USD $
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EFTA00020313

=== Page 5 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
1144-2081-6
Page:
5 of 9
FedEx Express Shipment Detail By Payor Type (Original)
Dropped off: Oct 17, 2003
Payor: Shipper
Reference: NO REFERENCE INFORMATION
Fuel Surcharge - FedEx has applied a fuel surcharge of 4.50% to this shipment.
Distance Based Pricing. Zone 6
Tracking ID
Sender
Recipient
Service Type FedEx Priority Overnight
G MAXWELL
JEPSTEIN
Package Type FedEx Box
JEFFREY E EPSTEIN
Zone
6
Packages
1
Weight
2.0 lbs, 0.9 kgs
Delivered
Oct 18, 2003 10:20
Transportation Charge
28.75
Svc Area
AA
Discount
-2.88
Signed by
A.MIHORDICH
Saturday Delivery
12.50
FedEx Use
290093030/01574/
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1.16
Residential Delivery
1.40
Total Charge
USD $
40.93
Dropped off: Oct 20, 2003
Payor: Shipper
Reference: NO REFERENCE INFORMATION
Fuel Surcharge - FedEx has applied a fuel surcharge of 4.50% to this shipment.
Distance Based Pricing, Zone 8
FedEx has audited this shipment for correct packages, weight, and service. Any changes made are reflected in the invoice amount.
We calculated your charges based on a dimensional weight of 19.0 lbs.,21" x 11" * 16", divided by 194.
Tracking ID
Sender
Recipient
Service Type FedEx 2Day
DAVE RODGERS
MEDSPACE INC
Package Type Customer Packaging
JEFFREY E EPSTEIN
Zone
8
Packages
1
Weight
7.0 lbs, 3.2 kgs
Delivered
Oct 22, 2003 12:46
Transportation Charge
45.00
Svc Area
A2
Discount
-4.50
Signed by
F.DUICAN
Fuel Surcharge
1.82
FedEx Use
293216660/06112/
Total Charge
USD $
42.32
Picked up: Oct 20, 2003
Payor: Shipper
Reference: NO REFERENCE INFORMATION
Fuel Surcharge FedEx has applied a fuel surcharge of 4.50% to this shipment.
Distance Based Pricing, Zone 6
Package sent from: 33461 zip code
Tracking ID
Sender
Recipient
Service Type FedEx Priority Overnight
LARRY VISOSKI
BELLA
Package Type FedEx Envelope
JEFFREY E EPSTEIN
J EPSTEIN & CO
Zone
6
Packages
1
Weight
1.0 lbs. 0.5 kgs
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Oct 21, 2003 09:19
Transportation Charge
16.60
Svc Area
A1
Discount
-2.66
Signed by
S.FUENTES
Fuel Surcharge
0.63
FedEx Use
293088900/00230/
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USD $
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EFTA00020314

=== Page 6 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
1144-2081-6
Page:
6 of 9
FedEx Express Shipment Detail By Payor Type (Original)
Picked up: Oct 21, 2003
Payor: Shipper
Reference: NO REFERENCE INFORMATION
Fuel Surcharge FedEx has applied a fuel surcharge of 4.50% to this shipment.
Distance Based Pricing. Zone 8
Package sent from: 10021 zip code
Tracking ID
Sender
Recipient
Service Type FedEx Priority Overnight
M CAMPOS
GHISLAINE MAXWELL
Package Type FedEx Box
JEFFREY E EPSTEIN
PENINSULA HOTEL
Zone
8
Packages
1
Weight
10.0 lbs, 4.5 kgs
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Oct 22. 2003 09:48
Transportation Charge
54.75
Svc Area
A1
Discount
-5.48
Signed by
W.VELSRAIO
Fuel Surcharge
2.22
FedEx Use
294166931/01618/
Courier Pickup Charge
0.00
Total Charge
USD $
51.49
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Payor: Shipper
Reference: NO REFERENCE INFORMATION
Fuel Surcharge - FedEx has applied a fuel surcharge of 4.50% to this shipment.
Distance Based Pricing, Zone 8
Package sent from: 10021 zip code
Tracking ID
Sender
Recipient
Service Type FedEx Priority Overnight
M CAMPOS
GHISLAINE MAXWELL
Package Type FedEx Box
JEFFREY E EPSTEIN
PENINSULA HOTEL
Zone
8
Packages
1
Weight
10.0 lbs. 4.5 kgs
Delivered
Oct 22. 2003 09:48
Transportation Charge
54.75
Svc Area
A1
Discount
-5.48
Signed by
W.VELSRAIO
Fuel Surcharge
2.22
FedEx Use
294166931/01618/
Courier Pickup Charge
0.00
Total Charge
USD $
51.49
Dropped off: Oct 22, 2003
Payor: Shipper
Reference: BELLA
Fuel Surcharge FedEx has applied a fuel surcharge of 4.50% to this shipment.
Distance Based Pricing, Zone 6
InternetShip
Sender
Recipient
Tracking ID
Service Type
FedEx Standard Overnight
JEFFREY E EPSTEIN
Package Type FedEx Envelope
Zone
6
Packages
1
Weight
1.0 lbs. 0.5 kgs
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14.75
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Oct 23, 2003 14:13
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-2.36
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AA
Fuel Surcharge
0.56
Signed by
Residential Delivery
1.40
FedEx Use
523003230/00244/
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14.35
EFTA00020315

=== Page 7 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
1144-2081-6
Page:
7 of 9
FedEx Express Shipment Detail By Payor Type (Original)
Dropped off: Oct 22, 2003
Payor: Shipper
Reference: LESLEY
Fuel Surcharge FedEx has applied a fuel surcharge of 4.50% to this shipment.
Distance Based Pricing. Zone 3
InternetShip
Sender
Recipient
Tracking ID
HENRY ROSOVSKY
Service Type
FedEx Standard Overnight
JEFFREY E EPSTEIN
Package Type FedEx Envelope
Zone
3
Packages
1
Weight
1.0 lbs, 0.5 kgs
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12.80
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Oct 23, 2003 10:21
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-2.05
Svc Area
A1
Fuel Surcharge
0.48
Signed by
T.OCONNOR
FedEx Use
523093160/00211/
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USD $
11.23
Picked up: Oct 23, 2003
Payor: Shipper
Reference: JE
Fuel Surcharge FedEx has applied a fuel surcharge of 4.50% to this shipment.
Distance Based Pricing. Zone 8
Release signature on file.
InternetShip
Sender
Recipient
Tracking ID
Service Type
FedEx Standard Overnight
JEFFREY E EPSTEIN
Package Type FedEx Pak
Zone
8
Packages
1
Weight
2.0 lbs. 0.9 kgs
Transportation Charge
27.00
Delivered
Oct 24. 2003 11:04
Discount
-2.70
Svc Area
A2
Fuel Surcharge
1.09
Signed by
Residential Delivery
1.40
FedEx Use
523233200/01415/02
Total Charge
USD $
26.79
Shipment Detail Subtotal
USD $
459.09
EFTA00020316

=== Page 8 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
1144-2081-6
Page:
8 of 9
FedEx Express Shipment Detail By Payor Type (Original)
Picked up: Oct 14, 2003
Payor: Third Party
Reference: WO#3286-N908JE
Fuel Surcharge FedEx has applied a fuel surcharge of 4.50% to this shipment.
Distance Based Pricing. Zone 4
FedEx has audited this shipment for correct packages, weight, and service. Any changes made are reflected in the invoice amount.
We calculated your charges based on a dimensional weight of 63.0 lbs.,24" x 23" X 22", divided by 194.
Powership
Sender
Recipient
Tracking ID
SHIPPING DEPT
TRADE AIR
Service Type FedEx Priority Overnight
FLIGHT STAR AIRCRAFT SVCE INC
10441 NW 28TH AVENUE
Package Type Customer Packaging
14821 YONGE DR
MIAMI FL 33172 US
Zone
4
JACKSONVILLE FL 32218 US
Packages
1
Weight
15.0 lbs, 6.8 kgs
Transportation Charge
144.50
Delivered
Oct 15, 2003 10:17
Discount
-14.45
Svc Area
A2
Fuel Surcharge
5.85
Signed by
B.ALLEN
FedEx Use
063466702/01530/
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USD $
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Shipment Detail Subtotal
USD $
135.90
EFTA00020317

=== Page 9 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
1144-2081-6
Page:
9 of 9
FedEx Ground Reference Chart
SERVICE CODES
FEDEX HOME DELIVERY SERVICE CODES
ZONE DEFINITIONS
FedEx Ground
800
AutoPOD. Prepaid
0-1
Ground Service Intra-Canada
804
Prepaid
2-6
Ground Service 48 contiguous states and Intra-Canada
808
Signature, Prepaid
7-8
Ground Service 48 contiguous states
015
AutoPOD Prepaid, Domestic
810
Evening, AutoPOD, Prepaid
9
Service to Hawaii
016
COO. Prepaid, Domestic
814
Evening, Prepaid
10
Service to Puerto Rico
017
ECOD, Prepaid Domestic
818
Evening, Signature Prepaid
14
Service to Oahu
018
FedEx Ground PRP, Prepaid, Domestic
820
Date Certain, AutoPOD. Prepaid
17
Service to Alaska
019
Prepaid, Domestic
824
Date Certain, Prepaid
22
Service within Alaska
020
AutoPOO Collect, Domestic
828
Date Certain, Signature, Prepaid
23
Service from Alaska
021
Collect. Domestic
830
Appointment AutoPOD. Prepaid
25
Service from Alaska
131
Ground 3rd Party, Returns Manager
834
Appointment Prepaid
51 Service to Canada
136
Ground Prepaid Net Return
836
Home Delivery, 3rd Party, Returns Manager
92 & Service from Hawaii (Deferred)
137
Ground Prepaid Returns Manager
842
Home Delivery, Prepaid, Returns Manager
408
Guaranteed Funds COD. Prepaid Domestic
850
Bill 3rd Party
409
Cash COD. Prepaid, Domestic
851
Bill 3rd Party, Auto POD
410
AutoPOD COO, Prepaid Domestic
852
Bill 3rd Party, Signature
412
AutoPOD. ECOD, Prepaid, Domestic
853
Evening Bill 3rd Party
415
AutoPOD. Guaranteed Funds COD, Ppd. Dom.
854
Evening, Bill 3rd Party, AutoPOD
OTHER CHARGE CODE DEFINITIONS
416
AutoPOD. Cash COD. Prepaid, Domestic
855
Evening Bill 3rd Party, Signature
417
Bill 3rd Party, Domestic
856
Date Certain, Bill 3rd Party
418
Bill 3rd Party, AutoPOD Domestic
857
Date Certain, Bill 3rd Party, AutoPOO
419
Bill 3rd Party, COD. Domestic
(1)
C.O.D. (Collect on Delivery)
858
Date Certain, Bill 3rd Party, Signature
420
Bill 3rd Party, Guaranteed Funds COO, Dom
(2)
A.O.D. (Acknowledgement of Delivery)
859
Appointment Bill 3rd Party
421
Bill 3rd Party, Cash COD, Domestic
(3)
Cal Tag
860
Appointment Bill 3rd Party, AutoPOD
422
Bill Recipient, Domestic
(4)
Oversize > 84" Combined Length and Girth
869
Bill Recipient
423
(5)
Declared Value
Bill Recipient, AutoPOD Domestic
870
Bill Recipient, AutoPOD
429
ECOD, Bill 3rd Party, Domestic
(6)
Address Correction
871
Bill Recipient, Signature
3
Hazardous Material
430
AutoPOD, COO. Bill 3rd Party, Domestic
872
Evening, Bill Recipient
431
AutoPOD. ECOD, Bill 3rd Party, Domestic
(8)
Automatic Proof of Delivery
873
Evening, Bill Recipient, AutoPOD
432
AutoPOD. Cash COD. Bill 3rd Party, Domestic
(9)
Additional Handing
874
Evening, Bill Recipient, Signature
433
AutoPOD. Guaranteed Funds COD, Bill 3rd Party, Dom
(10)
Oversize Extra Service Fee
875
Date Certain, Bill Recipient
434
ECOD. Bill Recipient, Domestic
(11)
Overweight 150 bs
876
Date Certain Bill Recipient, AutoPOD
435
(12)
Electronic C.O.D. 24 hours
AutoPOD COO, Bill Recipient, Domestic
877
Date Certain, Bill Recipient, Signature
436
AutoPOD ECOD, Bill Recipient Domestic
(13)
Electronic C.O.D. 48 hours
878
Appointment, Bill Recipient
437
AutoPOO. Cash COD. Bill Recipient Domestic
(14)
FedEx Ground Residential
879
Appointment, Bill Recipient, AutoPOD
438
AutoPOD. Guaranteed Funds COD, Bill Recipient, Dom
(15)
FedEx Ground Residential Rural
439
Ground Prepaid, Guaranteed Funds, ECOD
(16)
Returns Manager Transmission Fee
(20)
FedEx Signature Home Delivery
(21)
FedEx Date Certain Home Delivery
FedEx International Ground
(22)
FedEx Appointment Home Delivery
(23)
FedEx Evening Home Delivery
(24)
FedEx Home Delivery Residential
022
AutoPOD, Prepaid
(25)
FedEx Home Delivery Residential Rural
023
COO, Prepaid
(26)
Cash C.O.D. Charge
026
Prepaid
(27)
Cash C.O.D. High Density Charge
027
AutoPOD. Collect
(28)
Cash C.O.D. Extra Difference Charge
028
Collect
(29)
Proof of Delivery Advantage Charge
135
International Ground 3rd Party, Returns Manager
(30)
FedEx Home Delivery Forced Appointment
478
Guaranteed Funds COD. Prepaid
(35)
Fuel Surcharge
479
Cash COD. Prepaid
(36)
Oversize > 108" Combined Length and Girth
480
AutoPOD. COO. Prepaid
(37)
Oversize > 108" in Length
485
AutoPOD. Guaranteed Funds COD, Prepaid
(38)
Oversize > 130" Combined Length and Girth
486
AutoPOO. Cash COD. Prepaid
(39)
Supplemental Oversize Package Charge
487
Bill 3rd Party
(40)
Canada Goods & Services Tax GST
488
Bill 3rd Party, AutoPOD
(41)
Canada Harmonized Sales Tax HST
489
Bill 3rd Party, COD
(42)
Canada Quebec Sales Tax OST
490
Bill 3rd Party, Guaranteed Funds COO
(44)
Net Return
491
Bill 3rd Party, Cash COD
(45)
Credit Card Decline Surcharge
492
Bill Recipient
(46)
Consolidated Returns Polybag
493
Bill Recipient, AutoPOD
(47)
Consolidated Returns Package 2x2x4 2x6x8
(48)
Consolidated Returns Package 4x4x6 4x8x12
(49)
Consolidated Returns Package 6x6x10 6x10x16
(50)
Consolidated Returns Package 8x10x12 10x12x16
(51)
Consolidated Returns Package Fill Charge
(52)
Consolidated Returns Oversize Package Charge
(53)
Returns Manager
(54)
Canadian Dropship Linehaul Charge
EFTA00020318


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=== Page 1 ===
From:
)"
To:
Cc:
)"
Subject: Re: Epstein
Date: Tue, 27 Aug 2019 12:49:57 +0000
Hi
,
Thanks very much for letting us know. Would you please give me a call on my cell when you have a moment?
It's
On Aug 27, 2019, at 8:46 AM,
wrote:
Hi
Just a heads-up that Judge Berman invited the Warden and I to the hearing this morning. The Warden declined
because of another meeting and asked to meet the Judge at a later date, but I'll be attending. I asked
if
Judge Berman's expectation was for me to sit at counsel's table or in the galley, but she never responded. In
that case, I defer to you unless we hear otherwise when we get there.
Thanks,
Staff Attorney
CLC New York
Metropolitan Correctional Center
New York, NY 10007
)"
7/30/2019 7:11 PM
Hi
and
Is the investigation into Jeffrey Epstein's injuries still ongoing? I ask because we have a conference before Judge Berman
tomorrow morning, and we expect that he will ask us about what happened at the MCC. If the investigation is still
ongoing, we will tell him that. If it has been completed, would you please send us any new reports and whatever
documentation sets forth the conclusions that the investigators reached?
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00019990

=== Page 2 ===
New York, NY 10007
EFTA00019991


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=== Page 1 ===
Court Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Insured Aircraft Title Service, LLC
21 E Main Street, Suite 100
Oklahoma City, OK 73104
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the United States District Court for the Southern District of New York, 40 Foley Square, in the
Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the
following date, time and place:
Appearance Date:
November 29, 2021
Appearance Time: 9:00 a.m.
Appearance Place:
40 Foley Square, Courtroom 906
to testify and give evidence in the following matter:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
All records relating to the aircraft with tail number N750A or N722JE from January 1, 2008 to the
present
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
September 30, 2021
/s
AUDREY STRAUSS
United States Attorney for the
DEPARTMENT UNITED COURT
Southern District of New York
STATE
THE
Assistant United States Attorney
RICT
YORK
New York, New York 10007
Rev. 02.01.12
EFTA00018877


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=== Page 1 ===
From:
)"
To:
)"
Subject: Re: EMail 1 of 2: EPSTEIN -
,
signed application/affidavit
Date: Thu, 29 Oct 2020 18:03:07 +0000
You are the best!
On Oct 29, 2020, at 2:02 PM,
)
wrote:
Yep, I sent
the attachments, saved them on the share, and included them in the discovery production folder.
Thanks!
From:
(
Sent: Thursday, October 29, 2020 2:00 PM
To:
Subject: Re: EMail 1 of 2: EPSTEIN -
,
signed application/affidavit
I think the application had attachments right? We should include those on the version we save on the shared (you are
probably on top of this already)
On Oct 29, 2020, at 1:45 PM,
)
wrote:
Attached are the signed warrant materials.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From:
Sent: Thursday, October 29, 2020 11:51 AM
To:
Cc:
Subject: FW: EMail 1 of 2: EPSTEIN -
signed application/affidavit
Good Morning
Your signed Warrants are attached.
EFTA00018405

=== Page 2 ===
Arraignment Unit Clerk
United States District Court
<image003.jpg>
Southern District of New York
New York. NY 10007
From:
Sent: Wednesday, October 28, 2020 7:18 PM
To:
Cc:
Subject: FW: EMail 1 of 2: EPSTEIN -
signed application/affidavit
From
Sent: Tuesday, October 27, 2020 7:18 PM
To:
Subject: EMail 1 of 2: EPSTEIN -
signed application/affidavit
USDC-SDNY
Sent from my mobile device
<20 MAG 11668
Lpdf>
<20 MAG 11668. 1
.pdf>
EFTA00018406


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
X
N
)"
Cc:
(USANYS)"
Subject: RE: Epstein Victim Impact Statements
Date: Wed, 30 Oct 2019 20:19:07 +0000
I think it's difficult to be that precise, just because we don't have great visibility into how many (and which) victims each
lawyer represents. That said, we have consistently put every victims we're in touch with (including c/o their lawyers) into
the victim contact list, so I think the best and most accurate number would be the 39 from VNS. I can't recall anybody
who we spoke with who would have *not* been on the list at that time, though entirely possible that we were in touch
with additional victims through counsel-we spoke to Brad Edwards, Robert Josefsberg, Robbie Kaplan, and Boies Schiller,
all of whom have multiple victim clients, some of whom we don't know the identities of.
From:
(USANYS)
Sent: Wednesday, October 30, 2019 15:48
To:
(USANYS)
is
)
is
V.
Cc:
(USANYS)
Subject: RE: Epstein Victim Impact Statements
Team, were the attorneys you or agents spoke to for the same, or different victims? What is fair to represent in terms of
we spoke to at least X victims?
From:
(USANYS)
Sent: Wednesday, October 30, 2019 3:32 PM
To:
is
(USANYS)
>;
>;
Cc:
(USANYS)
Subject: RE: Epstein Victim Impact Statements
I sent out 39 notices to all the victims listed in VNS. One woman wanted to come and missed her flight the evening before
the hearing. I arranged another flight a 6:00AM the morning of the hearing and had a car waiting for her. She missed that
flight too. I believe she was either Brad Edwards client or Singrid McCally. I don't remember her name but can get it she
was a no show. Anyone that called and wanted to come was given a round trip ticket car service to and from the airport
and hotel.
From:
Sent: Wednesday, October 30, 2019 1:23 PM
To:
(USANYS)
is
>;
i
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein Victim Impact Statements
For the first question, the AUSAs contacted the attorneys we were aware of who represented victims to tell them that
their clients were welcome to attend and to make a statement. I believe
also sent out notifications, and hopefully
she can tell us how many she sent.
EFTA00017905

=== Page 2 ===
For the second question, based on my review of the transcript (attached), a total of 17 victims were present at the hearing
and either spoke at the hearing or had someone read a statement for them. An additional 7 did not attend the hearing
but had someone else speak for them or read a statement from them. It is possible there were others present who were
not referenced on the record.
I don't think we can answer the third question. I don't recall anyone off the top of my head who wanted to attend but
was unable to, but it's possible there were some in that position.
From:
(USANYS)
Sent: Wednesday, October 30, 2019 1:06 PM
To:
is
i
(USANYS)
Cc:
(USANYS)
Subject: FW: Epstein Victim Impact Statements
Importance: High
Are we able to answer these questions for ODAG quickly? I am sure we can answer the second, and maybe the first - not
sure about the third.
From:
(ODAG)
Sent: Wednesday, October 30, 2019 12:53 PM
To:
(USANYS)
Cc:
(ODAG)
Subject: Epstein Victim Impact Statements
Importance: High
,
The Petitioner in the Epstein CVRA case has filed an appeal to the 11th Circuit. One of their issues is the
District Court's refusal to hold a hearing allowing the Epstein victims to "have their day in court." The
Court's ruling is, in part, on the basis that a hearing held in SDNY satisfied this request. The Petitioner has
alleged that not all of the Epstein victims who wanted to speak were able to do so at the New York hearing
because they did not have sufficient notice and were unable to travel to NY.
Can your office provide us some details about the following: 1) how many victims were contacted about
making a victim impact statement; 2) how many victims were able to travel and make an in-person victim
impact statement; and 3) how many victims indicated they wanted to make a victim impact statement but
were unable to do so given the notice/timing of the hearing?
Please provide as much of this information as possible today. I'm very sorry for the quick turnaround but
the Department's response to the mandamus petition is due tomorrow.
I really appreciate your assistance.
National Coordinator for Child Exploitation Prevention & Interdiction
Office of the Deputy Attorney General
Direct:
EFTA00017906


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=== Page 1 ===
From:
To:
)"
Cc:
)"
(USANYS)"
Subject: RE: Follow Up Call
Date: Fri, 07 May 2021 18:13:17 +0000
No worries. I just dialed in. I don't think anyone is on the line yet. Let me know if you are and I just am not using this
properly.
From:
Sent: Friday, May 7, 2021 12:03 PM
To
Cc:
is
(USANYS)
Subject: RE: Follow Up Call
Apologies, I'm stuck on a call running a few minutes behind, but I'll dial in momentarily.
Thanks,
From
Sent: Friday, May 7, 2021 12:56 PM
To:
Cc:
is
(USANYS)
Subject: RE: Follow Up Call
In advance of our call, attached is an article that recently ran locally on this issue:
From:
Sent: Wednesday, May 5, 2021 9:26 AM
To:
Cc:
is
(USANYS)
Subject: RE: Follow Up Call
I have asked my PIO to find out if there is a deadline on this reporting that will necessitate moving up the timing of this
call. I will let you know if that turns out to be the case.
Below are the details for the conference call in number and participant code:
EFTA00019183

=== Page 2 ===
Phone Number: 866-880-0098
Participant code: 8704649#
From:
Sent: Wednesday, May 5, 2021 8:29 AM
To:
Cc:
)
is
(USANYS)
Subject: RE: Follow Up Call
Thanks for the advanced notice, we should definitely discuss, particularly since there are rules about press contacts in our
pending case that we're mindful of. 2:15 p.m. works for us. On timing, do you have a sense of when you anticipate this
happening?
From:
Sent: Wednesday, May 5, 2021 10:21 AM
To:
Cc:
is
(USANYS)
Subject: RE: Follow Up Call
As an FYI, I am really calling to get the contact information for your PIO since there will be reporting in our local news and
my USA wants to make a statement, but we want to run this by you all and your PIO first. As for time, does 2:15pm ET
work for you all? If so, I can get a conference line set up for that time.
H
From:
Sent: Wednesday, May 5, 2021 8:13 AM
To:
Cc:
)
is
(USANYS)
Subject: RE: Follow Up Call
H
Since our whole team will join to keep everyone looped in, it would be helpful to schedule a call at a particular time, if
possible. Could we pick a time on Friday afternoon and use a conference line?
Thanks,
From:
Sent: Wednesday, May 5, 2021 10:03 AM
To:
Cc:
is
(USANYS)
Subject: RE: Follow Up Call
I will reach out on Friday shortly after 2pm ET. What number should I call?
Best,
EFTA00019184

=== Page 3 ===
From:
Sent: Tuesday, May 4, 2021 7:11 PM
To:
Cc:
is
(USANYS)
Subject: Re: Follow Up Call
Hi
Hope you're doing well. We're free for a call on Friday anytime after 2 p.m. ET.
Thanks,
On May 4, 2021, at 5:00 PM,
All-
Please let me know when one of you have a moment to chat briefly about this matter.
Thanks,
From:
Sent: Monday, July 20, 2020 4:55 PM
To
Cc:
is
Subject: RE: Follow Up Call
That's perfect, thanks very much. You can call my cellphone at
as I will likely be working remotely.
From:
Sent: Monday, July 20, 2020 6:54 PM
To:
)
Cc:
is
Subject: RE: Follow Up Call
No worries about the delay. I know that it is especially difficult to keep all the balls in the air right now. I am fairly sure I
am dropping some as I type this email. I can do a call on Thursday at 1pm MT/ 3Pm ET. Should I call the office number
listed in your signature block below?
From:
Sent: Monday, July 20, 2020 4:51 PM
To
EFTA00019185

=== Page 4 ===
Cc:
is
Subject: RE: Follow Up Call
Apologies for the delay, and thank you for following up. I am available for a call any time after 1 p.m. Eastern on
Thursday 7/23. Please let me know if there is a convenient time for a call that afternoon.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, July 20, 2020 6:40 PM
To:
Cc:
>;
)
Subject: RE: Follow Up Call
All-
I am just following up on the below email request for a brief phone call. Please let me know when you have availability.
From:
Sent: Wednesday, July 15, 2020 8:41 AM
To:
)
Cc:
is
Subject: RE: Follow Up Call
Greetings from DNM,
Well done on the new indictment against Ms. Maxwell. We were pleased to see that conduct in New Mexico formed the
basis of one of your overt acts. I know that you all are very busy, but if you a moment for a brief call to discuss the
impact, if any, of the new indictment on seizure/forfeiture of Epstein's NM property, I would appreciate it. As you are
aware, this is an issue my US Attorney, John Anderson, has asked me to track.
Thanks,
From:
Sent: Tuesdav. November 19. 2019 1:59 PM
To
EFTA00019186

=== Page 5 ===
Cc:
is
Subject: RE: Follow Up Call
That works, thanks. You can reach me at my desk-212-637-2324.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York NY 10007
From
Sent: Tuesday, November 19, 2019 3:58 PM
To:
)
>
Cc:
>;
)
>; Fyffe,
Brandon (USANM) <bfyffe@usa.doj.gov>
Subject: RE: Follow Up Call
Could you do a call in 30 minutes -- 2:30pm MT/ 4:30 ET?
From:
Sent: Tuesday, November 19, 2019 12:03 PM
To:
Cc:
^
is
)
Subject: RE: Follow Up Call
Hi
I'm happy to chat today if you're available in the next few hours. Otherwise, I could do later in the day on Thursday.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York NY 10007
EFTA00019187

=== Page 6 ===
From:
Sent: Tuesday, November 19, 2019 10:33 AM
To:
Subject: RE: Follow Up Call
When you have a moment, can you let me know when we can conduct a call to discuss the reporting concerning Jane
Doe 15?
Subject: 'Jane Doe 15' Alleges Jeffrey Epstein Raped Her As A Teen, Referenced 'Good Friend' Bill Clinton - CBS Los
Angeles
https://losangeles.cbslocal.com/2019/11/18/jeffrey-epstein-bill-clinton-gloria-alred/
Thanks,
From:
Sent: Fridav. 11 2019 2:46 PM
To
Subject: RE: Follow UP can
Received, thanks very much
You're correct that we cover these topics during interviews, but it is helpful to
keep in mind the information you are interested in as well.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York NY 10007
From:
Sent: Friday, October 11, 2019 1:25 PM
To:
Subject: RE: Follow Up Call
When we last spoke, you expressed a willingness to review New Mexico-specific questions that we would like to be
included in future interviews of Epstein victims. While I am certain that you already cover the pertinent questions, we
did not want to turn down the invitation to submit a set of proposed questions, which I have attached.
EFTA00019188

=== Page 7 ===
I hope all is well with you and the ongoing investigation. As we mentioned on the phone, we are here to assist with any
investigation into New Mexico-related matters, including the submission of any application for a search warrant.
Best,
From:
Sent: Monday, September 09. 2019 10:49 AM
To:
Cc:
Subject: RE: Follow Up Call
You can call my desk at
Thanks
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York. NY 10007
From
Sent: Monday, September 9, 2019 11:27 AM
To:
is
Cc:
Subject: RE: Follow Up Call
Thank you for the response and the additional information about the NM AG's office. We look forward to speaking with
you on Thursday. What number should we call?
Thanks,
From:
Sent: Sunday, September 08, 2019 3:15 PM
To
Cc:
Subject: RE: Follow Up Call
EFTA00019189

=== Page 8 ===
H
Yes, a call on 9/12 at 1:30 MT / 3:30 ET will work for us, thanks very much.
As a preview in response to
email, we spoke with the New Mexico AG's office back in July 2019. In essence,
they agreed to cease any investigation into sex trafficking and share whatever they had gathered to date regarding sex
trafficking activity with our office. We agreed that they were free to proceed with whatever other investigations
(unrelated to sex trafficking) they may have concerning Epstein and told them that at the conclusion of our case, we
would pass along any information we may have gathered about state crimes that were committed in their jurisdiction.
We have not communicated with anyone from the New Mexico AG's office since that conversation in July 2019.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
From
Sent: Friday. Sentember 6. 2019 5:28 PM
To:
)
Cc:
is
Subject: RE: Follow Up Call
I just wanted to confirm that you all are able to do the phone call next Thursday, September 12th at 1:30 MT / 3:30 ET?
Please let me know what number we should call.
Thanks,
From:
Sent: Thursday. September 05. 2019 PM
To
Cc:
is
Subject: RE: Follow Up Call
FYI: state authorities in New Mexico are moving forward with their own plans with respect to the Epstein property.
Yesterday the state land commissioner revoked leases held by Cypress Inc.
https://www.abgjournal.com/1362185/land-commissioner-voids-epsteins-nm-grazing-leases.html
The linked news coverage quotes the New Mexico Attorney General as saying that he is conducting a criminal
investigation at the state level "in coordination with" the SDNY. Here are a few sentences from late in the article:
EFTA00019190

=== Page 9 ===
The [State] Attorney General's Office is investigating whether crimes took place on Zorro Ranch. [State Land
Commissioner Stephanie] Garcia Richard said Wednesday her office had notified [State] Attorney General
Hector Balderas to provide notice if any criminal activity was found to have occurred on the trust land leased
by Epstein "because we were looking for a reason to cancel these leases and criminal activity would have given
us the perfect reason."
Balderas did issue a statement saying he was pleased Garcia Richard was "taking back lands that should be
managed to best serve the State and for the benefit of New Mexico school children." Public schools are one
beneficiary of state trust land revenue. Balderas added: "We continue to investigate this matter at the state level
in coordination with U.S. Attorney's Office for the Southern District of New York."
Jonathon
Fraud and Public Corruption Section
U.S. Attorney's Office - District of New Mexico
Fro
Sent: Wednesday, September 4, 2019 4:12 PM
To:
Cc:
>;
Subject: RE: Follow Up Call
Thank you for the speedy response. Next week works for us. Can you all do the call next Thursday, September 12th at
1:30 MT / 3:30 ET?
From:
Sent: Wednesday. September 04. 2019 3:41 PM
To
Cc
Subject: RE: Follow Up Call
Hi
Hope you're doing well. This week is a bit tough for us. Are there dates next week that would work for you? We are
traveling Monday through Wednesday, but could talk Thursday or Friday.
Thanks,
EFTA00019191

=== Page 10 ===
From
Sent: Wednesday, September 4, 2019 4:28 PM
To:
Cc:
is
Subject: RE: Follow Up Call
and I were hoping to schedule a follow up call with you concerning Epstein's New Mexico conduct and
property sometime this week. We are both available tomorrow morning (9-12 MT / 11-2 ET) or Friday any time after
12pm MT / 2pm ET. Do you all have availability for a follow up call on either of these days?
Thanks,
From:
)
Sent: Saturday, August 17, 2019 12:46 PM
To: Kastrin, Holland S. (USANM) <HKastrin@usa.doj.gov>
Cc:
is
Subject: RE: Follow Up Call
We certainly can be in touch. I'm copying my colleagues on the case, Alison and Maurene, because I have a trial starting
August 26 so I'll be mostly unavailable next week, but it should be possible to find a time for one or both of them to
chat. If you send a couple possible times for next week we can figure it out.
thanks,
From: K
Sent: Friday, August 16, 2019 14:01
To:
)
Subject: Follow Up Call
Would you have a couple of minutes to chat with me and one of my colleagues about some NM-related Epstein matters
this afternoon or early next week? If today works for you, I am available any time after 1:30 MT/ 3:30 ET today. It is
nothing urgent.
Thanks,
EFTA00019192


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=== Page 1 ===
STATE
STATES
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
May 2, 2021
BY ELECTRONIC MAIL
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These discovery materials
are stamped with control numbers SDNY_GM_02753399 through SDNY_GM_02753431.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
SDNY GM 02753399
SDNY GM 02753431
Photographs
Confidential
EFTA00020248

=== Page 2 ===
Page 2
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
Assistant United States Attorneys
EFTA00020249


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 407 Filed 11/03/21 Page 1 of 7
LAW OFFICES OF BOBBI C. STERNHEIM
212-243-1100
Main
225 Broadway, Suite 715
917-912-9698
Cell
New York, NY 10007
888-587-4737
Fax
bcsternheim@mac.com
November 3, 2021
Honorable Alison J. Nathan
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States V. Ghislaine Maxwell
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
Counsel for Ghislaine Maxwell renew our request that the Court release the names of
potential jurors, for attorneys' eyes only, as soon as the written questionnaires are distributed.
Based on the Court's statement during the October 21 teleconference, it was counsel's
understanding that juror names would be provided to counsel on the Juror Sheet to be inserted in
the questionnaire. In responding to the Court's order regarding approval of the video to be played
to prospective jurors, the government importuned the Court to deny counsel the opportunity to
properly vet jurors at this critical state of the proceeding. Not knowing the names of the
potential jurors will prevent the parties from conducting necessary background research on the
jurors in advance of voir dire so that they may evaluate potential challenges and strikes. Due to
the large number of potential jurors (600), waiting until voir dire to release the names of the
jurors will make it virtually impossible for the parties to conduct any meaningful research to
uncover issues that may require follow-up questions, lead to additional cause challenges, or
enable the parties to exercise their peremptory challenges in an informed manner.
Recently, in Sines, et al. V. Kessler, et al., 17-CV-72 (KNM) (W.D. Va.), the civil case
brought against the organizers of the Unite the Right rally in Charlottesville, Virginia, the United
EFTA00018373

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 407 Filed 11/03/21 Page 2 of 7
LAW OFFICES OF BOBBI C. STERNHEIM
States District Court for the Western District of Virginia ordered a semi-anonymous jury (jurors
were publicly referred to by number only) and released the names of all potential jurors to
counsel, plus all pro se defendants (including Richard Spencer and Christopher Cantwell), who
are allegedly prominent white supremacists, neo-Nazis, and the leaders of hate groups that
planned, promoted, and executed the violent acts in Charlottesville. (See Exhibit A, annexed.)
The defendants in Sines included factions of the Ku Klux Klan. The concerns for juror privacy in
Sines dwarf any conceivable concerns in this case and Sines is also the subject of extensive
ongoing publicity. We submit that withholding the names of 600 jurors until the day of jury
selection will deprive Ms. Maxwell of her right to be tried by a fair and impartial jury and is a
procedure that would violate due process in this particular case.¹
"An impartial jury is one in which all of its members, not just most of them, are free of
interest and bias." United States V. Parse, 789 F.3d 83, 111 (2d Cir. 2015). In Parse, a case
before Judge Pauley sub nom United States V. Daugerdas, a jury convicted defendant Parse and
three of his co-defendants of numerous financial fraud and tax evasion charges. 789 F.3d at 86.
After trial, all defendants moved pursuant to Fed.R.Crim.P. 33(a) for a new trial on the ground
that one of the jurors, Juror No. 1 (Catherine M. Conrad), "had lied and withheld material
information during voir dire and was biased against defendants. Judge Pauley appointed Bobbi
C. Sternheim, Esq. to represent the juror and conducted an evidentiary hearing in which the juror
was examined, and in a detailed thorough opinion (see United States V. Daugerdas, 867
F.Supp.2d 445 (S.D.N.Y.2012) found it "undisputed that Conrad lied extensively during voir dire
and concealed important information about her background" (id. at 451), her level of education,
place of residence, criminal history, and other matters. Parse, 789 F.33 at 87-90.
1
We are unaware of any other recent high-profile case in which a written juror questionnaire was
used and the Court withheld the names of the jurors from counsel following the completion of
the questionnaires.
2
EFTA00018374

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 407 Filed 11/03/21 Page 3 of 7
LAW OFFICES OF BOBBI C. STERNHEIM
Judge Pauley granted a motion for a new trial as to Parse's three co-defendants but held
that Parse had waived his right to an impartial jury because his attorneys had sat on background
research collected before and during trial that suggested Conrad's voir dire answers were false.
Id. at 101. On appeal, the Second Circuit "had no difficulty with the ruling of the district court in
the present case that the jury empaneled to hear the case against these defendants was not an
impartial jury." Id. at 111. Moreover, the Second Circuit reversed Judge Pauley's ruling that
Parse had waived his right to an impartial jury, and vacated Parse's conviction. Id. at 118.
The result in Parse was that a three-month trial, with 41 witnesses and some 1,300
exhibits, was undone by the falsehoods of one juror during voir dire-falsehoods that could have
been uncovered by thorough background research and prompt action by the parties. Numerous
bar associations have recognized that trial counsel is expected to conduct internet research on
potential jurors. Some bar associations have opined that professional standards of competence
and diligence may require such research. For example, just weeks after Judge Pauley conducted
a post-conviction evidentiary hearing in Parse, the New York City Bar Association stated the
following in Formal Opinion 2012-2:
Just as the internet and social media appear to facilitate juror misconduct, the same
tools have expanded an attorney's ability to conduct research on potential and sitting
jurors, and clients now often expect that attorneys will conduct such research. Indeed,
standards of competence and diligence may require doing everything reasonably
possible to learn about the jurors who will sit in judgment on a case.
Similarly, in 2014, the American Bar Association recognized the "strong public interest
in identifying jurors who might be tainted by improper bias or prejudice," and therefore opined
that it was proper for counsel to research "a juror's or potential juror's Internet presence, which
may include postings by the juror or potential juror in advance of and during a trial. " See
Standing Committee on Ethics and Professional Responsibility, Formal Op. 466 at 1-2, Am. Bar
3
EFTA00018375

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 407 Filed 11/03/21 Page 4 of 7
LAW OFFICES OF BOBBI C. STERNHEIM
Assn. (2014); see also New York State Bar Association, Dec. 8, 2015 Report of the Social Media
Committee of the Commercial and Federal Litigation Section, at 15 ("[I]t is not only permissible
for trial counsel to conduct Internet research on prospective jurors, but [] it may even be
expected.").
Other courts have acknowledged that using the internet to conduct background research
on prospective jurors is a "rudimentary practice" during jury selection. United States V. Stone,
No. 19-0018 (ABJ), 2020 U.S. Dist. LEXIS 67359, at *93 (D.D.C. Apr. 16, 2020); see also
Carino V. Muenzen, No. A-5491-08T1, 2010 N.J. Super. Unpub. LEXIS 2154, at *27 (Super. Ct.
App. Div. Aug. 30, 2010) (trial judge erred in preventing counsel from using the internet during
jury selection). It is so routine that a party who fails to uncover disqualifying information about
a potential juror, despite a reasonable opportunity to do so, risks waiving the right to use that
information in post-conviction proceedings. Stone at *90 (denying motion to vacate conviction
and for a new trial because, inter alia, "the defense could have discovered the [foreperson's
social media] posts as early as September 12, 2019, the day counsel received access to the
completed juror questionnaires, including the foreperson's, which had her name printed legibly
on the signature page.").
Having additional time to conduct background research on each of the venirepersons is
the best way to ensure a fair and impartial jury. Balancing the need to protect juror privacy
against Ms. Maxwell's right to a fair and impartial jury weighs in favor of releasing the names of
potential jurors to counsel upon the completion of their written questionnaires, not at voir dire.
Respectfully submitted,
/s/
BOBBI C. STERNHEIM
Enc.
cc: All counsel of record
4
EFTA00018376

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 407 Filed 11/03/21 Page 5 of 7
EXHIBIT A
EFTA00018377

=== Page 6 ===
Case Pageid#: 21159
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF VIRGINIA
CHARLOTTESVILLE DIVISION
ELIZABETH SINES, et al.,
CASE No. 3:17-cv-00072
Plaintiffs,
V.
ORDER
JASON KESSLER, et al.,
JUDGE NORMAN K. MOON
Defendants.
Upon this Court's own motion, upon notice that Plaintiffs' counsel may seek to designate
certain non-lawyers within their list of six (6) persons to be provided electronic access to the jury
questionnaires, and otherwise finding good cause shown, the Court hereby AMENDS Pretrial
Order 13, (Dkt. 1172) as follows:
Plaintiffs, and Defendants represented by counsel collectively, may each designate no
more than six (6) persons, which may be comprised of (1) current counsel of record or (2) third
parties working under their direction, who are formally engaged and supervised by the attorneys
of record, and for whom such attorneys of record will be responsible, and who will have signed
the Court's protective order, Dkt. 167, so long as such persons include at least one attorney
admitted to practice in the Western District of Virginia, to be provided electronic access by the
Clerk to receive and review copies of the jury questionnaires, on a rolling basis. A list including
names and occupations of prospective jurors, and information matching such prospective jurors
with the questionnaires pursuant to Dkt. 1204 1 2, will also be provided to such specifically
designated persons by Plaintiffs and represented Defendants, no more than five (5) days before
trial. Jury questionnaires and such occupation list, and any information contained therein, are
1
EFTA00018378

=== Page 7 ===
Case Pageid#: 21160
subject to the Court's orders regarding confidentiality in Dkt. 1172 and 1204, and shall not be
disclosed to any other person without prior authorization of Court.
Any pro se Defendant-upon completing a declaration stating, under penalty of perjury,
they will not disclose the contents of such questionnaires or the jury occupation list provided to
such pro se Defendant to any other person-may review the questionnaires and jury occupation
list onsite in the Clerk's Office. A paper copy of the completed questionnaires and the jury
occupation list customarily made available to pro se litigants will be maintained in the Clerk's
Office.
If any party requests specific access to the confidential juror questionnaires in excess of
the provisions outlined above and in Dkts. 1172 and 1204, they shall file a motion to that effect.
In all other respects, this Court's Orders of Dkt. 1172 and 1204 shall remain unchanged and in
force.
It is so ORDERED.
The Clerk of the Court is directed to send a certified copy of this Order to the parties.
Entered this 19th day of October, 2021.
NORMAN normar K K. MOON
mon
SENIOR UNITED STATES DISTRICT JUDGE
2
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=== Page 1 ===
From:
)"
To:
)"
Subject: Accepted: Epstein Oral Argument-- Second Circuit
Date: Wed, 09 Jan 2019 19:18:51 +0000
Importance: Normal
Attachments: unnamed
EFTA00019533


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Subject: DAILY MAIL: Jeffrey Epstein 'befriended' first victim, 13, at Michigan arts camp
Date: Mon, 19 Jul 2021 12:36:23 +0000
Jeffrey Epstein 'befriended' first victim, 13, at Michigan arts camp
Jeffrey Epstein and his associate, Ghislaine Maxwell, 'befriended' the young girl at Interlochen Center for the
Arts, located in secluded woods of north Michigan. Claim was made in a new book (inset).
Read in Daily Mail: https://apple.news/AJhye_JwrTQCd8KUtO5mjGw
EFTA00019649


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
)"
(USANYS)"
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
i
,
(USANYS)"
Subject: RE: Filing today
Date: Thu, 13 Aug 2020 22:06:57 +0000
Attachments: 2020-08-
13,_GM,_letter_to_Judge_Nathan_re_victim_names_and_prison_privileges_docketed.pdf
Filed version is attached. Not the most exciting submission we've ever done, but as promised!
Original Message
From:
)
Sent: Thursday, August 13, 2020 16:34
To:
(USANYS) [Contractor]
)
(USANYS)
(USANYS)
(USANYS)
Cc:
(USANYS)
(USANYS)
(USANYS)
(USANYS)
Subject: RE: Filing today
Hi
,
We are filing a submission today, but it's not due by 5:00 -- but our hope is to file not long after that, and we'll
certainly send you the docketed version as soon as it's up.
thanks,
Original Message
From:
(USANYS) [Contractor]
Sent: Thursday, August 13, 2020 16:29
To:
(USANYS)
(USANYS)
(USANYS)
Cc:
(USANYS)
i
(USANYS)
(USANYS)
(USANYS)
Subject: Filing today
I understand you're supposed to be filing a response today (by 5:00?) to a defense motion to have Maxwell
released to the general population at MDC, or at least to be detained under conditions they say would allow her
greater access to a computer and the opportunity to review discovery materials? Main (OPA) is keenly interested
because of the AG's response last summer to Epstein's suicide and his bow to overhaul BOP and ensure inmate
safety, so a guy down there asked if we could send him what you file as soon as you do. (Apparently the AG is
EFTA00017830

=== Page 2 ===
getting questions from Congressional Republicans about what's being done to ensure Maxwell's safety.)
Chief Public Information Officer
U.S. Attorney's Office, SDNY
(office)
(cell)
EFTA00017831


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: Taint Review
Date: Sat, 21 Sep 2019 21:01:53 +0000
Embedded: RE:_US_v._Epstein.msg
The agents on the Epstein case have asked, below, about the status of the taint review of the materials seized
from his Manhattan residence, which were made available on September 10 (see attached). I know that you had
dealt directly with Epstein's attorneys regarding search terms, etc., so we haven't had visibility on that, but could
you please let us know the current status, and when you expect we'll be able to get access to the materials?
thanks very much,
Original Message
From:
Sent: Tuesday, September 17, 2019 17:17
To:
—
Subject: Taint Review
Hey guys,
Our supervisors are requesting a status update on the taint review process on your end. I simple percentage
complete is fine, they just want to know before tomorrow they have a meeting with the ADIC about the case.
Thanks
EFTA00017784


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein
Date: Mon, 08 Jul 2019 12:53:23 +0000
Importance: Normal
Good morning
Unfortunately we don't yet have any of those details, in terms of timing or judge, because the case isn't yet
unsealed and assigned but that will happen today at 9:15 and we can circle back immediately then. And he is
coming from MCC so will be there as soon as those folks arrive.
We are requesting detention and I expect there will be a bail argument.
Please feel free to reach out to me directly if that would be useful -- my cell is
thanks,
Original Message
From:
Sent: Monday, July 08, 2019 07:18
To:
Cc:
Subject: Re: Epstein
Thanks
Just trying to get the following info:
Will he be presented in mag court or district court(which judge)
When will the agents bring him through usms for processing?
Is there an Agreed bail package? Or is your office requesting Detention?
Thanks.
> On Jul 8, 2019, at 7:06 AM,
wrote:
V
> Looping in assigned AUSA,
V
> On Jul 8, 2019, at 06:55,
wrote:
V
> Hey
V
Do you have any info about the presentment etc for this case that we can forward to the Marshal.
V
> Thank you
EFTA00018151

=== Page 2 ===
V V V V V V VVVVVV
Supervisory Deputy U.S. Marshal
Southern District of New York
EFTA00018152


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=== Page 1 ===
From: "Martin G. Weinberg"
To:
)"
"Miller, Michael"
"Weingarten, Reid"
Cc:
)"
)"
"Martin G. Weinberg"
Subject: RE: US V Epstein
Date: Sun, 11 Aug 2019 19:54:44 +0000
Mr. Epstein's family has asked me to send to you and Adam Johnson at the MCC a request for the preservation of any
and all documents, records, reports, videos, pictures, physical evidence, electronic communication data, tape recordings,
logs, notes, papers, emails and any and all other forms of information that would be in the possession of the MCC, its
Warden, their legal counsel, the USMS, the FBI, the Inspector General, the USAO for the SDNY or any other federal or
relevant state or city agency that relate to Jeffrey Epstein's imprisonment/detention since July 6, 2019 and that relate
particularly but not exclusively to the July 23, 2019 occurrence which was investigated as an attempted suicide by the
MCC and the events relating to his death on August 10, 2019. The request encompasses but is not limited to any videos of
the 9th floor area in the proximity of his cell during the evening of August 9 through the time Mr. Epstein was taken out of
his cell for the last time on August 10, 2019, or videos of the cell itself during that time period, records of the identities of
(i.e. MCC employees or independent contractors or anyone else) who were on duty from midnight through 8 AM on
August 10, 2019 or otherwise had access to the 9th floor unit where Mr. Epstein was incarcerated during this time period,
records of any observations of Mr. Epstein on August 9-10, 2019, any and all photographs of Mr. Epstein or his cell taken
on August 10, 2019, any and all electronic or tape recordings or records of any internal communications within the MCC or
any external communciations by MCC staff on August 9 and August 10, 2019, records of any mental health interviews or
assessements of Mr. Epstein at anytime during his detention, records of any decision to put him on or take Mr Epstein off
suicide watch, photos of his cell taken on or before August 9 or on or after August 10, 2019, memoranda of interviews with
any prisoners who were in Mr. Epstein's SHU unit on the 9th floor on or about July 23 or on August 9-10, 2019 relating to
Mr. Epstein, the same request for interview memoranda of any MCC employee or independent contractor or any other
person in the MCC midnight-8 AM August 10, 2019, any and all medical and EMS and hospital records from July 23
and/or August 10, 2019, and the future pathology and toxicology and medical examiner's reports. Additionally, we would
request the preservation of any note or notes found in Mr. Epstein's cell on August 10, 2019, any ligature or other physical
evidence related to his cause of death, any bedding, any medication or vitamins, any log showing who entered or were
present in the MCC for the 12 hour period before 6:30 AM on August 10, 2019, as well as a list of inmates who were in Mr.
Epstein's unit during the evening of August 9 and the morning of August 10, 2019. We would in addition to the
preservation request ask for the production of all of the above. We would receive and retain in subject any information
received in response to this request subject to the terms and conditions of our Protective Order. In short, the family requests
a preservation and production of any and all records and documents relevant to his detention, treatment, and death. I will
send an identical request to Mr Johnson (as well as to Mark Epstein's personal counsel
Thank you for your consideration of these requests and your ongoing assistance
Martin Weinberg
Martin G. Weinberg, Esq.
20 Park Plaza
Suite 1000
Boston, MA 02116
- Office
Cell
This Electronic Message contains information from the Law Office of
Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee only. If you are
not the addressee, please note that any disclosure, copying, distribution, or use of the contents of this message is prohibited.
From:
)
[mailto:
Sent: Saturday, August 10, 2019 7:31 PM
To: Miller, Michael ; Martin G. Weinberg ; Weingarten, Reid
Cc:
);
Subject: RE: US V Epstein
Mike, Marty, Reid,
EFTA00019067

=== Page 2 ===
I just wanted to let you know that I don't expect we'll have any further updates today, and so wanted to send you a brief
note to let you know that since we hadn't otherwise been in touch since earlier this afternoon. I imagine we will continue to
be in contact in the coming days; meanwhile, I appreciate you being in touch today, and I hope the investigations of these
events will be thorough and swift.
respectfully,
From:
Sent: Saturday, August 10, 2019 14:14
To: Miller, Michael
; Martin G. Weinberg
Weingarten, Reid
Cc:
)
Subject: RE: US V Epstein
Following up on the below, wanted to make sure the attached letter from the Warden immediately got to Mike as well (in
addition to Marty and Reid having been copied and emailed). As the letter indicates, there are now investigations ongoing,
including as initiated by the Attorney General himself. Separately, we have not received additional information on topics
such as the apparent cause of death, the status of observation of Mr. Epstein at the time, etc., but we will continue to be in
touch immediately if that changes.
thank you,
From:
Sent: Saturday, August 10, 2019 11:57
To: Miller, Michael
Martin G. Weinberg
Weingarten, Reid
Cc:
D
Subject: Re: US V Epstein
Mike, Marty, Reid,
Following up on my conversations with Mike and Marty this morning, and my discussion with Mike moments
ago, attached is a press release just sent to us (and I believe also issued publicly) some minutes ago. It represents
all the information we have from BOP so far, but of course if we are successful in our continuing efforts to get
additional information we will pass it along immediately.
Separately, we can tell you that the reports that an FBI investigation into the death has been initiated are
accurate, and I fully expect that investigation to be extremely rigorous.
As always please don't hesitate to reach out to us directly at any time if that would be useful.
thank you,
EFTA00019068


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=== Page 1 ===
From:
To:
Cc:
Bec:
Subject: Re: Expert Witness
Date: Wed, 28 Oct 2020 22:24:06 +0000
Embedded: Re:_Expert_Witness.msg
Sender:
Subject: Re: Expert Witness
Message-Id:
Recipient:
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=== Page 1 ===
From: adrian edwards
To:
Subject: Fwd:
Date: Fri, 12 Jul 2019 12:29:04 +0000
FYI : The Domestic Agencies who supply the Staff to the rich and famous, cover up crimes in order to collect
fee's and to continue doing business.
They send Staff for interviews knowing fine well that the client is either violent, a drunk/ drug abuser,
physically/ verbally abusive, or even YES, a pedophile.
MANY very rich clients ask for "Pretty Staff" and often they are sexual harassed on a daily basis in return for
monies
favors, etc.
For example
"Do this for me, and your family in the Philippines will be able to buy that house"
These very rich families have the Staff sign "Confidentiality Clauses" and then have their lawyers scare the hell
out of any Staff Members who dares to answer back, criticize, or threaten to go to the Police or the Press, as the
lawyers threaten the Staff with the "Confidentiality Papers" and say things like
"You will NEVER work
again, and we will take your house, or apt away from you with Court costs so shut up"
Then the same lawyers hand checks to disgruntled, or abused Domestic Workers as a pay-off to shut up and to go
away.
and the Domestic Agencies then are told to blacklist the individual.
This is how 5th and Park Avenue operate
and yes, even CPW and Tribeca
THEN to top it off the Domestic Agencies then threaten the Staff and say.
"If you dare to go to the Police, or
the Press, or even the US Attorneys Office, we will blacklist you and no Agency will ever work with you ever
again"
How do you think Epstein and so many others get away with abuse for so long ?????????
It is designed that way. All are scared to talk
and all are threatened
one way or another.
The US Attorneys Office could expose this, and for sure the damn will burst wide open on the likes of Seinfeld,
Kalikow, Black, Soros, and many many more
The Domestic Agencies are just as guilty as the Clients who are up to no good, as they are licensed and bonded,
and should know better.
They cover up for the Clients, and even work with the lawyers of the rich to defend the rich from any legal cases
against them.
The key to all the abuse by the rich and famous in NYC is for the Domestic Employee's to feel safe to walk into
the US Attorney's Office any time and file a complaint.
NOT the 19th Precinct who cover up for the rich
as the rich are very cunning, and offer ex Detectives
cushy jobs as Driver/ Security when they retire from the 19th
EFTA00018180

=== Page 2 ===
No, the US Attorneys Office need to have an open door for employee's of the rich and famous, so that they can
feel safe.
The NYPD are hired by the rich, so there is a bias
No US Attorney ever goes to work for a Celebrity as a Security/ Driver detail
Allow Domestic Workers a safety net to walk into your office, regardless of "Confidentiality Clauses" and you
will hear it all
Trust me, it's not pretty.
Epstein is NOT alone in NYC
The abuse is all over.
From sexual to major tax evasion. Suitcases
of cash taken onto private planes
and more
Adrian Edwards-Smith
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=== Page 1 ===
From:
"
)"
=
To:
)"
Subject: Accepted: Proffer:
Date: Thu, 05 Sep 2019 15:17:21 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
Event: Accepted: 227815.002 USA V GHISLAINE MAXWELL 20 CR 330 (AJN)
Start Date: 2021-11-24 19:00:00 +0000
End Date: 2021-11-24 19:30:00 +0000
Location: att prep call
Class: X-PERSONAL
Comment:
Date Created: 2021-11-23 21:33:56 +0000
Date Modified: 2021-11-23 21:33:56 +0000
Priority: 5
DTSTAMP: 2021-11-23 18:35:26 +0000
Attendee: testimony
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=== Page 1 ===
From:
To:
Subject: Discovery production for Maxwell
Date: Thu, 17 Dec 2020 17:52:27 +0000
Attachments: 2020.12.17_MDC_-_Maxwell_MAINpdf;2020.12.17_MDC__Maxwel_PASSWORD.pdf
Hi
Today we are sending via FedEx a new disc containing a new discovery production for Ghislaine Maxwell. Attached please
find copies of the cover letters.
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
)"
To: "Miller, Michael"
"Martin G. Weinberg"
"Weingarten,
Cc:
)"
)"
Subject: Re: US V Epstein
Date: Sat, 10 Aug 2019 15:56:37 +0000
Attachments: attachment_1.pdf; ATT00001.htm
Mike, Marty, Reid,
Following up on my conversations with Mike and Marty this morning, and my discussion with Mike moments
ago, attached is a press release just sent to us (and I believe also issued publicly) some minutes ago. It represents
all the information we have from BOP so far, but of course if we are successful in our continuing efforts to get
additional information we will pass it along immediately.
Separately, we can tell you that the reports that an FBI investigation into the death has been initiated are
accurate, and I fully expect that investigation to be extremely rigorous.
As always please don't hesitate to reach out to us directly at any time if that would be useful.
thank you,
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 16, 2019
Experian Information Solutions, Inc.
701 Experian Parkway
Allen, TX 75013
Attn: Subpoena Compliance Dept.
Re:
Grand Jury Subpoena
Please be advised that the accompanying grand jury subpoena has been issued in
connection with an official criminal investigation of a suspected felony being conducted by a
federal grand jury. The Government hereby requests that you voluntarily refrain from disclosing
the existence of the subpoena to any third party. While you are under no obligation to comply
with our request, we are requesting you not to make any disclosure in order to preserve the
confidentiality of the investigation and because disclosure of the existence of this investigation
might interfere with and impede the investigation.
Thank you for your cooperation in this matter.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
By:
Assistant United States Attorney
Southern District of New York
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=== Page 2 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Experian Information Solutions, Inc.
701 Experian Parkway
Allen, TX 75013
Attn: Subpoena Compliance Dept.
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the GRAND JURY of the people of the United States for the Southern District of New York, at
the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New
York, New York, in the Southern District of New York, at the following date, time and place:
Appearance Date:
August 30, 2019
Appearance Time: 10 a.m.
to testify and give evidence in regard to alleged violations of federal criminal law, including:
18 U.S.C. §§ 1591, 1594(c), 2422(b), 371
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
SEE ATTACHED RIDER. Personal appearance is not required if the requested records are (1)
produced by on or before the return date to Special
Federal Bureau of
Investigation, 26 Federal Plaza, New York, NY 10278, telephone
;
and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. Please
contact Forensic Accountant
at
or Special
at
with any questions.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
August 16, 2019
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
Assistant United States Attorney
One St. Andrew's Plaza
New York, New York 10007
Telephone:
EFTA00019982

=== Page 3 ===
RIDER
(Grand Jury Subpoena to Experian, dated August 16, 2019)
Please provide any and all credit reports, fraud alerts, and related documents pertaining to the
following individuals listed, including all known accounts and lines of credit, addresses and
personal identifying information, and all credit inquiries regarding the individuals and the
addresses provide at the time of said inquiry regardless of whether accounts were open.
Please utilize the identifiers below:
NAMES/ENTITIES
DOB
SSN
ADDRESS
PHONE
EMAIL
ACCOUNT NUMBERS:
N.B.: Personal appearance is not required if the requested records are (1) produced by on or
before the return date to Special
, Federal Bureau of Investigation, 26
Federal Plaza, New York, NY 10278, telephone
n
; and (2)
accompanied by an executed copy of the attached Declaration of Custodian of Records.
PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE.
Please contact Forensic Accountant
at
or Special
at
with any questions.
3
EFTA00019983

=== Page 4 ===
IMPORTANT: REQUEST FOR NON-DISCLOSURE
Due to the ongoing nature of the investigation, it is requested that you do not
disclose any information relating to this Grand Jury subpoena request to any third party.
4
EFTA00019984

=== Page 5 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. $ 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of
records of the business named below, or I am otherwise qualified as a result of my position with
the business named below to make this declaration.
I am in receipt of a Grand Jury Subpoena, dated August 16, 2019, and signed by Assistant
United States Attorney
,
requesting specified records of the business named
below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify
that the records provided herewith and in response to the Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records,
by, or from information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
.
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data
compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business"
as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution,
association, profession, occupation, and calling of every kind, whether or not conducted for profit.
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=== Page 1 ===
From:
)
1"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Re: Catch up tomorrow? 10:30?
Date: Tue, 27 Aug 2019 01:17:18 +0000
Who is Epstein? Oh, right.
I'm not sure re the message but want to talk forfeiture and rico
Sent from my iPhone
> On Aug 26, 2019, at 9:14 PM,
(USANYS)
wrote:
>
>
is our this week, and I have Epstein conference before Berman at that time.
>
> Do you know when the message for
was left? My understanding is that our team connected with someone
in that office late last week, and they agreed to stand down pending the end of our investigation.
V
> Sent from my iPhone
V
>> On Aug 26, 2019, at 9:05 PM,
) 1
wrote:
Sent from my iPhone
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: CD for MDC
Date: Thu, 17 Dec 2020 17:49:02 +0000
Attachments: 2020.12.17_MDC_-_Maxwell_MAIN.pdf; 2020.12.17_MDC_-_Maxwell_PASSWORD.pdf
Of course! They are attached and also saved on the shared.
From:
Sent: Thursday, December 17, 2020 12:48 PM
To:
Cc:
Subject: RE: CD for MDC
Thanks so much,
Would you please send me the MDC cover letters so I can send them to MDC counsel?
From:
Sent: Thursday, December 17, 2020 12:43 PM
To:
Subject: CD for MDC
Hi all,
The envelope with the CD containing the Eighth Production materials and the envelope with the CD's password have both
been left for FedEx pickup at the Office. I included the cover letter sent to defense counsel on the CD as well. The tracking
number for the envelope containing the CD is 816289189888.
Thanks so much, all!
Paralegal Specialist
U.S. Attorney's Office I
SDNY
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Letter from Tartaglione counsel
Date: Wed, 21 Aug 2019 12:57:53 +0000
Thanks,
What day did the facilities manager talk to him / test run the shower?
Assistant U.S. Attorney
212-637-1023
On Aug 21, 2019, at 08:56,
wrote:
Hi
Just a couple updates:
I caught one of the officers who normally does SHU rec. He confirmed that Tartaglione can go to the roof for
recreation. SHU rec is normally from about 6:00/6:30 to 10:30/11:00. The officer said Tartaglione is usually
sleeping, and once he eventually wakes up, he never asks them to go. The officer said when Tartaglione and
Epstein were housed together, Epstein asked about rec. The officer told Epstein he would take him at 6:00 AM
before his attorneys showed up. Tartaglione was in the cell during this conversation, and the officer told me
made a comment like "I can take you up together" to both of them.
The Facilities Manager told me they talked to Tartaglione. He had no complaints about his cell. He only
complained that water leaked in his cell when people "took long showers." Facilities ran the shower for awhile
and didn't see the water leaking down to Tartaglione's cell, but if I give Tartaglione the benefit of the doubt, he
may be correct that the water makes its way down there eventually after it's been running for a long, long time.
Evening watch SHU staff confirmed they gave Tartaglione the three newspapers that arrived in the mail
yesterday morning.
I think that's it for now. Let me know if you need anything else.
Thanks!
Staff Attorney
CLC New York
Metropolitan Correctional Center
EFTA00019986

=== Page 2 ===
8/20/2019 2:47 PM
and
Bruce Barket just filed the attached letter on ECF. Are you available for another call this afternoon, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Subject: RE: expert witness
Date: Wed, 24 Nov 2021 16:03:40 +0000
Yes, this is her UC Davis one:
From:
Sent: Wednesday, November 24, 2021 10:47 AM
To:
Subject: FW: expert witness
Do we have an email address for
? This is the email
originally sent to
From:
Sent: Thursday, January 28, 2021 8:59 AM
To:
Cc:
is
Subject: expert witness
Good morning,
My colleagues,
and
and I are the prosecutors in the case of United States V. Ghislaine
Maxwell, which is scheduled to go to trial on July 12, 2021 in the Southern District of New York. We are reaching out
because we would be interested in speaking with Dr.
about potentially testifying at trial. Would it be possible to
schedule a call with Dr.
to discuss?
Thanks very much,
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 1 of 55
EXHIBIT
A
EFTA0001877

=== Page 2 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 2 of 55
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN
GOVERNMENT OF THE UNITED STATES
VIRGIN ISLANDS,
Case No.:
PLAINTIFF,
ACTION FOR DAMAGES
V.
DARREN K. INDYKE, in his capacity as the
JURY TRIAL DEMANDED
EXECUTOR FOR THE ESTATE OF JEFFREY E.
EPSTEIN and ADMINISTRATOR OF THE 1953
TRUST; RICHARD D. KAHN, in his capacity as
the EXECUTOR FOR THE ESTATE OF JEFFREY
E. EPSTEIN, and ADMINISTRATOR OF THE
1953 TRUST; ESTATE OF JEFFREY E. EPSTEIN,
THE 1953 TRUST, PLAN D, LLC; GREAT ST.
20 FEBILL MEDIS
SUPERIOR COURT
JIM, LLC; NAUTILUS, INC.; HYPERION AIR,
LLC; POPLAR, INC., SOUTHERN TRUST
COMPANY, INC.; JOHN AND JANE DOES
DEFENDANTS,
FIRST AMENDED COMPLAINT
COMES NOW, the Government of the United States Virgin Islands ("Government") and
files this First Amended Complaint against the above-named Defendants and in support thereof,
would show unto the Court as follows:
JURISDICTION AND PARTIES
1.
The Attorney General of the United States Virgin Islands (herein after "Virgin
Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant
to 3 V.I.C. $ 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate
for the public interest, safety, health and well-being of persons in the Virgin Islands.
EFTA00018779

=== Page 3 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 3 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 2 of 55
2.
This Court has subject matter jurisdiction over this civil matter pursuant to 4 V.I.C.
§ 76 and 14 V.I.C. § 607.
3.
This Court has personal jurisdiction over the parties pursuant to 5 V.I.C. $ 4903.
4.
The Virgin Islands is an unincorporated territory of the United States. It consists
of St. Thomas, St. Croix, St. John, and Water Island, and more than 40 surrounding islands and
Cays, some of which are privately owned. Among these privately owned islands are Little St.
James and Great St. James.
5.
Jeffrey E. Epstein ("Epstein") was a resident of the Virgin Islands and he
maintained a residence on Little St. James, which he acquired in 1998 and in 2016 he also
purchased Great St. James.
6.
Epstein registered as a sex offender in the Virgin Islands in 2010. He was a Tier 1
offender under Virgin Islands law based upon his Florida conviction of procuring a minor for
prostitution. As a Tier 1 offender, Epstein was required to register annually with the Virgin Islands
Department of Justice ("VIDOJ") and give advance notice of his travel to and from the Virgin
Islands. Epstein was also subject to random address verification by VIDOJ.
7.
Epstein was found dead on August 10, 2019 while in custody in New York for sex
crimes.
8.
Defendant Darren K. Indyke ("Defendant Indyke") is co-executor of the Estate of
Jeffrey E. Epstein and Administrator of The 1953 Trust.
9.
Defendant Richard D. Kahn ("Defendant Kahn") is co-executor of The Estate of
Jeffrey E. Epstein and Administrator of The 1953 Trust.
10.
Defendant, the Estate of Jeffrey E. Epstein ("Estate"), created upon Epstein's death,
is domiciled in the Virgin Islands. On August 15, 2019, Defendants Indyke and Kahn filed a
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=== Page 4 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 4 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 3 of 55
Petition for Probate and Letters Testamentary which included Epstein's last will and testament
with the Probate Division of the Superior Court of the Virgin Islands.
11.
The Petition reports the value of the real and personal property in The Estate located
in the Virgin Islands at $577,672,654.00 dollars.
12.
According to the Petition, the assets in the Virgin Islands thus far includes:
a. $56.5 million in cash;
b. $127 million in fixed income and equity investments;
c. $195 million in hedge fund and private equity investments; and
d. $18.5 million in planes, boats, and automobiles.
The Estate has not yet valued his fine arts, antiques, and other valuables.
13.
The Estate also includes shares of various corporate entities which hold residences
and real property used by Epstein, namely:
a. Brownstone in New York City valued at $56 million;
b. Ranch in New Mexico valued at $72 million;
c. Gated home in Palm Beach, Florida, valued at $12 million;
d. Seven units in an apartment building in Paris, valued at $8 million; and
e. Great St. James and Little St. James, collectively valued at $86 million.
14.
The Estate is responsible to pay damages for the acts committed by Epstein and the
Epstein Enterprise described below.
15.
Defendant The 1953 Trust ("The Trust") was created by Epstein, who "amended
and restated" its terms only two days before his suicide. That same day, Epstein revised his Last
Will and Testament, transferring all of his "property, real and personal, wherever situated" to The
Trust.
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=== Page 5 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 5 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 4 of 55
16.
The Trust also contains Epstein's financial assets and is also responsible to pay
damages for the acts committed by Epstein and the Epstein Enterprise described below.
Defendants Indyke and Kahn, filed a Certificate of Trust in the Superior Court of the Virgin Islands
for The Trust on August 26, 2019.
17.
Epstein maintained a deliberately complex web of Virgin Islands corporations,
limited liability companies, foundations, and other entities, not all of which are yet known to the
Government of the Virgin Islands, through which he carried out and concealed his criminal
conduct.
18.
Epstein regularly created new entities in the territory and transferred properties and
funds between them in order to preserve and shield Epstein's assets and to facilitate and conceal
the unlawful acts described in this Complaint.
19.
These entities held properties, including Little St. James and Great St. James, at
which Epstein trafficked and sexually abused women and underage girls. Epstein owned and
arranged for private planes, helicopters, boat and automobiles to transport victims to, from, and
within the Virgin Islands, and provided money to pay these young women and underage girls.
20.
Epstein sat at the hub of this web, serving as president, member, manager, or
director of each of the entities and, upon information and belief, directing their activities.
21.
Defendant, Nautilus, Inc., is a corporation established and organized under the laws
of the Virgin Islands. It was incorporated on November 22, 2011.
22.
According to records of the Virgin Islands Recorder of Deeds, Nautilus, Inc. owns
Little St. James, a/k/a Parcel Number 109803010100, a parcel of 3.1 million square feet valued at
$3.2 million, with buildings and improvements valued at $4 million.
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=== Page 6 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 6 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 5 of 55
23.
Epstein was president and director of Nautilus, Inc., which corporate filings
describe as "holding property for personal use." Defendants Indyke and Kahn are the secretary and
treasurer of Nautilus, Inc., respectively. The Estate values Epstein's holdings of Nautilus, Inc.,
which holds title to Little St. James at $63.9 million.
24.
A deed recorded with the Virgin Islands Recorder of Deeds on December 30, 2011
reflects that the property was transferred from a Delaware entity, L.S.J., LLC, to Nautilus, Inc. for
"TEN DOLLARS ($10.00) and other good and valuable consideration." The quitclaim deed lists
Jeffrey Epstein as the sole member of L.S.J., LLC, which it acquired Little Saint James via a
warranty deed dated April 27, 1998.
25.
As described below, Epstein engaged in a pattern and practice of trafficking and
sexually abusing young women and female children on this private, secluded island of Little St.
James where Epstein and his associates could avoid detection of their illegal activity from Virgin
Islands and federal law enforcement and prevent these young women and underage girls from
leaving freely and escaping the abuse.
26.
Thus, Nautilus, Inc. participated in carrying out, facilitating and concealing
Epstein's crimes, hence Little St. James became an instrumentality of those crimes.
27.
Defendant, Great St. Jim, LLC, is a limited liability company established and
organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26,
2015. Great St. Jim, LLC, according to records of the Virgin Islands Recorder of Deeds, owns at
least three properties that make up Great St. James acquired on January 28, 2016: Parcel Number
109801010100, consisting of 3.5 million square feet and valued at $17.5 million; Parcel Number
109801010200, consisting of 450,000 square feet of land, valued at $2.8 million; and Parcel
Number 109801010300, 1.2 million square feet of land, valued at $2.7 million. According to a
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=== Page 7 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 7 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 6 of 55
warranty deed filed with the Virgin Islands Recorder of Deeds, Epstein, through Great St. Jim,
LLC, acquired the last two parcels for $5 million each.
28.
Epstein is listed as manager and a member of Great St. Jim, LLC and the nature of
its business is described as "holding assets."
29.
Upon information and belief, Epstein purchased these Great St. James properties—
the island with closest proximity to Little St. James-to further shield his conduct on Little St.
James from view, prevent his detection by law enforcement or the public, and allow him to
continue and conceal his criminal enterprise. Epstein's significant investment in the purchase of
Great St. James demonstrates his intent to expand his illegal operation in the Virgin Islands for
years to come. Thus, Great St. Jim, LLC participated in carrying out, concealing, facilitating and
continuing Epstein's crimes, and Great St. James became an instrumentality of those crimes.
30.
Defendant, Poplar, Inc., is a corporation established and organized under the laws
of the Virgin Islands. Poplar, Inc. was incorporated on November 22, 2011. Epstein was president
and director of Poplar, Inc., and its purpose was described in corporate filings as "holding property
for personal use." Defendants Indyke and Kahn are secretary and treasurer of Poplar, Inc.,
respectively.
31.
A certificate of incumbency provided to the Department of Planning and Natural
Resources ("DPNR") also lists Epstein as president of Poplar, Inc. and expressly authorizes the
incorporators to conduct "transactions related to permitting matters submitted on behalf of Great
St. Jim, LLC."
32.
Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim,
LLC, and the signature appears to be Epstein's. The Petition for Probate and Letters Testamentary
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=== Page 8 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 8 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 7 of 55
filed by The Estate lists Poplar, Inc. as holding title to Great St. James. Thus, Poplar, Inc.
participated in carrying out, concealing, facilitating and continuing Epstein's crimes.
33.
Defendant, Plan D, LLC is a limited liability company established and organized
under the laws of the Virgin Islands. In its original Articles of Organization, filed October 19,
2012, and Annual Report filings, Epstein's pilot, Larry Visoski, was listed as Plan D, LLC's sole
manager/member. However, the July 31, 2019 Annual Report revealed Epstein as the principal
behind Plan D, LLC.
34.
Upon information and belief, Plan D, LLC owns one or more of the airplanes and
helicopters that Epstein used to transport young women and children to and from the Virgin Islands
to carry out the criminal pattern of activity described below. Among the airplanes owned by Plan
D, LLC is a Gulfstream with N-number N212JE. Flight logs and travel notices indicate that
Epstein used this plane to traffic and transport and young women and underage girls to the Virgin
Islands.
35.
Defendant, Hyperion Air, LLC is a limited liability company established and
organized under the laws of the Virgin Islands on October 19, 2012. Jeffrey Epstein is a
manager/member of Hyperion Air, LLC, along with his pilot, Larry Visoski. The purpose of
Hyperion Air, LLC is listed in its Annual Report as "holding assets."
36.
Hyperion Air, LLC is the registered owner of a Bell helicopter with N-number
N331JE and a Keystone helicopter with N-number N722JE. Upon information and belief, Epstein
used these helicopters to transport young women and underage girls between St. Thomas and Little
St. James.
37.
Defendant Southern Trust Company, Inc. was originally incorporated in the Virgin
Islands on November 18, 2011 as Financial Informatics, Inc., but changed its name to Southern
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=== Page 9 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 9 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 8 of 55
Trust Company in September 2012. Southern Trust Company is a tenant at American Yacht
Harbor in Red Hook, St. Thomas, and Epstein is a "passive investor" in IGY-AYH, d/b/a American
Yacht Harbor. By the end of 2013, according to its corporate filings, Southern Trust Company
has assets of $198.5 million; four years later, its assets reached $391.3 million. From 2011 until
at least 2018, Jeffrey Epstein was the President/Director of Southern Trust Company, and
Defendants Kahn and Indyke were Treasurer/Director and Secretary/Director, respectively.
Epstein was the sole owner of Southern Trust Company.
38.
John and Jane Does represent individuals and entities whose identities or
involvement with Epstein are currently unknown. The Government of the Virgin Islands will
amend the Complaint to add these individuals and entities when discovered.
39.
The Attorney General brings this action to seek all remedies available to the
Government of the Virgin Islands in enforcing its laws and protecting the public interest and public
safety. These claims are distinct from, and are not intended to supplant, the claims of victims who
were unconscionably harmed by Jeffrey Epstein and his associates.
FACTUAL ALLEGATIONS
A. The Conduct of the "Epstein Enterprise" in the Virgin Islands
40.
Epstein and his associates, including Defendants, identified and recruited female
victims, including children, and transported them to the Virgin Islands where they were abused
and injured. Epstein, through and in association with Defendants, trafficked, raped, sexually
assaulted and held captive underage girls and young women at his properties in the Virgin Islands.
41.
Epstein created a network of companies and individuals who participated in and
conspired with him in a pattern of criminal activity related to the sex trafficking, forced labor,
sexual assault, child abuse, and sexual servitude of these young women and children. Epstein and
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=== Page 10 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 10 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 9 of 55
his associates trafficked underage girls to the Virgin Islands, held them captive, and sexually
abused them, causing them grave physical, mental, and emotional injury.
42.
To accomplish his illegal ends, Epstein formed an association in fact with multiple
Defendants and others (both companies and individuals) who were willing to participate in,
facilitate, and conceal Epstein's criminal activity in exchange for Epstein's bestowal of financial
and other benefits, including sexual services and forced labor from victims.
43.
This illicit association of Epstein, Defendants, and his associates constitute what is
referred to herein as the "Epstein Enterprise." Epstein's associates in the Epstein Enterprise,
including, but not limited to, those named as Defendants knowingly facilitated, participated in, and
concealed Epstein's illegal conduct.
44.
Epstein used his wealth and power to create the Epstein Enterprise which engaged
in a pattern of criminal activity in the Virgin Islands by repeatedly procuring and subjecting
underage girls and young women to unlawful sexual conduct, sex trafficking, and forced labor.
45.
The Epstein Enterprise engaged in a pattern of criminal activity in the Virgin
Islands (and elsewhere) with the criminal purpose and goal of placing a steady supply of vulnerable
female children and young women into sexual servitude in service of Epstein's desires, and those
of his associates. The Epstein Enterprise maintained and made available young women and
underage girls for the purpose of engaging them in forced labor and sexual activities and used
coercion and deception to procure, abuse, and harbor its victims.
46.
Flight logs and other sources establish that between 2001 and 2019 the Epstein
Enterprise transported underage girls and young women to the Virgin Islands, who were then taken
via helicopter or private vessel to Little St. James where they were then deceptively subjected to
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=== Page 11 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 11 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 10 of 55
sexual servitude, forced to engage in sexual acts and coerced into commercial sexual activity and
forced labor.
47.
In furtherance of its criminal activities, the Epstein Enterprise used its aircrafts to
transport the young women and underage girls to the Virgin Islands for purposes of sexual abuse
and exploitation.
48.
The Epstein Enterprise facilitated and participated in the sexual molestation and
exploitation of numerous girls between the age of 12 and 17 years old.
49.
On the pretext of providing modeling opportunities, careers and contracts,
associates of the Epstein Enterprise, funded by the Epstein Enterprise, lured and recruited young
women and underage girls to travel to locations including the Virgin Islands where, upon
information and belief, based on the pattern and practice of the Epstein Enterprise, they were
sexually abused and exploited.
50.
Associates in the Epstein Enterprise recruited both victims and abusers into the
Epstein Enterprise, participated in sexual acts of rape and abuse of minors and witnessed Epstein
and others engage in sexual acts with children.
51.
As recent as 2018, air traffic controllers and other airport personnel reported seeing
Epstein leave his plane with young girls some of whom appeared to be between the age of 11 and
18 years.
52.
Upon information and belief, based on Epstein's pattern of trafficking and sexually
abusing young girls, the Epstein Enterprise trafficked and abused these girls, and others, in the
Virgin Islands through 2018.
53.
When sued in civil court for committing sex trafficking and sex crimes, Epstein
never denied engaging in sexual acts with underage females and procuring underage females for
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=== Page 12 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 12 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 11 of 55
prostitution, but instead consistently invoked his Fifth Amendment privilege against self-
incrimination.
54.
Upon information and belief, the Epstein Enterprise kept a computerized list of
underage girls who were in or proximate to the Virgin Islands, and able to be transported to
Epstein's residence at Little St. James in the Virgin Islands.
55.
The Epstein Enterprise engaged in a pattern of criminal conduct by trafficking
children and young women and placing them in sexual servitude and forced labor in the Virgin
Islands. The Epstein Enterprise repeatedly violated 14 V.I.C. §§ 133 to 138, which prohibit
trafficking and sexual abuse. The Epstein Enterprise also repeatedly violated laws against child
abuse and neglect, including 14 V.I.C. § 505, which defines the crime of child abuse as knowingly
or recklessly causing "a child to suffer physical, mental, or emotional injury," or causing a child
to be placed in a situation where such injury is foreseeable, and 14 V.I.C. $ 506, which applies, as
here, where the child suffers serious physical, mental, or emotional injury as a result of that abuse.
The harm to Epstein's victims was both fully foreseeable and deeply damaging.
56.
The Epstein Enterprise knowingly recruited, transported, transferred, harbored,
received, procured, obtained, isolated, maintained, and enticed young women and girls to engage
in forced labor (such as providing massages) and, ultimately, sexual servitude at his little St. James
residence.
57.
A 15 year old victim was forced into sexual acts with Epstein and others and then
attempted to escape by swimming off the Little St. James island. Epstein and others organized a
search party that located her and kept her captive by, among other things, confiscating her passport.
58.
Another victim, who was first engaged in provide massages to Epstein, was then
forced to perform sexual acts at Little St. James in the Virgin Islands. When she attempted to
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escape from the "private island," Epstein and a search party found her, returned her to his house,
and suggested physical restraint or harm if she failed to cooperate.
59.
The Epstein Enterprise deceptively lured underage girls and women into its sex
trafficking ring with money and promises of employment, career opportunities and school
assistance. The Epstein Enterprise preyed on their financial and other vulnerabilities, and
promised victims money, shelter, gifts, employment, tuition and other items of value. For
example, participants in the Epstein Enterprise targeted young and underage females under the
pretext that they would be paid substantially merely to provide massages to him and others.
However, once drawn in, victims were then pressured and coerced to engage in sexual acts.
60.
The Epstein Enterprise forced underage victims to recruit others to perform services
and engage in sexual acts-a trafficking pyramid scheme.
61.
The Epstein Enterprise paid girls for each "meeting," with additional money if they
brought additional girls. Epstein reportedly required three meetings per day.
62.
The Epstein Enterprise used the term "work" as a code for sexual abuse, and, upon
information and belief, reportedly kept computer records of the contact information for the victims.
63.
Consistent with his creation and use of a complex web of entities to carry out and
conceal the criminal trafficking enterprise in the Virgin islands, the Epstein Enterprise sometimes
paid young women and underage girls he exploited and trafficked through his charitable
foundations.
64.
Once the girls and women were recruited, participants in the Epstein Enterprise
enforced their sexual servitude of victims by coercion, including but not limited to, confiscating
passports, controlling and extinguishing external communications, and threatening violence. They
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also made fraudulent statements to family members of victims, claiming victims were being well
cared for and supported financially in college and other educational opportunities.
65.
The Epstein Enterprise transported, held, sexually abused, trafficked, and
concealed women and children at his property in the Virgin Islands dozens of times over nearly
two decades.
B. The "Epstein Enterprise" Abused Privileges of Residency to Carry out its
Criminal Scheme
66.
The Epstein Enterprise in 1998 acquired Little St. James in the Virgin Islands as
the perfect hideaway and haven for trafficking young women and underage girls for sexual
servitude, child abuse and sexual assault. Little St. James is a secluded, private island, nearly two
miles from St. Thomas with no other residents. It can be visited only by private boat or helicopter;
no public or commercial transportation is available to carry persons on or off the island, and no
bridge connects the island to St. Thomas. Epstein had easy access to Little St. James from the
private airfield on St. Thomas, only 10 minutes away by his private helicopter, but the women and
children he trafficked, abused, and held there were not able to leave without his permission and
assistance, as it was too far and dangerous to swim to St. Thomas.
67.
In 2016, upon information and belief, using a straw purchaser to hide Epstein's
identity, the Epstein Enterprise acquired Great St. James the nearest island to Little St. James. By
then, Epstein was a convicted sex offender. Upon information and belief, the Epstein Enterprise
purchased the island for more than $20 million because its participants wanted to ensure that the
island did not become a base from which others could view their activities or visitors. By acquiring
ownership and control of Great St. James to the exclusion of others, the Epstein Enterprise created
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additional barriers to prevent those held involuntarily on Little St. James from escaping or
obtaining help from others.
68.
Great St. James and Little St. James are environmentally sensitive locations, with
native coral and wildlife protected by federal and territorial law and enforcement authorities. The
Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in
the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin
Islands. Under its authority, DPNR repeatedly issued citations and assessed thousands of dollars
of fines for violations of the Virgin Islands construction code and environmental protection laws
on both Little St. James and Great St. James-significant penalties to the agency and to the average
resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had little
effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its activities
to the law.
69.
As a result of illegal construction activity of the Epstein Enterprise, the Virgin
Islands has incurred, and will incur, significant expenses to remove the illegal construction or
remediate its effects on natural resources in and around Little St. James and Great St. James. The
extent of the potential environmental damage is unknown at this time as the illegal construction
has not been removed or remediated.
70.
The Epstein Enterprise continues to attempt to prevent or limit DPNR authorities
from conducting random inspections on the Little St. James and Great St. James necessary to
comply with Virgin Islands law.
71.
The Epstein Enterprise's violation of the construction and environmental laws was
part of a pattern of behavior in flouting the laws of the Virgin Islands and holding itself above the
law. Upon information and belief, as described above, the Epstein Enterprise undertook
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construction at Great St. James after 2016 to continue the scheme to carry out and conceal his
trafficking and sexual abuse of young women and children in the Virgin Islands. These actions
are also indicative of the Epstein Enterprise's disregard for Virgin Islands' law. The Epstein
Enterprise used the Virgin Islands' land, resources, people, and laws for its illicit purposes. Rather
than participating lawfully in this community, the Epstein Enterprise took advantage of the
secluded nature of the islands in furtherance of its crimes.
72.
As a result of its deplorable and unlawful conduct, the Epstein Enterprise has
subjected the Virgin Islands to public portrayals as a hiding place for human trafficking and sex
crimes.
C. The "Epstein Enterprise" Fraudulently Concealed its Conduct
73.
The Epstein Enterprise fraudulently concealed its actions to prevent detection by
the Government of the Virgin Islands.
74.
The secluded properties at Little St. James and Great St. James were repeatedly
used by the Epstein Enterprise as the locations for unlawfully soliciting, transporting, transferring,
harboring, receiving, providing, isolating, patronizing, maintaining, deceiving, coercing, and
sexually abusing young women and children and concealing these crimes.
75.
The Epstein Enterprise was able to hide the trafficking ring from law enforcement,
despite the fact that Epstein was a registered sex offender. Given the isolation of the Little St.
James and Great St. James and the nature of the crimes and of the victims targeted by the Epstein
Enterprise, the activities of the Epstein Enterprise were not readily detectable. Moreover, Epstein's
great wealth and power likely made witnesses reluctant to report their observations to the local law
enforcement.
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76.
Upon information and belief, the Epstein Enterprise prevented its employees from
cooperating with law enforcement. Employees and others were required to sign confidentiality
agreements that prohibited them from speaking to or sharing information with law enforcement. If
they were contacted by law enforcement they were to notify the Epstein Enterprise and be
represented by Epstein's counsel.
77.
The employees were directed not to communicate or interact with guests visiting
Little St. James and were also directed not to disclose to anyone events that occurred on the island.
78.
Monitoring a sex offender with his own private islands and the resources to fly
victims in and out on private planes and helicopters presented unique challenges and allowed the
Epstein Enterprise to limit scrutiny by the Government of the Virgin Islands.
79.
Sexual Offender Registration and Community Protection Act ("SORCPA") 14
V.I.C. § 1721, et. seq. requires sex offenders to register in their resident jurisdictions and to make
periodic in-person appearances to verify and update their registration information.
80.
Epstein renewed his registration each year in the Virgin Islands. In addition,
beyond this statutory requirement, the Virgin Islands periodically visited-or attempted to visit-
Little St. James to conduct additional address verifications.
81.
At his last verification in July 2018, Epstein refused to permit Virgin Islands
Department of Justice Investigators, assisted by United States Marshals, to enter Little St. James
beyond its dock, claiming that the dock was his "front door." Instead, Epstein arranged to be met
at his office on St. Thomas.
82.
Epstein also misled the Government regarding his travel plans. On March 19, 2019,
the Virgin Islands was notified that Epstein would be traveling to France for 10 days on the private
plane owned by Plan D, LLC. His notification form did not disclose travel to any other countries.
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It was later found by law enforcement authorities that Epstein also travelled to Vienna and Monaco
during that trip.
83.
Similarly, the Epstein Enterprise sought to prevent DPNR from conducting routine
site visits to inspect unpermitted and potentially damaging construction activity on Great St. James.
The Epstein Enterprise repeatedly objected to DPNR's inspections referring to them as "invasions"
of Epstein's constitutional right to privacy in his home, which he described defined as the entire
island. These DPNR inspections are required for all construction and Virgin Islands residents are
required to cooperate with the inspections to assure compliance with the law throughout the
construction phases.
84.
These efforts represent Epstein Enterprise's intent to conceal its unlawful activity
on Little St. James and Great St. James.
85.
The Epstein Enterprise also created numerous corporations and limited liability
companies in the Virgin Islands to help conceal its unlawful activity. Most of these companies
were created in 2011 and 2012, soon after Epstein registered as a sex offender in the Virgin Islands.
86.
Epstein's pilot, Larry Visoski is identified as member or co-member in companies
that serviced and maintained the planes that the Epstein Enterprise used to traffick young women
and children - Freedom Air Petroleum, LLC (registered November 28, 2011 to hold assets); and
JEGE, LLC (registered October 19, 2012 to hold assets).
87.
Other Epstein entities include LSJ Employees, LLC (registered October 27, 2011
to provide services); Southern Financial, LLC (registered February 25, 2013 to provide services)
and LSJ Emergency, LLC (registered December 2, 2015 to provide services).
88.
Some of these companies held considerable assets: Financial Informatics, Inc.
(incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of
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approximately $391 million in 2015; and Financial Trust Company, Inc. (incorporated November
6, 1998) had assets of $212 million when it publicly filed its last balance sheet in 2012.
89.
Though often absent in the original incorporation or registration documents or
annual filings, Epstein ultimately appeared as president, director, manager, or sole member of each
of these companies. Upon information and belief, the purpose of this complex array of corporate
entities-some of which may still be discovered-was to allow Epstein to shelter his assets in
order to fund, carry out, and conceal his identity and pattern of criminal conduct.
90.
The Estate continues to engage in a course of conduct aimed at concealing the
criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an
Expedited Motion for Establishment of a Voluntary Claims Resolution Program in the Superior
Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to
be designed to "establish an independent and voluntary claims resolution program for purposes of
resolving sexual abuse claims against Jeffrey E. Epstein." (Motion, at 1).
91.
The program proposed by the Estate, whose executors are trustees of The 1953
Trust and officers in at least two Epstein entities, imposes confidentiality requirements and
requires any claimant accepting an award under the program to sacrifice any other claims against
"any person or entity arising from or related to Mr. Epstein's conduct." (Motion, at 5). It acts to
conceal the criminal activities of the Epstein Enterprise and shield its participants from liability
and accountability for the injury they caused to the victims.
92.
Two days before his death, Epstein amended The Trust and his Last Will and
Testament. Upon information and belief, he did so, as part of a pattern and ongoing effort to
conceal and shield his assets from potential recovery by claimants.
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D. The "Epstein Enterprise" Violated Numerous Virgin Islands Laws
93.
The pattern of criminal activity engaged in by Epstein and other participants in the
Epstein Enterprise violated 14 V.I.C. §§ 605 and 607 of the Criminally Influenced and Corrupt
Organizations Act ("CICO").
94.
The Epstein Enterprise also violated Title 14, Chapter 3A, The Virgin Islands
Uniform Prevention of and Remedies for Human Trafficking Act relating to Trafficking of
Persons; Title 14, Chapter 24, relating to Child Protection and Child Abuse and Neglect; Title 14,
Chapter 81, relating to Prostitution and Related Offenses; Title 18, Chapter 85, relating to Rape
and Sexual Assault and other related offenses, as well as other Virgin Islands laws.
95.
The Epstein Enterprise violated Virgin Islands laws by engaging in the human
trafficking of underage girls and young women and commercial sex with young women and
underage girls by force, fraud, enticement, or coercion, which serve as predicates to the Epstein
Enterprise's violations of CICO.
96.
Certain participants who recruited women and underage girls to be trafficked and
forced into sexual servitude themselves were sexually trafficked and abused by the Epstein
Enterprise and may be afforded the protections of 14 V.I.C. $ 145.
97.
Specifically, Plan D, LLC knowingly and intentionally facilitated the trafficking
scheme by flying underage girls and young women into the Virgin Islands to be delivered into
sexual servitude. Plan D LLC repeatedly made flights from the mainland to St. Thomas with
Epstein and underage girls and young women for the purpose of engaging in sexual activity on
Little St. James. On some occasions, they would transport Epstein and female children by
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helicopter to Little St. James. On other occasions, Epstein and the young women and girls would
be transported by boat.
98.
Great St. Jim, LLC and Nautilus, Inc. knowingly participated in the Epstein
Enterprise and facilitated the trafficking and sexual servitude of young women and underage girls
by providing the secluded properties at, from, or to which Epstein and his associates were able to
transport, transfer, receive, maintain, isolate, harbor, provide, entice, deceive, coerce, and sexually
abuse underage girls and young women.
99.
The Epstein Enterprise engaged in a continuing course of unlawful conduct.
100. After Epstein's suicide, the Epstein Enterprise continued to exist as each of the
participants continued to conspire to prevent detection of the breadth and scope of the Epstein
Enterprise's criminal wrongdoing and to prevent accountability. These conspiratorial acts are
ongoing.
101. The conduct of the Epstein Enterprise offends the core purpose of the Virgin Islands
Uniform Prevention of and Remedies for Human Trafficking Act, 14 V.I.C. §131 et seq, and
violates CICO, enacted to "curtail criminal activity and lessen its economic and political power in
the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law
enforcement and the victims of criminal activity new civil sanctions and remedies." 14 V.I.C. $
601.
102. The Epstein Enterprise is an illicit enterprise within the meaning of 14 V.I.C. §§
604 and 605.
103. The Government is entitled to recover civil penalties, damages and other remedies
and to extinguish and recoup from the Epstein Enterprise any and all financial and other benefits,
and any personal and real property that was used during the course of, or intended for use in the
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course of the conduct or criminal activity in violation of the laws of the Virgin Islands. The
Government is entitled to obtain through divestiture, forfeiture, or other equitable relief all
properties and instrumentalities used by the Epstein Enterprise in the criminal pattern of trafficking
and sexual abuse in the Virgin Islands, including but not limited to Great St. James and Little St.
James, and all other remedies and penalties permitted by law in the interest of justice.
E. The Epstein Enterprise Used Corporate Entities to Defraud the Government and
Fund its Criminal Activities
104. In October 2012, the Southern Trust Company applied for economic benefits from
the Economic Development Commission ("EDC"). The EDC is a subsidiary of the Virgin Islands
Economic Development Authority ("EDA"), a semi-autonomous governmental instrumentality
created and governed pursuant to 29 VIC $ 1101.
105. In sworn testimony at a public hearing on the tax incentive application conducted
by the EDC on November 15, 2012, Epstein and his attorney, Ericka Kellerhals, described
Southern Trust Company as providing "cutting edge consulting services" in the area of
"biomedical and financial informatics."
106. The EDC granted Southern Trust Company a 10-year package of economic
incentives running from February 1, 2013 until January 31, 2023 that included a 90% exemption
from income taxes and 100% exemptions from gross receipts, excise, and withholding taxes in the
Virgin Islands.
107. Between 2013 and 2019, Southern Trust Company employed 13 different
individuals (not including Epstein). Of those 13 individuals, 11 served in administrative or support
roles: six as personal, administrative, or executive assistants, receptionists, or as a driver/helper,
one as an office manager, one as a clerk, and three in accounting or payroll functions (though only
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one was licensed as a certified public accountant). There was one network administrator/IT
manager, and a second who was added in 2019.
108. In fact, several of those individuals seemed to perform other personal services for
Jeffrey Epstein. Though he was reported by Southern Trust Company to be resident of the Virgin
Islands, the network administrator/IT manager was issued a Florida driver's license, which listed
an address in Miami. Further, he appears, in fact, to have served as Epstein's driver and picked up
luggage and cargo from Epstein's private planes on his behalf.
109. Another executive assistant lived at 301 E. 66th Street, Apartment 11B, New York,
New York. Epstein's address book lists units various units in this building as providing "Apt. for
models" and she is publicly identified as a model. As noted above, the Epstein Enterprise used
modeling opportunities and contracts as a pretext for recruiting underage girls and young women
into its sex trafficking scheme.
110. During several time periods, Southern Trust Company affirmed to EDC that it had
no employees who were non-residents, even though it employed non-residents.
111. Despite having only one full-time employee working on information technology
during the bulk of the period, Southern Trust Company reportedly generated net income of $50.3
million in 2013, $67.5 million in 2014, $52.8 million in 2015, and $4.8 million in 2016 and $17.1
million in 2017, with aggregate income of $117.8 million in 2014, $170.6 million in 2015, $175.3
million in 2016 and $192.4 million in 2017, or aggregate income for the period of $656 million.
112. For the period between January 1, 2013 and December 31, 2017, Southern Trust
Company received tax exemptions totaling $73.6 million.
113. As of December 31, 2017, Southern Trust Company, Inc. elected to file its income
tax as an S-corporation, which elects to pass corporate income, losses, deductions and credits
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through to its sole shareholder-Jeffrey Epstein-for tax purposes. For this time period, Epstein's
income tax exemption was $71.3 million.
114. Based upon these facts, it is clear that Southern Trust Company did not perform the
"informatics" business represented to the EDC and could not have generated the business income
attributable to that business. Instead, upon information and belief, Southern Trust Company
existed to secure tax benefits for Epstein, to employ individuals associated with the Epstein
Enterprise, and to provide a source of income to support his criminal activities and properties in
the Virgin Islands.
COUNT ONE
Human Trafficking - Trafficking an Individual
Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"),
14 V.I.C. § 600 et seq.; and 14 V.I.C §133
115. The Government restates and realleges paragraphs 1 to 115 of this Complaint as if
fully set forth herein.
116. At all times material herein, each Defendant directly and indirectly participated in
or associated with the Epstein Enterprise, an illicit enterprise.
117. The Epstein Enterprise engaged in two or more occasions of conduct that constitute
criminal predicate acts as defined by CICO, including, but not limited to, knowingly recruiting,
transporting, transferring, harboring, receiving, providing, obtaining, isolating, maintaining, or
enticing female children and young women in the furtherance and performance of forced labor,
sexual servitude and commercial sexual activity in violation of Virgin Islands laws codified in 14
V.I.C. §§ 133-138.
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118. Defendants through a pattern of criminal activity acquired and maintained, directly
or indirectly, an interest in or control of the Epstein Enterprise or real property.
119. Defendants benefited, directly and indirectly, from the pattern of criminal activity
conducted by the Epstein Enterprise.
120. At all times material herein, Defendants engaged in said pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. §600 et seq.
COUNT TWO
Human Trafficking - Trafficking an Individual
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act
14 V.I.C. $ 600 et seq. and 14 V.I.C §133
121. The Government restates and realleges paragraphs 1-120 of this Complaint as if
fully set forth herein.
122. At all times material herein, each Defendant joined in a conspiracy to violate laws
prohibiting human trafficking.
123. Each Defendant engaged in acts that revealed its intent to join and participate in the
criminal conspiracy by recruiting, transporting, transferring, harboring, receiving, providing,
obtaining, isolating, maintaining or enticing female children and young women in the furtherance
and performance of forced labor, sexual servitude and commercial sexual activity in violation of
Virgin Islands laws codified in 14 V.I.C. $ 133 -138.
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124. Defendants knowingly benefited financially and/or obtained other non-financial
value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced
labor, sexual servitude and commercial sexual activity of girls and young women in knowing or
reckless disregard of the laws of the Virgin Islands.
125. At all times material herein, each Defendant conspired with Epstein and other
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking,
forced labor, and sexual servitude. 14 V.I.C. 604(j).
126. At all times material herein, Defendants engaged in said pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. §600 et seq.
COUNT THREE
Human Trafficking - Forced Labor
Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"),
14 V.I.C. § 600 et seq.; and 14 V.I.C $134
127. The Government restates and realleges paragraphs 1-126 of this Complaint as if
fully set forth herein.
128. At all times material herein, each Defendant directly and indirectly participated in
or associated with the Epstein Enterprise, an illicit enterprise.
129. The Epstein Enterprise engaged in two or more occasions of conduct that constitute
criminal predicate acts as defined by CICO, including, but not limited to, knowingly using coercion
to compel underage girls and young women to provide labor or services by forced labor in violation
of 14 V.I.C. § 134.
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130. The Epstein Enterprise knowingly provided or obtained the labor services of
individuals by means of force, threats of force, physical restraint, and/or threats of physical
restraint; by means of serious harm or threats of serious harm; by means of abuse or threatened
abuse of law or legal processes; and by means of the Epstein Enterprise with the intent to cause
individuals to believe that, if individuals did not perform such labor or services, individuals would
suffer serious harm or physical restraint.
131. Defendants through a pattern of criminal activity directly and indirectly participated
in or associated with the Epstein Enterprise, an illicit enterprise.
132. Defendants through a pattern of criminal activity acquired and maintained, directly
or indirectly, an interest in or control of the Epstein Enterprise or real property.
133. Defendants benefited, directly and indirectly, from the pattern of criminal activity
conducted by the Epstein Enterprise.
134. At all times material herein, Defendants engaged in said pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. $600 et seq.
COUNT FOUR
Human Trafficking - Forced Labor
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act,
14 V.I.C. § 600 et seq.; and 14 V.I.C §134
135. The Government restates and realleges paragraphs 1-134 of this Complaint as if
fully set forth herein.
136. At all times material herein, each Defendant joined in a conspiracy to violate laws
prohibiting human trafficking.
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137. Each Defendant engaged in acts that revealed its intent to join and participate in the
criminal conspiracy by knowingly using coercion to compel underage girls and young women to
provide labor or services by forced labor in violation of 14 V.I.C. $ 134.
138. Defendants knowingly benefited financially and/or obtained other non-financial
value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced
labor, sexual servitude and commercial sexual activity of girls and young women in knowing or
reckless disregard of the laws of the Virgin Islands.
139. At all times material herein, each Defendant conspired with Epstein and other
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking,
forced labor, and sexual servitude. 14 V.I.C. §604(j).
140. At all times material herein, Defendants engaged in said pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. $600 et seq.
COUNT FIVE
Human Trafficking - Sexual Servitude
Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"),
14 V.I.C. § 600 et seq.; 14 V.I.C §135
141. The Government restates and realleges paragraphs 1-140 of this Complaint as if
fully set forth herein.
142. At all times material herein, each Defendant directly and indirectly participated in
or associated with the Epstein Enterprise, an illicit enterprise.
143. The Epstein Enterprise engaged in two or more occasions of conduct that constitute
criminal predicate acts as defined by CICO, including, but not limited to, knowingly maintaining
or making available minors for the purpose of engaging the minors in commercial sexual activities
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or using coercion or deception to force young women to engage in commercial sexual activity in
violation of 14 V.I.C. § 135.
144. On the pretext of providing modeling opportunities, careers and contracts,
Defendants facilitated the transporting or recruiting of young women and girls or lured and
recruited young women and underage girls to travel to the Virgin Islands where they engaged in
sexual acts with Epstein and others. In some instances, young women and underage girls were
given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts
with Epstein and others.
145. Defendants through a pattern of criminal activity directly and indirectly participated
in or associated with the Epstein Enterprise, an illicit enterprise.
146. Defendants through a pattern of criminal activity acquired and maintained, directly
or indirectly, an interest in or control of the Epstein Enterprise or real property.
147. Defendants benefited, directly and indirectly, from the pattern of criminal activity
conducted by the Epstein Enterprise.
148. At all times material herein, Defendants engaged in said pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. §600 et seq.
COUNT SIX
Human Trafficking - Sexual Servitude
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act
14 V.I.C. § 600 et seq.; 14 V.I.C §135
149. The Government restates and realleges paragraphs 1-148 of this Complaint as if
fully set forth herein.
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150. At all times material herein, each Defendant joined in a conspiracy to violate laws
prohibiting human trafficking.
151. Each Defendant engaged in acts that revealed its intent to join the criminal
conspiracy by knowingly maintaining or making available minors for the purpose of engaging the
minors in commercial sexual activities or using coercion or deception to force young women to
engage in commercial sexual activity in violation of 14 V.I.C. $ 135.
152. On the pretext of providing modeling opportunities, careers and contracts,
Defendants facilitated the transporting or recruiting of young women and girls or lured and
recruited young women and underage girls to travel to the Virgin Islands where they engaged in
sexual acts with Epstein and others. In some instances, young women and underage girls were
given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts
with Epstein and others.
153. Defendants knowingly benefited financially and/or obtained other non-financial
value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced
labor, sexual servitude and commercial sexual activity of girls and young women in knowing or
reckless disregard of the laws of the Virgin Islands.
154. At all times material herein, each Defendant conspired with Epstein and other
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking,
forced labor, and sexual servitude. 14 V.I.C. 604(j).
155. At all times material herein, Defendants engaged in said pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. $600 et seq.
EFTA00018807

=== Page 31 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 31 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 30 of 55
COUNT SEVEN
Human Trafficking - Patronizing Minors and Victims of Sexual Servitude
Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"),
14 V.I.C. § 600 et seq.; 14 V.I.C §§ 136-37
156. The Government restates and realleges paragraphs 1-155 of this Complaint as if
fully set forth herein.
157. At all times material herein, each Defendant directly and indirectly participated in
or associated with the Epstein Enterprise, an illicit enterprise.
158. The Epstein Enterprise engaged in two or more occasions of conduct that constitute
criminal predicate acts as defined by CICO, including, but not limited to, knowingly giving,
agreeing to give, or offering to give items of value to young women and minors so that the young
women and minors would engage in commercial sexual activity with Epstein, other Defendants,
and other individuals in violation of 14 V.I.C. §§ 136-137.
159. In some instances, young women and underage girls were given scholarships,
money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and
others.
160. Defendants through a pattern of criminal activity directly and indirectly participated
in or associated with the Epstein Enterprise, an illicit enterprise.
161. Defendants through a pattern of criminal activity acquired and maintained, directly
or indirectly, an interest in or control of the Epstein Enterprise or real property.
162. Defendants benefited, directly and indirectly, from the pattern of criminal activity
conducted by the Epstein Enterprise.
EFTA00018808

=== Page 32 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 32 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 31 of 55
163. At all times material herein, Defendants engaged in said pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO
14 V.I.C. $600 et seq.
COUNT EIGHT
Human Trafficking - Patronizing Minors and Victims of Sexual Servitude
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act
14 V.I.C. § 600 et seq.; 14 V.I.C §§ 136-37
164. The Government restates and realleges paragraphs 1-163 of this Complaint as if
fully set forth herein.
165. At all times material herein, each Defendant joined in a conspiracy to violate laws
prohibiting human trafficking.
166. Each Defendant engaged in acts that revealed its intent to join and participate in the
criminal conspiracy by knowingly giving, agreeing to give, or offering to give items of value to
young women and minors so that the young women and minors would engage in commercial
sexual activity with Epstein, other Defendants, and other individuals in violation of 14 V.I.C. §§
136-137.
167. In some instances, young women and underage girls were given scholarships,
money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and
others.
168. Defendants knowingly benefited financially and/or obtained other non-financial
value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced
labor, sexual servitude and commercial sexual activity of girls and young women in knowing or
reckless disregard of the laws of the Virgin Islands.
EFTA00018809

=== Page 33 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 33 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 32 of 55
169. At all times material herein, each Defendant conspired with Epstein and other
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking,
forced labor, and sexual servitude.
170. At all times material herein, Defendants engaged in said pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO
14 V.I.C. §600 et seq.
COUNT NINE
Child Abuse and Neglect
Violation of the Criminally Influenced and Corrupt Organization Act ("CICO"),
14 V.I.C. § 600 et seq.; 14 V.I.C §§ 505, 506 and 507
171. The Government restates and realleges paragraphs 1-170 of this Complaint as if as
if fully set forth herein.
172. At all times material herein, each Defendant directly and indirectly participated in
or associated with the Epstein Enterprise, an illicit enterprise.
173. The Epstein Enterprise engaged in two or more occasions of conduct that constitute
criminal predicate acts as defined by CICO, including, but not limited to, knowingly or recklessly
causing a child to suffer physical, mental or emotional injury, or knowingly or recklessly causing
a child to be placed in a situation where it is reasonably foreseeable that such child may suffer
physical, mental or emotional injury, in violation Virgin Islands criminal laws prohibiting Child
Abuse and Neglect in Title 14 V.I.C. § 500 et. seq.
174. As a result of the Epstein Enterprise's actions numerous young girls suffered
serious physical, mental and emotional injury.
175. Defendants through a pattern of criminal activity acquired and maintained, directly
or indirectly, an interest in or control of the Epstein Enterprise or real property.
EFTA00018810

=== Page 34 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 34 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 33 of 55
176. Defendants benefited, directly and indirectly, from the pattern of criminal activity
conducted by the Epstein Enterprise.
177. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. §600 et seq.
COUNT TEN
Child Abuse and Neglect
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act,
14 V.I.C. § 600 et seq.; 14 V.I.C §§ 505, 506 and 507
178. The Government restates and realleges paragraphs 1-177 of this Complaint as if as
if fully set forth herein.
179. At all times material herein, each Defendant joined in a conspiracy to violate laws
prohibiting child abuse and neglect.
180. Each Defendant engaged in acts that revealed its intent to join and participate in the
criminal conspiracy as they knowingly or recklessly caused a child to suffer physical, mental or
emotional injury, or knowingly or recklessly caused a child to be placed in a situation where it is
reasonably foreseeable that such child may suffer physical, mental or emotional injury, in violation
Virgin Islands criminal laws prohibiting Child Abuse and Neglect in Title 14 V.I.C. § 500 et seq.
181. As a result of Defendants' actions, numerous young girls suffered serious physical,
mental and emotional injury.
182. Defendants knowingly benefited financially and/or obtained other non-financial
value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced
labor, sexual servitude and commercial sexual activity of girls and young women in knowing or
reckless disregard of the laws of the Virgin Islands.
EFTA00018811

=== Page 35 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 35 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 34 of 55
183. At all times material herein, each Defendant conspired with Epstein and other
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking,
forced labor, and sexual servitude. 14 V.I.C. $604(j).
184. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. $600 et seq.
COUNT ELEVEN
Aggravated Rape
Violation of the Criminally Influenced and Corrupt Organization Act ("CICO"),
14 V.I.C. § 600 et seq.; 14 V.I.C § 1700a
185. The Government restates and realleges paragraphs 1-184 of this Complaint as if
fully set forth herein.
186. At all times material herein, each Defendant directly and indirectly participated in
or associated with the Epstein Enterprise, an illicit enterprise.
187. The Epstein Enterprise engaged in two or more occasions of conduct that constitute
criminal predicate acts as defined by CICO, including, but not limited to, conduct that constituted
or facilitated the rape of minors by force, intimidation, or the perpetrator's position of authority
over the victim.
188. Epstein and others, using force or intimidation, engaged in sexual intercourse with
underage girls without their consent in violation of 14 V.I.C. § 1700a.
189. As a result of the Epstein Enterprise's actions, numerous underage girls suffered
serious physical, mental and emotional injury.
190. Defendants through a pattern of criminal activity acquired and maintained, directly
or indirectly, an interest in or control of the Epstein Enterprise or real property.
EFTA00018812

=== Page 36 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 36 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 35 of 55
191. Defendants benefited, directly and indirectly, from the pattern of criminal activity
conducted by the Epstein Enterprise.
192. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. §600 et seq.
COUNT TWELVE
Aggravated Rape
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act,
14 V.I.C. § 600 et seq.; 14 V.I.C § 1700a
193. The Government restates and realleges paragraphs 1-192 of this Complaint as if
fully set forth herein.
194. At all times material herein, each Defendant joined in a conspiracy to violate laws
prohibiting aggravated rape.
195. Each Defendant engaged in acts that revealed its intent to join and participate in the
criminal conspiracy by engaging in conduct that constituted or facilitated the rape of minors by
force, intimidation, or the perpetrator's position of authority over the victim.
196. Epstein and others, using force or intimidation, engaged in sexual intercourse with
underage girls without their consent in violation of 14 V.I.C. § 1700a.
197. As a result of Defendants' actions, numerous underage girls suffered serious
physical, mental and emotional injury.
198. Defendants knowingly benefited financially and/or obtained other non-financial
value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced
labor, sexual servitude and commercial sexual activity of girls and young women in knowing or
reckless disregard of the laws of the Virgin Islands.
EFTA00018813

=== Page 37 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 37 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 36 of 55
199. At all times material herein, each Defendant conspired with Epstein and other
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking,
forced labor, and sexual servitude. 14 V.I.C. $604(j).
200. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. §600 et seq.
COUNT THIRTEEN
Rape in the Second Degree
Violation of the Criminally Influenced and Corrupt Organization Act ("CICO"),
14 V.I.C. § 600 et seq.; 14 V.I.C § 1702
201. The Government restates and realleges paragraphs 1- 200 of this Complaint as if
fully set forth herein.
202. At all times material herein, each Defendant directly and indirectly participated in
or associated with the Epstein Enterprise, an illicit enterprise.
203. The Epstein Enterprise engaged in two or more occasions of conduct that constitute
criminal predicate acts as defined by CICO, including, but not limited to, conduct that constituted
or facilitated the rape of girls under 18 years of age.
204. Epstein and others who engaged in rape were over 18 years old at the time of the
incidents.
EFTA00018814

=== Page 38 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 38 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 37 of 55
205. As a result of the Epstein Enterprise's actions, numerous minors suffered serious
physical, mental and emotional injury.
206. Defendants through a pattern of criminal activity acquired and maintained, directly
or indirectly, an interest in or control of the Epstein Enterprise or real property.
207. Defendants benefited, directly and indirectly, from the pattern of criminal activity
conducted by the Epstein Enterprise.
208. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. $600 et seq.
COUNT FOURTEEN
Rape in the Second Degree
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act,
14 V.I.C. § 600 et seq.; 14 V.I.C $ 1702
209. The Government restates and realleges paragraphs 1-208 of this Complaint as if
fully set forth herein.
210. At all times material herein, each Defendant joined in a conspiracy to violate laws
prohibiting rape in the second degree.
211. Each Defendant engaged in acts that revealed its intent to join and participate in the
criminal conspiracy by engaging in conduct that constituted or facilitated the rape of girls under
18 years of age.
212. Epstein and others who engaged in rape were over 18 years old at the time of the
incidents.
EFTA00018815

=== Page 39 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 39 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 38 of 55
213. As a result of Defendants' actions, numerous minors suffered serious physical,
mental and emotional injury.
214. Defendants knowingly benefited financially and/or obtained other non-financial
value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced
labor, sexual servitude and commercial sexual activity of girls and young women in knowing or
reckless disregard of the laws of the Virgin Islands.
215. At all times material herein, each Defendant conspired with Epstein and other
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking,
forced labor, and sexual servitude. 14 V.I.C. $604(j).
216. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. $600 et seq.
COUNT FIFTEEN
Unlawful Sexual Contact in the First or Second Degree
Violation of the Criminally Influenced and Corrupt Organization Act ("CICO"),
14 V.I.C. § 600 et seq.; 14 V.I.C §§ 1708 and 1709
217. The Government restates and realleges paragraphs 1- 216 of this Complaint as if as
if fully set forth herein.
218. At all times material herein, each Defendant directly and indirectly participated in
or associated with the Epstein Enterprise, an illicit enterprise.
219. The Epstein Enterprise engaged in two or more occasions of conduct that constitute
criminal predicate acts as defined by CICO, including, but not limited to, using or facilitating the
EFTA00018816

=== Page 40 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 40 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 39 of 55
use of force or coercion to accomplish sexual contact or engaging in sexual contact with a minor
between 13 and 16 years of age.
220. Epstein and others who engaged in the sexual contact were over 18 years old at the
time of the incidents.
221. As a result of the Epstein Enterprise's actions numerous young women and minors
suffered serious physical, mental and emotional injury.
222. Defendants through a pattern of criminal activity acquired and maintained, directly
or indirectly, an interest in or control of the Epstein Enterprise or real property.
223. Defendants benefited, directly and indirectly, from the pattern of criminal activity
conducted by the Epstein Enterprise.
224. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO
14 V.I.C. §600 et seq.
COUNT SIXTEEN
Unlawful Sexual Contact in the First or Second Degree
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act,
14 V.I.C. § 600 et seq.; 14 V.I.C §§ 1708 and 1709
225. The Government restates and realleges paragraphs 1 - 224 of this Complaint as if
as if fully set forth herein.
226. At all times material herein, each Defendant joined in a conspiracy to violate laws
prohibiting unlawful sexual contact.
227. Each Defendant engaged in acts that revealed its intent to join and participate in the
criminal conspiracy by using or facilitating the use of force or coercion to accomplish sexual
contact or engaging in sexual contact with a minor between 13 and 16 years of age.
EFTA00018817

=== Page 41 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 41 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 40 of 55
228. Epstein and others who engaged in the sexual contact were over 18 years old at the
time of the incidents.
229. As a result of Defendants' actions, numerous young women and minors suffered
serious physical, mental and emotional injury.
230. Defendants knowingly benefited financially and/or obtained other non-financial
value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced
labor, sexual servitude and commercial sexual activity of girls and young women in knowing or
reckless disregard of the laws of the Virgin Islands.
231. At all times material herein, each Defendant conspired with Epstein and other
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking,
forced labor, and sexual servitude. 14 V.I.C. $604(j).
232. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO
14 V.I.C. $600 et seq.
COUNT SEVENTEEN
Prostitution and Keeping House of Prostitution
Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"),
14 V.I.C. § 600 et seq.: 14 V.I.C. §§ 1622, 1624
233. The Government restates and realleges paragraphs 1 - 232 of this Complaint as if
fully set forth herein.
234. At all times material herein, each Defendant directly and indirectly participated in
or associated with the Epstein Enterprise, an illicit enterprise.
EFTA00018818

=== Page 42 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 42 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 41 of 55
235. The Epstein Enterprise engaged in two or more occasions of conduct that constitute
criminal predicate acts as defined by CICO, including the engaging in or facilitating the knowing
and/or reckless abuse of minors through the acts alleged herein.
236. The Epstein Enterprise knowingly persuaded, induced, enticed, and/or coerced
women and children to travel to the Virgin Islands to engage in prostitution and/or sexual activity,
and/or attempted to do the same.
237. The Epstein Enterprise kept, maintained, and/or permitted his property at Little St.
James to be used for the purpose of prostitution, lewdness or assignation with knowledge or
reasonable cause to know the same.
238. The Epstein Enterprise received or offered or agreed to receive women and children
at his property at Little St. James for the purposes of prostitution, lewdness or assignation, and/or
permitted women and children to remain there for such purposes.
239. The Epstein Enterprise directed, took, transported, and or offered or agreed to take
or transport women and children to Little St. James with the knowledge or reasonable cause to
know that the purpose of such directing, taking or transporting was prostitution, lewdness or
assignation.
240. The Epstein Enterprise knew or should reasonably have known that individuals that
were the subjects of the actions described in this Count were minors.
241. As a result of Defendants' actions, numerous young women and minors suffered
serious physical, mental and emotional injury.
242. Defendants through a pattern of criminal activity acquired and maintained, directly
or indirectly, an interest in or control of the Epstein Enterprise or real property.
EFTA00018819

=== Page 43 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 43 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 42 of 55
243. Defendants benefited, directly and indirectly, from the pattern of criminal activity
conducted by the Epstein Enterprise.
244. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. §600 et seq.
COUNT EIGHTEEN
Prostitution and Keeping House of Prostitution
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act,
14 V.I.C. § 600 et seq.: 14 V.I.C. §§ 1622, 1624.
245. The Government restated and realleges paragraph 1 - 244 of this Complaint as if
fully set forth herein.
246. At all times material herein, each Defendant joined a conspiracy to laws against
prostitution.
247. Each Defendant engaged in acts that revealed its intent to join and participate in the
criminal conspiracy by engaging in or facilitating the persuasion, inducement, enticement or
coercion of women and children to travel to the Virgin Islands to engage in prostitution and/or
sexual activity, and/or attempted to do the same; keeping, maintaining, and/or permitting Epstein's
property at Little St. James, to be used for the purpose of prostitution, lewdness or assignation with
knowledge or reasonable cause to know the same; receiving, offering, or agreeing to receive
individuals at his property at Little St. James for the purposes of prostitution, lewdness or
assignation, and/or permitted women and children to remain there for such purposes; and directing,
taking, transporting, and/or offering or agreeing to take or transport women and children to Little
St. James with the knowledge or reasonable cause to know that the purpose of such directing,
EFTA00018820

=== Page 44 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 44 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 43 of 55
taking or transporting was prostitution, lewdness or assignation, in violation of 14 V.I.C. §§ 1622
and 1624.
248. Defendants knew or should reasonably have known that individuals that were the
subjects of the actions described in this Count were minors.
249. As a result of Defendants' actions numerous young women and minors suffered
serious physical, mental and emotional injury.
250. Defendants knowingly benefited financially and/or obtained other non-financial
value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced
labor, sexual servitude and commercial sexual activity of girls and young women in knowing or
reckless disregard of the laws of the Virgin Islands.
251. At all times material herein, each Defendant conspired with Epstein and other
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking,
forced labor, and sexual servitude. 14 V.I.C. 604(j).
252. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO
14 V.I.C. §600 et seq.
EFTA00018821

=== Page 45 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 45 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 44 of 55
COUNT NINETEEN
Sex Offender Registry
Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"),
14 V.I.C. § 600 et seq.: 14 V.I.C. $ 1721 et seq.
253. The Government restates and realleges paragraphs 1- 240 of this Complaint as if
fully set forth herein.
254. Epstein was required to, and did, register under the Virgin Islands Sexual Offender
Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq.
255. SORCPA requires that offenders required to register provide information relating
to intended travel in foreign commerce.
256. On at least two occasions, Epstein traveled to Vienna and Monaco without
disclosing that travel to the Virgin Islands sex offender registry.
257. Epstein's failure to disclose this travel before, during, or even after his travel was
knowing.
258. Epstein's violation SORPCA was part of a pattern of criminal activity that was not
isolated but was related to the affairs of the Epstein Enterprise. 14 V.I.C. $604(j).
COUNT TWENTY
Fraudulent Conveyance
Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"),
14 V.I.C. § 600 et seq.: 14 V.I.C. §§ 832-833
259. The Government restates and realleges paragraphs 1- 258 of this Complaint as if
fully set forth herein.
260. At all times material herein, each Defendant directly and indirectly participated in
or associated with the Epstein Enterprise, an illicit enterprise.
EFTA00018822

=== Page 46 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 46 of 55
GVI v. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 45 of 55
261. Each Defendant engaged in two or more occasions of conduct that constitute
criminal predicate acts as defined by CICO, including, but not limited to transferring assets to and
between various entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder
or delay claims against them.
262. Upon information and belief, in an effort to defeat the claims of creditors and avoid
the oversight of the court probating his estate, Epstein, days before his death, transferred significant
assets, including assets held by other Defendants, into The 1953 Trust.
263. At the time of these transfers, Epstein had numerous actions pending against him
related to his trafficking and sexual assaults seeking financial judgments.
264. Through these transfers, Epstein and the Epstein Enterprise fraudulently removed
property and effects beyond the jurisdiction of the probate court.
265. Epstein and the Epstein Enterprise were parties to the fraudulent conveyance of the
property, real or personal, and/or the interests or rights arising out of property, contracts, or
conveyances of Epstein and the Epstein Enterprise.
266. Epstein and the Epstein Enterprise acted with the intent to defeat, hinder, or delay
creditors and claimants, including the Government of the Virgin Islands, in collecting on their
judgements, debts and demands.
267. Defendants through a pattern of criminal activity acquired and maintained, directly
or indirectly, an interest in or control of the Epstein Enterprise or real property.
268. Defendants benefited, directly and indirectly, from the pattern of criminal activity
conducted by the Epstein Enterprise.
EFTA00018823

=== Page 47 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 47 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 46 of 55
269. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. §600 et seq.
COUNT TWENTY-ONE
Fraudulent Conveyance
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act,
14 V.I.C. § 600 et seq.: 14 V.I.C. §§ 832-833
270. The Government restates and realleges paragraphs 1 to 269 of this Complaint as if
fully set forth herein.
271. At all times material herein, each Defendant joined in a conspiracy to commit
fraudulent conveyances.
272. Each Defendant engaged in acts that revealed its intent to join and participate in the
criminal conspiracy, including, but not limited to, transferring assets to and between various
entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder or delay claims
against them.
273. Upon information and belief, in an effort to defeat the claims of creditors and avoid
the oversight of the court probating his estate, Epstein, days before his death, transferred significant
assets, including assets held by other Defendants, into The 1953 Trust.
274. At the time of this transfer, Epstein had numerous actions pending against him
related to his trafficking and sexual assaults seeking financial judgments.
275. Through this transfer, Epstein and the Epstein Enterprise fraudulently removed
property and effects beyond the jurisdiction of the probate court.
EFTA00018824

=== Page 48 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 48 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 47 of 55
276. Epstein and the Epstein Enterprise were parties to the fraudulent conveyance of the
property, real or personal, and/or the interests or rights arising out of property, contracts, or
conveyances of Epstein and the Epstein Enterprise.
277. Epstein and the Epstein Enterprise acted with the intent to defeat, hinder, or delay
the Government of the Virgin Islands and other creditors and claimants to collect on their
judgements, debts and demands.
278. Defendants knowingly benefited financially and/or obtained other non-financial
value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced
labor, sexual servitude and commercial sexual activity of girls and young women in knowing or
reckless disregard of the laws of the Virgin Islands.
279. At all times material herein, each Defendant conspired with Epstein and other
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking,
forced labor, and sexual servitude. 14 V.I.C. 604(j).
280. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. $600 et seq.
COUNT TWENTY-TWO
Civil Conspiracy
281. The Government restates and realleges paragraphs 1 - 280 of this Complaint as if
fully set forth herein.
EFTA00018825

=== Page 49 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 49 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 48 of 55
282. Defendants acted in concert and joined with others to perform the wrongful acts
identified in Counts 1 to 13, among others, concealing the sexual abuse of minor females by
unlawful means.
283. Each co-conspirator knew, or in the exercise of reasonable care should have known,
about the conduct of the others and about the common unlawful scheme.
284. These unlawful acts could not have been carried to the length and extent
accomplished without the common understanding shared by Epstein and the Epstein Enterprise
Defendants.
285. Each of the Defendants had a duty to report, stop or terminate the wrongful conduct,
but instead each Defendant concealed, assisted and furthered the wrongful acts by use of civil
conspiracy.
286. As a direct and proximate result of Defendants' conspiracy, the Virgin Island has
been injured.
287. Each co-conspirator is jointly and severally liable for the acts alleged herein.
COUNT TWENTY-THREE
Fraudulent Claims Upon the Government
Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO),
14 V.I.C. $ 600 et seq.; 14 V.I.C. $ 843
288. The Government restates and realleges paragraphs_1-287 of this Complaint as if
fully set forth herein.
289. At all times relevant and material herein, each Defendant directly and indirectly
participated in or associated with the Epstein Enterprise, an illicit enterprise.
EFTA00018826

=== Page 50 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 50 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 49 of 55
290. Each Defendant engaged in two or more occasions of conduct that constitute
criminal predicate acts as defined by CICO, including, but not limited to, making fraudulent claims
upon the Government.
291. The Epstein Enterprise misrepresented the purpose, activities, employment, and
income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax
incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epstein
Enterprise used Southern Trust Company to employ, pay, and conceal the activities of participants
in the criminal activities of the Enterprise.
292. The Epstein Enterprise made and presented an application for tax incentives,
testimony, and quarterly reports to the EDC, a commission of the Government, regarding the
Southern Trust Company, knowing such claims to be false, fictitious, or fraudulent; knowingly
and willfully falsified, concealed or covered up material facts regarding the Southern Trust
Company; made false or fraudulent statements or representations about the purpose, activities,
income, and employment of Southern Trust Company; and made and submitted false affidavits
knowing the same to contain any fraudulent or fictitious statement or entry.
293. These false statements and documents included affidavits, testimony, an
application, and other documents that misrepresented that Southern Trust Company was engaged
in, and failed to disclose it did not and could not carry out, in its stated purpose of providing
consulting services in financial and biomedical informatics.
294. Defendants knowingly benefited financially and/or obtained other non-financial
value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced
labor, sexual servitude, and commercial sexual activity of underage girls and young women in
knowing and reckless disregard of the laws of the Virgin Islands.
EFTA00018827

=== Page 51 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 51 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 50 of 55
295. Defendants through a pattern of criminal activity acquired and maintained, directly
or indirectly, an interest in or control of the Epstein Enterprise or real property.
296. Defendants benefited, directly and indirectly, from the pattern of criminal activity
conducted by the Epstein Enterprise.
297. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. §600 et seq.
COUNT TWENTY-FOUR
Fraudulent Claims Upon the Government
Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act,
14 .I.C. § 600 et seq.; 14 V.I.C. $ 843
298. The Government restates and realleges paragraphs 1 to 297 of this Complaint as if
fully set forth herein.
299. At all times material herein, each Defendant joined in a conspiracy to commit
fraudulent conveyances.
300. Each Defendant engaged in acts that revealed its intent to join and participate in the
criminal conspiracy, including, but not limited to, transferring assets to and between various
entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder or delay claims
against them.
301. The Epstein Enterprise misrepresented the purpose, activities, employment, and
income of the Southern Trust Company, Inc., in order to obtain and maintain valuable tax
incentives in order to fund the criminal activities of the Epstein Enterprise. In addition, the Epstein
EFTA00018828

=== Page 52 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 52 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 51 of 55
Enterprise used Southern Trust Company to employ, pay, and conceal the activities of participants
in the criminal activities of the Enterprise.
302. The Epstein Enterprise made and presented an application for tax incentives,
testimony, and quarterly reports to the EDC, a commission of the Government, regarding the
Southern Trust Company, knowing such claims to be false, fictitious, or fraudulent; knowingly
and willfully falsified, concealed or covered up material facts regarding the Southern Trust
Company; made false or fraudulent statements or representations about the purpose, activities,
income, and employment of Southern Trust Company; and made and submitted false affidavits
knowing the same to contain any fraudulent or fictitious statement or entry.
303. These false statements and documents included affidavits, testimony, an
application, and other documents that misrepresented that Southern Trust Company was engaged
in, and failed to disclose it did not and could not carry out, in its stated purpose of providing
consulting services in financial and biomedical informatics.
304. Defendants knowingly benefited financially and/or obtained other non-financial
value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced
labor, sexual servitude, and commercial sexual activity of underage girls and young women in
knowing and reckless disregard of the laws of the Virgin Islands.
305. At all times material herein, each Defendant conspired with Epstein and other
Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking,
forced labor, and sexual servitude. 14 V.I.C. 604(j).
306. At all times material herein, Defendants engaged in a pattern of criminal activity
that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO.
14 V.I.C. $600 et seq.
EFTA00018829

=== Page 53 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 53 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 52 of 55
Notice of Allegation of
PUNITIVE DAMAGES
307.
The purpose of punitive damages in the common law is to punish the defendant
for outrageous conduct that is reckless or intentional and to deter others from engaging in such
conduct in the future.
308. This Complaint describes intentional conduct so egregious, persistent, and injurious
that it shocks the conscience and offends a civilized society.
309. Punitive damages are especially important in the case of persons or companies that
have so money, assets, and power that mere fines, penalties, and economic damages are simply
not sufficient.
310. At all times material herein, Epstein and the Epstein Enterprise engaged repeatedly
in wrongful acts which were intentional and outrageous. The Government gives notice that it
intends to pursue the possibility of punitive damages in any jury verdict.
PRAYER FOR RELIEF
WHEREFORE, the Government respectfully requests that the Court:
A.
Enter a judgment in favor of the Government and against Defendants on all counts;
B.
Declare that Defendants, through the Epstein Enterprise, have engaged in a pattern
of criminal activity in the Virgin Islands including but not limited to human trafficking, forced
labor and sexual servitude of female children and young women, unlawful sexual contact, child
sexual abuse, child abuse and neglect, rape, prostitution civil conspiracy and other offenses elated
offenses, and civil conspiracy;
EFTA00018830

=== Page 54 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 54 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 53 of 55
C.
Pursuant to 14 V.I.C. $ 610, enforce and maintain the criminal activity liens the
Government is filing contemporaneously with this lawsuit, or shall file in connection with this
action;
D.
Pursuant to 14 V.I.C. $ 607(a)(1) and 14 V.I.C. $ 141, issue an order forfeiting and
divesting in favor of the Government of the Virgin Islands all of Defendants' interests in any real
and personal property within the territory of the U.S. Virgin Islands used to facilitate the criminal
enterprise carried out by the Epstein Enterprise, including but not limited to Little St. James Island
and Greater St. James Island;
E.
Issue an order forfeiting to the Government of the Virgin Islands any proceeds or
funds obtained by Defendants, whether directly or indirectly, during the course of the criminal
activity of the Epstein Enterprise;
F.
Pursuant to 14 V.I.C. § 607(a)(1), require Defendants to divest themselves of any
real property or other interests in favor of the Government of the Virgin Islands used to further the
goals of the Epstein Enterprise;
G.
Pursuant to 14 V.I.C. § 607(a)(3) and (5), order the dissolution of the Epstein
Enterprise, including but not limited to, order the dissolution of the corporate Defendants;
H.
Pursuant to 14 V.I.C. $ 607(a)(2) enter an injunction to prevent the further criminal
conduct, and concealment of the criminal conduct, by the Epstein Enterprise;
I.
Pursuant to 14 V.I.C. $ 607(a)(4), order the revocation of any and all licenses,
permits and approvals that had been granted by any agency of the Territory, and require the
repayment of any tax benefits that had been bestowed on any Defendant;
J.
Pursuant to 14 V.I.C. § 607(a)(6)(e), award the Government the maximum civil
penalty for each and every violation of law committed by the Epstein Enterprise;
EFTA00018831

=== Page 55 ===
Case 1:15-cv-07433-LAP Document 1111-1 Filed 09/01/20 Page 55 of 55
GVI V. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 54 of 55
K.
Pursuant to 14 V.I.C. $ 607, award treble damages and all other available remedies,
including attorneys' fees and costs;
L.
Award compensatory and punitive damages for Defendants' civil conspiracy;
M.
Void the transfer of assets as fraudulently conveyed to the The 1953 Trust;
N.
Award such equitable relief, including disgorgement of all ill-gotten gains, as may
be just and proper and appropriate, pursuant to 14 V.I.C. $ 608(c)(4), to protect the rights of victims
and innocent persons in the interest of justice and consistent with the purposes of CICO;
O.
Assess and award a judgment in favor of the Government and against the
Defendants for attorneys' fees and costs and pre- and post-judgment interest; and
P.
Award any and all other relief this Court deems appropriate.
The Government demands a jury trial on all issues so triable.
RESPECTFULLY SUBMITTED,
Dated: February 5, 2020
GOVERNMENT OF THE UNITED STATES
VIRGIN ISLANDS
DENISE N. GEORGE, ESQUIRE
ATTORNEY GENERAL
V.I. Department of Justice
Office of the Attorney General
34-38 Kronprindsens Gade
GERS Building, 2nd Floor
St. Thomas, U.S.V.I. 00802
Telephone: (340) 774-5666
Email: Carol.Jacobs@vi.gov
Email: Ariel.Smith@doj.vi.gov
EFTA00018832


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=== Page 1 ===
From: Roberta Kaplan
To:
)"
Conlon"
Cc:
L. Doniger"
Subject: RE: Transcript from yesterday's conference
Date: Fri, 13 Dec 2019 21:52:58 +0000
That is what Bennet Moskowitz said (I believe) at the earlier conference before M.J. Freeman
can you pls check the transcript? I know they have also said it to me directly and he certainly didn't disagree with
me when I said it before J Failla.
Also: we got the Feinberg draft protocol today; its exactly as much of a disaster as we expected.
psl send to
along with their recent VI filings.
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
From:
Sent: Friday, December 13, 2019 1:09 PM
To:
Conlon
>; Roberta Kaplan
Subject: RE: Transcript from yesterday's conference
This is helpful and interesting, thanks very much for sending. Among other things, notable that Judge Failla assumes, even
were punitive damages to be excluded, a claim "for millions upon millions of dollars."
Separately, Robbie, I noticed near the end of the conference you mentioned, at p. 27, that: "They [the estate and/or the
trustees?] have identified the sole beneficiary as Mr. Epstein's brother." I'm wondering if you might have a recollection of
what the estate has said or represented to you about that? And if you recall whether any discussion of beneficiaries was
in connection with the will versus the trust versus the estate, etc. Just if you feel comfortable sharing any of that
information, of course- obligation at all. And if it's more convenient to relay in real time, rather than drafting up an
email, please don't hesitate to give a call. No emergency or rush, but did want to ask.
thanks,
From:
Conlon
Sent: Thursday, December 12, 2019 18:34
To:
Cc: Roberta Kaplan
Subject: Transcript from yesterday's conference
Hi there,
Attached is the transcript from yesterday's conference that Robbie described in the call today.
Take care,
Conlon Kaplan Hecker & Fink LLP
EFTA00019559

=== Page 2 ===
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.
EFTA00019560


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Epstein OIG Report
Date: Tue, 18 Aug 2020 15:59:22 +0000
Great. Wil do. Thanks.
From:
(USANYS)
Sent: Tuesday, August 18, 2020 11:58 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: Epstein OIG Report
I think putting comments in an email would be easier for OIG to consider
From:
(USANYS)
Sent: Monday, August 17, 2020 6:48 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: OCR'd OPR Report
- The team has a couple of small factual comments on the OPR draft report, none material to any of its conclusions.
How would you like us to handle these - do you want me to just call
? Draft an email or a letter? They're sufficiently
insignificant that I think a phone call would suffice, but let me know if you feel differently.
Thanks,
From:
(USANYS)
Sent: Friday, August 7, 2020 11:27 AM
To:
(USANYS)
Subject: OCR'd OPR Report
Thanks for clueing me in that it was not word-searchable-saved me a major embarrassment. I created a OCR'd
version, and there are indeed several references to "global." The OCR'd version is 121 megs, so I'll USAFx it to
you.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
(desk)
(mobile)
EFTA00017837


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=== Page 1 ===
From:
"
(NY) (FBI)"
To:
(USANYS)"
Cc:
(OIG)"
Subject: Finalized 302
Date: Wed, 18 Sep 2019 16:29:06 +0000
Attachments:
.pdf
Special Agent
FBI New York Field Office
Violent Crimes Task Force
Desk:
EFTA00017783


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Transcript
Date: Tue, 02 Nov 2021 16:36:24 +0000
Attachments: LB1TMAXF.PDF
Hey Chiefs,
Transcript attached.
Thanks,
Original Message
From:
Sent: Monday, November 1, 2021 6:17 PM
To:
Subject: Re: Transcript
For sure!
> On Nov 1, 2021, at 6:16 PM,
USANYS)
wrote:
>
> Will you send it once it comes in?
>
> Sent from my iPhone
EFTA00019060


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=== Page 1 ===
From:
To:
Subject: RE: Brass materials
Date: Wed, 14 Aug 2019 23:59:56 +0000
Attachments: Brass_Presentation_Outline_v2.docx
Here is an updated outline, also on shared. I also made some updates to the PPT on the shared, which I hope are ok - all
stylistic.
From:
Sent: Wednesday, August 14, 2019 7:15 PM
To:
Subject: Brass materials
This is super high level. Do you want to add in your stuff then we can send to the chiefs?
l'll fill this in more for my own purposes but they don't need that tonight.
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00019401


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 10893150(1) prepared by a travel arranger is pending your review
Date: Wed, 18 Dec 2019 22:03:27 +0000
Importance: Normal
Dear
Final voucher 10893150(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 10893150
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: 1407.98
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
emails that you receive from us.
Reference ID# V0012
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00019873


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: Fwd: GM Suppression Replies
Date: Tue, 16 Mar 2021 23:43:49 +0000
Attachments: !Reply_Memo_of_Law_ISO_Motion_to_Suppress_Evidence_Obtained_from_BSF_Subpoe
na_(Unredacted).pdf;
!Reply_Memo_of_Law_ISO_Motion_to_Suppress_BSF_Subpoena_Under_4A,_5A,_Martin
dell.pdf
Begin forwarded message:
From:
(USANYS)"
Date: March 16, 2021 at 7:39:41 PM EDT
To:
)"
Subject: GM Suppression Replies
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:
EFTA00018994


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
)"
)"
Cc:
)"
Subject: RE: Subpoenas Re
Date: Fri, 16 Aug 2019 17:13:18 +0000
Attachments: 2019-08-16,_subpoena_to_Western_Union.pdf; 2019-08-16,_subpoena_to_Wells_Fargo.pdf;
2019-08-16,_subpoena_to_Citibank.pdf; 2019-08-16,_subpoena_to_MoneyGram.pdf; 2019-
08-16,_subpoena_to_Experian.pdf
Subpoenas attached, thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Original Message
From:
(NY) (FBI)
Sent: Thursday, August 15, 2019 5:08 PM
To:
Cc:
i
Subject: Subpoenas Re
Please prepare and return to me subpoenas for Wells Fargo, CITI, MoneyGram, Western Union and Experian
regarding
+
I have attached the riders for the subpoenas. I will serve the subpoenas.
Additionally, please utilize the following text in the subpoenas:
If you have any questions, please contact Forensic Accountant
at
or Special Agent
at
Please forward the results in an electronic format to Special Agent
Federal Bureau of
.
Investigation, 26 Federal Plaza, New York, NY 10278, telephone
,
If you have any questions or comments, please contact me.
Thanks
EFTA00019959

=== Page 2 ===
Forensic Accountant
FBI New York Field Office
26 Federal Plaza
NYC, NY 10278
Office:
EFTA00019960


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=== Page 1 ===
From: "Miller, Michael"
To:
"bermannysdchambers@nysd.uscourts.gov" <bermannysdchambers@nysd.uscourts.gov>
Cc:
'Martin
Weinberg'
"Weingarten, Reid"
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), letter motion for order of nolle prosequi
Date: Mon, 19 Aug 2019 20:00:32 +0000
Thank you,
Mike
Michael C. Miller
Partner
Steptoe
Steptoe & Johnson LLP
1114 Avenue of the Americas I New York, NY 10036
www.steptoe.com
This message and any attached documents contain information from the law firm Steptoe & Johnson LLP that may be confidential and/or privileged. If you
are not the intended recipient, please do not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the
sender immediately by reply e-mail and then delete this message.
From:
Sent: Monday, August 19, 2019 3:57 PM
To: "bermannysdchambers@nysd.uscourts.gov' <bermannysdchambers@nysd.uscourts.gov>
Cc:
>; 'Martin Weinberg'
>; Weingarten, Reid
>; Miller, Michael
>;
is
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), letter motion for order of nolle prosequi
To the Chambers of Judge Berman:
Attached please find a courtesy copy of the Government's letter motion requesting that the Court approve the enclosed
proposed order of nolle prosequi, in connection with the above-captioned case, filed this afternoon. Defense counsel is
copied.
Thank you,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
)"
To: "Miller, Michael"
"Martin G. Weinberg"
,
"Weingarten, Reid"
Cc:
)"
)"
Subject: RE: US V Epstein
Date: Sat, 10 Aug 2019 18:13:42 +0000
Attachments: mltC634.pdf
Following up on the below, wanted to make sure the attached letter from the Warden immediately got to Mike as well (in
addition to Marty and Reid having been copied and emailed). As the letter indicates, there are now investigations
ongoing, including as initiated by the Attorney General himself. Separately, we have not received additional information
on topics such as the apparent cause of death, the status of observation of Mr. Epstein at the time, etc., but we will
continue to be in touch immediately if that changes.
thank you,
From:
Sent: Saturday, August 10, 2019 11:57
To: Miller, Michael
>; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
Subject: Re: US V Epstein
Mike, Marty, Reid,
Following up on my conversations with Mike and Marty this morning, and my discussion with Mike moments
ago, attached is a press release just sent to us (and I believe also issued publicly) some minutes ago. It represents
all the information we have from BOP so far, but of course if we are successful in our continuing efforts to get
additional information we will pass it along immediately.
Separately, we can tell you that the reports that an FBI investigation into the death has been initiated are
accurate, and I fully expect that investigation to be extremely rigorous.
As always please don't hesitate to reach out to us directly at any time if that would be useful.
thank you,
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=== Page 1 ===
From:
To:
Subject: t/c with
re: Epstein investigation
Date: Wed, 19 Dec 2018 19:22:36 +0000
Importance: Normal
Called
12/19/18 at 09:30, to advise that we had opened an investigation into Jeffrey Epstein because
represents multiple victims / plaintiffs, wanted to ask about other individuals who might be useful to speak with in the
initial stages of our investigation.
on the call
advised the following:
-
primary
attorneys on the case are / were
said
also may work on it, in response to inquiry
-
also
has worked with
former DOJ, and
-
believes there was significant misconduct in or in connection to New York
-
believes there has been possible obstruction / perjury conduct in connection with civil suits
-
best place to start is with victim attorneys, worth talking to
We requested that our inquiry remain generally confidential given the sensitivities of the investigation, including the
primarily covert nature of the investigation as well as a desire not to raise the hopes of victims at this early investigative
stage.
-
advised that he intended to honor the request to keep the investigation confidential, within the bounds
of collaborating attorneys
We agreed to speak again in the near future to arrange for subsequent discussions.
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Cc:
"
(USANYS)"
(USANYS)"
,
)"
Subject: Epstein/Maxwell FOIA
Date: Wed, 10 Mar 2021 20:13:38 +0000
Importance: Normal
Attachments: unnamed
-- Do not delete or change any of the following text. --
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EFTA00017894

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=== Page 1 ===
From:
To:
Subject: RE: Efrain Reyes
Date: Mon, 30 Nov 2020 15:25:10 +0000
Sorry to hear that. You're correct that we didn't need his testimony.
From:
Sent: Monday, November 30, 2020 9:51 AM
To:
Subject: Efrain Reyes
just learned from Probation that Efrain Reyes died. It sounds like it was in his sleep. Given his history, I
think it may have been drug related, but perhaps not. Either way, my recollection is that you didn't expect to need him for
anything Epstein/MCC-related, but just want to keep you in the loop in case my memory is wrong.
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: FW: letter re Maxwell S2 indictment
Date: Thu, 08 Apr 2021 14:57:44 +0000
Attachments: 2021-04-09_Gov't_response_to_GM_letter_re_S2_Indictment_v3. docx
I think she did a really nice job and the tone is perfect. Some edits attached.
From:
)
Sent: Thursday, April 8, 2021 10:35 AM
To:
(USANYS)
is
(USANYS)
Cc:
is
(USANYS)
is
)
Subject: letter re Maxwell S2 indictment
Hi
and
Attached for review is a draft response to defense counsel's letter complaining about the S2 Indictment. I've also attached
the defense letter for reference. Our response is due EOD tomorrow.
Thanks,
EFTA00017961


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=== Page 1 ===
##############
*
Google Confidential and Proprietary *
GOOGLE SUBSCRIBER INFORMATION
Google Account ID:
Name: Tim Routch
e-Mail:
Alternate e-Mails:
Created on: 2011-06-29 20:29:48 UTC
Terms of Service IP: 166.137.8.236
Services: Gmail, Android, Google Calendar, Google Hangouts, Google Services, Google Play, Google Payments,
Google Play Music, Google Chrome Sync, Google Cloud Print, Location History, YouTube, Google Maps,
Google Photos, Google My Maps, Web & App Activity
Deletion Date:
Deletion IP:
Last Logins: 2020-08-30 23:23:25 UTC, 2020-06-26 01:07:33 UTC, 2020-06-21 00:36:14 UTC
ACCOUNT RECOVERY
Recovery e-Mail:
Recovery SMS:
PHONE NUMBERS
Signin Phone Numbers:
2-Step Verification Phone Numbers:
IP ACTIVITY
Timestamp
IP Address
Activity Type
2020-06-26 01:09:03 UTC
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2020-06-21 00:36:14 UTC
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2020-05-02 16:27:54 UTC
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2020-05-02 16:27:50 UTC
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2020-03-27 19:16:33 UTC
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##############
*
Google Confidential and Proprietary
*
EFTA00019641


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=== Page 1 ===
From:
To:
Subject: Accepted: SDNY-ODAG Call (Epstein/Maxwell)
Date: Tue, 18 Aug 2020 16:59:09 +0000
Importance: Normal
Attachments: unnamed
EFTA00017839


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=== Page 1 ===
From
To:
@usdoj.gov>
Cc:
Subject: Epstein updates
Date: Mon, 08 Jul 2019 17:22:20 +0000
Importance: Normal
Epstein's presentment proceeding has just started.
Thanks,
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
EFTA00018158


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=== Page 1 ===
From:
)"
@usa.doj.gov>
To:
@nysd.uscourts.gov"
@nysd.uscourts.gov>
Cc: Xavier Donaldson
@aol.com>,
(USANYS)"
Subject: 13 Cr. 416 (PGG) - United States V.
(Proposed Redactions to Sentencing
Transcript) (Request to be Filed Under Seal)
Date: Sat, 19 Oct 2019 00:14:34 +0000
Attachments: Exhibit A - -
_Proposed_Redactions_to_190912_Sentencing_Transcript_(with_red_boxes),pdf;
Letter_re_Proposed_Redactions_to_Sentencing_Transcript_v1.pdf
Attached is a letter and an exhibit regarding proposed redactions to the sentencing transcript in the above-referenced
case. Because the letter and proposed redactions discuss an ongoing criminal investigation, the Government respectfully
requests that the letter and exhibit be filed under seal. Thanks so much -
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One Saint Andrews Plaza
New York, NY 11106
EFTA00019718


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=== Page 1 ===
Event: Epstein Estate
Start Date: 2020-11-09 21:30:00 +0000
End Date: 2020-11-09 22:00:00 +0000
Organizer: Weinstein, Marc A.
Location: Skype Meeting; Conference ID: 570 579 045;
Class: X-PERSONAL
Date Created: 2020-11-09 15:53:08 +0000
Date Modified: 2020-11-09 15:53:08 +0000
Priority: 5
DTSTAMP: 2020-11-09 15:30:14 +0000
Attendee:
Andrew Tomback <ATombad
Alarm: Display the following message 15m before start
Reminder
Dial-In Information (for meetings with no presentations or video)
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EFTA00019131

=== Page 2 ===
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EFTA00019132


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: RE: Epstein investigation
Date: Mon, 01 Apr 2019 16:28:20 +0000
Importance: Normal
Thank you.
From:
Sent: Monday, April 01, 2019 12:24 PM
To:
(USANYS)
Subject: RE: Epstein investigation
: )
l'll chime in too, so we have a one-two punch going.
From:
(USANYS)
Sent: Monday, April 01, 2019 12:23
To:
Subject: RE: Epstein investigation
You assume correctly.
From:
Sent: Monday, April 01, 2019 12:22 PM
To:
(USANYS)
Subject: RE: Epstein investigation
I assume you didn't hear back from her on this, but wanted to check? Thanks!
From:
(USANYS)
Sent: Friday, March 29, 2019 16:39
To:
is
(IMD) (FBI)
Cc:
is
(NY) (FBI)
is
Subject: RE: Epstein investigation
Hi
Just following up on our conversation from Wednesday. I am writing to see if everything has been uploaded to the W
drive.
Thank so much,
Abby
EFTA00019550

=== Page 2 ===
From:
Sent: Wednesday, February 13, 2019 9:53 AM
To:
(IMD) (FBI)
Cc:
is
(USANYS)
>;
(NY) (FBI)
is
Subject: RE: Epstein investigation
Hi
Wanted to quickly check in to follow up on our conversations last week and earlier this week - I think you were able to
transmit the scanned records to
but I'm not sure whether that was just the 16,000 pages you mentioned when we
last spoke, or if you were able to get all 29,000 to her? And we're also hoping to confirm for sure that all the materials
you received were definitely scanned in, and to get an index or catalog of those materials (including what media was
included).
Another person on our team,
who's copied, is jumping in to coordinate on this, so if it's easier to chat via
phone her number is
and please let us know if anything would be helpful on our end.
thanks again!
From:
Sent: Wednesday, January 30, 2019 17:19
To:
(IMD) (FBI)
Cc:
in
(USANYS)
>;
(NY) (FBI)
is
Subject: RE: Epstein investigation
Following up on our conversation from yesterday, wanted to send a quick email as promised so you have my full contact
info - I'm reachable at this email address or by phone at
(office) or
(cell). Please don't
hesitate to reach out anytime day or night if we can provide any useful info, or if you have any questions at all, and we
appreciate you talking with us about the records information. Let us know if it makes sense to set up another call for
Friday or early next week to check in on the questions we had, and thanks very much for your help.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00019551


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=== Page 1 ===
SDNY News Clips, Wednesday, July 31, 2019
SDNY News Clips
Wednesday, July 31, 2019
Contents
Public Corruption
2
Epstein
2
Collins
17
Securities and Commodities Fraud
19
Stewart
19
Thompson
21
Pinto-Thomaz
23
Narcotics
25
Castro
25
Rochester Drug Company
27
Civil
29
Life Spine
29
Matters of Interest
31
The U.S. said a California cherry-picker went to Pakistan for terrorist training. Now the case has collapsed. 31
Fed Cuts Interest Rates for First Time Since 2008 Crisis
34
1
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SDNY News Clips, Wednesday, July 31, 2019
Public Corruption
Epstein
Jeffrey Epstein Hoped to Seed Human Race With His DNA
New York Times
By James B. Stewart, Matthew Goldstein and Jessica Silver-Greenberg
7/31/19
Jeffrey E. Epstein, the wealthy financier who is accused of sex trafficking, had an unusual dream: He hoped to
seed the human race with his DNA by impregnating women at his vast New Mexico ranch.
Mr. Epstein over the years confided to scientists and others about his scheme, according to four people familiar
with his thinking, although there is no evidence that it ever came to fruition.
Mr. Epstein's vision reflected his longstanding fascination with what has become known as transhumanism: the
science of improving the human population through technologies like genetic engineering and artificial
intelligence. Critics have likened transhumanism to a modern-day version of eugenics, the discredited field of
improving the human race through controlled breeding.
Mr. Epstein, who was charged in July with the sexual trafficking of girls as young as 14, was a serial illusionist:
He lied about the identities of his clients, his wealth, his financial prowess, his personal achievements. But he
managed to use connections and charisma to cultivate valuable relationships with business and political leaders.
Interviews with more than a dozen of his acquaintances, as well as public documents, show that he used the
same tactics to insinuate himself into an elite scientific community, thus allowing him to pursue his interests in
eugenics and other fringe fields like cryonics.
Lawyers for Mr. Epstein, who has pleaded not guilty to the sex-trafficking charges, did not respond to requests
for comment.
Mr. Epstein attracted a glittering array of prominent scientists. They included the Nobel Prize-winning physicist
Murray Gell-Mann, who discovered the quark; the theoretical physicist and best-selling author Stephen
Hawking; the paleontologist and evolutionary biologist Stephen Jay Gould; Oliver Sacks, the neurologist and
best-selling author; George M. Church, a molecular engineer who has worked to identify genes that could be
altered to create superior humans; and the M.I.T. theoretical physicist Frank Wilczek, a Nobel laureate.
The lure for some of the scientists was Mr. Epstein's money. He dangled financing for their pet projects. Some
of the scientists said that the prospect of financing blinded them to the seriousness of his sexual transgressions,
and even led them to give credence to some of Mr. Epstein's half-baked scientific musings.
Scientists gathered at dinner parties at Mr. Epstein's Manhattan mansion, where Dom Pérignon and expensive
wines flowed freely, even though Mr. Epstein did not drink. He hosted buffet lunches at Harvard's Program for
Evolutionary Dynamics, which he had helped start with a $6.5 million donation.
2
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SDNY News Clips, Wednesday, July 31, 2019
Others flew to conferences sponsored by Mr. Epstein in the United States Virgin Islands and were feted on his
private island there. Once, the scientists - including Mr. Hawking - crowded on board a submarine that Mr.
Epstein had chartered.
The Harvard cognitive psychologist Steven Pinker said he was invited by colleagues - including Martin
Nowak, a Harvard professor of mathematics and biology, and the theoretical physicist Lawrence Krauss - to
"salons and coffee klatsches" at which Mr. Epstein would hold court.
While some of Mr. Pinker's peers hailed Mr. Epstein as brilliant, Mr. Pinker described him as an "intellectual
impostor."
"He would abruptly change the subject, A.D.D.-style, dismiss an observation with an adolescent wisecrack,"
Mr. Pinker said.
Another scientist cultivated by Mr. Epstein, Jaron Lanier, a prolific author who is a founding father of virtual
reality, said that Mr. Epstein's ideas did not amount to science, in that they did not lend themselves to rigorous
proof. Mr. Lanier said Mr. Epstein had once hypothesized that atoms behaved like investors in a marketplace.
Mr. Lanier said he had declined any funding from Mr. Epstein and that he had met with him only once after Mr.
Epstein in 2008 pleaded guilty to charges of soliciting prostitution from a minor.
Mr. Epstein was willing to finance research that others viewed as bizarre. He told one scientist that he was
bankrolling efforts to identify a mysterious particle that might trigger the feeling that someone is watching you.
At one session at Harvard, Mr. Epstein criticized efforts to reduce starvation and provide health care to the poor
because doing so increased the risk of overpopulation, said Mr. Pinker, who was there. Mr. Pinker said he had
rebutted the argument, citing research showing that high rates of infant mortality simply caused people to have
more children. Mr. Epstein seemed annoyed, and a Harvard colleague later told Mr. Pinker that he had been
"voted off the island" and was no longer welcome at Mr. Epstein's gatherings.
Then there was Mr. Epstein's interest in eugenics.
On multiple occasions starting in the early 2000s, Mr. Epstein told scientists and businessmen about his
ambitions to use his New Mexico ranch as a base where women would be inseminated with his sperm and
would give birth to his babies, according to two award-winning scientists and an adviser to large companies and
wealthy individuals, all of whom Mr. Epstein told about it.
It was not a secret. The adviser, for example, said he was told about the plans not only by Mr. Epstein, at a
gathering at his Manhattan townhouse, but also by at least one prominent member of the business community.
One of the scientists said Mr. Epstein divulged his idea in 2001 at a dinner at the same townhouse; the other
recalled Mr. Epstein discussing it with him at a 2006 conference that he hosted in St. Thomas in the Virgin
Islands.
The idea struck all three as far-fetched and disturbing. There is no indication that it would have been against the
law.
Once, at a dinner at Mr. Epstein's mansion on Manhattan's Upper East Side, Mr. Lanier said he talked to a
scientist who told him that Mr. Epstein's goal was to have 20 women at a time impregnated at his 33,000-
3
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SDNY News Clips, Wednesday, July 31, 2019
square-foot Zorro Ranch in a tiny town outside Santa Fe. Mr. Lanier said the scientist identified herself as
working at NASA, but he did not remember her name.
According to Mr. Lanier, the NASA scientist said Mr. Epstein had based his idea for a baby ranch on accounts
of the Repository for Germinal Choice, which was to be stocked with the sperm of Nobel laureates who wanted
to strengthen the human gene pool. (Only one Nobel Prize winner has acknowledged contributing sperm to it.
The repository discontinued operations in 1999.)
Mr. Lanier, the virtual-reality creator and author, said he had the impression that Mr. Epstein was using the
dinner parties - where some guests were attractive women with impressive academic credentials - to screen
candidates to bear Mr. Epstein's children.
Mr. Epstein did not hide his interest in tinkering with genes - and in perpetuating his own DNA.
One adherent of transhumanism said that he and Mr. Epstein discussed the financier's interest in cryonics, an
unproven science in which people's bodies are frozen to be brought back to life in the future. Mr. Epstein told
this person that he wanted his head and penis to be frozen.
Southern Trust Company, Mr. Epstein's Virgin Island-incorporated business, disclosed in a local filing that it
was engaged in DNA analysis. Calls to Southern Trust, which sponsored a science and math fair for school
children in the Virgin Islands in 2014, were not returned.
In 2011, a charity established by Mr. Epstein gave $20,000 to the Worldwide Transhumanist Association, which
now operates under the name Humanity Plus. The group's website says that its goal is "to deeply influence a
new generation of thinkers who dare to envision humanity's next steps."
Mr. Epstein's foundation, which is now defunct, also gave $100,000 to pay the salary of Ben Goertzel, vice
chairman of Humanity Plus, according to Mr. Goertzel's résumé.
"I have no desire to talk about Epstein right now," Mr. Goertzel said in an email to The New York Times. "The
stuff I'm reading about him in the papers is pretty disturbing and goes way beyond what I thought his misdoings
and kinks were. Yecch."
Alan M. Dershowitz, a professor emeritus of law at Harvard, recalled that at a lunch Mr. Epstein hosted in
Cambridge, Mass., he steered the conversation toward the question of how humans could be improved
genetically. Mr. Dershowitz said he was appalled, given the Nazis' use of eugenics to justify their genocidal
effort to purify the Aryan race.
Yet the lunches persisted.
"Everyone speculated about whether these scientists were more interested in his views or more interested in his
money," said Mr. Dershowitz, who was one of Mr. Epstein's defense lawyers in the 2008 case.
Luminaries at Mr. Epstein's St. Thomas conference in 2006 included Mr. Hawking and the Caltech theoretical
physicist Kip S. Thorne. One participant at that conference, which was ostensibly on the subject of gravity,
recalled that Mr. Epstein wanted to talk about perfecting the human genome. Mr. Epstein said he was fascinated
with how certain traits were passed on, and how that could result in superior humans.
4
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SDNY News Clips, Wednesday, July 31, 2019
Mr. Epstein appears to have gained entree into the scientific community through John Brockman, a literary
agent whose best-selling science writers include Richard Dawkins, Daniel Goleman and Jared Diamond. Mr.
Brockman did not respond to requests for comment.
For two decades, Mr. Brockman presided over a series of salons that matched his scientist-authors with
potential benefactors. (The so-called "billionaires' dinners" apparently became a model for the gatherings at Mr.
Epstein's East 71st Street townhouse, which included some of the same guests.)
In 2004, Mr. Brockman hosted a dinner at the Indian Summer restaurant in Monterey, Calif., where Mr. Epstein
was introduced to scientists, including Seth Lloyd, the M.I.T. physicist. Mr. Lloyd said that he found Mr.
Epstein to be "charming" and to have "interesting ideas," although they "turned out to be quite vague."
Also at the Indian Summer dinner, according to an account on the website of Mr. Brockman's Edge Foundation,
were the Google founders Sergey Brin and Larry Page and Jeff Bezos, who was accompanied by his mother.
"All the good-looking women were sitting with the physicists' table," Daniel Dubno, who was a CBS producer
at the time and attended the dinner, was quoted as saying. Mr. Dubno told The Times that he did not recall the
dinner or having said those words.
Mr. Brockman was Mr. Gell-Mann's agent, and Mr. Gell-Mann, in the acknowledgments section of his 1995
book "The Quark and the Jaguar," thanked Mr. Epstein for his financial support.
However impressive his roster of scientific contacts, Mr. Epstein could not resist embellishing it. He claimed on
one of his websites to have had "the privilege of sponsoring many prominent scientists," including Mr. Pinker,
Mr. Thorne and the M.I.T. mathematician and geneticist Eric S. Lander.
Mr. Pinker said he had never taken any financial or other support from Mr. Epstein. "Needless to say, I find
Epstein's behavior reprehensible," he said.
Mr. Thorne, who recently won a Nobel Prize, said he attended Mr. Epstein's 2006 conference, believing it to be
co-sponsored by a reputable research center. Other than that, "I have had no contact with, relationship with,
affiliation with or funding from Epstein," he said. "I unequivocally condemn his abhorrent actions involving
minors."
Lee McGuire, a spokesman for Mr. Lander, said he has had no relationship with Mr. Epstein. "Mr. Epstein
appears to have made up lots of things," Mr. McGuire said, "and this seems to be among them."
5
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SDNY News Clips, Wednesday, July 31, 2019
Some of Jeffrey Epstein's victims don't want new charges in South Florida
South Florida Sun Sentinel
By Marc Freeman
7/30/19
Financier Jeffrey Epstein has been branded a pervert and an abuser, but not all of his victims want to see him
prosecuted further in South Florida.
Some of the girls Epstein assaulted at his Palm Beach mansion before 2008 have already reached financial
settlements with him and fear they'll lose their anonymity. Federal prosecutors - the ones who approved his
lenient plea deal to begin with - say they fully support that position.
Epstein faces separate federal sex trafficking charges in New York, but the debate about prosecuting him in
South Florida will be resolved soon enough. A federal judge in West Palm Beach is considering whether to
strike down parts of a controversial 2007 deal that gave him and unnamed co-conspirators immunity from
federal charges.
U.S. District Judge Kenneth Marra ruled in February that Epstein's non-prosecution agreement violated the
federal Crime Victims' Rights Act. Dozens of victims were improperly kept in the dark about it until after it had
been finalized.
Marra must decide how to rectify this violation 12 years later, after receiving arguments from lawyers for two
of Epstein's victims, prosecutors and Epstein.
The victims in the case, cited as Jane Does, say the necessary remedy is for Epstein to face what they say are
long overdue charges in Florida.
"To be sure, Jane Doe 1 and 2 very much appreciate the laudable efforts of the diligent prosecutors in New
York," their lawyers wrote. "But those New York charges, important though they are, still leave Epstein's
crimes in Florida uncharged and all of his co-conspirators at large."
Lawyers for the U.S. government disagree.
They concede that prosecutors back then "fell short" of treating victims properly as they reached a settlement
with Epstein. But the attorneys now contend "the past cannot be undone" and the deal must be upheld under the
law.
Among their arguments is that many victims clearly want to let it go, because they are content with financial
settlements they obtained from Epstein, and his 2008 guilty plea to two state prostitution charges. That plea
resulted in 13 months in Palm Beach County Jail and registering as a sex offender.
The prosecutors say they reached this position based on "conversations" with the victims and their lawyers,
without giving a specific number.
Attorney Spencer Kuvin of West Palm Beach said he represents one victim who met with the U.S. Attorney's
Office in April.
6
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SDNY News Clips, Wednesday, July 31, 2019
"She said she'd like to see him prosecuted and put in jail," Kuvin said. "She said, 'I don't know if that's a
realistic possibility, but that's what I want."
He said it's not surprising that other victims are less inclined to participate.
"When you have so many victims, you're going to have just as many different opinions as to how it should be
handled," Kuvin said. "But that shouldn't stop the prosecution of a predator. One victim that wants to come
forward is enough to put him away."
The federal prosecutors explained that while some victims "would like to see Epstein prosecuted for his crimes,
they valued anonymity above all and were not willing to speak with law enforcement or otherwise participate in
any criminal or civil litigation due to the risk that their involvement may become known to family, friends, or
the public."
This is not to say there aren't many victims who are eager to see Epstein face new charges in South Florida,
wrote Byung J. Pak, U.S. Attorney for the Northern District of Georgia, and Jill E. Steinberg and Nathan P.
Kitchens, special attorneys for the Southern District of Florida.
But they conclude that reopening their cases against Epstein in South Florida still "exacerbates the harm to
victims who have attempted to readjust their lives in the interim."
Kuvin said he agrees, "It's a valid concern for some of the victims."
Attorneys for two victims in the pending Crime Victims' Right Act litigation blasted the government's
reasoning to leave Epstein's non-prosecution agreement in place.
Lawyers Bradley Edwards, Paul Cassell and Jack Scarola say any South Florida victims who are not willing to
prosecute Epstein because of privacy concerns can simply decline to do so and remain anonymous.
The lawyers say there's no way that prosecuting Epstein for some victims would harm other victims unless the
prosecutors somehow disclose their identities in the process.
"The Government's argument thus boils down to a stop-us-before-we-do-something-bad claim that deserves no
credence from the Court," wrote Edwards and his co-counsel on behalf of the two women, identified as Jane
Doe 1 and Jane Doe 2.
They also pointed out that the prosecutors weren't asserting the alleged "risk" to some victims outweighs
obtaining justice for their clients.
"But in any event, on closer examination, the Government's argument turns out to be vaporous," they wrote this
month.
Epstein's lawyers told the judge they support the South Florida prosecutors' arguments that the once-secret deal
shouldn't be blown up to allow new charges.
Jeffrey Epstein faces 'a million pages' of evidence: defense lawyer
New York Post
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SDNY News Clips, Wednesday, July 31, 2019
By Andrew Denney and Bruce Golding
7/31/19
Prosecutors have 1 million pages of evidence against Jeffrey Epstein, his lawyer revealed in court Monday -
without shedding any new light on the jailhouse incident that left the convicted pedophile with bruises on his
neck.
No marks were visible on Epstein's neck, and he never appeared to be in pain during the 15-minute hearing in
Manhattan federal court.
The judge overseeing the case tentatively scheduled Epstein's trial for June 2020 after a prosecutor said the
child sex-trafficking charges against him should be resolved as "swiftly as possible."
"We don't think any delay in this is in the public interest," Manhattan Assistant US Attorney
said.
Epstein's trial is expected to last four to six weeks, and the defense will have all the prosecution's evidence
against the multimillionaire financier by Oct. 31, she said.
Defense lawyer Martin Weinberg objected to starting the trial before September 2020, saying, "We need time to
review a million pages of discovery."
But Judge Richard Berman said he was blocking out time in June 2020 on the presumption that the defense
would be ready by then.
Weinberg didn't make any mention of the July 23 incident in which law enforcement sources have said Epstein,
66, was found sprawled on the floor of his cell in the Metropolitan Correctional Center, where he's being held
without bail.
Weinberg declined to answer questions about the incident outside court.
Epstein, who wore dark blue jail scrubs over a brown T-shirt, didn't speak during the hearing.
He's pleaded not guilty to accusations he sexually abused dozens of underage girls - some as young as 14 -
in his Upper East Side townhouse and his waterfront mansion in Palm Beach, Florida, between 2002 and 2005.
Berman set a Sept. 13 deadline for defense motions in the case, and Weinberg said he planned to seek dismissal
of a conspiracy charge on grounds of double jeopardy tied to allegations that underpinned a non-prosecution
agreement that Epstein struck in 2008 with then-Miami US Attorney Alex Acosta.
That deal was exposed last year in an award-winning series of stories by the Miami Herald, and controversy that
erupted following Epstein's July 6 arrest forced Acosta to resign as President Trump's labor secretary.
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SDNY News Clips, Wednesday, July 31, 2019
Jeffrey Epstein appears in court for first time since reported jail injuries
The Guardian
By Victoria Bekiempis
7/31/19
Financier Jeffrey Epstein looked physically healthy when he appeared in court in New York on Wednesday in
his sex trafficking case, about a week after reportedly being found unconscious in his jail cell with neck injuries.
He wore dark blue jail scrubs during his brief appearance in Manhattan federal criminal court on Wednesday
morning, in a proceeding scheduled before the apparent incident behind bars last week.
There were no signs of injuries that had been reported at the time and he appeared well and more neatly
presented than at some previous hearings.
The Jeffrey Epstein scandal
His lawyers did not bring up the incident in court and refused to comment on the topic following the hearing,
which focused on scheduling issues.
Prosecutor
asked for a June 2020 trial date to be set, telling the judge: "We don't think that any
delay in this case is in the public interest."
The Manhattan US attorney's office alleged earlier in July that Epstein "sexually exploited and abused dozens
of minor girls" from 2002 to 2005. Some of his victims were just 14 years old, prosecutors alleged.
The disgraced financier, who was arrested on 6 July, pleaded not guilty several weeks ago.
Epstein has long been accused of sexually abusing underage girls. He also has purported connections to Donald
Trump, Bill Clinton and Prince Andrew, and moved in elite circles, including for several years in a relationship
with Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell.
Epstein and the Miami US attorney's office, headed at the time by Alexander Acosta, brokered a plea deal in
2008 that closed a federal inquiry involving at least 40 teenage girls.
Under this arrangement, Epstein pleaded guilty to state charges, which presented far less potential jail time than
if he had faced federal charges. The Miami Herald reporter Julie K Brown exposed the secretive nature of this
agreement. Acosta resigned from his post as Trump's labor secretary following extensive criticism of the deal.
Epstein has unsuccessfully requested bail while awaiting trial. The 66-year-old, who registered as a sex offender
following the Florida case, had maintained through lawyers that he neither posed a danger nor risk of flight.
In rejecting Epstein's request, Judge Richard Berman said, "the government has established danger to others
and to the community by clear and convincing evidence", adding: "I doubt that any bail package can overcome
a danger to the community."
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SDNY News Clips, Wednesday, July 31, 2019
Epstein's lawyers are appealing against the decision, according to court filings.
Late last week, Judge Berman also ruled in favor of prosecutors' proposed protective order, which will keep
case materials relating to "the government's ongoing investigation of uncharged individuals" under wraps.
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SDNY News Clips, Wednesday, July 31, 2019
Judge sets tentative date for Jeffrey Epstein's trial
Associated Press
By Larry Neumeister and Jim Mustian
7/31/19
A subdued Jeffrey Epstein listened passively in court Wednesday as a judge said he won't face trial on sex
trafficking charges before June 2020, and more likely a few months afterward.
There was no mention at the Manhattan federal court appearance or any visible sign of injuries after the 66-
year-old financier was found on the floor of his cell last week with neck bruises.
Epstein's lawyer, Martin Weinberg, refused to say what might have left his client with neck bruises after the
court hearing.
Assistant U.S. Attorney
urged a June trial date for the man accused of arranging to have sex with
girls as young as age 14, saying there is "a public interest in bringing this case to trial as swiftly as possible."
But Weinberg said the case is far from "ordinary," adding the defense team won't be ready before Labor Day
2020. He said prosecutors delayed bringing charges that relate to alleged crimes that occurred in the early 2000s
at Epstein's residences in Manhattan and Florida.
U.S. District Judge Richard M. Berman said a trial projected to last four to six weeks could tentatively begin
June 8, but he'll likely defer to defense lawyers' needs if they are not ready.
Epstein's demeanor in court was noticeably different from previous appearances, when he was actively engaged
with his lawyers and looking through papers.
On Wednesday, he sat quietly, his hands folded in front of his face through much of the 20-minute proceeding.
Occasionally, he looked toward courtroom artists and reporters seated in a jury box.
Epstein has remained at the Metropolitan Correction Center, which is adjacent to the downtown Manhattan
courthouse.
He has pleaded not guilty to sex trafficking charges that carry the potential for up to 45 years in prison.
Berman refused bail after concluding he is a danger to the community and a flight risk. Prosecutors have said
they fear he might try to influence a growing number of witnesses who support charges that he recruited and
abused dozens of girls in New York and Florida in the early 2000s. His lawyers had argued he should be
allowed to stay under house arrest in his Manhattan mansion.
His lawyers say an agreement reached with federal prosecutors a dozen years ago disallows the charges and
they say he has committed no new crimes.
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SDNY News Clips, Wednesday, July 31, 2019
The lawyers agreed to file written arguments about the agreement and double jeopardy claims by Sept. 13. Oral
arguments will occur in October.
The non-prosecution deal was reached before he pleaded guilty in state court in Florida to prostitution-related
charges involving underage girls. Afterward, he was required to register as a sex offender and pay restitution to
many victims. While he served a 13-month jail term, he was permitted to leave jail to work for 12 hours a day,
six days a week.
Epstein was arrested July 6 when he arrived at a New Jersey airport on a private jet from Paris, where he has a
home.
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SDNY News Clips, Wednesday, July 31, 2019
Did Jeffrey Epstein try to kill himself? He and his lawyer, back in court, aren't saying
Miami Herald
By Miami Herald Staff
7/31/19
Victims of Jeffrey Epstein share the emotional toll that sexual abuse has taken on them - even years after the
abuse occurred. Miami Herald reporter Julie K. Brown interviewed the young women, most speaking for the
first time about Epstein. BY EMILY MICHOT I JULIE K. BROWN
For the first time since he was found semi-conscious in his jail cell with telltale bruise marks on his neck,
accused sex trafficker Jeffrey Epstein appeared in a Manhattan court room.
Epstein - onetime friend of the rich and powerful, including current President Donald Trump and past
President Bill Clinton - learned Wednesday that he will not face trial until at least next June.
The multimillionaire part-time resident of Palm Beach sat subdued in front of U.S. District Court Judge Richard
M. Berman. The 66-year-old defendant wore dark blue jail scrubs and glasses.
His lawyer, Martin Weinberg, declined to reveal any details about the incident at the Metropolitan Correctional
Center, which occurred July 23, including whether it was a suicide attempt, an attack by a fellow detainee or
something else. His client is being held without bond.
Wednesday's hearing in New York City lasted just 15 minutes.
Epstein, a financier who owns homes around the world, including a waterfront estate in Palm Beach, was
arrested July 6, nearly eight months after the Miami Herald published Perversion of Justice, a two-year
investigation of a much-reviled secret plea deal in 2007-2008 that spared Epstein a sweeping federal indictment
despite allegations of sexual abuse by nearly three dozen underage girls.
He had just arrived from France at New Jersey's Teterboro airport on his private jet when authorities met him
and took him into custody.
During the early- and mid-2000s, Epstein allegedly ran what amounted to a sexual pyramid scheme, using
recruiters to lure girls as young as 14 to his lavish Palm Beach and Manhattan mansions with the promise that
they would receive $200 to give a man a massage. The girls have alleged that they were coerced into sex.
The girls were paid additional money if they would recruit others girls, police and court records allege. Epstein
had assistants schedule as many as three visits a day.
Rather than face federal charges that could have put him away for life, Epstein pleaded guilty in state court to
minor prostitution charges and served just a year in the county stockade - which permitted him to leave the
lockup for his luxurious downtown West Palm Beach office for 12 hours a day, six days a week. This "work
release" arrangement, highly unusual for a sex offender, is now under criminal investigation by order of the
Palm Beach sheriff, Ric Bradshaw, who oversees the stockade and approved the work release.
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SDNY News Clips, Wednesday, July 31, 2019
Although Assistant U.S. Attorney
said it is important to move swiftly ahead with Epstein's court
case, his defense attorney said he needs time in light of the approximately one million pages of documents that
that comprise the evidence collected against his client.
Labor Secretary Alex Acosta held a press conference to defend his role in handling the Jeffrey Epstein sexual
abuse case. Acosta was a U.S. Attorney who approved the Epstein plea deal in 2008. By CSPAN
In the meantime, Epstein will be given a chance to argue that the non-prosecution agreement, executed in 2008,
gave him, his schedulers, his alleged madam and others immunity from federal charges and that the new
charges constitute impermissible double jeopardy.
In its series of articles, the Herald highlighted the role of Alexander Acosta, then-U.S. attorney for the Southern
District of Florida, in approving the immunity agreement, including a controversial stipulation that Epstein's
accusers not be told of the arrangement. Facing searing criticism after Epstein's arrest, Acosta resigned his post
as President Trump's labor secretary.
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SDNY News Clips, Wednesday, July 31, 2019
Jeffrey Epstein could face sex trafficking trial next June
Reuters
7/31/19
Financier Jeffrey Epstein could go to trial on charges of sex trafficking involving dozens of underage girls as
early as next June, though his lawyers told a court on Wednesday they may need more time.
At a hearing in Manhattan federal court, prosecutors sought a June 2020 trial date, while a lawyer for Epstein
asked that it wait another three months.
The lawyer, Martin Weinberg, said Epstein and his legal team needed more time to review evidence, expected
to total more than 1 million pages.
U.S. District Judge Richard Berman said he would tentatively set aside time for a trial beginning June 8, but
revisit the issue later. He said he normally allowed defendants more time to prepare if they wished.
Assistant U.S. Attorney
said a trial is expected to last four to six weeks.
Prosecutors have accused Epstein of arranging for girls under the age of 18 to perform nude "massages" and
other sex acts, and of paying some girls to recruit others. Epstein has pleaded not guilty.
Wednesday's hearing occurred one week after Epstein was reportedly found unconscious and with neck injuries
in his jail cell at the Metropolitan Correctional Center in downtown Manhattan.
Epstein, dressed in blue jail scrubs, had no visible injuries on Wednesday. His lawyers declined to comment on
the reports after the hearing.
Epstein is appealing Berman's July 18 denial of his request to remain under house arrest in his $77 million
mansion on Manhattan's Upper East Side while awaiting trial.
The charges against Epstein focus on alleged misconduct from at least 2002 to 2005.
They followed Epstein's 2008 guilty plea to state prostitution charges in Florida, in exchange for the Justice
Department's agreement not to prosecute him on similar charges.
Epstein served 13 months in jail and agreed to register as a sex offender under the 2008 agreement, which is
now widely considered too lenient.
His lawyers have argued this month that the agreement barred federal prosecutors in Manhattan from pursuing
the current case over the same conduct. Weinberg said at Wednesday's hearing that they intended to file
motions on the issue.
U.S. Attorney Geoffrey Berman, whose office is overseeing the current case, has said there is no such bar.
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SDNY News Clips, Wednesday, July 31, 2019
Epstein Lawyers Ask for a Year to Review a Million Pages
Bloomberg
By Chris Dolmetsch, Bob Van Voris, and Patricia Hurtado
7/31/19
Jeffrey Epstein's lawyers say they need at least a year to review a blizzard of documents prosecutors have
gathered against the fund manager as they prepare to defend him against charges of sex trafficking in minors
and conspiracy.
Prosecutors asked a judge to schedule Epstein's trial for next June, but defense attorney Martin Weinberg said
his team wanted to wait until September 2020, because they haven't yet begun to receive documents from the
government.
"We need time to receive a million pages of discovery and prepare to defend a four- to six-week trial,"
Weinberg said during a brief hearing in Manhattan on Wednesday. "We need time to assess events that occurred
14 to 17 years ago."
The judge set a tentative trial date of June 8 and asked the parties to keep him updated on their progress.
Epstein, who didn't speak in court, was arrested on July 6 after stepping off his private plane in New Jersey
from a trip to Paris. He has pleaded not guilty and said he has fully complied with the law for more than 14
years.
Marks on Neck
Epstein is accused of molesting teenage girls from 2002 to 2005. He pleaded guilty in 2008 to Florida state
charges of soliciting prostitution, after striking a non-prosecution agreement with the U.S. Federal prosecutors
in New York say they are not bound by the deal as they now pursue their own charges.
In court Wednesday, there was no discussion of what happened to the 66-year-old Epstein last week at New
York's Metropolitan Correctional Center, where he has been held since his arrest. People familiar with the
matter said he was found injured and unresponsive in his cell, with marks on his neck. Authorities are
investigating whether he was assaulted, possibly by another inmate, or whether the injuries were self-inflicted.
Weinberg declined to respond to questions about the incident outside court.
Also in court was Gloria Allred, the activist lawyer who has represented women accusing Roy Moore, Bill
Cosby and President Donald Trump of sexual assault. After the hearing, she said she was representing other
Epstein accusers who "were not in the Florida case." She said other women have approached her about their
experiences with Epstein but were reluctant to discuss them for fear of retaliation.
The U.S. attorney in Manhattan, Geoffrey Berman, has urged others who may be victims to come forward and
cooperate with the government. Allred declined to say whether her clients have spoken to prosecutors.
The case is U.S. V. Epstein, 19-cr-490, U.S. District Court, Southern District of New York (Manhattan).
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SDNY News Clips, Wednesday, July 31, 2019
Collins
Editorial: Failures of ethics
Buffalo News
By News Editorial Board
7/29/19
The ethics specialists are right and so are the members of a special ethics panel, including both Democrats and
Republicans, who are paying attention. Good for them. The conduct of Rep. Chris Collins, R-Clarence, exposed
a range of issues Congress needs to treat as tumors, and cut them out.
Collins was indicted last year on allegations of insider trading. But he was routinely smashing ethical standards
- of both formal and common sense varieties - before he was ever charged with a crime.
A year before Collins was indicted, the Office of Congressional Ethics reported that it found "a substantial
reason to believe" that Collins violated federal law by touting the stock of Innate Immunotherapeutics, an
Australian biotech firm, based on inside information.
The office also said Collins may have broken House ethics rules by persuading National Institutes of Health
officials to meet with a staffer from that company.
At least as troubling are the actions Collins took that were not deemed to be ethical violations. Speaking to a
bipartisan House task force charged with drawing up new ethics rules based on Collins' arrest, ethics experts
worried about lawmakers who sit on the boards of privately owned companies, or who serve as partners in other
businesses or who are directors of nonprofit organizations. Collins still does all three.
Earlier this year, in response to Collins' arrest, the House barred lawmakers from serving on the boards of
publicly traded companies. Collins did that, too, as a board member - and leading stockholder - of Innate
Immunotherapeutics. It's how prosecutors say he obtained the insider information that led to his arrest.
There was more. Collins authored a provision of the 2016 "21s Century Cures Act" that sped drug approval for
companies like Innate. Collins, with a straight face, claimed there was no conflict because Innate had no
business before U.S. regulators. But in 2017, the company practically beamed that it had "received clearance
from the U.S. Food and Drug Administration for the Company's Investigational New Drug (IND) application
lodged last month."
The fact that Collins' role in the legislation could also have benefited other companies - and may even have
been worthy of passage - does nothing to change the associated fact that he was pushing for legislation whose
adoption could have lined his pockets. It was classic self-dealing.
The drug in question was meant to treat multiple sclerosis. It failed in clinical trials in 2017 and prosecutors say
Collins illegally spread the word to family and others who were able to sell their stock before its price collapsed
on the bad news.
Collins has pleaded not guilty to the charges. His trial is scheduled for February. But regardless of what a judge
or jury ultimately decides about Collins, he has shown himself to be indifferent to the need for a member of
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SDNY News Clips, Wednesday, July 31, 2019
Congress to conduct himself in a way that reflects well on the institution and on the voters who entrust him with
public office.
In that, he has shown Congress that it needs to act. It can't count on its members using good judgment,
especially when millions of dollars are at stake.
The good news is that it seems ready to meet that public obligation. It is considering measures that would
prohibit lawmakers from serving as partners in limited liability corporations, joining committees that oversee
their business interests and serving on the boards of nonprofit organizations. Staff members would also be
barred.
Sadly, some Republican members have defended Collins, despite the clear conflicts of interest. But the
Republican on the ethics task force, Rep. Van Taylor of Texas, expressed no disagreement with the panel's
Democrat, Pennsylvania Rep. Susan Wild, who said she expected to move "rather quickly" on writing new
rules.
Taylor sees the tasks as "very narrow," focused on preventing lawmakers from serving in outside positions that
could pose conflicts. The remarkable thing is that those restrictions need to be put in writing. Thank Collins for
that.
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SDNY News Clips, Wednesday, July 31, 2019
Securities and Commodities Fraud
Stewart
Southern District Will Pursue A Retrial Of "Silver Platter" Case
Forbes
By Walter Pavlo
7/30/19
Sean Stewart was indicted on insider trading charges back in May 2015 during U.S. Attorney Preet Bharara's
reign over the Southern District of New York. Now, over four years since his indictment, Sean can reflect back
on a wild journey of being convicted, sentenced to 3 years prison, having that conviction overturned, being
released from prison halfway through his term and, now, having a new date to go back to trial to face the
charges again.
Sean Stewart was indicted on insider trading for passing material non-public information on potential deals to
his father, Robert, who then passed it on to his former friend and trader, Richard Cunniffe. Sean, a Yale
graduate who had worked in investment banking at JPMorgan Chase and Perella Weinberg, mentioned some
details about his work while talking to Robert. Sean's information made it to Cunniffe who made over a million
dollars on the trades, sharing a small amount (less $100,000) with Robert. How much did Sean make on the
trades? ZERO dollars. He had no idea that Cunniffe traded because he did not even know who Cunniffe was.
It was a clear case of misappropriation where information was used without Sean's knowledge, so it was not a
"classical" insider trading case. However, Bharara's team of U.S. attorneys was looking for cases that targeted
wealthy Wall Street traders who seemed to have an advantage over the average trader. Sean's case was a good
fit.
Cunniffe was busted by the FBI and soon became a government informant, taping calls and other meetings with
Robert. In one of those calls, Robert stated that Sean said of the information he had passed on to Cunniffe, "I
can't believe it. I handed you this on a silver platter and you didn't invest." So the primary evidence in the case,
the case that came to be known as the "silver platter" case, was based on a statement that was attributed to Sean.
It's a phrase that Sean's new defense team wants to be excluded from the proceedings.
When Robert was arrested, under duress of FBI questioning, he said nine (9) times that Sean was not in on his
scheme with Cunniffe (here is entire tape transcript here). Robert also admitted his own role and that of
Cunniffe's during the interrogation. When it came to trial, neither that tape nor Robert's testimony was allowed
because of legal maneuvering by prosecutors. The video tape was suppressed and Robert did not testify due to
threats from prosecutors that he would be charged for perjury due to his conflicting accounts. Here is what the
jury missed from that tape:
FBI AGENT: Tell me about the first time that Sean gave you information on a deal.
ROBERT STEWART: Well, uh, I wouldn't characterize any of these as
I mean Sean would mention stuff.
I don't think he had any idea that I would trade on any of this stuff. Uh, I've never mentioned that I did, to him.
Ummm
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SDNY News Clips, Wednesday, July 31, 2019
AGENT: If that's true, how do you explain the comment you made to Rick [Cunniffe] that Sean got angry with
you when he gave you this information on a silver platter and you didn't invest.
ROBERT: Uhh, I think I was just saying that to Rick because Sean said, oh, you know, ahh, all these deals, you
know, you
if you were trading you could make like millions of dollars. And I said, you know, Sean, no
one's going to trade and make millions of dollars on this stuff. That wasn't his intention.
Robert took the 5th but did submit an affidavit that if he were to testify he would have said Sean did not know
about the trades by Cunniffe.
Looking back at the trial, there was not a single email, document, or text message that suggested that Sean was
a knowingly participated in the trading scheme. This is interesting since there were so many incriminating
documents between Cunniffe and Robert. There were no witnesses who gave testimony on Sean's knowledge
and intent, including Cunniffe, the cooperator, who on the stand acknowledged that he never knew Sean.
Furtnermore, trading records and actions undertaken by Sean suggest he did not know trading had taken place.
Last fall, the 2nd Circuit overturned Sean's conviction, something rare in most cases, especially a reversal on an
evidentiary ruling, which suggests the 2nd Circuit felt that Sean may be innocent and the judge's mistakes
resulted in an unfair trial. The appellate court ruled that Robert's post-arrest video interrogation should have
been allowed. Sean was released from prison and has been in legal limbo until the SDNY decided that they
would move to move forward with another trial on the same charges.
Stewart will have a new judge this time around. U.S. District Judge Laura Taylor Swain was replaced by Judge
Rakoff, a man who seems to be on a mission to define insider trading laws himself. He also has new attorneys
Steven M. Witzel, Lawrence Gerschwer, R. David Gallo and Leigh G. Rome of Fried Frank Harris Shriver &
Jacobson LLP.
If Sean is found guilty, he would face the prospect of being sentenced to prison and returning to prison to
complete a term. On the other hand, it would not be out of the question for Judge Rakoff to give him "time
served" in prison even if Sean is found guilty. Rakoff, not a fan of the Federal Sentencing Guidelines, seems to
be one of those judges that uses common sense in his approach to sentencing. Earlier this week, Rakoff
sentenced a man to 14 months in prison for knowingly leaking insider information on Sherwin Williams'
acquisition of Valspar.
While Sean may have made some mistakes, these could have been handled by the companies he worked for
and, at the most severe, an enforcement action by the Securities and Exchange Commission. The SDNY seems
intent on trying to interpret insider trading laws by putting on elaborate trials with the threat of putting people in
prison for years. It is a waste of resources.
It looks like the ghost of Bharara still haunts the SDNY.
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SDNY News Clips, Wednesday, July 31, 2019
Thompson
Easton man accused of stealing $7M via fake Bitcoin transactions
Lehigh Valley Live
By Sarah Cassi
7/30/19
An Easton man who headed a cryptocurrency escrow company was arrested last week on federal charges he
allegedly stole $7 million from two companies by lying about Bitcoin transactions.
Jon Barry Thompson, also known as J. Barry Thompson, was the principal of Volantis, which included a
cryptocurrency escrow company called Volantis Escrow Platform LLC and a related company, Volantis Market
Making LCC.
The 48-year-old Thompson was arrested in Easton, and was charged with two counts each of commodities fraud
and wire fraud. Easton police assisted in serving the arrest warrant at 6:15 a.m. Thursday at Thompson's West
Burke Street home on College Hill.
What happens to the money when a criminal's stash is in bitcoin?
When a criminal's stash is in bitcoin, the stakes are now much higher in forfeiture cases with the soaring value
of the virtual currency.
Thompson was released after posting $500,000 bond. Messages left for comment at a phone number listed for
Thompson and for his defense attorney, Matthew Siembieda, were not immediately returned.
Prosecutors said Thompson stole $7 million from two companies after lying about transactions of the peer-to-
peer digital currency Bitcoin -- $3 million from one company and $4 million from a second.
Thompson offered minimized settlement default risk in cryptocurrency transactions, and claimed there was no
risk of default, prosecutors allege.
In June and July 2018, Thompson convinced the first company to send Volantis more than $3 million for a
Bitcoin purchase, prosecutors allege. Thompson allegedly assured the company he had the Bitcoin in hand and
that money could not be lost.
Thompson took the money, but never provided the company the promised Bitcoin or returned its money,
prosecutors said.
Thompson allegedly gave the company a fake account statement showing he had the company's money but in
reality sent the more than $3 million to a third-party entity purportedly in exchange for Bitcoin without first
receiving any of the Bitcoin in hand.
In July 2018, Thompson allegedly convinced a second company to send Volantis more than $4 million for
Bitcoin purchases. Again, Thompson is accused of sending a substantial portion of the money to a third party
without first receiving any Bitcoin in return, prosecutors allege.
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SDNY News Clips, Wednesday, July 31, 2019
Thompson never gave the second company any Bitcoin and did not return its money, prosecutors said.
"Jon Thompson induced investors to engage in cryptocurrency transactions through his company, Volantis
Market Making, by touting a transaction structure that would eliminate any risk of loss during the purchase,"
Manhattan U.S. Attorney Geoffrey S. Berman said in a news release. "As his clients soon realized, however,
Thompson's representations were false, and these cryptocurrency investors ultimately lost all of the money they
had entrusted with him because of his lies."
FBI Assistant Director-in-Charge Sweeney said Thompson used phrases and terminology that the victimized
companies didn't understand, and he "allegedly preyed on their ignorance of the emerging cryptocurrency."
"Thompson allegedly thought no one would ask where their actual money went when they trusted him to invest
in Bitcoin," Sweeney said.
The complaint doesn't identify the companies allegedly victimized by Thompson.
Forbes previously reported Symphony, an Irish investment company that specializes in trading
cryptocurrencies, gave Thompson 3.6 million Euros to purchase Bitcoin on its behalf.
Symphony never received any Bitcoin and its money was never returned.
In that case, the plaintiff withdrew the complaint it had brought in federal court in Pennsylvania and, instead,
reached a private settlement with Thompson. Thompson then breached the agreement by failing to make the
first settlement payment, Forbes reported.
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SDNY News Clips, Wednesday, July 31, 2019
Pinto-Thomaz
Popular Paint Brand Insider Trading Results In Prison Term: Feds
Patch
By Chris Dehnel
7/30/19
A former analyst for a major financial ratings agency is to spend more than a year in prison for an insider
trading scheme involving his hairdresser, a jeweler and two major paint brands sold prominently in Connecticut.
Geoffrey S. Berman, the United States Attorney for the southern district of New York, announced that
Sebastian Pinto-Thomaz, 34, a former credit ratings analyst at Standard & Poor's, was sentenced in Manhattan
federal court to 14 months in prison for participating in two schemes to trade on material, nonpublic information
in advance of the Sherwin-Williams Company's acquisition of the Valspar Corporation.
Valspar is the brand sold by Lowe's.
Pinto-Thomaz was convicted on April 26, following a jury trial before U.S. District Judge Jed S. Rakoff, who
also imposed Monday's sentence.
In summarizing the case, Berman said, "As an employee of Standard & Poor's, Sebastian Pinto-Thomaz was
privy to potentially lucrative information about business acquisition plans. Instead of protecting that
information, as he had sworn to do, he shared it with a friend and with his hairdresser. In turn, they bet on a
stock that they knew to be a sure thing, and raked in nearly $300,000 in profits. Pinto-Thomaz painted himself
into a corner when he and his co-defendants exploited insider information to reap illegal profits. Now they all
face time in prison for their misdeeds."
When a company announces an acquisition, the acquiring company often seeks the opinion of a credit rating
agency regarding the potential impact that the acquisition could have on the acquiring company's
creditworthiness, Berman said. Therefore, companies often contact rating agencies before an acquisition is
publicly announced in order to secure the rating agency's views on how a possible acquisition could impact a
company's credit rating, he said.
All major rating agencies offer a service - sometimes known as a Rating Evaluation Service, or RES - that
provides the company with a rating committee decision with respect to a proposed acquisition.
In March 2016, Standard and Poor's, a credit rating agency in New York, assigned Pinto-Thomazto work on a
RES for the Sherwin-Williams Company in advance of its contemplated but unannounced acquisition of the
Valspar Corporation, according to casae records.
In connection with the assignment, Pinto-Thomaz received material, nonpublic or "inside" information the deal
about Sherwin-Williams's planned acquisition of Valspar prior to the public announcement of the acquisition.
S&P's written policies prohibited the unauthorized disclosure of confidential information, which included the
inside information, Berman said.
During his tenure at S&P, Pinto-Thomaz reviewed and certified his duties of loyalty and confidentiality to S&P
and its clients, according to case records.
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SDNY News Clips, Wednesday, July 31, 2019
In March 2016, Pinto-Thomaz passed the inside information about the paint merger to Jeremy Millul, a friend,
and to Abell Oujaddou, his hairdresser, so that they could "use it to make profitable trades in Valspar stock and
options.," Berman said.
On March 21, 2016, the first trading day after the public announcement of the acquisition, the price of Valspar
stock increased approximately 23 percent over the prior day's close.
Millul, a Manhattan jeweler opened a brokerage account on March 13, 2016, and shortly thereafter purchased
480 shares of Valspar common stock, case records show. On March 18, 2016, the last trading day before the
acquisition was publicly announced, Millul also purchased 75 out-of-the-money Valspar call options, according
to case records.
After the acquisition was publicly announced, Millul sold his Valspar stock and options for approximately
$106,806 in profits, Berman said.
Oujaddou, a Manhattan hairstylist and salon owner who has known Pinto-Thomaz for years and is a close friend
with his mother, was given inside information during a haircut on March 8 or 9, 2016, according to case
records. On March 10 through March 18, 2016, Oujaddou, who had never previously purchased Valspar or
Sherwin-Williams purchased 8,630 shares of Valspar stock, case records show.
After the acquisition was publicly announced, Oujaddou sold his Valspar shares for approximately $192,080 in
profits, according to case records.
Following the trading, Oujaddou met Pinto-Thomaz in the paint aisle of a hardware store and paid him a
kickback, Berman said.
Pinto-Thomaz denied having a relationship with anyone on the list of pre-merger trading.
In addition to his prison term, Pinto-Thomaz was sentenced to three years of supervised release and ordered to
pay a fine of $15,000 and a forfeiture money judgment in the amount of $7,500.
Millul and Oujaddou each previously pled guilty and were to be sentenced on July 30.
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SDNY News Clips, Wednesday, July 31, 2019
Narcotics
Castro
Drug Dealer Forfeits Over $4M in Bitcoin as Part of a Guilty Plea
All Stocks
By Ravi Rd
7/31/19
According to a July 25 press release from the United States Attorney's Office of the Southern District of New
York, the very active Bitcoin drug dealer Richard Castro has pleaded guilty of committing illicit activities such
as money laundering and distributing three controlled substances through the dark web and encrypted emails.
Castro was charged by the US Department of Justice (DoJ) and agreed to forfeit more than $4 million including
cryptocurrency funds available in his seven different Bitcoin wallets.
Castro, 36-year-old based in Windermere, Florida, operated under multiple badges, such as "Chems_usa,"
"Chemical_usa" and "Jagger109" to distribute three controlled opioid substances namely carfentanil, fentanyl,
and phenyl fentanyl. Dream Market and AlphaBay were two of his primary market places on the dark web,
where he sold drugs in exchange for cryptocurrency.
The three controlled opioid substances were sold from November 2015 to 2019 by Castro and another co-
conspirator, Luis Fernandez. Fentanyl, the first of these three is considered to be significantly stronger than
heroin while Carfentanil is believed to be 100 times stronger than fentanyl. Castro sold these substances under
the three aforementioned monikers which ultimately used to prove that he is indeed the leader of this
conspiracy.
On Dream Market, Castro once boasted about 3,200 transactions that he had completed on various dark web
marketplaces. Out of these 3,200 transactions, 1,800 transactions were successfully completed on AlphaBay
alone. The conspirators apparently also received many positive reviews for the quality of synthetic opioid
substance they were selling.
In June 218, Castro informed his clients that he would only accept orders received by encrypted emails and
declared the organization is getting the business off from the dark web. Customers who wanted to buy narcotics
had to acquire the address of the encrypted email from "Chems_usa" by paying certain fees. Unfortunately for
Castro, an undercover law enforcement officer also obtained the encrypted email and placed an order, which
ultimately led to his arrest.
Castro was accepting the payments in Bitcoin which were later distributed in seven different BTC wallets.
Manhattan U.S. Attorney Geoffrey S. Berman said:
"As he admitted today, for years, Richard Castro used the dark web to distribute prolific quantities of powerful
opioids, including fentanyl and carfentanil. Castro thought he could hide behind the anonymity of the internet,
and use online pseudonyms to deal drugs like "Chems_usa" and 'Chemical_usa.' Thanks to our law
enforcement partners, 'Chems_usa' is now in U.S. prison."
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SDNY News Clips, Wednesday, July 31, 2019
Castro has agreed to forfeit $4,156,198.18 including the funds on those seven Bitcoin wallets.
26
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SDNY News Clips, Wednesday, July 31, 2019
Rochester Drug Company
Distributor Has Been Shipping Excess Opioids to Small Towns
Legal Reader
By Sara E. Teller
7/31/19
Miami-Luken Inc., an Ohio drug wholesale distributor, and four people including two former executives have
been charged with selling millions of pills amid the opioid epidemic despite knowing the dangers. The
indictment charged the Springboro, Ohio-based company; Anthony Rattini, the company's former president;
James Barlay, former compliance officer, and two pharmacists with "conspiring to distribute controlled
substances." Prosecutors have alleged "Miami-Luken ignored obvious signs that drugs were being diverted to
illegal users and dealers between 2011 and 2015." The company was shipping 4.9 million pills to Miller-
West's drugstore in Oceana, W.Va., where the population is just under 1,400.
"Miami-Luken and the executives failed to guard against the dangerous drugs it was shipping to pharmacies in
five states from being diverted for illegal uses or to report suspicious orders to the U.S. Drug Enforcement
Administration," they added.
The distributor shipped millions of pills to desolate and rural areas of Appalachia which was hit especially hard
by the epidemic. "Records show Miami-Luken also distributed 3.7 million hydrocodone pills from 2008 to
2011 to a pharmacy in Kermit, West Virginia, a town of just 400 people," prosecutors said. The pharmacists
charged were Devonna Miller-West, the owner of Oceana, West Virginia's Westside Pharmacy, and Samuel
Ballengee, owner of Williamson, West Virginia's Tug Valley Pharmacy.
The company was also shipping some to other "unnamed pharmacists and physicians," the indictment alleged.
"There's a need, in my opinion, to devote sufficient charges right here and now to stop the dying," United States
Attorney Benjamin C. Glassman said, adding investigators found "many overdose deaths that could arguably be
linked to the conduct of people accused in the conspiracy."
In April of this year, criminal charges were brought against Rochester Drug Co-operative. Geoffrey S. Berman,
the United States Attorney for the Southern District of New York, and Ray Donovan, the Special Agent in
Charge of the New York Division of the U.S. Drug Enforcement Administration (DEA), announced the
charges. Rochester Drug Co-Operative is one of the 10 largest pharmaceutical distributors in the United States.
Charges were also filed against Laurence F. Doud III, the company's former chief executive officer; and
William Pietruszewski, the company's former chief compliance officer. The indictment was specifically for
"unlawfully distributing oxycodone and fentanyl, and conspiring to defraud the DEA," according to court
documents.
Berman said at the time, "This prosecution is the first of its kind: executives of a pharmaceutical distributor and
the distributor itself have been charged with drug trafficking, trafficking the same drugs that are fueling the
opioid epidemic that is ravaging this country. Our Office will do everything in its power to combat this
epidemic, from street-level dealers to the executives who illegally distribute drugs from their boardrooms." The
company paid $20 million to resolve the charges.
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SDNY News Clips, Wednesday, July 31, 2019
DEA Special Agent in Charge Ray Donovan said, "Today's charges should send shock waves throughout the
pharmaceutical industry reminding them of their role as gatekeepers of prescription medication. The
distribution of life-saving medication is paramount to public health; similarly, so is identifying rogue members
of the pharmaceutical and medical fields whose diversion contributes to the record-breaking drug overdoses in
America. DEA investigates DEA Registrants who divert controlled pharmaceutical medication into the wrong
hands for the wrong reason. This historic investigation unveiled a criminal element of denial in RDC's
compliance practices and holds them accountable for their egregious non-compliance according to the law."
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SDNY News Clips, Wednesday, July 31, 2019
Civil
Life Spine
Lawsuit against Huntley-based medical device company alleges kickback scheme
Northwest Herald
By Drew Zimmerman
7/30/19
Life Spine, a medical technology manufacturer in Huntley, is the defendant in a federal lawsuit alleging
violations of the False Claims Act by offering lucrative incentives to surgeons in exchange for their use of Life
Spine products.
The suit, which was filed last week by the U.S. Attorney's Office in the Southern District of New York, alleges
that the company entered into agreements with dozens of surgeons as a means to pay more than $7 million in
illegal kickbacks - including consulting fees, royalties and intellectual acquisition payments - for the surgeon's
use of Life Spine's equipment.
The suit also alleges that these agreements, spanning an estimated seven-year period, were done with the
knowledge, involvement and participation of Life Spine President and CEO Michael Butler and Vice President
of Business Development Richard Greiber, who also are being charged.
"Defendants are liable for damages based on the payment of claims submitted to Medicare and Medicaid for
medical services and procedures involving Life Spine Products that were tainted by illegal kickbacks," the suit
reads.
About half of Life Spine's total domestic sales of spinal products between January 2012 and at least December
2018, were attributable to surgeries performed by these paid surgeons, according to the suit.
In addition to the consulting fees and royalties being paid, surgeons also were treated to dinners at high-end
restaurants, Chicago Cubs games and other perks.
"As alleged, Life Spine and its senior management flagrantly ignored the law by paying surgeons millions of
dollars in fees and royalties to get them to use Life Spine products during spinal surgeries," Manhattan U.S.
Attorney Geoffrey S. Berman said in a release. "Kickbacks to doctors can alter or compromise their judgment
about the medical care and services to provide to patients, and can increase healthcare costs."
For the first two counts of violating the False Claims Act - which are against Life Spine, Butler and Greiber -
the plaintiff is seeking treble damages and civil penalties to the maximum amount allowed by state law.
For the third count of unjust enrichment - which is only against Life Spine - the plaintiff is seeking damages to
the extent allowed by law.
The plaintiff also is seeking pre- and post-judgment interest, costs and any other relief the court deems
appropriate.
29
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SDNY News Clips, Wednesday, July 31, 2019
A statement from Life Spine said that both parties are engaged in discussions and look forward to resolving the
matter.
30
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Matters of Interest
The U.S. said a California cherry-picker went to Pakistan for terrorist training. Now the case has
collapsed.
Washington Post
By Meagan Flynn
7/31/19
It was a month after 9/11, and Osama bin Laden's face flashed across the news on Naseem Khan's TV screen.
The FBI was sitting in his living room in Bend, Ore., and Khan sensed an opportunity. The agents had come for
an entirely different purpose and were ready to leave - until Khan pointed at the screen and said he thought he
could help with something else. A few years ago, he said, he saw bin Laden's second-in-command, Ayman al-
Zawahiri, one of the most wanted terrorists in the world, at a mosque in the wine-country town of Lodi, Calif.
The agents perked up, intrigued by the possibility. Had they really just stumbled into a hot tip on al-Qaeda
while speaking to a 28-year-old McDonald's worker and convenience store clerk? The FBI thought Khan was
onto something - a possible "sleeper cell" of terrorism hidden in Lodi - and decided to dispatch him there as
a confidential informant.
Khan wouldn't find any associates of Zawahiri at the mosque in Lodi, and U.S. officials and terrorism experts
now doubt his initial claim about Zawahiri was ever true. But Khan would find 19-year-old Hamid Hayat -
who would soon become the face of homegrown terrorism in post-9/11 America.
They met at the mosque, and Khan learned Hayat was taking a trip to Pakistan with family. Over and over, in
recorded conversations, he returned to the same question: Would Hayat commit to attending a terrorist training
camp, as he had promised?
Now, a judge's order on Tuesday casts doubt on whether Hayat ever actually did.
Hayat, a cherry-picker and son of an ice cream truck driver, was convicted of attending the alleged terrorist
training camp and sentenced to 24 years in prison in 2006. Prosecutors, relying on Khan and Hayat's own
statements, alleged that he attended the camp for three to six months sometime in 2003. The case would become
one of the most high-profile examples of the government's fight against terrorism in the immediate aftermath of
9/11, especially because Hayat, after hours of interrogation by FBI agents, confessed to attending the camp.
But on Tuesday, U.S. District Judge Garland E. Burrell Jr. vacated his conviction and sentence, finding that
Hayat had inadequate defense during the 2006 trial while casting doubt on the facts of the case. Burrell
questioned whether jurors would have convicted him had they heard evidence from witnesses in Pakistan,
which the judge said likely would have "undermined" jurors' confidence in Hayat's confession alone. His
attorneys have maintained the confession was coerced during an exhausting interrogation.
Had the defense attorney actually interviewed any witnesses in Pakistan who spent significant time with Hayat
during his trip, she would have discovered that they recalled Hayat spent most of his time playing video games
and cricket and that the purpose of his visit was for his family to find him a wife, according to Burrell's order.
No one identified any prolonged disappearance that would have allowed him to visit a terrorist training camp
for three to six months as prosecutors alleged and Hayat said in the confession, Burrell noted. Burrell, who
31
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SDNY News Clips, Wednesday, July 31, 2019
oversaw Hayat's original trial, found the witnesses gave consistent statements and could have provided Hayat a
credible alibi.
"Showing that Hayat could not have been at a jihadi training camp for the "period of months' specified in the
indictment would have been completely consistent with the defense that Hayat's confession should not be
credited and the government lacked other supporting evidence," a U.S. magistrate wrote in making the
recommendation that Hayat's conviction be vacated. Burrell adopted most of the magistrate's findings of fact.
The government has not decided yet whether to appeal the decision, a spokeswoman in the U.S. attorney's
office in the Eastern District of California said in a statement, the Sacramento Bee reported. "We are in the
process of reviewing the district court decision and assessing what steps, if any, should be taken and
considering all our options," the statement said.
Hayat, now 36, is currently being held in a federal prison in Phoenix. His attorneys are seeking his immediate
release.
The case against Hayat and his father, Umer, who was accused of lying to the FBI, heaped international
attention on the Northern California town of Lodi. Seemingly overnight, the town went from the zinfandel
capital of the world to an alleged terrorism "sleeper cell" - a claim authorities would later walk back.
At the time he met Khan in August 2002, Hayat lived in his parents' garage and didn't have many friends, as
the Intercept recounted in a 2016 investigation. Posing as a radical Islamist, Khan nudged Hayat into
conversations that were anti-American and supportive of Islamic fundamentalist groups, and to his delight
Hayat went along with it, according to recorded conversations cited in federal court documents. Hayat approved
of the beheading of Wall Street Journal journalist Daniel Pearl by Pakistani militants. He told Khan he believed
jihadists had attended his grandfather's religious school in Pakistan and claimed his grandfather was so
politically well connected that the Pakistani president enlisted him in efforts to persuade the Taliban to turn over
bin Laden after 9/11.
Then came the terrorist camps. Hayat said he had seen one in an online video - and expressed interest in going
himself. Khan, feeding the intel to the FBI, egged him on.
But once in Pakistan, Hayat kept making excuses, according to the judge's order. When Khan told him he was
being "lazy," Hayat claimed the climate had changed and it got too hot outside - the terrorist camp was
canceled, he said. Khan was starting to get mad. His nudges turned to threats.
"God willing, when I come to Pakistan and I see you, I'm going to force you to, get you from your throat and
throw you in the madrassa," Khan said in one expletive-laden recorded conversation, as the Intercept
reported.
"I'm not going to go with that," Hayat said.
"Oh yeah, you will go," Khan told him. "Yeah, you will go. You know what? Maybe I can't fight with you in
America, but I can beat your a-- in Pakistan, so nobody's going to come to your rescue."
In their last conversation, according to the Intercept, which obtained all the recordings, Hayat said he "never
intended on going to a camp."
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SDNY News Clips, Wednesday, July 31, 2019
Hayat denied attending a camp in his first interview with the FBI in Japan, before flying to San Francisco. He
confessed during his second interview in California upon his return in June 2005.
"FBI: Al Qaeda plot possibly uncovered," rang a CNN headline in June 2005, saying those involved "Trained
on how to kill Americans."
Months after Hayat's arrest, then-director of national intelligence, John D. Negroponte, testified in a
congressional hearing that a "network of Islamic extremists in Lodi, Calif., for example, maintained connections
with Pakistani militant groups, recruited United States citizens."
But ultimately, no other terrorism cases arose from the investigation except for the one against Hayat. Two
imams were investigated but were never criminally charged with anything. They had overstayed religious
worker visas, authorities discovered.
A retired FBI agent who watched Hayat's interrogation and the resulting confession told the Los Angeles Times
it was "the sorriest interrogation, the sorriest confession, I've ever seen," believing the agents fed Hayat the
details they wanted to hear and that Hayat repeated them so he could leave. He was barred from offering his
testimony at trial. Burrell found that the failure to challenge the validity of the confession by presenting a false
confession expert also contributed to his finding that Hayat had ineffective counsel.
Khan was ultimately paid nearly $230,000 for assisting the FBI over three years. During Hayat's trial, his
defense attorney questioned how one fast-food worker's implausible claim that he saw the world's most wanted
terrorist in a small-town mosque could have "sparked this whole investigation with this ridiculous claim," the
Times reported in 2006.
Hayat's attorneys filed an appeal in 2014 and ultimately sought to interview numerous witnesses in Pakistan
who could account for his whereabouts during the trip from 2003 to 2005. They appeared for sworn depositions
on video in 2018. When Hayat's attorney, Dennis Riordan, asked his uncle whether he "would have known" if
Hayat disappeared from their rural hamlet, Muhammad Anas said, "Naturally, I would have noticed," the
Marshall Project reported then.
The judge found that the witnesses "corroborated each other on some important points," regarding trips the
family took throughout Pakistan and who they visited. Once or twice a month, they traveled to a hospital for his
mother's medical treatment.
On Tuesday, Hayat's family issued a statement applauding the judge's decision to throw out Hayat's
conviction, the Sacramento Bee reported.
"We have been waiting 14 long years for Hamid to be freed," the statement read. "Hamid cannot get those 14
years of his life back, but we are relieved to see the case take such a big step forward. We miss him and hope to
be reunited with him soon."
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SDNY News Clips, Wednesday, July 31, 2019
Fed Cuts Interest Rates for First Time Since 2008 Crisis
New York Times
By Jeanna Smialek
7/31/19
The Federal Reserve cut interest rates for the first time in more than a decade on Wednesday as it attempted to
guard the record-long economic expansion against mounting global risks.
The widely expected quarter-point move, the Fed's first since it cut rates to near zero in 2008, is meant to
protect the economy against the potentially harmful effects of a growth slowdown in China and Europe and
uncertainty from President Trump's trade war.
"In light of the implications of global developments for the economic outlook as well as muted inflation
pressures, the committee decided to lower the target range for the federal funds rate," according to the Federal
Open Market Committee's policy statement.
But the Fed did not indicate that this was the beginning of a rate-cutting campaign, suggesting instead that the
cut was a minor adjustment intended to help the economy weather any challenges from slowing global growth
and Mr. Trump's trade fights.
Subscribe to With Interest
Catch up and prep for the week ahead with this newsletter of the most important business insights, delivered
Sundays.
While Jerome H. Powell, the Fed chair, left the door open to additional rate moves if the economy showed signs
of sputtering, he did not indicate the central bank was poised to engage in the sort of deep cutting cycle that the
Fed has done in the past to avert or offset recessions.
"It's not the beginning of a long series of rate cuts - I didn't say it's just one," Mr. Powell said at a news
conference following the Fed's two-day policy meeting. "What we're seeing is that it's appropriate to adjust
policy to a somewhat more accommodative stance over time, and that's how we're looking at it."
The widely expected move from the central bank was initially greeted with a shrug in financial markets, where
investors have been factoring in a rate cut for months. But the stock market turned lower after Mr. Powell began
his news conference at 2:30 p.m., as investors absorbed the chair's comments as indicating the Fed was unlikely
to make additional cuts anytime soon, as investors had hoped.
By the end of the day, the S&P 500 was down 1.1 percent. It was the benchmark index's worst decline since
May 31.
The Fed dropped its target rate to a range between 2 percent to 2.25 percent. Officials also announced an early
end to its efforts to shrink the Fed's balance sheet, another attempt to keep the economy moving. The central
bank's holdings of government-backed bonds swelled during the financial crisis as it bought assets to try to
reinvigorate growth. Policymakers have been slowly siphoning off securities to return their balance sheet to a
more normal size, and that process was slated to end in September. It will now conclude Aug. 1.
Why the Federal Reserve Cut Interest Rates
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SDNY News Clips, Wednesday, July 31, 2019
The move is what's called an "insurance cut" - one that central bankers are making to keep growth chugging
along.
Both Eric Rosengren, the president of the Federal Reserve Bank of Boston, and Esther George, the president of
the Federal Reserve Bank of Kansas City, voted against Wednesday's decision, preferring instead to leave rates
unchanged. Those dissents marked the second and third of Jerome H. Powell's term as chair.
While Fed officials said they expect economic expansion to continue and the labor market to remain strong
"uncertainties about this outlook remain."
Mr. Powell said the Fed's move was "intended to insure against downside risks from weak global growth and
trade tensions."
He said that manufacturing around the world was weakening and that Mr. Trump's trade dispute was continuing
to spook American businesses. "The ongoing uncertainty is making some companies more cautious about their
capital spending," he said.
Officials did not indicate in their statement whether this cut would be followed by additional moves. The Fed's
June economic projections suggest policymakers envision cutting rates slightly to shore up the economy, rather
than beginning an easing cycle that will return rates to zero.
"As the committee contemplates the future path of the target range for the federal funds rate, it will continue to
monitor the implications of incoming information for the economic outlook and will act as appropriate to
sustain the expansion," the Fed said in its statement, seemingly leaving its options open.
Mr. Powell said the committee viewed the move as a "mid-cycle adjustment to policy," suggesting that the Fed
sees this cut as more similar to two instances in the 1990s, during which the Fed moved rates down slightly to
get the economy through periods of uncertainty, rather than the beginning of a rate-cutting campaign.
The Fed's rate cut carries political risks, given Mr. Trump's attacks on the central bank. Mr. Trump has been
denouncing the Fed in speeches and on Twitter for the past year, criticizing its four 2018 rate increases and
blaming its policies for slowing the American economy. Some onlookers may see Wednesday's move as caving
to the president.
The Fed operates independently of the White House. It attributed the change, which officials have been
signaling for months and which investors fully expected, to growing economic concerns.
"We also don't conduct monetary policy to prove our independence," Mr. Powell said.
The central bank is trying to extend a record-long economic expansion, because officials believe that doing so
will allow the Fed to achieve its goals of maximum employment and slow but steady inflation. The
unemployment rate is hovering around its lowest level in 50 years, but that has yet to push wages dramatically
higher in a way that forces companies to lift prices more quickly.
Inflation has run shy of the Fed's 2 percent goal since the central bank formally adopted it in 2012. A little
inflation helps to grease the wheels of a healthy economy, allowing businesses to raise wages faster and lifting
interest rates, giving the central bank more room to cut in the event of a downturn.
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SDNY News Clips, Wednesday, July 31, 2019
Prices picked up just 1.6 percent in the year through June, not counting volatile food and fuel costs.
Wages are growing only moderately. An index of employment costs climbed by 2.7 percent in the second
quarter from a year earlier, less than expected and a slowdown from earlier in 2019, according to data released
on Wednesday.
Global policy uncertainty has also increased, and manufacturing is slumping the world over. Growth is slowing
in China and Europe, and Mr. Trump's trade war with China and threats of further tariffs on United States
trading partners are stoking uncertainty and causing businesses to hold off on investment.
Those developments threaten the economic outlook, even as growth remains solid, consumer spending is robust
and the job market holds up for now.
36
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein
Date: Fri, 18 Jan 2019 14:07:42 +0000
Importance: Normal
I am likely not in Monday (MLK day) --
are you around at any point today for at least a brief update?
Brass is also interested in how things went.
Original Message
From:
)
Sent: Friday, January 18, 2019 9:05 AM
To:
(USANYS)
Cc:
)
i
(USANYS)
Subject: Re: Epstein
I'm traveling back today, could we set a time for Monday? Once I get in later I'm slammed with stuff that has
come up the past few days in other cases.
Sent from my iPhone
> On Jan 18, 2019, at 08:51,
wrote:
>
> You guys back? Can we circle up this morning? Definitely want to hear more about the trip.
and I have
something at 11:30 but I at least am free before/after.
>
> Sent from my iPhone
-
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein Related Civilian Crime Report Submission
(
)
Date: Tue, 22 Sep 2020 14:46:29 +0000
Thanks very much,
From:
Sent: Tuesday, September 22, 2020 10:35 AM
To:
Cc:
Subject: Epstein Related Civilian Crime Report Submission
(
Attached is a submission from a civilian. It purports to relate to Epstein. Because it is
from someone in a foreign country, we do not respond. In any event, there is nothing
more for you to do if this is not of any use. If we get anything else, we will forward it
along.
please make a note in the log. Thanks.
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=== Page 1 ===
From:
To:
Subject: FW: expert witness
Date: Wed, 24 Nov 2021 15:47:06 +0000
Do we have an email address for
? This is the email
originally sent to
From:
Sent: Thursday, January 28, 2021 8:59 AM
To:
Cc:
is
Subject: expert witness
Good morning,
My colleagues,
and
and I are the prosecutors in the case of United States V. Ghislaine
Maxwell, which is scheduled to go to trial on July 12, 2021 in the Southern District of New York. We are reaching out
because we would be interested in speaking with
about potentially testifying at trial. Would it be possible to
schedule a call with
to discuss?
Thanks very much,
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From: Kimberly Mehlman-Orozco
To:
)"
Cc:
)"
(USANYS)"
Subject: Re: Expert Witness
Date: Thu, 29 Oct 2020 00:47:38 +0000
Attachments: October2020Mehlman-OrozcoCV.pdf; CriminalCaseFeeSchedule2020.pdf
Sure, that works. CV and fee schedule attached.
I look forward to chatting tomorrow.
Best,
Kim
On Wed, Oct 28, 2020 at 6:48 PM
)
wrote:
Thanks very much -- 3:30 p.m. tomorrow would be great, if that works for you, and if you're able to send
those materials that would be helpful. We can use the following conference line:
,
passcode
Thanks,
From: Kimberly Mehlman-Orozco
Sent: Wednesday, October 28, 2020 6:23 PM
To: Kimberly Mehlman-Orozco
Cc:
)
)
(USANYS)
Subject: Re: Expert Witness
Also, I have some availability tomorrow before noon or after 3:00pm, if that works better.
Please let me know what works for you and if you'd like a CV and fee schedule in the interim.
Best,
EFTA00018629

=== Page 2 ===
Kim
Sent from my iPhone
On Oct 28, 2020, at 1:17 PM, Kimberly Mehlman-Orozco
wrote:
Hi
,
Yes, I have some time to chat this week. I have availability today or Friday before noon or after 3:00pm.
I can be reached on my cell
or feel free to circulate a call-in number.
Best,
Kim
Sent from my iPhone
On Oct 28, 2020, at 1:10 PM,
)
wrote:
Dr. Mehlman-Orozco,
My colleagues,
and
and I are the prosecutors in the case of United States
V. Ghislaine Maxwell, which is scheduled to go to trial on July 12, 2020 in the Southern District of New
York. We would be interested in speaking with you about your availability to testify at trial. Are you
available for a call this week to discuss?
Thanks very much,
EFTA00018630

=== Page 3 ===
Assistant United States Attorney
Southern District of New York
Dr. Kimberly Mehlman-Orozco
www.mehlmanorozco.com
Available for Purchase Barnes and Noble & Amazon
EFTA00018631


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=== Page 1 ===
From: "Martin G. Weinberg"
To:
)"
)"
Reid
Weingarten
"Miller, Michael"
Cc: "Martin G. Weinberg"
Subject: US V Epstein
Date: Mon, 12 Aug 2019 12:54:55 +0000
first if the emails regarding Mr. Epstein's death and our preservation/production requests on behalf of his family
should be sent to another prosecutor (Mike Miller had the name of
but not the full name) please advise. We would
ask you to confirm the request sent to you yesterday has been forwarded. We also request that DNA be lifted from the
ligatures and/or bed stripping found in Mr Epstein's MCC cell on August 10, 2019.
Separately, since the attorney client privilege survives death, we are still requesting a taint review in the event any review
at all of his emails from the seizures at Teterboro on Aug 6 or from his NYC residence are to be undertaken. If you provide
me with the name of the taint attorney when selected, I will provide a list of attorneys.
Lastly, is it the Government's intention to move to dismiss the Indictment against Mr. Epstein and if so will that occur
today?
Thanks, Marty
Martin G. Weinberg, Esq.
20 Park Plaza
Suite 1000
Boston, MA 02116
- Office
- Cell
This Electronic Message contains information from the Law Office of Martin G.
Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee only. If you are not the
addressee, please note that any disclosure, copying, distribution, or use of the contents of this message is prohibited.
EFTA00019069


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Maxwell Letter
Date: Thu, 20 Aug 2020 19:14:11 +0000
Attachments: 2020-08-20_GM_letter_to_Judge_Nathan_re_unsealing_materials.rd.docx
Sorry, use this version.
From:
(USANYS)
Sent: Thursday, August 20, 2020 3:14 PM
To:
(USANYS)
Subject: Maxwell Letter
U.S. Attorney's Office
Southern District of New York
Desk
Cell
EFTA00017842


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=== Page 1 ===
From: "Berman, Geoffrey (USANYS)"
To:
(USANYS)
Cc:
(USANYS)"
(USANYS)"
Subject: Re: Maxwell Clip (Email 1 of 11)
Date: Wed, 27 May 2020 19:39:09 +0000
This is good
Sent from my iPad
On May 27, 2020, at 3:36 PM,
(USANYS)
wrote:
Will attempt to send all of them via email. Sorry for the quality. Should be 11 emails. This is #1. Corresponds to the
following transcript passage in the pros memo (with some additional time before and after):
Q: Did you ever give a massage to anyone other than Mr. Epstein at any of Mr. Epstein's properties?
A: First of all, I never said I gave Mr. Epstein a massage.
Q: I will ask that question if you want, but I was focusing on people other than Mr. Epstein right now.
A: I don't give massages.
Q: Let's just tie that down. Is it your testimony that you've never given anybody a massage?
A: I have not given anyone a massage.
Q: You never gave Mr. Epstein a massage, is that your testimony?
A: That is my testimony.
Q: You never gave
a massage is your testimony?
A: I never gave
a massage.
<clip 1.MOV>
EFTA00018542


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=== Page 1 ===
From:
To:
Cc:
Subject: notes/302s
Date: Wed, 14 Aug 2019 16:16:13 +0000
and
Could you please send us scans of all the interview notes since Epstein's arrest? If there are any 302s ready, that would be
great, but in the first instance notes would be helpful.
We are working on memos briefing our supervisors on a series of issues, and it would be helpful to reference notes.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00019763


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=== Page 1 ===
From:
To:
Subject: FW: Meet and Confer
Date: Mon, 22 Mar 2021 23:43:30 +0000
Attachments: 202102.26_Government_Ommibus_Opposition_to_Maxwell_Defense_Motions_FINAL_(Pr
oposed_Redactions_Per_Order_and_Defense_Requested_Redaction).pdf;_2021-03-
22_GM_letter_re_pre-trial_opposition_redactions.docx
Inline-Images: image001.jpg; image002.jpg
Here is a draft letter to the Court. I'm going to send to the chiefs in 10 minutes so please let me know if you have any
edits.
Subject: RE: Meet and Confer
Judge Nathan agreed with us that sections of the deposition transcripts that appear unredacted in the publicly filed
indictment should still be redacted in your opposition because they were sealed in the defamation case. The redactions
we are proposing refer to those sections. So the fact that the language appears in the indictment does not mean it should
not be redacted.
That said, to move this along, we will preserve this objection and raise it with the Court at a later time, if we choose to.
However, we do ask that you redact "[Minor Victim-2]" at the bottom of page 134 so that it is consistent with the
redactions ordered by Judge Nathan on the top of the same page.
Thanks,
Chris
Subject: RE: Meet and Confer
Chris,
We have confirmed that our proposed redactions to Exhibit 11 and those you circulated to Exhibit 11 are the same. As to
your newly proposed redactions, we understand that you are requesting that we redact portions of our brief that either
quote or generally refer to unredacted portions of your publicly filed opening brief (Dkt. 136 at pages 14 to 17) or
language contained in the publicly filed indictment. We don't understand why you are requesting that this language now
be sealed. Can you please explain your position?
EFTA00019474

=== Page 2 ===
Thanks,
Subject: RE: Meet and Confer
I believe we agree on the redactions to Exhibit 11. I have attached our proposed redacted version of Exhibit 11. I have
checked it against yours and I believe they track exactly, but maybe you could double check. We also agree that no
redactions to the cover letter are necessary. We also confirm that you should keep the redactions on pp. 118-119.
We also noticed that on pages 130-134 of the opposition brief there are a few quotations and other references to
testimony in the civil case that are still sealed. In light of Judge Nathan's order, we think those should be redacted as
well. We have attached the relevant pages. The additional redactions are noted in red boxes.
Please let me know if you want to discuss further.
Thanks,
Chris
Subject: RE: Meet and Confer
Chris,
Thanks for your email. In accordance with Judge Nathan's order, we are writing to confer regarding Exhibit 11 and your
cover letter dated March 9, 2021. Attached please find proposed redactions to Exhibit 11. We do not believe any
redactions are necessary to your cover letter.
We intend to the file the brief with the redactions as set forth in Judge Nathan's March 18, 2021 order, attached here for
your convenience. We note that the redactions contained on pages 118 to 119 redact quotations from and references to
a document that you filed under seal (Exhibit H). We understand that the quoted portions of that document are also
under seal on the civil docket before Judge Preska. Given those facts, we wanted to double check with you to see
whether you in fact want those redactions removed. We will defer to you on whether these should be redacted.
Best,
EFTA00019475

=== Page 3 ===
Subject: Meet and Confer
Per Judge Nathan's order, we need to meet and confer today about proposed redactions to Exhibit 11 of your opposition
and to our letter dated March 9, 2021 regarding redactions. We are free from now through the rest of the afternoon.
Please let us know what works for you.
Regards,
Chris
Christian R Everdell
COHEN & GRESSER LLP
New York
Paris
Washington DC
London
GG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00019476


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-58 United States of America V. Maxwell "Motion Order FILED denying for bail"
Date: Tue, 27 Apr 2021 17:57:04 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 04/27/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Document(s): Document(s)
Docket Text:
MOTION ORDER, denying motion for bail [39] filed by Appellant Ghislaine Maxwell, by PNL, RJL, RJS,
FILED. [3087715][86] [21-58, 21-770]
Notice will be electronically mailed to:
Notice will be stored in the notice cart for:
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Motion Order FILED
Original Filename: 21-58.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=04/27/2021] [FileNumber=3087715-0]
[c4dae9d83e3602096564248f5bfcc0e89b9f8c55fe4ec1014f3c2db1a909f4f7c8b360f2544b2115306751b7aa82b9
4f70f4198d95fcdcb8ef868b204742b03e]]
EFTA00018234


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=== Page 1 ===
From:
)"
To:
@epllc.com>
@epllc.com>
Cc:
(USANYS)"
)"
Subject: Local Criminal Rule 23.1
Date: Mon, 02 Aug 2021 14:49:55 +0000
Attachments: :2021.07.30_Order_Regarding_Local_Rule_23.1.pdf
and
We wanted to let you know about a recent order from Judge Nathan regarding Local Criminal Rule 23.1, which applies not
only to counsel of record in a criminal case, but also to attorneys associated with a case, such as attorneys for witnesses.
The order is attached, and the full text version of the local SDNY rules can be found on the court's website. If you have
any questions about the rule or the order, please let us know.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00018032


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=== Page 1 ===
BUT
U.S. Department of Justice
United States Attorney
Southern District of New York
United States Courthouse
300 Quarropas Street
White Plains, New York 10601
January 9, 2020
BY ECF
The Honorable Kenneth M. Karas
United States District Judge
Southern District of New York
300 Quarropas Street
White Plains, NY 10601
Re:
United States V. Nicholas Tartaglione, S4 16 Cr. 832 (KMK)
Dear Judge Karas:
The Government respectfully submits this letter to provide a further update to the Court
regarding the defense's request for video footage from outside the defendant's cell at the
Metropolitan Correctional Center ("MCC") on July 22 - July 23, 2019. On or about December
19, 2019, the Government informed the Court and defense counsel that it had confirmed with MCC
staff that the requested video had been preserved, and that the Government was working to obtain
a copy from MCC. As set forth in greater detail below, the Government has learned that the MCC
inadvertently preserved video from the wrong tier within the MCC, and, as a result, video from
outside the defendant's cell on July 22 - 23, 2019 (i.e. the requested video) no longer exists.
On or about July 23, 2019, at approximately 1:27 a.m., MCC corrections officers responded
to the cell ("Cell-1") that the defendant shared with Jeffrey Epstein. On or about July 25, 2019,
defense counsel requested that MCC preserve video footage from outside the defendant's cell from
July 22, 2019 at 11:00 p.m. through July 23, 2019 at 4:00 a.m. From speaking with MCC legal
counsel, the Government understands that in response to this request, MCC legal counsel looked
up the defendant's cell number in the MCC computer system and thereafter requested that MCC
staff preserve video from outside of that cell for the requested time period. An MCC staff member
confirmed that the video had been preserved.
On or about January 3, 2020, the MCC provided the Government with a copy of the video
that it had preserved, which the Government then converted into a playable format. After
reviewing the video, it appeared to the Government that the footage contained on the preserved
video was for the correct date and time, but captured a different tier than the one where Cell-1 was
located because the preserved video did not show corrections officers responding to any of the
cells seen on the video. After speaking with MCC legal counsel, the Government was informed
that the MCC computer system listed a different, incorrect cell for Tartaglione ("Cell-2").
Therefore, when MCC legal counsel asked that the video outside of the defendant's cell be
preserved, the MCC preserved video outside of Cell-2 instead of Cell-1.
EFTA00017953

=== Page 2 ===
January 9, 2020
Page 2 of 2
The Government understands from speaking with MCC legal counsel that there was a
backup system in place that housed all video for the Special Housing Unit, including the video
requested by defense counsel. The Government further understands from the Federal Bureau of
Investigation that it has reviewed that backup system as part of an unrelated investigation and
determined that the requested video no longer exists on the backup system and has not since at
least August 2019 as a result of technical errors.
The Government will make the video of the tier containing Cell-2 available for defense
counsel's review at the United States Attorney's Office.
Respectfully submitted,
GEOFFREY S. BERMAN
United States Attorney
By:
/s/
Assistant United States Attorneys
Cc:
Counsel of record (by ECF)
EFTA00017954


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Cc:
)"
(USANYS)"
Subject: Re: Epstein
Date: Thu, 24 Jan 2019 03:09:41 +0000
Importance: Normal
Double wow.
Sent from my iPhone
On Jan 23, 2019, at 9:18 PM,
(USANYS)
wrote:
Thanks. Re this letter, wow.
From:
)
Sent: Wednesday, January 23, 2019 6:39 PM
To:
(USANYS)
Cc:
(USANYS)
i
>; Kurland, Abigail
(USANYS)
Subject: RE: Epstein
Yes, got 'em, but unfortunately most of the files are too big to send via email - l'll send an email to Lou asking for share
drive access for you both, and when you get access the defense letters we currently have are here (the smallest one is
attached):
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#Florida Scans\efrey
Epstein\Letters from Epstein's attorneys
and the indictment materials we currently have, including draft indictments, are here:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#Florida Scans\JefreyEpstein\Gl
thanks,
Alex.
From:
(USANYS)
Sent: Wednesday, January 23, 2019 18:25
To:
);
);
(USANYS)
Cc:
(USANYS)
Subject: Epstein
Any progress in getting the scanned docs from the trip? Particularly interested in seeing the draft indictment and
defense submissions.
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office for the
EFTA00019213

=== Page 2 ===
Southern District of New York
Tel.
EFTA00019214


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=== Page 1 ===
From: Roberta Kaplan
To:
)"
Cc: "Kate L. Doniger"
Alex Conlon
Subject: Fwd: Epstein Victims' Compensation Program
Date: Sat, 14 Dec 2019 14:55:17 +0000
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
350 Fifth Avenue I Suite 7110
New York, New York 10118
From: Jordy Feldman
Sent: Saturday, December 14, 2019 9:46:10 AM
To: Kate L. Doniger
>; Roberta Kaplan
>; Julie Fink
>; Alex Conlon
>; Rachel Harris
Cc:
is
Subject: Re: Epstein Victims' Compensation Program
Roberta and Kate,
Ken, Camille and I have spent many years designing and running these types of claims resolution programs. Our
reputations rest on our credibility and independence, as demonstrated in those other programs, and we bring the same
independence and fair-mindedness to this Program. There is no need for an additional administrator. This Program will
be non-adversarial and will treat the victims with the dignity they deserve. We hope that you will meet with us and share
your feedback on the Draft Protocol. And, once the Program is up and running, we hope you will participate and see the
process for yourself.
Jordy
From: Kate L. Doniger
Sent: Friday, December 13, 2019 5:17 PM
To: Jordy Feldman
>; Roberta Kaplan
>; Julie Fink
>; Alex Conlon
>; Rachel Harris
Cc:
is
Subject: RE: Epstein Victims' Compensation Program
Jordy, Ken, and Camille
We have received the protocol and will get back to you. In the meantime, we would appreciate your response to our
proposal regarding the addition of an administrator selected by plaintiffs. Thank you,
Kate L. Doniger Kaplan Hecker & Fink LLP
350 Fifth Avenue Suite 7110
EFTA00019565

=== Page 2 ===
New York, New York 10118
(W)
(M)
From: Jordy Feldman
Sent: Friday, December 13, 2019 2:00 PM
To: Roberta Kaplan
>; Kate L. Doniger
>; Julie Fink
>; Alex Conlon
>; Rachel Harris
Cc:
Subject: Re: Epstein Victims' Compensation Program
Roberta,
I wanted to let you know that Ken, Camille and I have prepared a Draft Protocol for the Program, setting forth
the proposed criteria and requirements for the evaluation of claims, and the claims process. As you know, the
establishment of the Program is still pending approval by the Superior Court of the U.S. Virgin Islands. However,
we felt that it was important for us to move forward on the proposed design of the Program and to engage you
in the process as soon as possible.
To that end, we have attached a copy of the Draft Protocol, for your review and consideration. We welcome an
opportunity to meet with you to discuss any comments you may have. The comment period will run through
January 31, 2020.
Whenever you have a chance, please let us know if you are available to meet on any of the following dates:
December 18, January 6, 7, 8, 10, and 16. If none of those dates work, please provide alternate dates and
times, and we will try to coordinate schedules and set something up.
Looking forward to hearing your thoughts.
Regards,
Jordy, Ken and Camille
From: Kate L. Doniger
Sent: Monday, December 9, 2019 4:46 PM
To: Jordy Feldman
Cc: Roberta Kaplan
>; Julie Fink
>; Alex Conlon
>; Rachel Harris
is
is
Subject: RE: Epstein Victims' Compensation Program
On behalf of Roberta Kaplan
Jordy,
Thank you for your email. We appreciate your commitment to a program that is independent of the Estate, which we also
view as a central feature of any viable alternative to litigation. As I'm sure you can understand, however, a claims
resolution program in which the three decision-makers were selected and hired by the Estate-and, we presume, are
being paid by the Estate-cannot be said to be independent. In our view, there is a straightforward solution to this
otherwise intractable problem: the program should add a fourth administrator, selected by plaintiffs, and require that all
claims decisions are rendered unanimously.
EFTA00019566

=== Page 3 ===
We look forward to discussing this proposal with you. We suggest arranging a time to do so before the protocol is
finalized, since it will be important to incorporate the input of an additional administrator into that process. We will, of
course, also raise this with the Estate.
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
350 Fifth Avenue Suite 7110
New York, New York 10118
From: Jordy Feldman
Sent: Wednesday, December 4, 2019 7:24 PM
To: Kate L. Doniger
>; Roberta Kaplan
Cc: Julie Fink
>; Alex Conlon
>; Mariann Wang
>; Arick Fudali
>; Daniel Mullkoff
>; Brad
Edwards
is
Lisa Bloom
>; Brittany
Henderson
>; ECF <ecf@epllc.com> Laura Starr
is
Andrew Buzin
>; Gloria Allred
>; Colleen
Mullen
is
;
Subject: RE: Epstein Victims' Compensation Program
Roberta,
Thank you for your email. I hear your concerns and want to reiterate that this proposed Program is entirely voluntary and
independent of the Estate. It in no way imposes a process or outcome on the victims, and will in no way be administered
or controlled by the Estate. Those are signature features of the Program.
As I mentioned in my email last week, Ken, Camille and I are in the process of drafting a claims protocol and plan to
circulate it - in draft form - to you and your counterparts before the holidays, and welcome any input you may have at
that time. We will provide ample time for you to review and respond to the draft protocol, and will be happy and
available to discuss your comments before the protocol is finalized.
We look forward to speaking with you.
Regards,
Jordy
From: Kate L. Doniger
Sent: Monday, December 2, 2019 9:05 PM
To: Jordy Feldman
Cc: Roberta Kaplan
>; Julie Fink
>; Alex Conlon
>; Mariann Wang
>; Arick Fudali
>; ; Daniel
Mullkoff
>; ; Brad Edwards
; Lisa Bloom
>; Brittany Henderson
>; ; ECF <ecf@epllc.com>; Laura Starr
is
; Andrew Buzin
>; ; Gloria Allred
>; Colleen Mullen
i
;
Subject: RE: Epstein Victims' Compensation Program
On behalf of Roberta Kaplan
Jordy,
EFTA00019567

=== Page 4 ===
Thank you for reaching out to us. We are writing back on behalf of (and copying) certain plaintiffs' counsel who
appeared at an SDNY conference last week for sexual abuse survivors of Epstein. We intend no disrespect to
you and your colleagues, but, candidly, we have serious concerns about the Estate's purported decision to
impose a non-binding settlement process on our clients unilaterally. All of these women still struggle today
because of the profound manipulation, objectification, and physical abuse to which Jeffrey Epstein subjected
each of them. Regardless of your own significant experience and good intentions, the fact that the Estate chose
an administrator without any participation, input, or consideration of our clients' views or wishes is
disconcerting, particularly given the personal nature of the claims at issue.
We are, of course, interested above all in advancing our clients' interests. As you may know, at a status
conference last week in the Southern District, Magistrate Judge Freeman instructed counsel for the Estate and
counsel for plaintiffs to engage in good faith discussions about any proposed claim resolution program. We
have already directed a request for information on the proposed program to Bennet Moskowitz, and look
forward to his response and to a productive dialogue with counsel ahead of the Jan. 10, 2019 deadline set by
the Magistrate for an update on the status of our negotiations. Assuming that our settlement discussions with
Defendants progress, we look forward to working with you at the appropriate time to design an effective and
appropriate settlement program.
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
350 Fifth Avenue I Suite 7110
New York, New York 10118
From: Jordy Feldman
Sent: Monday, November 25, 2019 4:00 PM
To: Roberta Kaplan
Cc:
Subject: Epstein Victims' Compensation Program
Roberta,
As you know, I will be serving as co-Designer, along with Ken Feinberg and Camille Biros, and Administrator of
the proposed Epstein Victims' Compensation Program. I wanted to reach out to you to introduce myself, as I
understand that you represent victims who have asserted, or may assert, claims of sexual abuse against Jeffrey
Epstein or his Estate. I also wanted to reinforce the key guiding principles of the Program and give you a sense
of timing in the near term.
This proposed Program is purely voluntary, non-adversarial and entirely independent of the Estate. The Estate
will have no authority whatsoever to interfere with the administration of the Program or the evaluation of
individual claims.
Ken, Camille and I are in the process of drafting a proposed protocol - setting forth the proposed terms,
conditions, and criteria that will govern the Program - and plan to circulate a draft protocol before the end of
the year. We will be seeking your input at that time in whatever format you would like to provide it, through a
meeting with us and/or written comments, before the protocol is finalized.
We look forward to serving these deserving victims.
Regards,
EFTA00019568

=== Page 5 ===
Jordy
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.
EFTA00019569


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=== Page 1 ===
From:
"
(USANYS) [Contractor]"
To:
(USANYS)"
Subject: 2019-07-12, JE, government opposition to bail motion (with exhibits).pdf
Date: Mon, 15 Jul 2019 13:54:21 +0000
Importance: Normal
Attachments: 2019-07-12,_JE,_government_opposition_to_bail_motion_(with_exhibits).pdf;
ATT00001.txt
EFTA00020346


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=== Page 1 ===
From:
To: Gloria Allred
Cc:
Subject: Re: Urgent!
,an Epstein victim, just told me that she was able to get child care
and would like to fly to New York for the hearing Tuesday. What is your telephone number,
so that I can call you a.s.a.p.?
Date: Sun, 25 Aug 2019 18:21:17 +0000
Inline-Images: image001.png; image002.jpg
Thanks very much. Sorry if missed it, but would you also please send me her DOB?
On Aug 25, 2019, at 2:18 PM, Gloria Allred
wrote:
On her driver's license it states on one line
and then on the next line below it,
Thanks again for
working on a Sunday to assist
with her travel from Las Vegas to New York tomorrow.
Gloria Allred
Allred, Maroko & Goldberg
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.jpg>
From:
Sent: Sunday, August 25, 2019 7:43 AM
To: Gloria Allred
Cc:
Subject: Re: Urgent!
,an Epstein victim, just told me that she was able to get child care and would like to fly
to New York for the hearing Tuesday. What is your telephone number,
so that I can call you a.s.a.p.?
Thanks Gloria. I've reminded
about the previous booking but have not heard back. Please do send me that
information when you can, just in case
still needs it.
On Aug 25, 2019, at 10:35 AM, Gloria Allred
wrote:
Thank you very much,
would like to fly from Las Vegas to New York tomorrow morning.
booked
last flight to New York to meet with you, so she should have a copy of her driver's license., which my
assistant, Diane , had sent to her for travel for that meeting. If not, I had told
that I would speak to her at noon
pacific today re her travel and I can get it then. I will also try to reach her earlier, but I know that she is not available
until later this morning.
Gloria Allred
EFTA00020080

=== Page 2 ===
Allred, Maroko & Goldberg
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.jpg>
From:
Sent: Sunday, August 25, 2019 7:21 AM
To:
Cc: Gloria Allred
Subject: Re: Urgent!
,an Epstein victim, just told me that she was able to get child care and would like to
fly to New York for the hearing Tuesday. What is your telephone number,
so that I can call you a.s.a.p.?
Gloria,
is going to try to book this flight, but she asked me to confirm what airport she will be flying from, her name
exactly as it appears on her ID, and her DOB. Would you please send me that information?
Thanks,
On Aug 25, 2019, at 8:53 AM,
wrote:
Hi Gloria,
We will try to connect with
today to see if we can sort this out. It's possible we won't be able to make
arrangements this late, but we will do our best and we understand the time sensitivity. Thanks for reaching out.
Sent from my iPhone
On Aug 25, 2019, at 1:41 AM, Gloria Allred
wrote:
Is there a cell number for
that I can call to make travel arrangements for
? I sent
the email
below and left a voice mail for her on her office phone but she did not respond. I understand.
It is the weekend ,but is there a way that I can reach her or another agent to arrange
trip from Las Vegas to
New York on Monday morning ? It would mean so much to her to attend the hearing and
does not have
funds to pay for the flight and get reimbursed after that.
Gloria Allred
Allred, Maroko & Goldberg
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.jpg>
EFTA00020081

=== Page 3 ===
From: Gloria Allred
Sent: Saturday, August 24, 2019 4:09 PM
To: Olsen,
(USANYS)
Cc:
Subject: Urgent!
,an Epstein victim, just told me that she was able to get child care and would like to
fly to New York for the hearing Tuesday. What is your telephone number,
so that I can call you a.s.a.p.?
Sorry about the late notice.
Gloria Allred
Allred, Maroko & Goldberg
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.jpg>
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not
the addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU
RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING
THE SENDER NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
Martindale-Hubbell"
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2017
ALLRED, MAROKO & GOLDBERG
2018
Best Lawyers
EFTA00020082


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=== Page 1 ===
From: Christian Everdell
To:
"
)"
(USANYS)"
Cc: 'Jeff Pagliuca'
>, Laura Menninger
"Bobbi Sternheim
(
(USANYS) [Contractor]"
"Thomas J. Powers"
Subject: RE: Discovery Issues
Date: Mon, 29 Mar 2021 22:22:28 +0000
Inline-Images: image001.jpg; image002.jpg
Thanks,
Please send the docs via the link below:
From:
) [mailto:
Sent: Monday, March 29, 2021 3:53 PM
To: Christian Everdell;
);
(USANYS)
Cc: 'Jeff Pagliuca'; Laura Menninger; Bobbi Sternheim
(
);
(USANYS) [Contractor]
Subject: RE: Discovery Issues
Chris,
Following up on point number 7, that gap would not come in between those two productions but would instead be
contained solely in the November 18, 2020 production. If you are missing those files, the omission was unintentional, and
we have those files available to produce immediately. If you can send a link to your ftp site, our paralegal can upload
those materials right away.
Best,
Assistant United States Attorney
Southern District of New York
From:
Sent: Monday, March 29, 2021 3:36 PM
To: Christian Everdell
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; ; Laura Menninger
>; Bobbi Sternheim
EFTA00020430

=== Page 2 ===
Subject: RE: Discovery Issues
Chris,
We are available for a call to discuss tomorrow between 1pm and 2pm, between 3pm and 5pm, or after 5:30pm. Please
let us know if there is a time in those windows that would work on your end. In the meantime, below are some initial
responses:
1. Our supervisors have indicated that we are not permitted to send a drive that our IT department did not load to
the MDC. As a result, we cannot provide the drive directly to the MDC. That said, I am happy to join you in asking
the MDC to accept the drive from you. If the MDC still refuses, then my office would not object to an application to
Judge Nathan for an order directing the MDC to accept the drive from you, though we would need to allow MDC
legal counsel the opportunity to note their objections to Judge Nathan.
2. The MDC recently alerted us to this issue, and our paralegal converted the excel files at issue to pdfs and sent a
new CD with those pdfs to the MDC. If you client still cannot view them, then we are happy to load them to a drive
if you would like to provide one for us.
3. I have asked our vendor to look into this issue and will get back to you when I have spoken with them.
4. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said,
similar to the note I sent in my email regarding highly confidential images on March 16, 2021, the electronic files
recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized
each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except for data
showing when a particular file was saved to a drive by the investigative team or prepared for production.
5. As indicated in our November 9, 2020 discovery letter, all images within Bates range SDNY_GM_00467566 though
SDNY_GM_00514100 were seized during the 2019 searches of Epstein residences. These are the images from the
CDs that were recovered during those searches, so they did not come from any of the electronic devices that were
the subject of extractions by CART. As a result, these images would not have CART numbers. As for the metadata, I
have asked our vendor to look into this issue and will get back to you when I have spoken with them.
6. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, I
note again that the electronic files recovered from Epstein's devices have the same metadata on the hard drive that
was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so
none is viewable. Additionally, as indicated in our November 9, 2020 discovery letter, all images within the
SDNY011 load file (Bates range SDNY_GM_00467566 though SDNY_GM_00514100) were seized during the 2019
searches of Epstein residences. These are the images from the CDs that were recovered during those searches, so
they did not come from any of the electronic devices that were the subject of extractions by CART. As a result,
these images would not have CART numbers.
7. I have asked our paralegals and vendor to look into the Bates gap and will get back to you when I have spoken to
them.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00020431

=== Page 3 ===
From: Christian Everdell
Sent: Monday, March 29, 2021 2:40 PM
To:
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; Laura Menninger
>; Bobbi Sternheim
Subject: Discovery Issues
and
-
We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a
call to discuss.
1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created
(without the highly confidential items). You had said you would check to see if you could facilitate this. We have
not heard back from you. Are you able to send Ms. Maxwell the hard drive?
2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and
must use the prison computer. But the prison computer cannot read some of the files. We can include these files
on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please
advise which way you would like to proceed.
3. A number of the emails in the discovery - over 109,000 - were produced without their attachments (see tab 1 of
the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the
missing attachments, if they exist.
4. A number of electronic documents - over 110,000 - that were extracted from one of Epstein's devices, as identified
by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or
afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with the original
metadata for these files.
5. A number of photographs - over 6500 - were produced in native format, but do not have a CART number and have
"date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please
provide the CART number for these photographs or specify which device they came from. Also, we request that
you produce a metadata overlay with the original metadata for these files.
6. A number of the audio/visual files - over 460 - have similar metadata issues (see tab 4 of the attached Excel file).
These fall into the following buckets:
a. SDNY GM SUPP: these have CART numbers, but were produced without metadata load files and have
"date created" and "date last modified" dates in September-November 2020, after the date the device was
seized. We request that you produce a metadata overlay with the original metadata for these files.
b. SDNY005 (October 20, 2020 production): these are a few videos from the SDFL or PBPD investigations that
were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that
you produce a metadata overlay with the original metadata for these files.
C. SDNY011 (November 9, 2020 production): these were produced in native form with load files, but do not
reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these
files or indicate their source. Also, we request that you produce a metadata overlay with the original
metadata for these files.
EFTA00020432

=== Page 4 ===
7. There is a gap between 11/18 and 12/18 production numbers (SDNY_GM_02742044 to 2742183). Was that
intentional or are we missing those documents?
Please let us know your responses as soon as possible.
Thanks,
Chris
Christian R Everdell
COHEN & GRESSER LLP
I
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00020433


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: piling on
Date: Sat, 11 Jul 2020 02:38:21 +0000
Thanks for looking.
From:
Sent: Friday, July 10, 2020 7:33 PM
To:
is
Subject: RE: piling on
I haven't been able to find anything in which Maxwell's attorneys claim they don't know where Maxwell is. That
statement was only reported on (as best I can tell) in this article
(https://creativedestructionmedia.com/news/politics/2020/01/23/ghislaine-maxwels-lawyers-admit-they-dont-knov-
where-she-is-either/), which refers to a letter filed with Judge Preska in January 2020, and dated December 2019. The
article claims that the letter admitted Maxwell's lawyers don't know where their client is. Maxwell's attorneys filed one
letter from that time period to Judge Preska that I've found. That letter does not include any suggestion that Maxwell's
counsel does not know where Maxwell is. Rather, the letter cites to newspaper articles about the frenzied attempts of
reporters to track Maxwell down. So seems that the article misrepresented the letter from Maxwell's attorneys.
In case it's helpful, though, I found a couple orders permitting alternative service because of plaintiffs' inability to serve
Maxwell.
Here is a text order in
case approving alternative service after Maxwell's counsel refused to accept service.
06/15/2020
45
ORDER granting 43 Motion To Approve Alternate Service on Defendant Ghislaine Maxwell
("Maxwell"). Plaintiff's motion is unopposed, and, based on Plaintiff's representations regarding
her unsuccessful efforts to locate Maxwell's current residence, her fruitless attempts to serve
Maxwell at multiple locations, her equally fruitless attempts to contact Maxwell via several
email addresses publicly associated with Maxwell, and her rejected request to Maxwell's
known litigation counsel to accept service on Maxwell's behalf, this Court finds that Plaintiff has
adequately demonstrated that she has made diligent efforts to effect service, and that personal
service would be impracticable. See Ransome V. Epstein, No. 17cv616 (JGK), 2018 WL 637421,
at *1 (S.D.N.Y. Jan. 30, 2018); see also Farmer V. Indyke, No. 19cv10475 (LGS)(DF) (Text Order,
dated Feb. 12, 2020). This Court further finds that Plaintiff's provision of a copy of the
Summons and Complaint by email to Maxwell's current counsel of record in the Farmer case
(see Declaration of Robert S. Glassman, dated May 27, 2020 (Dkt. 43-2), Ex. 3) was reasonably
calculated to place Maxwell on notice of this suit and to constitute sufficient service under the
circumstances presented here. No later than 6/18/20, Plaintiff is directed to serve Maxwell with
a copy of this Text Order by the same means (i.e., by email to Maxwell's counsel of record in the
Farmer case), and to file proof of such service on the Docket of this action. Maxwell may then
have until 7/9/20 to move, answer, or otherwise respond to the Complaint. (HEREBY ORDERED
by Magistrate Judge Debra Freeman)( Only Order) (Freeman, Debra) (Entered: 06/15/2020)
And here is a similar text order granting the same request in
case after Maxwell's counsel refused to accept
service.
EFTA00020397

=== Page 2 ===
06/15/2020
45
ORDER granting 43 Motion To Approve Alternate Service on Defendant Ghislaine Maxwell
("Maxwell"). Plaintiff's motion is unopposed, and, based on Plaintiff's representations regarding
her unsuccessful efforts to locate Maxwell's current residence, her fruitless attempts to serve
Maxwell at multiple locations, her equally fruitless attempts to contact Maxwell via several
email addresses publicly associated with Maxwell, and her rejected request to Maxwell's
known litigation counsel to accept service on Maxwell's behalf, this Court finds that Plaintiff has
adequately demonstrated that she has made diligent efforts to effect service, and that personal
service would be impracticable. See Ransome V. Epstein, No. 17cv616 (JGK), 2018 WL 637421,
at *1 (S.D.N.Y. Jan. 30, 2018); see also Farmer V. Indyke, No. 19cv10475 (LGS)(DF) (Text Order,
dated Feb. 12, 2020). This Court further finds that Plaintiff's provision of a copy of the
Summons and Complaint by email to Maxwell's current counsel of record in the Farmer case
(see Declaration of Robert S. Glassman, dated May 27, 2020 (Dkt. 43-2), Ex. 3) was reasonably
calculated to place Maxwell on notice of this suit and to constitute sufficient service under the
circumstances presented here. No later than 6/18/20, Plaintiff is directed to serve Maxwell with
a copy of this Text Order by the same means (i.e., by email to Maxwell's counsel of record in the
Farmer case), and to file proof of such service on the Docket of this action. Maxwell may then
have until 7/9/20 to move, answer, or otherwise respond to the Complaint. (HEREBY ORDERED
by Magistrate Judge Debra Freeman)( (Text Only Order) (Freeman, Debra) (Entered: 06/15/2020)
From:
Sent: Friday, July 10, 2020 7:01 PM
To:
is
Subject: piling on
Could you guys possibly locate the transcript or filing where GM's attorneys said they did not know where she was? I tried
calling Sigrid but didn't reach her today. That would be a big help. Thanks team.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00020398


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Press Coverage re Op Stolen Globe/Epstein
Date: Thu, 28 Jan 2010 23:07:10 +0000
Importance: Normal
The AUSAs we recommend in each district are:
LA
New Mexico
What about New York,
? Have they been approached? What district?
We've worked with both
and
and they're very good. As we've discussed, I think they AUSAs will want as
much information from
as they can get - on all aspects of the case. I'm not sure whether an individual or group
approach is best, but I leave that decision to USAFLS. We are happy to facilitate and participate in any phone meetings
that are called, but, as I said at our meeting, we can't get involved substantively in the investigation.
Let me know how we can help.
From:
C. (USAFLS) [mailto:
Sent: Tuesday, January 26, 2010 10:21 AM
Subject: Press Coverage re Op Stolen Globe/Epstein
I have suspicions about who tipped off the press given my recent back and forth with some of the plaintiffs'
attorneys, but in any event, this appeared in this morning's Palm Beach Post.
- Can we set up the meeting with the AUSAs in California and New Mexico some time soon?
<<ex-epstein-worker-faces.pdf>>
Thank you.
Assistant U.S. Attorney
500 E. Broward Blvd, 7th Floor
Ft Lauderdale, FL 33394
EFTA00019178

=== Page 2 ===
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=== Page 1 ===
From:
"
)"
To:
(USANYS)"
Subject: Tentative: TC with Reid Weingarten re Epstein
Date: Tue, 19 Nov 2019 20:17:54 +0000
Importance: Normal
Attachments: unnamed
EFTA00019833


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=== Page 1 ===
JEGE, INC.
PASSENGER MANIFEST
Registration Number: N908JE
Type: B-727-31
Pilots:
Flight Engineer:
DATE: 120,20 2004 FROM PBI
TO
JFK
Departure 621 AM PM
Arrival
Time
8 39
AM
Trip
Time
PM
Number
243
PASSENGERS
1. Jeffrey Epstein
FROM Identifier Defined
2
City WEST PALM BEACH
3
State or Country
FL
TO Identifier Defined
City NEW YORK
6.
State or Country
N.Y.
7.
Nautical Miles
893
8.
Statute Miles
1027
9.
Gallons
AIRFRAME
10.
Pounds 19187 328539
11.
Flight Time 2.17
23
12.
Altitude FL F370 328562
13.
20.
Night
15
14.
21.
T/L
11
15.
22.
IMC
.
16.
23.
Approach
17.
24.
18.
25.
19.
26.
MM11-727 BOEING-N908JE_JEGE INC-000004
EFTA00019441


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=== Page 1 ===
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN
IN THE MATTER OF THE ESTATE OF
)
JEFFREY E. EPSTEIN,
)
PROBATE NO. ST-19-PB-80
)
19 NOV 14 AM 9:02
(IF N THE VIRGIN ISL ANDS
SUPERIOR COURT
Deceased.
)
ACTION FOR TESTATE
)
ADMINISTRATION
EXPEDITED MOTION FOR ESTABLISHMENT OF
A VOLUNTARY CLAIMS RESOLUTION PROGRAM
COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"),
DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Court for an
expedited order to establish an independent and voluntary claims resolution program (the
"Program") for purposes of resolving sexual abuse claims against Jeffrey E. Epstein, deceased, as
more fully described infra. As contemplated by the Co-Executors, the Program would provide all
eligible claimants an opportunity to receive compensation and voluntarily resolve their claims of
sexual abuse against Mr. Epstein through a confidential, non-adversarial alternative to litigation.
To be designed and implemented by independent, nationally recognized claims administration
experts, with input from interested parties including claimants and their representatives, the
Program would seek to timely resolve these claims through a process that is sensitive to the
experiences and concerns of claimants and treats them with compassion, dignity and respect.
I.
BACKGROUND
As widely reported in the news media, multiple individuals have asserted or expressed their
intent to assert claims of sexual abuse by Mr. Epstein (collectively, the "Sexual Abuse Claims").
To date, twelve lawsuits involving Sexual Abuse Claims have been filed in the state and federal
courts of the State of New York, where claimants assert some of the complained-of conduct
occurred, and which recently amended its statute of limitations to permit such claims. These
EFTA00018905

=== Page 2 ===
Estate of Jeffrey Epstein
Probate No. ST-19-PB-80
Motion for Establishment of Compensation Program
Page 2
lawsuits name as defendants the Estate, the Co-Executors, and various entities owned or controlled
by Mr. Epstein prior to his death, as well as purported agents and employees of Mr. Epstein or
those entities.
Pursuant to this Court's order, Notice to Creditors was duly first published on
September 18, 2019. However, only one Sexual Abuse Claim has so far been filed in the Virgin
Islands. As noted above, claimants have named the Estate and others in various lawsuits in
jurisdictions outside the Virgin Islands and, based on media reports and statements by various
counsel for plaintiffs, the Co-Executors anticipate that more Sexual Abuse Claims may be filed in
various jurisdictions including New York, Florida, New Mexico and France.
Purpose of the Motion
The Co-Executors believe that the interests of justice require the Estate to fairly
address and timely resolve the Sexual Abuse Claims, no matter where filed, as
a matter of national and international importance. As much of the value to
claimants lies in the fair and timely resolution of their claims, the Co-Executors
request that this Court grant the instant Motion expeditiously.
Guided by independent, nationally recognized claims administration experts,
the Co-Executors have worked diligently to begin formulating a comprehensive
process for determination and resolution of the Sexual Abuse Claims. If
approved by the Court, the Program would provide, to the fullest extent
possible, victims of sexual abuse access to a confidential claims resolution
process that does not entail the rigors and publicity of litigation. To our
knowledge, this Court is the first probate court that has been called upon to
approve the establishment of a mass tort-type program for achieving the fair,
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Estate of Jeffrey Epstein
Probate No. ST-19-PB-80
Motion for Establishment of Compensation Program
Page 3
independent determination and resolutions of sexual abuse claims filed by
multiple claimants against a decedent's estate. As a matter of public policy
alone, the urgency of this matter cannot be overstated.
Development of the Program for evaluation and resolution of the Sexual Abuse Claims, in
a manner designed to evaluate those claims in a confidential manner and to streamline their
determination by the country's most experienced claims administrators - individuals who have
designed, implemented and administered extensive mass tort programs including the September
11th Victim Compensation Fund, the Roman Catholic Church sex-abuse scandal, the BP
Deepwater Horizon oil spill in the Gulf of Mexico, the Agent Orange toxic chemical matter, and
others - would be in the best interests of claimants, the Estate, its creditors and its beneficiaries.
Accordingly, in order to create a mechanism for the just and efficient resolution of the Sexual
Abuse Claims that will attract the voluntary participation of claimants, the Co-Executors request
the Court's authorization to use the Estate's funds to retain the services of the claims administration
experts described below, so that they may properly proceed with preparation of the Program and
design of an appropriate protocol to establish a fair, independent claims resolution process.
II.
PROPOSED EPSTEIN VICTIMS' COMPENSATION PROGRAM
As contemplated by the Co-Executors, the proposed Epstein Victims' Compensation
Program would ultimately function as follows:
Participation in the Program by claimants would be entirely voluntary, and would not affect
any rights a claimant has, unless and until the claimant accepts the Program's compensation
determination and executes a release. All claimants would be afforded an opportunity to meet
with the Program Administrator (described below) if they so desire, and will be treated with
compassion, dignity and respect. The planned situs of the Program would be in New York, where
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Estate of Jeffrey Epstein
Probate No. ST-19-PB-80
Motion for Establishment of Compensation Program
Page 4
the majority of the Sexual Abuse Claims thus far have been filed, in order to alleviate the burden
of requiring claimants to travel to the Virgin Islands. Proceeding in that forum would also provide
claimants and their counsel with easier access to the Program Administrator, who is highly
qualified and experienced with this type of claims process, and is therefore likely to reduce the
overall costs of Program administration. The Program would be open to claimants wherever they
are located, and would use an electronic filing system to make the process available regardless of
the claimant's location.
A.
PROPOSED MECHANICS AND ADMINISTRATION OF THE
PROGRAM
If this Court authorizes the Co-Executors to proceed with development of the proposed
Program, a detailed Program protocol (the "Protocol") would be designed by the claims
administration experts, with input from the Co-Executors and those with an interest in resolution
of the Sexual Abuse Claims (including claimants and their representatives), and submitted to the
Court for its approval.
A ten-point summary of the contemplated Program follows:
1.
Participation in the Program would be entirely voluntary.
2.
The Program would be available to all claimants with sexual abuse claims
against Mr. Epstein who satisfy certain eligibility criteria, as defined in the
Protocol.
3.
While strict confidentiality will be required of the Program Administrator
and the Estate, each claimant would be free to disclose any and all
information concerning her participation in the Program, at claimant's sole
discretion, including information concerning the mechanics of the Program
and the resolution of her claim.
4.
Claimants who elect to file a claim with the Program would be invited to
provide documentation identified in a claim form to be developed by the
claims administration experts, and any additional corroborating or
supporting information to help substantiate their claim.
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Estate of Jeffrey Epstein
Probate No. ST-19-PB-80
Motion for Establishment of Compensation Program
Page 5
5.
All claimants would be afforded a voluntary, confidential opportunity to
meet with the Program Administrator to provide additional information that
may bear upon evaluation of their claims.
6.
Claims would be processed promptly and efficiently. Claimants would be
notified of any deficiency that prevents processing of their claim and
provided an opportunity to cure that deficiency.
7.
Once a completed claim has been submitted, the Program Administrator
would evaluate that claim based on all available information and would
determine whether the claimant is eligible to receive compensation and the
amount of compensation to be paid. This independent, individual
determination will be based on factors and criteria identified in the Protocol.
The Estate will have no authority to reject or modify the independent
determination of the Program Administrator.
8.
Upon issuance of a compensation determination by the Program
Administrator, the claimant would have complete freedom to accept or
reject that determination. If the claimant elects to accept the determination,
the claimant would execute a release waiving her right to litigate any claims
she may have against any person or entity arising from or related to Mr.
Epstein's conduct, as set forth in the Protocol. Upon the Program
Administrator's receipt of the claimant's acceptance of the compensation
determination and an executed release, the Program Administrator would
approve payment. The approval of any claim by the Program Administrator
will be deemed to have the effect of a claim "examined and approved"
within the meaning of 15 V.I.C. § 394, and, as already indicated, the Co-
Executors would have no authority to reject or modify the Program
Administrator's determination of any compensatory award made in
accordance with the Protocol.
9.
The Program Administrator will submit status reports to the Court on a
quarterly basis to provide updated information regarding the progress of the
Program, including the number of claims received, the number of claims
reviewed, the number of claims approved for payment, the aggregate value
of determinations issued, the aggregate value of determinations accepted,
and the aggregate value of determinations issued.
10.
Following conclusion of the Program, the Program Administrator would
issue a Final Report to the Court and the Co-Executors summarizing the
Program.
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Estate of Jeffrey Epstein
Probate No. ST-19-PB-80
Motion for Establishment of Compensation Program
Page 6
B.
PROPOSED CLAIMS PROCESS FOR PROGRAM PARTICIPATION
With respect to the timing and notice of claims, the Program would, if approved by the
Court, establish an effective commencement date and deadline for submission of all claims. A
claim form would be developed by the Program Administrator and disseminated to all known
claimants identified in a confidential database. Instructions for completing the form would be
included along with the form. The Program would operate and maintain a website that provides
general information about the Program, including the Protocol, Frequently Asked Questions, and
information about filing deadlines. Contact information for the Program would also be available
on the Program website. That website would also allow claimants, directly or through their
representatives, to register a new claim and/or upload their claim form or supporting documents to
facilitate submission and processing of individual claims.
C.
PROPOSED DESIGN, IMPLEMENTATION AND ADMINISTRATION
OF THE PROGRAM
To establish the Program and design and implement the Protocol, the Co-Executors
propose engaging the services of independent, nationally recognized experts in this field:
Jordana H. Feldman, Kenneth R. Feinberg and Camille S. Biros, whose credentials are discussed
in Section D below. The Protocol developed by these experts, with input from the Co-Executors
and those with an interest in resolution of the Sexual Abuse Claims (including claimants and their
representatives), would include eligibility criteria, the methodology for determining compensatory
damages, proof requirements and claims procedures, and timing, as follows:
Eligibility. Identifying the criteria to determine whether a claimant is eligible to
receive compensation under the Program.
Determination Methodology. Defining the factors and considerations to be used to
determine the amount of compensation to be offered to any eligible claimant.
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Estate of Jeffrey Epstein
Probate No. ST-19-PB-80
Motion for Establishment of Compensation Program
Page 7
Proof Requirements and Claims Procedures. Determining what types of
supporting documentation or other evidence each individual may be required to
submit to substantiate the claim, satisfy Protocol requirements, and allow the
Program Administrator to review, process and evaluate the claim.
Timing. Expressly stating the timeframe of the Program, including an effective
commencement date and deadline for submission of all claims.
In addition to leading the design and implementation of the Program, Ms. Feldman would
serve as the Program Administrator and would administer the Program and process all claims. The
Program Administrator would have final decision-making authority relating to the administration,
evaluation and valuation of claims. As noted above, the approval of any claim by the Program
Administrator will be deemed to have the effect of a claim "examined and approved" within the
meaning of 15 V.I.C. § 394.
D.
CREDENTIALS OF PROGRAM ADMINISTRATOR AND DESIGNERS
The Program Administrator and Program Designers' qualifications for participation in the
Program are set forth below.
1.
Jordana H. Feldman (Program Administrator & Designer)
Ms. Feldman has spent her career engaged in the design,
implementation and administration of mass tort claims programs
and complex settlements as effective and creative alternatives to
litigation.
Until recently, Ms. Feldman served as the Deputy Special
Master and Director of the New York Office of the September
11th Victim Compensation Fund ("VCF"), the litigation-
alternative program established in 2001 and reopened in 2011 to
compensate individuals who have become sick or died as a result
of their September 11th-related exposure, and administered by
the United States Department of Justice. She has worked on the
VCF for over ten years, playing a key role in developing
guidelines for eligibility and the valuation of losses, and
adjudicating thousands of claims, valued in the aggregate over
$12 billion. In that position, she has extensive experience
interviewing victims of the September 11 tragedy.
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Estate of Jeffrey Epstein
Probate No. ST-19-PB-80
Motion for Establishment of Compensation Program
Page 8
Before joining the Justice Department to work on the VCF, Ms.
Feldman worked in the complex dispute resolution practice at
the law firm Dickstein Shapiro, LLP, where she represented
clients in the design, implementation and administration of
complex settlements and mass claims resolution programs
arising out of class actions, legislation and Chapter 11
bankruptcy reorganizations. Before working at Dickstein
Shapiro, LLP, Feldman worked as a litigation associate at Fried,
Frank, Harris, Shriver & Jacobson.
Ms. Feldman is the co-author of the Master Guide to Mass
Claims Resolution Facilities (2011) and graduated in 2000 from
the University of Pennsylvania Law School. She received her
undergraduate degree magna cum laude in 1997 from the
University of Pennsylvania.
2.
Kenneth R. Feinberg (Program Designer)
Mr. Feinberg is the nation's leading expert in mediation and
alternative dispute resolution, and the founder of the Law
Offices of Kenneth R. Feinberg, PC. He has been appointed to
administer numerous high-profile compensation programs,
having served as special master of the September 11th Victim
Compensation Fund, the Troubled Asset Relief Program
("TARP") Executive Compensation Program, and the Agent
Orange Victim Compensation Program.
Mr. Feinberg and his colleague Camille Biros have designed and
implemented the New York Archdiocese Independent
Reconciliation and Compensation Program for resolution of
claims of sexual abuse of minors by members of the clergy, as
well as similar compensation funds for the Dioceses of Brooklyn
and Rockville Centre, New York and for Dioceses in the states
of California, Colorado, New Jersey and Pennsylvania.
Mr. Feinberg has served as adjunct professor of law at Harvard
Law School, Columbia Law School, University of Pennsylvania
School of Law, Georgetown University Law Center, New York
University School of Law, University of Virginia School of
Law, and Benjamin N. Cardozo School of Law. Before his
academic career, he served as an Assistant U.S. Attorney for the
Southern District of New York, special counsel for the U.S.
Senate Committee on the Judiciary, and founding partner of the
Washington office of the law firm Kaye Scholer LLP, among
other positions.
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=== Page 9 ===
Estate of Jeffrey Epstein
Probate No. ST-19-PB-80
Motion for Establishment of Compensation Program
Page 9
Mr. Feinberg graduated from New York University School of
Law in 1970 and received his undergraduate degree in 1967
from the University of Massachusetts.
3.
Camille S. Biros (Program Designer)
Ms. Biros is a nationally recognized expert in the design,
implementation and administration of public and private
compensation programs. She currently serves as Director,
Claims Administration, at the Law Offices of Kenneth R.
Feinberg, P.C.
Ms. Biros and Mr. Feinberg have designed and implemented the
New York Archdiocese Independent Reconciliation and
Compensation Program for resolution of claims of sexual abuse
of minors by members of the clergy, as well as similar
compensation funds for the Dioceses of Brooklyn and Rockville
Centre, New York and for Dioceses in the states of California,
Colorado, New Jersey and Pennsylvania. Ms. Biros has served
as the primary Administrator of these various funds.
Ms. Biros has also served as Administrator of the DuPont
Medical Monitoring Program, Deputy Administrator of the Gulf
Coast Claims Facility after the BP Deepwater Horizon oil spill,
Deputy Administrator of the GM Ignition Switch Compensation
Program and Deputy Special Master of the September 11th
Victim Compensation Fund.
III.
REQUEST FOR RELIEF
In their fiduciary capacity, the Co-Executors have engaged in discussions with relevant
parties in interest regarding the independent, fair and timely resolution of the Sexual Abuse
Claims. It is their understanding that many existing and potential claimants would prefer to
participate in the Program, if fairly and expeditiously administered, rather than proceeding with
litigation. Furthermore, although there would be significant expense in developing and
administering the Program, the Co-Executors anticipate that the Program would substantially
reduce the expenses to the Estate of litigating multiple lawsuits in numerous jurisdictions, and thus
would ultimately reduce expenses to the benefit of all parties with an interest in the Estate,
EFTA00018913

=== Page 10 ===
Estate of Jeffrey Epstein
Probate No. ST-19-PB-80
Motion for Establishment of Compensation Program
Page 10
including claimants and creditors. The expedited nature of the planned Program would also
ensure resolution and compensation to claimants in a far more timely manner than through
litigation. Additionally, the Protocol associated with the Program would be designed to ensure the
proportionate restitution of approved claims for all claimants, in a manner that would provide
similar compensation to similarly situated claimants. The Co-Executors submit that such a
Program is in the best interests of both the claimants and the Estate because, among other things,
it avoids the potential of disproportionate and inconsistent awards and should help to reduce the
time, expense and burden of handling claims through the courts, which could involve years of
litigation and appeals and consume enormous resources, along with inflicting costs attendant to
delay and uncertainty on all affected parties.
Rule 1 of the Virgin Islands Probate and Fiduciary Rules states that, "[w]here no procedural
provision is included herein, procedures set forth in the Virgin Islands Rules of Civil Procedure
may be adapted by the court as appropriate." In this regard, Rule 90 of the Virgin Islands Rules
of Civil Procedure evinces a clear intent in favor of the use of alternative dispute resolution to
resolve civil disputes. Thus, it is respectfully submitted that the establishment here of a voluntary
claims resolution program is within the Court's authority and would serve the interests of justice.
Furthermore, development and implementation of the Program, and the claims process
contemplated therein, is within the Court's sound discretion to establish a process by which the
rights of claimants will be fairly and efficiently ascertained and administered. See 5 V.I.C. § 1264
1. Such lawsuits have already begun to generate substantial costs and fees for both the Estate and claimants. The
expenses of litigation are expected to ratchet up significantly in coming months, absent implementation of the
Program as an alternative path for resolution of the Sexual Abuse Claims.
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=== Page 11 ===
Estate of Jeffrey Epstein
Probate No. ST-19-PB-80
Motion for Establishment of Compensation Program
Page 11
(allowing the court to declare rights, status and other legal relations of various classes of creditors
or other interested parties of a trust or estate).
At this juncture, the Co-Executors seek the Court's authorization to use Estate funds to
retain the services of the proposed Program Administrator and Program Designers - Ms.
Feldman, Mr. Feinberg and Ms. Biros - so that they may promptly proceed with preparation of
the Program and design of the Protocol to establish a fair, independent claims resolution process.
Once the Protocol is developed and finalized, the Co-Executors would submit it to the Court for
approval and would seek an order to formally commence claims resolution proceedings under the
Program.
Finally, the Co-Executors seek the Court's approval to submit under seal the proposed
engagement agreement of the Program Administrator and Program Designers, as it is proprietary
to the extent it establishes a methodology and formula for their compensation. Given the very
small group of people sufficiently qualified to design, implement and administer the proposed
Program and contemplated Protocol, the terms under which they are engaged would be subject to
intense scrutiny and may have the unintended effect of distracting from the Program. The Co-
Executors will of course disclose the fees for services rendered by the Program Administrator and
Program Designers as they are accounted for by the Estate.
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=== Page 12 ===
Estate of Jeffrey Epstein
Probate No. ST-19-PB-80
Motion for Establishment of Compensation Program
Page 12
WHEREFORE, the Co-Executors request the expedited entry of an Order granting the
relief requested herein substantially in the form of the attached proposed order.
Respectfully,
Dated: November 14, 2019
Christopher Allertho
CHRISTOPHER ALLEN KROBLIN, ESQ.
ANDREW W. HEYMANN, ESQ.
WILLIAM L. BLUM, ESQ.
SHARI N. D'ANDRADE, ESQ.
MARJORIE WHALEN, ESQ.
V.I. Bar Nos. 966, 266, 136, 1221 & R2019
KELLERHALS FERGUSON KROBLIN PLLC
Royal Palms Professional Building
9053 Estate Thomas, Suite 101
St. Thomas, V.I. 00802
Telephone: (340) 779-2564
Facsimile: (888) 316-9269
Email: ckroblin@kellfer.com
aheymann@solblum.com
wblum@solblum.com
sdandrade@kellfer.com
mwhalen@kellfer.com
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=== Page 13 ===
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS & ST. JOHN
IN THE MATTER OF THE ESTATE OF
)
JEFFREY E. EPSTEIN,
)
PROBATE NO. ST-19-PB-80
)
Deceased.
)
ACTION FOR TESTATE
)
ADMINISTRATION
ORDER
THIS MATTER is before the Court on the Co-Executors' Expedited Motion for
Establishment of a Voluntary Claims Resolution Program. Having reviewed the motion, the
Court will grant the same.
Accordingly, it is hereby:
ORDERED that the Co-Executors' Motion is GRANTED; and it is further
ORDERED that the Co-Executors shall submit to the Court, under seal, the proposed
engagement agreement for the Program Administrator and Designers (as defined in the Motion)
for approval and authorization; and it is further
ORDERED that a copy of this Order shall be directed to counsel of record.
Dated:
CAROLYN P. HERMON-PERCELL
Magistrate Judge of the Superior Court
of the Virgin Islands
ATTEST: ESTRELLA H. GEORGE
Clerk of the Court
BY:
Court Clerk Supervisor
/
/
EFTA00018917


