# docs_fts_content

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c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028321.pdf
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=== Page 1 ===
Case 1:19-cr-00490-RMB Document 5 Filed 07/08/19 Page 1 of 1
DOCKET No. 19CR490
DEFENDANT Jeffrey Epstein
AUSA
DEF.'S COUNSEL
RETAINED
FEDE
INTERPRETER NEEDED
DEFENDANT WAIVES PRETRIAL REPORT
Rule 5
Rule 9
Rule 5(c)(3)
Detention Hrg.
DATE OF ARREST 7-6-18
VOL. SURR.
TIME OF ARREST 5:30pm
ON WRIT
Other:
TIME OF PRESENTMENT 7-8-19
1:25Pm
BAIL DISPOSITION
LED
SEE SEP.ORDER
DETENTION ON CONSENT W/O PREJUDICE
DETENTION: RISK OF FLIGHT/DANGER
SEE TRANSCRE
DETENTION HEARING SCHEDULED FOR: 7-711-19@ZiPm
AGREED CONDITIONS OF RELEASE
DEF. RELEASED ON OWN RECOGNIZANCE
$
PRB
FRP
SECURED BY $
CASH/PROPERTY:
TRAVEL RESTRICTED TO SDNY/EDNY/
TEMPORARY ADDITIONAL TRAVEL UPON CONSENT OF AUSA & APPROVAL OF PRETRIAL SERVICES
SURRENDER TRAVEL DOCUMENTS (& NO NEW APPLICATIONS)
DOCUMENT
ELFC TRONICALLY
JUL 2019
JSDC DNY
DOC
DATE ILED:
PRETRIAL SUPERVISION:
REGULAR
STRICT
AS DIRECTED BY PRETRIAL SERVICES
DRUG TESTING/TREATMT AS DIRECTED BY PTS
MENTAL HEALTH EVAL/TREATMT AS DIRECTED BYPTS
DEF. TO SUBMIT TO URINALYSIS; IF POSITIVE, ADD CONDITION OF DRUG TESTING/TREATMENT
HOME INCARCERATION
HOME DETENTION
CURFEW
ELECTRONIC MONITORING
GPS
DEF. TO PAY ALL OF PART OF COST OF LOCATION MONITORING, AS DETERMINED BY PRETRIAL SERVICES
DEF. TO CONTINUE OR SEEK EMPLOYMENT [OR]
DEF. TO CONTINUE OR START EDUCATION PROGRAM
DEF. NOT TO POSSESS FIREARM/DESTRUCTIVE DEVICE/OTHER WEAPON
DEF. TO BE DETAINED UNTIL ALL CONDITIONS ARE MET
DEF. TO BE RELEASED ON OWN SIGNATURE, PLUS THE FOLLOWING CONDITIONS:
; REMAINING CONDITIONS TO BE MET BY:
ADDITIONAL CONDITIONS/ADDITIONAL PROCEEDINGS/COMMENTS:
- DEFT DETAINED UNTIL CONTINUATION
OF DET'N HEARING 18USC 3142(f)
DEF. ARRAIGNED; PLEADS NOT GUILTY
CONFERENCE BEFORE D.J. ON 7-8-19
DEF. WAIVES INDICTMENT
SPEEDY TRIAL TIME EXCLUDED UNDER 18 U.S.C. § 3161(h)(7) UNTIL
For Rule 5(c)(3) Cases:
IDENTITY HEARING WAIVED
DEFENDANT TO BE REMOVED
PRELIMINARY HEARING IN SDNY WAIVED
CONTROL DATE FOR REMOVAL:
PRELIMINARY HEARING DATE:
ON DEFENDANT'S CONSENT
DATE: 7/8/19
I tm
UNITED STATES MAGISTRATE JUDGE, S.D.N.Y.
WHITE (original) COURT FILE
PINK U.S. ATTORNEY'S OFFICE
YELLOW US MARSHAL
GREEN PRETRIAL SERVICES AGENCY
Rev'd 2016 IH 2
EFTA00028321


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
(USANYS)"
Subject: Scanning
Date: Tue, 27 Aug 2019 20:51:15 +0000
The beast has been slayed.
I organized the files out of the jumble that they were brought to us in. A few things that
probably be helpful to know:
1. There were some commissary receipts/finance documents pertaining to Epstein's activity inside of prison. I didn't
know where to put this so I left it outside of the folders but still inside MCC Recs
2. In the MCC Regs folder, I put a few things:
a. One file had inventory and then at the end some documents pertaining to daily key counts. I wasn't sure
if these were different so I created a separate file for the key counts just in case (while also keeping them
in the inventory file)
b. The MCC training 06-06-19 & information file was confusing to me. It was massive and I couldn't tell
whether or not I needed to separate anything out.
Everything else should be pretty straightforward as to where it is located. Let me know if you need me to clarify anything
or help any further.
EFTA00027253


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=== Page 1 ===
From:
Subject: Accepted: Call on Epstein/Maxwell Documents
Date: Wed, 22 Jul 2020 20:23:47 +0000
Importance: Normal
Attachments: unnamed
EFTA00027957


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=== Page 1 ===
From:
"
To:
Subject:
questionnaire
Date: Fri, 24 Jan 2020 15:52:07 +0000
Attachments: Questionnaire_for_Official_Foreign_Travel,_Stockholm,_2020_0
).pdf
Assistant United States Attorney
Southern District of New York
EFTA00028457


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
Subject: RE: Cite Check
Date: Wed, 27 Oct 2021 17:46:00 +0000
Attachments: Govt_Reply_v2.docx
I finished a first check of the document and have attached what comments I had. I was not able to check stuff like the
docket numbers or citations to previous briefs or motions in this case. That said the case cites look good overall, if there is
any other way I can help or if there is something you want me to go back and check again just let me know.
Thanks,
From:
Sent: Wednesday, October 27, 2021 12:44 PM
To:
(USANYS)
is
(USANYS)
Cc:
Subject: RE: Cite Check
Thanks. If you come across cites that you can't check because you don't have access to the document, just highlight it and
l'll check it at the end.
From:
(USANYS)
Sent: Wednesday, October 27, 2021 12:43 PM
To:
is
(USANYS)
Cc:
Subject: RE: Cite Check
Got it, will check in at 3:30 then.
From:
Sent: Wednesday, October 27, 2021 12:42 PM
To:
(USANYS)
is
(USANYS)
Cc:
Subject: RE: Cite Check
Thanks,
!
Our filing is due today, so the sooner the better. But why don't we plan to check in around 3:30 or
so and see where you are, and we can get others on board to help at that point if it makes sense.
From:
(USANYS)
Sent: Wednesday, October 27, 2021 12:41 PM
To:
i
(USANYS)
Cc:
Subject: RE: Cite Check
EFTA00028036

=== Page 2 ===
Great! I will makes sure to do so if I do. Just to check, is there a deadline you need this by? It shouldn't take too long but
just wanted to check.
Thanks,
From:
Sent: Wednesday, October 27, 2021 12:07 PM
To:
(USANYS)
i
(USANYS)
Cc:
Subject: RE: Cite Check
Hi
Thanks for the help with this project! I've attached the document we need citechecked. Feel free to give me a call if you
have any questions!
From:
(USANYS)
Sent: Wednesday, October 27, 2021 11:03 AM
To:
(USANYS)
Cc:
)
i
Subject: RE: Cite Check
Thanks so much
!
We really appreciate you helping out. We should have something to send to you for cite
checking fairly soon. Thanks again!
From:
(USANYS)
Sent: Wednesday, October 27, 2021 10:39 AM
To:
(USANYS)
Subject: Cite Check
Good Morning,
My name is
and I am an intern in the office assigned to
- He told me to reach out to
you as I believe you wanted something cite checked? If so I would be happy to help with whatever the assignment is.
Thank you,
EFTA00028037


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein Account Documents
Date: Thu, 07 Oct 2021 21:27:06 +0000
I have uploaded the documents I was able to find in the Epstein Account Document Folder in DOJ USA File Exchange site.
You should already have access to that folder.
I also came across two documents requesting removal for Ghislaine Maxwell from the Hyperion Air, Jeffery Epstein and
JEGE accounts, I have already provided those accounts documents. I also came across a memo requesting removal of
Ghislaine Maxwell from NES LLC Account #
I was unable to come across documents for that account. Those
removal memos have been placed in the Epstein Accounts Document folder as well.
If you have any questions, please call me.
Thanks
From:
Sent: Thursday, October 7, 2021 12:57 PM
To:
(NY) (FBI)
Cc:
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Epstein Account Documents
Thanks! Could you please send me the account opening/signature/KYC documents for the two accounts attached here?
From:
Sent: Thursday, October 7, 2021 7:38 AM
To:
Cc:
(USANYS)
i
(USANYS) [Contractor]
Subject: RE: Epstein Account Documents
I have uploaded the account statement to DOJ USA File Exchange site. I have give you,
and
access rights to the
folder.
If you have any questions, please contact me.
Best
From:
Sent: Wednesday, October 6, 2021 4:12 PM
EFTA00029172

=== Page 2 ===
To:
(NY) (FBI)
Cc:
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Epstein Account Documents
Hi
Thanks very much. Could you please send us the account statements for a few months after these documents were
executed? It would be helpful to see the balances.
Thanks!
From:
Sent: Monday, October 4, 2021 8:27 AM
To:
Subject: Epstein Account Documents
As a follow up to our conversation regarding Epstein accounts where Ghislaine Maxwell was a signer on the account, I
have compiled the attached documents for your review.
If you have any question, please contact me.
Best
Forensic Accountant
FBI New York Field Office
EFTA00029173


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=== Page 1 ===
From: "spamcontrol@usdoj.gov" <spamcontrol@usdoj.gov>
To:
Subject: End User Digest: 1 New Message
Date: Mon, 24 Aug 2020 10:09:05 +0000
Inline-Images: logo.jpeg
End User Digest: 1 New Message
DEPARTMENT
JUSTICE
For
The emails listed below have been placed in your personal Quarantine since you received your last End User Digest. They will
be deleted after 14 days. To deliver an e-mail to your inbox, click on Release. To deliver an e-mail to your inbox and add the e-
mail sender to your Safe Senders List, click on Release and Allow Sender. This ensures that no emails from that sender will be
blocked in the future. To report messages that are not spam but are reported in the digest, click on Not Spam.
Request New End User Digest Request Safe/Blocked Senders List Manage My Account Questions about digesting?
The emails listed in this section have been placed in your personal Quarantine. Click Release to deliver the email to your inbox.
To continue to receive future emails from the sender, click Allow Sender. To report messages that are not spam but are included
in the Spam - Quarantined section, click Not Spam.
Spam - Quarantined
Score
From
Subject
Date
Action
100
Epstein's 2020-
Release
Buddy 08-23
and
Not
Clinton 15:02:20
Release
Allow
Spam
Sender
For more information contact your System Administrator.
Powered by Proofpoint Protection Server
EFTA00028732


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=== Page 1 ===
From:
)"
To: Isidro Garcia
Cc:
)"
)"
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Date: Thu, 11 Jul 2019 01:00:07 +0000
Importance: Normal
Sid,
As you may already know, pursuant to the Crime Victims' Rights Act, specifically 18 U.S.C. 3771(a)(4), a crime victim has
the right to be reasonably heard at certain public proceedings in the district court, including proceedings involving
release. Accordingly, we wanted to be in touch consistent with our responsibilities and obligations-and your client's
rights-under that statute, to see whether your client would like to be heard in any fashion, whether through a
submission, a representation that we can include in our bail submission due Friday, or some other form. Of course no
requirement or obligation, but we would be happy to discuss it if that would be useful.
To the extent this information is useful in your consideration, I can say that we expect to vigorously oppose bail, as we
indicated to the judge we would in the proceedings earlier this week.
Please let me know if you'd like to discuss, no problem either way, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00028353


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=== Page 1 ===
From:
To:
Subject: Re: AG
Date: Tue, 19 Feb 2019 23:35:18 +0000
Importance: Normal
I sent pic and
stuff to
But bear in mind that what they want is detailed briefing for brass - not, as of yet, a more summary memo for
AG (though that request may come)
Sent from my iPhone
On Feb 19, 2019, at 6:32 PM,
wrote:
We did briefings on most of these for our meeting down in DC in December. I'm not sure the teams have the
final copies of what we sent down, but we might want to give them those to update rather than starting a new?
Sent from my iPhone
On Feb 19, 2019, at 6:21 PM,
wrote:
and
are meeting with the AG on Monday, and he asked to be briefed on our sensitives cases. The political
stuff and Epstein. I have spoken to the teams about preparing detailed briefing memos for
they will get us
drafts tomorrow, to get to the brass by Thursday morning. Then we'll meet with brass toward end of week. Not ideal
for me to be out Friday, but nothing I can do about it.
Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
t.
EFTA00027925


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
(USANYS)"
Subject: Re:
Date: Mon, 10 Feb 2020 21:00:01 +0000
What should I say in response to an Epstein statement?
On Feb 10, 2020, at 3:59 PM,
(USANYS)
wrote:
Begin forwarded message:
From:
(USANYS)"
Date: February 10, 2020 at 9:04:00 AM EST
To:
(USANYS) [Contractor]"
Ray Statement.ebd.docx>
EFTA00027557


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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
:
UNITED STATES OF AMERICA
:
PROTECTIVE ORDER
:
- V. -
:
19 Cr. 490 (RMB)
JEFFREY EPSTEIN,
:
:
Defendant.
:
:
X
RICHARD M. BERMAN, United States District Judge:
WHEREAS the Government intends to produce to JEFFREY
EPSTEIN, the defendant, certain documents and materials that
(i) affect the privacy and confidentiality of individuals,
(ii) would impede, if prematurely disclosed, the Government's
ongoing investigation of uncharged individuals; (iii) would risk
prejudicial pretrial publicity if publicly disseminated, and
(iv) is not authorized to be disclosed to the public or
disclosed beyond that which is necessary for the defense of this
action, and other materials pursuant to Federal Rule of Criminal
Procedure 16 ("Rule 16") and pursuant to any other disclosure
obligations (collectively, the "Discovery"), which contain
sensitive, confidential, or personal identifying information;
WHEREAS, the Government seeks to protect sensitive,
confidential, or personal identifying information contained in
the materials it produces consistent with Rule 16 or other
disclosure obligations;
1
EFTA00028425

=== Page 2 ===
WHEREAS the defendant, through his counsel, consents
to the entry of this Order;
IT HEREBY IS ORDERED:
1.
The Discovery disclosed to the defendant
("Defendant") and/or to the defendant's attorneys ("Defense
Counsel") during the course of proceedings in this action:
a)
Shall be used by the defendant or his
counsel solely for purposes of the defense of this action;
b)
Shall not be copied or otherwise recorded or
transmitted by the defendant;
c)
Shall not be disclosed or distributed in any
form by the defendant or his counsel except as set forth in
paragraph 2 (d) below;
d)
May be disclosed only by Defense Counsel and
only to the following persons ("Designated Persons") :
i. investigative, secretarial, clerical,
or paralegal personnel employed full-time or part-time by the
defendant's counsel ("Defense Staff") ;
ii. any expert, advisor, or any other
individual retained or employed by the Defendant and Defense
Counsel for the purpose of assisting in the defense of this case
("Defense Experts/Advisors") ;
iii. such other persons as hereafter may be
authorized by Order of the Court ("Other Authorized Persons") ;
2
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=== Page 3 ===
e)
May be shown to, but not disseminated to or
provided copies of to, prospective witnesses and their counsel
(collectively, "Potential Witnesses"), to the extent deemed
necessary by defense counsel, for trial preparation.
2.
To the extent the Discovery is disclosed to
Defense Staff, Defense Experts/Advisors, Other Authorized
Persons, or Potential Witnesses, Defense Counsel shall instruct
such individual (s) of the terms of this Order and that such
individual (s) are bound by this Order. To the extent that
Discovery is disseminated to Defense Staff, Defense
Experts/Advisors, or Other Authorized Persons, Defense Counsel
shall encrypt and/or password protect the Discovery. The
provisions of this paragraph do not apply to communications
exclusively between and among Defense Counsel.
3.
The Government, the Defendant, Defense Counsel,
Defense Staff, Defense Experts/Advisors, Potential Witnesses,
and Other Authorized Persons are prohibited from posting or
causing to be posted any of the Discovery or information
contained in the Discovery on the Internet, including any social
media website.
4.
The Government (other than in the discharge of
their professional obligations in this matter), Defense Counsel,
Defense Staff, Defense Experts/Advisors, Potential Witnesses,
and Other Authorized Persons are precluded from publicly
3
EFTA00028427

=== Page 4 ===
disclosing or disseminating the identity of any victims or
witnesses referenced in the Discovery. This Order does not
prohibit Defense Counsel from publicly referencing individuals
who have spoken on the public record in litigation - criminal or
otherwise - relating to Jeffrey Epstein.
5.
The Defendant, Defense Counsel, Defense Staff,
Defense Experts/Advisors, Potential Witnesses, and Other
Authorized Persons are prohibited from filing publicly as an
attachment to a filing or excerpted within a filing any of the
Discovery or information contained in the Discovery, unless
authorized by the Government in writing or by Order of the
Court. Any filings that incorporate the Discovery by
attachment, contain any excerpts of Discovery, or incorporate
Discovery by reference must be filed under seal. Nothing in
this Order precludes Defense Counsel from using the Discovery in
judicial proceedings in this case.
6.
Copies of Discovery or other materials produced
by the Government in this action bearing "confidential" stamps
or otherwise designated as "confidential" and/or electronic
Discovery materials designated as "confidential" by the
Government, including such materials marked as "confidential"
either on the documents or materials themselves, or designated
as "confidential" in a cover letter, index, folder title, or
4
EFTA00028428

=== Page 5 ===
other identifying designation, are deemed "Confidential
Information. "
7.
Confidential Information may contain personal
identification information of specific individuals who are not
parties to this action, and other confidential information; as
well as information that identifies, or could lead to the
identification of, witnesses in this matter. The Government's
designation of material as Confidential Information will be
controlling absent contrary order of the Court.
8.
Confidential Information disclosed to the
defendant, or Defense Counsel, respectively, during the course
of proceedings in this action:
a)
Shall be used by the defendant or his
counsel only for purposes of the defense of this action;
b)
Shall be maintained in a safe and secure
manner solely by Defense Counsel;
c)
Shall be reviewed by the Defendant solely in
the presence of Defense Counsel;
d)
Shall not be possessed outside the presence
of Defense Counsel, or maintained, by the Defendant;
e)
May be disclosed only by Defense Counsel and
only to Designated Persons;
f)
May be shown to, but not disseminated to or
provided copies of to, Potential Witnesses, to the extent deemed
5
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=== Page 6 ===
necessary by defense counsel, for trial preparation, and after
defense counsel and/or Defense Staff instructs such
individual (s) of the terms of this Order and that such
individual (s) are bound by this Order.
9.
Copies of Discovery or other materials produced
by the Government in this action bearing "highly confidential"
stamps or otherwise designated as "highly confidential" and/or
electronic Discovery materials designated as "highly
confidential" by the Government, including such materials marked
as "highly confidential" either on the documents or materials
themselves, or designated as "highly confidential" in a cover
letter, index, folder title, or other identifying designation,
are deemed "Highly Confidential Information."
10. Highly Confidential Information contains images
of nude or partially-nude individuals. The Government's
designation of material as Highly Confidential Information will
be controlling absent contrary order of the Court. Highly
Confidential Information disclosed to Defense Counsel during the
course of proceedings in this action:
a)
Shall not be disseminated, transmitted, or
otherwise copied and provided to Defense Counsel or the
Defendant;
b)
Shall be reviewed by the Defendant solely in
the presence of Defense Counsel;
6
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=== Page 7 ===
c)
Shall not be possessed outside the presence
of Defense Counsel, or maintained, by the Defendant;
d)
Shall be made available for inspection by
Defense Counsel and the Defendant, under the protection of law
enforcement officers or employees; and
e)
Shall not be copied or otherwise duplicated
by Defense Counsel or the Defendant during such inspections.
11. The Defendant and Defense Counsel shall provide a
copy of this Order to Designated Persons to whom they disclose
Confidential Information or Highly Confidential Information.
Prior to disclosure of such information to Designated Persons,
any such Designated Person shall agree to be subject to the
terms of this Order by signing a copy hereof and stating that
they "Agree to be bound by the terms herein," and providing such
copy to the defendant's counsel. However, the defendant and his
or her respective counsel need not obtain signatures from any
member of the defense team (i.e., attorneys, experts,
consultants, paralegals, investigators, support personnel, and
secretarial staff involved in the representation of the
defendants in this case), all of whom are nonetheless bound by
this Protective Order.
12. Except for Discovery that has been made part of
the record of this case, Defense Counsel shall return to the
Government or securely destroy or delete all Discovery,
7
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=== Page 8 ===
including but not limited to Confidential Information, within 30
days of the expiration of the period for direct appeal from any
verdict in the above-captioned case; the period of direct appeal
from any order dismissing any of the charges in the above-
captioned case; the expiration of the period for a petition
pursuant to 28 U.S.C. $ 2255; or the granting of any motion made
on behalf of the Government dismissing any charges in the above-
captioned case, whichever date is later.
8
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=== Page 9 ===
13. The foregoing provisions shall remain in effect
unless and until either (a) the Government and Defense Counsel
mutually agree otherwise, or (b) this Order is modified by
further order of the Court.
SO ORDERED:
Dated:
New York, New York
, 2019
HONORABLE RICHARD M. BERMAN
United States District Judge
AGREED AND CONSENTED TO:
Dated: July 24, 2019
New York, New York
GEOFFREY S. BERMAN
United States Attorney
Southern District of New York
By:
/s/
Assistant United States Attorneys
Dated:
, 2019
New York, New York
JEFFREY EPSTEIN
By:
Martin Weinberg, Esq.
Reid Weingarten, Esq.
Counsel for Jeffrey Epstein
9
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=== Page 1 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 1 of 17 PageID 1
CLERK US DISTRICT COURT
NORTHERN DIST. OF TX
FILED
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS 2014MAR 12 PM 45
ABILENE DIVISION
DEPUTY CLERK Lo
UNITED STATES OF AMERICA
V.
No. -14CR- 018-c
FREDERICK HERNANDEZ (1)
JOEY ROSAS
(2)
CHRISTOPHER MOORE (3)
INDICTMENT
The Grand Jury Charges:
INTRODUCTION
At all times pertinent to this Indictment:
1.
The Big Spring Correctional Center (BSCC) is a correctional facility under
contract with the GEO Group, Inc., under the jurisdiction of an agency of the United States,
the United States Department of Justice, in which persons are held in custody by direction
of and pursuant to a contract with the head of a Federal agency, the United States
Department of Justice.
2.
The BSCC consists of four correctional units, including the Flight Line
Unit, managed under contract by the GEO Group, Inc., under the jurisdiction of an agency
of the United States, the Bureau of Prisons (BOP).
3.
The Flight Line Unit at the BSCC provides contract housing services for
approximately 1,500 federal inmates. The Flight Line Unit is equipped with a Special
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 1
EFTA00027136

=== Page 2 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 2 of 17 PageID 2
Housing Unit (SHU) for inmates requiring special supervision. The SHU consists of four
cell block ranges: the 500, 600, 700 and 800 ranges, totaling 130 double occupancy
individual inmate cells.
4.
Correctional Officers assigned to the Flight Line Unit SHU are required to
conduct and document random (irregular) 30-minute checks of each inmate cell.
5.
Correctional Officers assigned to the Flight Line Unit SHU are also required
to conduct and document formal counts of inmates, said counts conducted at specific times
of the day, evening and morning watches. There are six formal counts during each
24-hour period: 12:01 a.m., 3:00 a.m., 5:00 a.m., 10:00 a.m., 4:00 p.m. and 10:00 p.m.
The 4:00 p.m. count is a mandatory stand-up count.
6.
On or about August 22, 2012, and continuing to on or about August 23, 2012,
defendants Frederick Hernandez (Hernandez), Joe Rosas (Rosas), and Christopher
Moore (Moore) were Correctional Officers assigned to the Flight Line Unit SHU from
8:00 p.m., on August 22, 2012, until 8:00 a.m., on August 23, 2012. Hernandez was the
supervising officer overseeing the Flight Line Unit SHU for this Shift (hereinafter referred
to as the August 22 - August 23 Shift).
7.
Hernandez, Rosas and Moore were responsible for conducting the
30-minute checks and formal counts of inmates in the Flight Line Unit SHU, 500, 600, 700
and 800 ranges, during the August 22 - August 23 Shift.
8.
During the August 22 - August 23 Shift, BOP inmate Luis Bent was confined
to cell number 502, Range 500, in the Flight Line Unit SHU.
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 2
EFTA00027137

=== Page 3 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 3 of 17 PageID 3
Count One
False Statements and Aiding and Abetting
(Violation of 18 U.S.C. §§ 1001 and 2)
1.
The Grand Jury realleges all of the allegations contained in the Introduction
of this indictment.
2.
Beginning on or about August 22, 2012, and continuing to on or about
August 23, 2012, in the Abilene Division of the Northern District of Texas, in a matter
within the jurisdiction of an agency of the United States, the United States Department of
Justice, defendants Frederick Hernandez (Hernandez), Joey Rosas (Rosas), and
Christopher Moore (Moore), each being a being public official, that is, a Correctional
Officer, assigned to the Flight Line Unit in the Special Housing Unit (SHU) at the Big
Spring Correctional Center (BSCC), a correctional facility under contract with the GEO
Group, Inc., under the jurisdiction of an agency of the United States, the United States
Department of Justice, did knowingly and willfully make, and cause to be made, false,
fictitious, and fraudulent statements and representations to the Department of Justice as to
material facts, by signing and submitting to the Department of Justice, as required by law,
the "GEO FLIGHTLINE 12 HOUR SHIFT, 30 MINUTE ROUNDS, 600/700 RANGE"
Form, for the time period 8:00 p.m. to 8:00 a.m., wherein Hernandez, Rosas, and Moore,
each certified by placing his initials on the Form that it was true and correct, and that the 30
MINUTE ROUNDS reflected therein had been performed, when in truth and in fact, as
Hernandez, Rosas, and Moore, then and there well knew, the Form was not correct and
was false in that Hernandez, Rosas, and Moore, had not conducted the 30 MINUTE
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 3
EFTA00027138

=== Page 4 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 4 of 17 PageID 4
ROUNDS.
A violation of Title 18, United States Code, Sections 1001 and 2.
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 4
EFTA00027139

=== Page 5 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 5 of 17 PageID 5
Count Two
False Statements and Aiding and Abetting
(Violation of Title 18 U.S.C. §§ 1001 and 2)
1.
The Grand Jury realleges all of the allegations contained in the Introduction
of this indictment.
2.
Beginning on or about August 22, 2012, and continuing to on or about
August 23, 2012, in the Abilene Division of the Northern District of Texas, in a matter
within the jurisdiction of an agency of the United States, the United States Department of
Justice, defendants Frederick Hernandez (Hernandez) and Joey Rosas (Rosas), each
being a being public official, that is, a Correctional Officer, assigned to the Flight Line Unit
in the Special Housing Unit (SHU) at the Big Spring Correctional Center (BSCC), a
correctional facility under contract with the GEO Group, Inc., under the jurisdiction of an
agency of the United States, the United States Department of Justice, did knowingly and
willfully make, and cause to be made, false, fictitious, and fraudulent statements and
representations to the Department of Justice as to material facts, by signing and submitting
to the Department of Justice, as required by law, the "GEO FLIGHTLINE 12 HOUR
SHIFT, 30 MINUTE ROUNDS, 600/700 RANGE" Form, for the time period 8:01 p.m. to
12:20 a.m., wherein Hernandez and Rosas each certified by placing his initials on the
Form that it was true and correct, and that the 30 MINUTE ROUNDS reflected therein had
been performed, when in truth and in fact, as Hernandez and Rosas then and there well
knew, the Form was not correct and was false in that Hernandez and Rosas had not
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 5
EFTA00027140

=== Page 6 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 6 of 17 PageID 6
conducted the 30 MINUTE ROUNDS.
A violation of Title 18, United States Code, Sections 1001 and 2.
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 6
EFTA00027141

=== Page 7 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 7 of 17 PageID 7
Count Three
False Statements and Aiding and Abetting
(Violation of Title 18 U.S.C. §§ 1001 and 2)
1.
The Grand Jury realleges all of the allegations contained in the Introduction
of this indictment.
2.
Beginning on or about August 22, 2012, and continuing to on or about
August 23, 2012, in the Abilene Division of the Northern District of Texas, in a matter
within the jurisdiction of an agency of the United States, the United States Department of
Justice, defendants Frederick Hernandez (Hernandez) and Christopher Moore
(Moore), each being a being public official, that is, a Correctional Officer, assigned to the
Flight Line Unit in the Special Housing Unit (SHU) at the Big Spring Correctional Center
(BSCC), a correctional facility under contract with the GEO Group, Inc., under the
jurisdiction of an agency of the United States, the United States Department of Justice, did
knowingly and willfully make, and cause to be made, false, fictitious, and fraudulent
statements and representations to the Department of Justice as to material facts, by signing
and submitting to the Department of Justice, as required by law, the "GEO FLIGHTLINE
12 HOUR SHIFT, 30 MINUTE ROUNDS, 600/700 RANGE" Form, for the time period
12:37 a.m. to 4:55 a.m., wherein Hernandez and Moore each certified by placing his
initials on the Form that it was true and correct, and that the 30 MINUTE ROUNDS
reflected therein had been performed, when in truth and in fact, as Hernandez and Moore
then and there well knew, the Form was not correct and was false in that Hernandez and
Moore had not conducted the 30 MINUTE ROUNDS.
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 7
EFTA00027142

=== Page 8 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 8 of 17 PageID 8
A violation of Title 18, United States Code, Sections 1001 and 2.
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 8
EFTA00027143

=== Page 9 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 9 of 17 PageID 9
Count Four
False Statements and Aiding and Abetting
(Violation of Title 18 U.S.C. §§ 1001 and 2)
1.
The Grand Jury realleges all of the allegations contained in the Introduction
of this indictment.
2.
Beginning on or about August 22, 2012, and continuing to on or about
August 23, 2012, in the Abilene Division of the Northern District of Texas, in a matter
within the jurisdiction of an agency of the United States, the United States Department of
Justice, defendant Frederick Hernandez (Hernandez), being a being public official, that
is, a Correctional Officer, and during the time period, being the Senior Shift
Officer-in-Charge, assigned to the Flight Line Unit in the Special Housing Unit (SHU) at
the Big Spring Correctional Center (BSCC), a correctional facility under contract with the
GEO Group, Inc., under the jurisdiction of an agency of the United States, the United
States Department of Justice, did knowingly and willfully make, and cause to be made,
false, fictitious, and fraudulent statements and representations to the Department of Justice
as to material facts, by signing and submitting to the Department of Justice, as required by
law, the "GEO GROUP, INC., OFFICIAL COUNT SLIP" Form, for the formal count of
inmates at 12:01 a.m., wherein Hernandez certified by placing his initials on the Form that
it was true and correct, and that the formal count of inmates reflected therein had been
performed, when in truth and in fact, as Hernandez then and there well knew, the Form
was not correct and was false in that Hernandez had not conducted the formal count of
inmates.
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 9
EFTA00027144

=== Page 10 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 10 of 17 PageID 10
A violation of Title 18, United States Code, Sections 1001 and 2.
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 10
EFTA00027145

=== Page 11 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 11 of 17 PageID 11
Count Five
False Statements and Aiding and Abetting
(Violation of Title 18 U.S.C. §§ 1001 and 2)
1.
The Grand Jury realleges all of the allegations contained in the Introduction
of this indictment.
2.
Beginning on or about August 22, 2012, and continuing to on or about
August 23, 2012, in the Abilene Division of the Northern District of Texas, in a matter
within the jurisdiction of an agency of the United States, the United States Department of
Justice, defendant Frederick Hernandez (Hernandez), being a being public official, that
is, a Correctional Officer, and during the time period, being the Senior Shift
Officer-in-Charge, assigned to the Flight Line Unit in the Special Housing Unit (SHU) at
the Big Spring Correctional Center (BSCC), a correctional facility under contract with the
GEO Group, Inc., under the jurisdiction of an agency of the United States, the United
States Department of Justice, did knowingly and willfully make, and cause to be made,
false, fictitious, and fraudulent statements and representations to the Department of Justice
as to material facts, by signing and submitting to the Department of Justice, as required by
law, the "GEO GROUP, INC., OFFICIAL COUNT SLIP" Form, for the formal count of
inmates at 3:00 a.m., wherein Hernandez certified by placing his initials on the Form that
it was true and correct, and that the formal count of inmates reflected therein had been
performed, when in truth and in fact, as Hernandez then and there well knew, the Form
was not correct and was false in that Hernandez had not conducted the formal count of
inmates.
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 11
EFTA00027146

=== Page 12 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 12 of 17 PageID 12
A violation of Title 18, United States Code, Sections 1001 and 2.
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 12
EFTA00027147

=== Page 13 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 13 of 17 PageID 13
Count Six
False Statements and Aiding and Abetting
(Violation of Title 18 U.S.C. §§ 1001 and 2)
1.
The Grand Jury realleges all of the allegations contained in the Introduction
of this indictment.
2.
Beginning on or about August 22, 2012, and continuing to on or about
August 23, 2012, in the Abilene Division of the Northern District of Texas, in a matter
within the jurisdiction of an agency of the United States, the United States Department of
Justice, defendant Frederick Hernandez (Hernandez), being a being public official, that
is, a Correctional Officer, and during the time period, being the Senior Shift
Officer-in-Charge, assigned to the Flight Line Unit in the Special Housing Unit (SHU) at
the Big Spring Correctional Center (BSCC), a correctional facility under contract with the
GEO Group, Inc., under the jurisdiction of an agency of the United States, the United
States Department of Justice, did knowingly and willfully make, and cause to be made,
false, fictitious, and fraudulent statements and representations to the Department of Justice
as to material facts, by signing and submitting to the Department of Justice, as required by
law, the "GEO GROUP, INC., OFFICIAL COUNT SLIP" Form, for the formal count of
inmates at 5:00 a.m., wherein Hernandez certified by placing his initials on the Form that
it was true and correct, and that the formal count of inmates reflected therein had been
performed, when in truth and in fact, as Hernandez then and there well knew, the Form
was not correct and was false in that Hernandez had not conducted the formal count of
inmates.
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 13
EFTA00027148

=== Page 14 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 14 of 17 PageID 14
A violation of Title 18, United States Code, Sections 1001 and 2.
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 14
EFTA00027149

=== Page 15 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 15 of 17 PageID 15
Count Seven
False Statements and Aiding and Abetting
(Violation of Title 18 U.S.C. §§ 1001 and 2)
1.
The Grand Jury realleges all of the allegations contained in the Introduction
of this indictment.
2.
Beginning on or about August 22, 2012, and continuing to on or about
August 23, 2012, in the Abilene Division of the Northern District of Texas, in a matter
within the jurisdiction of an agency of the United States, the United States Department of
Justice, defendant Frederick Hernandez (Hernandez), being a being public official, that
is, a Correctional Officer, and during the time period, being the Senior Shift
Officer-in-Charge, assigned to the Flight Line Unit in the Special Housing Unit (SHU) at
the Big Spring Correctional Center (BSCC), a correctional facility under contract with the
GEO Group, Inc., under the jurisdiction of an agency of the United States, the United
States Department of Justice, did knowingly and willfully make, and cause to be made,
false, fictitious, and fraudulent statements and representations to the Department of Justice
as to material facts, by signing and submitting to the Department of Justice, as required by
law, the "SHU Control Log" Form, for the time period 12:01 a.m. to 5:10 a.m., wherein
Hernandez certified by placing his initials on the Log that it was true and correct, and that
the SHU Control Log reflected therein that the formal counts of inmates had been
performed, when in truth and in fact, as Hernandez then and there well knew, the Log was
not correct and was false in that Hernandez had not conducted the formal counts of
inmates.
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 15
EFTA00027150

=== Page 16 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 16 of 17 PageID 16
A violation of Title 18, United States Code, Sections 1001 and 2.
A TRUE BILL
Saice Was
FOREPERSON
SARAH R. SALDAÑA
UNITED STATES ATTORNEY
PAULINA
Assistant
Texas State Bar No. 10516700
1205 Texas Avenue, Suite 700
Lubbock, Texas 79401
Telephone: 806-472-7351
Facsimile: 806-472-7394
Email:
paulina.jacobo@usdoj.gov
Indictment (Frederick Hernandez, Joey Rosas, and Christopher Moore) - Page 16
EFTA00027151

=== Page 17 ===
Case 1:14-cr-00018-O-BL Document 1 Filed 03/12/14 Page 17 of 17 PageID 17
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF TEXAS
ABILENE DIVISION
THE UNITED STATES OF AMERICA
V.
FREDERICK HERNANDEZ (1)
JOEY ROSAS (2)
CHRISTOPHER MOORE (3)
INDICTMENT
18 U.S.C. §§ 1001 and 2
False Statements and Aiding and Abetting
(7 COUNTS)
A Lubbock true bill rendered: Hill Think
Foreperson
Filed in open court this
12th day of March, A.D. 2014.
Clerk
WARRANT TO ISSUE AS TO EACH DEFENDANT
UNITED STATES MAGISTRATE JUDGE
EFTA00027152


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Subject: 10/1/2020 Call with Special Agent
Date: Thu, 01 Oct 2020 21:35:33 +0000
10/1/2020 Call with Special Agent
provided background, explaining that we are producing discovery in the Maxwell case. As part of that
process, we are trying to be as thorough as possible in gathering materials about this case in order to comply with
discovery obligations; taking a very broad approach to discovery; previously gathered boxes from Florida case.
explained that we wanted to reach out to make sure we have everything. Want to gather copies of what
everyone has, even if duplicative if what is already in the files
: originally
who investigated case and
joined later on?
estimated joining in approximately 2006 or 2007; he came down to Miami from Louisville in 2006 and started
working on the case not too long after that
asked if
has materials relating to Epstein investigation
said he would have to go through his computer to check
explained that we have access to Sentinel; looking for things
may have saved to his computer, things in box
or red weld, or anything on his phone, hard copy notes
said he thought most of what he has would already be in the file but can look back through computer and old
boxes
said that even if
found stuff that he thinks we already have, we will take a copy just to be cautious;
said he thought he gave us everything last time we were in Florida (binders with victim information); said will
do whatever we need to support us
asked if there was anything that we should know about from
participation in the investigation (whether
helpful or harmful or exculpatory)
said not that he could think of, but it's been 12 years; will think back; had good interview with
on
Ghislaine; as far as anything exculpatory, not that he's aware of, but will look back; have some old boxes from
Palm Beach, will go through it
asked
to hold onto materials as he gathered them and we will discuss; plan to talk next Friday at 12
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00028044


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=== Page 1 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare:
My name is PATRICK M. Kessel
(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 March 26, 2021, 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 5/12/21
(date)
Parth (signature of declarant)
Kenel
PATRICK M. Kessel - UPof FiNANCE Operations
(name and title of declarant)
InterLochen Center for the ARTS
(name of business)
4000 J MADDY PARKWAY INTERLOCHEN MI 49643
(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.
EFTA00029341


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=== Page 1 ===
From:
To:
Cc:
Subject:
Date: Fri, 29 Jan 2021 20:17:24 +0000
Attachments:
-29.pdf
Attached is a letter with our thoughts on an appropriate disposition for
We are available to discuss.
EFTA00028160


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=== Page 1 ===
From:
To:
Subject: FW: Indexes
Date: Mon, 20 May 2019 18:26:59 +0000
Importance: Normal
Attachments: Copy of Sentinel Reportof_1A-1C-Report-1.xlsx; SENTINEL_Evidence_Report-
20190517-1832.xlsx; SENTINEL_Serial-Report-4.xlsx
Will put on the share.
Original Message
From:
Sent: Monday, May 20, 2019 2:26 PM
To:
Subject: Indexes
Hi
asked that I send these to you. Let me know if you have questions.
Thanks,
Special Agent
FBI New York
VCAC/Human Trafficking
EFTA00027764


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
(USANYS)"
Subject: RE: 20cr330, US V. Maxwell
Date: Fri, 12 Nov 2021 16:28:41 +0000
Attachments: 20cr330_Order_11.11.21.pdf
Counsel,
To implement this order, we propose docketing the various motions in limine the same way we did last time. Assuming
you agree, we'll begin by filing our opening brief.
Thanks,
From: Nathan NYSD Chambers
Sent: Thursday, November 11, 2021 9:55 PM
To:
(USANYS)
Subject: 20cr330, US V. Maxwell
Counsel:
Attached please find an order issued by Judge Nathan, which will be filed on the docket tomorrow morning.
Sincerely,
Chambers of the Hon. Alison J. Nathan
EFTA00028277


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=== Page 1 ===
From:
Jeffrey Epstein
To:
Staley, Jes
Sent:
3/6/2011 12:44:18 AM
Subject:
Re:
no,, english papers have gone berserk,, claiming fbi re opening investigation. not true,, publishinga phonebook
that is not mine, butwas stolen by my houseman cuurently in prison for doing so
On Sat, Mar 5, 2011 at 4:43 PM, Staley, Jes
wrote:
The post?
From: Jeffrey Epstein
To: Staley, Jes
Sent: Sat Mar 05 19:41:53 2011
Subject:
more bad press. ignore it
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to
and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
This email is confidential and subject to important disclaimers and conditions including on offers for the purchase
or sale of securities, accuracy and completeness of information, viruses, confidentiality, legal privilege, and legal
entity disclaimers, available at http://www.jpmorgan.com/pages/disclosures/emalil
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
Confidential Treatment Requested by JPMorgan Chase
JPM-SDNY-00001504
EFTA00029437

=== Page 2 ===
communication in error, please notify us immediately by
return e-mail or by e-mail to
, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
Confidential Treatment Requested by JPMorgan Chase
JPM-SDNY-00001505
EFTA00029438


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=== Page 1 ===
THE STATE OF FLORIDA,
)
COUNTY OF PALM BEACH.
)
IN RE:
PALM BEACH INVESTIGATION.
/
SWORN STATEMENT OF
Monday, November 21, 2005
12:25 p.m. - 1:05 p.m.
401 N. Dixie Highway
West Palm Beach, Florida 33401
ORIGINAL
Reported By:
Susan Shelling, RPR
Notary Public, State of Florida
Consor & Associates Reporting and Transcription
Phone - 561.835.9738
J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
NON PARTY (VR) 000529
DEPOSITION
PENGAD 800-631 800-631-6989
EXHIBIT
/
6/1/16 HAW
EFTA00029390

=== Page 2 ===
Page 2
1
APPEARANCES:
2
On behalf of the State:
DALIAH H. WEISS, Esquire
3
ASSISTANT STATE ATTORNEY
401 North Dixie Highway
4
West Palm Beach, Florida 33401
561.355.7100
5
On behalf of the Witness:
6
DONNIE MURRELL, Esquire
L.D. MURRELL, P.A.
7
400 Executive Center Drive
Suite 201
8
West Palm Beach, Florida 33409
561.686.2700
9
10
ALSO PRESENT:
11
DETECTIVE
Palm Beach Police Department
12
13
14
15
16
17
18
19
20
21
22
23
24
25
J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
NON PARTY (VR) 000530
EFTA00029391

=== Page 3 ===
Page 3
1
INDEX
2 WITNESS:
PAGE:
3
EXAMINATION BY DET.
4
4
- - -
5
NO EXHIBITS MARKED
6
- - -
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
NON PARTY (VR) 000531
EFTA00029392

=== Page 4 ===
Page 4
1
Sworn statement taken before Susan
2
Shelling, Registered Professional Reporter and Notary
3
Public in and for the State of Florida at Large, in the
4
above cause.
5
-
6
Thereupon,
7
8
having been first duly sworn or affirmed, was examined
9
and stated as follows:
10
MR. MURRELL: I just want to repeat that
11
we're here under the State investigative subpoena
12
that was served on Mr.
although it was
13
dated for, I believe, Wednesday or something.
14
This is Monday the 21st, and we are here by
15
agreement.
16
EXAMINATION
17
BY DET.
:
18
Q.
Mr.
I'm Detective
with
19
the Palm Beach P.D. As I explained to you on the
20
telephone, I am conducting an investigation on a former
21
employer of yours
22
I just spoke with your wife and she told me
23
you guys worked for Mr. Epstein for eight years?
24
A.
Yes, she did work for eight years. I
25
worked longer. I was there before my wife came.
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1
Q.
Before your wife came.
2
A.
I started full-time with him on January 1,
3
1991, and we both left December 31, 2002. So I worked
4
eleven years exactly. Prior to that, prior to working
5
full-time for him, I worked part-time for him, on-and-off
6
basis.
7
Q.
What were your responsibilities?
8
A.
In the full-time basis, I started as a
9
houseman, and I became a major domo and butler and
10
everything else, driver, and did everything. We both did
11
all the chores in the house, but I was in charge of the
12
house. I was above my wife and above the cleaning crew,
13
the gardners, pool people. So I was house manager, major
14
domo.
15
Q.
You would have been the go-to guy for the
16
house?
17
A.
Yes. And the one who would get the blame.
18
Q.
We are talking about Jeffrey Epstein?
19
A.
Of course.
20
Q.
Do you remember the address of the house?
21
A.
558 El Brillo
22
Q.
Was it in the beginning of the street --
23
A.
At the end of the street, on the left-hand
24
side.
25
Q.
We're talking about the same house.
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1
A.
Yeah.
2
Q.
Your wife said the same number you did.
3
A.
558?
358?
558?
4
Q.
It was 358.
5
A.
We left three years ago.
6
Q.
And I understand it's been some time since
7
then. So the questions I'm going to ask you basically
8
is: During your time, did you deal directly with
9
Mr. Epstein?
10
A.
Yes. And her -- and her -- girlfriend,
11
manager. She was the manager of all the households,
12
because he has homes all over the world.
13
Q.
Right.
14
A.
So we have -- she was my boss, and I deal
15
directly with her.
16
Q.
Who was --
17
A.
Elaine Maxwell.
18
&
Ms. Maxwell, that's his girlfriend,
19
correct?
20
A.
Um-hum.
21
a
During the eleven years, he would come
22
down, she would inform you that they were coming down?
23
A.
Right.
24
Q.
Make arrangements to have the house ready?
25
A.
Right.
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1
Q.
During the time that he was here, you
2
prepared the house, did all the chores.
3
Did you do any of the cleaning?
4
A.
Sometimes. Many times. I did -- last two
5
or three years the work was so much that we have to
6
hire -- we hire a clean-up crew that they came twice a
7
week or once a week, then it was twice a week. Depends
8
upon his schedule, because he did not allow anybody at
9
the house except us when he was in town. So when he was
10
in town, it was just us doing the cleaning and the
11
cooking, the driving, shopping, everything else.
12
Q.
Did you stay on property in the guest
13
house?
14
A.
Yes and no. We had an apartment right
15
across the bridge. We had an apartment in
16
and we had an apartment at the house.
17
a
Why would you stay at the house, then?
18
A.
We stay at the house mostly when he was
19
there. When he was not in town, we went home. We went
20
to our apartment. When he was there, it was -- the job
21
was just too much to go home 9 o'clock, 10 o'clock and
22
come back 5 o'clock in the morning. We would just stay
23
and sleep and get up and work.
24
Q.
When he was in town, did he receive a lot
25
of guests at the house?
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1
A.
Yes. Many, many, many guests. It was
2
never with no guests.
3
Q.
Did he have assistants with him?
4
A.
Assistants? At the last year he had an
5
assistant just for him. They would travel with him all
6
the time. At the last -- in the last two years of my
7
stay there, he also have a chef, a gourmet chef that he
8
would travel with him. That's it.
9
Q.
Do you remember the chef's name?
10
A.
There were quite a few. The last one I
11
know is
I think. And he was from
12
New York.
13
And there was another French chef,
14
(phonetic); I don't know his last name.
15
And there was another English chef. But
16
they went quickly.
17
Q.
They would come and go, come and go.
18
What about the assistant that was his
19
personal assistant that would fly with him?
20
A.
It was an English girl that
21
would travel with him a lot, and became the personal
22
assistant. But most of the time it was Ms. Maxwell that
23
traveled with him all the time.
24
Q.
She was basically like his --
25
A.
Girlfriend, whatever it was. Boss,
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girlfriend. She was our immediate superior.
2
Q.
Did he have girls come over to give
3 massages?
4
A.
Yes.
5
Q.
How many massages would he have in a day?
6
A.
Sometimes one, sometimes two, three.
7
Q.
Was it the same girl that would come back
8
to do the massages?
9
A.
Yeah, yeah. Not the same girl -- I mean
10
during eleven years, I probably saw a hundred, two
11
hundred different massage therapists.
12
Q.
Did they seem young to you?
13
A.
No, sir. Mostly no. We saw one or two
14
young ones in the last year. Before that, it was all
15 adults.
16
Q.
During your last year when you were working
17
with him, what do you mean that they looked young? Did
18
they look like they were still in high school?
19
A.
I remember one girl was young. We never
20
asked how old she was. It was not in my job.
21
d
Right T understand
22
A.
But I imagine she was 16, 17. In my
23
judgment, she was 16, 17.
24
2.
Where would these massages take place?
25
A.
All the time it was in his room. Sometimes
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it was in the balcony of his quarters. His room has a
2
wraparound balcony facing the pool. So the massages were
3
in the balcony outside in the sun, or inside in his
4
bathroom or her bathroom.
5
a
Would you set up the room for the massages?
6
A.
Many times. Yes, he will tell me, Set up
7
the room inside my bathroom or in the bedroom or in
8
Elaine's bathroom, or outside on the balcony. And I
9
would go and set up or my wife would go and set up the
10 table.
11
We had a table in every room of the house,
12
the massage tables, for the different guests. Because
13
not only he got massages, all the other guests got
14
massages too. So we have a table -- massage table in
15
basically every room, guest room.
16
Q.
The girls that would come over to do
17
massages, they would massage him first or massage guests?
18
A.
Different times. There were -- mostly they
19
was his massage. Mostly he would get massages.
20
Q.
Would Ms. Maxwell be in the room with him
21
while he was getting the massage?
22
A.
We don't know. Apparently we saw her going
23
upstairs, because it was -- when they went upstairs, they
24
closed -- his quarters, it had a double door, so it was a
25
door on top of the stairs -- I don't know if you've been
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in the house -- and then there's another door going into
2
his room. So it was a long corridor. So everything was
3
closed and nobody saw anything.
4
Q.
Would you clean up after?
5
A.
Once in a while, yes, I did. Most of the
6
times I did. I did the cleanup.
7
Q.
Did it appear as if there was going to be
8
more than one massage going on in the room?
9
A.
More than one massage? I don't know. It
10
was massages. There was massages, because it was a hot
11
oil, and it was -- you know this vibrator, the neck
12
vibrators with the long handles. And towels, a lot of
13
towels. We used a lot of towels in the house. Used like
14
maybe 40, 50 towels a day, because every time he go in
15
into the pool, it was two or three towels. Everything
16
had to be cleaned up. I went most of the time to pick up
17
the room and get it ready.
18
Q.
Did it ever appear to you that more went on
19
in the room other than a massage?
20
A.
I just imagine. I never saw anything. But
21
I imagine there was more than I never saw anything
22
because it was closed doors. It was never done outside.
23
Q.
Based on the cleanup?
24
A.
Based on the cleanup -- at the end, I
25
cannot say there was. At the end, it was a few times
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that the bed was undone. You know, we make the beds
2
three or four times a day. And sometimes we went to
3
clean up the massage to put it back, the massage table,
4
to pick up the towels, but the bed was undone again. So
5
either he took a nap or he went for a nap, I don't know.
6
Q.
Or something else occurred?
7
A.
Or something else. I cannot.
8
a
Did the girls, would they bring their own
9
stuff or they would use his stuff?
10
A.
No. We had everything. We had gallons of
11
stuff, different stuff.
12
Q.
Different massage oils?
13
A.
Different, all kinds.
14
Q.
Different massagers?
15
A.
Different stuff.
16
They would buy all over the world different
17
types of -- for different --
18
a
Did any of these massagers look like sex
19
toys?
20
A.
At the end, at the last year that we were
21
there they had like sex toys, some of them. I can say
22
maybe three or four occasions that I saw in the sink,
23
they were left out on the sink, and just --
24
Q.
Where would he keep these massagers?
25
A.
When I was there, we keep all the stuff in
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a basket inside Ms. Maxwell's closet. It was a big
2
basket, about this round (indicating), with a cover on
3
it. And we used to pick up from the towel and just dump
4
it in there. That's it. That's the standard we went
5
through.
6
a
What sink would you find those massagers
7
in?
8
A.
Mostly in his sink, in his bathroom sink.
9
a
His bathroom sink?
10
Was Ms. Maxwell still his girlfriend at
11
that time?
12
A.
Oh, yeah.
13
Q.
Still his girlfriend that you know of right
14
now?
15
A.
Yeah. We left, she was still his
16
girlfriend. I don't know now, but she was still there.
17
Q.
Why did you leave at the end?
18
A.
It was a hard job. It was an incredible
19
hard job. So demanding. Hours were terrible, from
20
5 o'clock in the morning to 10 o'clock at night.
21
Constantly on your feet
22
I got very sick. My health went down the
23
drain. I was diagnosed with cancer, polycythemia, a kind
24
of blood cancer, and we had to leave. It was just too
25
much for me.
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a
Sounds like a lot.
2
A.
Yeah. For me and my wife, we both left.
3
Q.
It was very demanding when he was here in
4
town?
5
A.
It was terrible. Bad job. Pay was good,
6
but we had enough.
7
Q.
I know you guys had a falling out a couple
8
of years ago; I guess you weren't working with him
9
anymore. This would have been in 2003. You guys had a
10
falling out, remember?
11
A.
Yeah, we settled that.
12
Q.
That was settled?
13
A.
That was settled with him between us.
14
Q.
Was that --
15
A.
It was an amicable -- it was an agreement,
16
mutual agreement. It was a mistake on my part.
17
Q.
Are there any questions you have of me?
18
A.
No. I told you the truth.
19
We just imagined things that could have
20
happened. I used to talk to my wife all day, working and
21
under that environment But we didn't know for sure what
22
was going on.
23
We never heard anything. We never heard a
24
complaint, or a girl crying.
25
Q.
Would these massage girls, especially
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towards the end, would they come alone or would they come
2
with other people?
3
A.
Mostly they would come alone. It was one
4
girl, one of the young girls, the one I can't think of
5
it, she would bring somebody else. She'd bring other
6
girls. But I didn't even know the names.
7
Q.
All of them would go downstairs?
8
A.
Yes.
9
a
Or would one stay downstairs?
10
A.
Most of the times when that girl came, it
11
was at night. So after dinner -- after dinner, they went
12
to the movies. And by the time they went to the movies,
13
we clean up right away and tried to get out of there.
14
And that was about 8, 9 o'clock at night.
15
After, when they come back, I don't know
16
what happened. Our quarters were a different -- I don't
17
know if you've been in the house, but our quarters were
18
separate.
19
Q.
It's separate.
20
A.
Separate. Before -- that building is new.
21
They build the building in 2001.
22
Q.
The guest quarters?
23
A.
Yeah, the guest quarters.
24
Before, we had an apartment upstairs.
25
Q.
They have the laundry and a little office
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1
and the bedroom?
2
A.
Yes. That was 2001. Before that, we had
3
an apartment upstairs in their house, in the main house.
4
Q.
In the little rooms upstairs across from
5
his master bedroom?
6
A.
Right.
7
&.
Was there ever any photographs that you can
8
recall around the house?
9
A.
Girls, girls' photographs and guests'
10
photographs, yes.
11
Q.
Were they dressed or were they naked?
12
A.
Most of them were dressed. It was a lot of
13
entertainment in the pool, around the pool area. But
14
most of them were dressed.
15
Q.
When was the last time you spoke with
16
Mr. Epstein?
17
A.
The last time I spoke with Mr. Epstein was
18
about a week ago, when you left me the card. I got
19
scared because of that fallout that we had, and I thought
20
it was a consequence of that. And I called and says,
21
Jeffrey, what's going on, what's happening? Because I
22
thought it was an investigation against me on his part.
23
Q.
I'm sorry if I gave you that impression.
24
A.
That's why I called him. That's the only
25
reason that I called.
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1
Before I even spoke to you.
2
a
Just when you found the card?
3
A.
When I find the card, I get scared. I
4
said, What's going on now? Why are you bothering me now
5
in my house?
6
That's why I called him.
7
He said,
there is an investigation
8
going on. I have nothing to talk to you. That's it.
9
I said, Okay.
10
Q.
He didn't give you any information as to --
11
A.
No, not a word.
12
Q.
Has anybody else contacted you from
13
Mr. Epstein or his organization, his assistants, his
14
attorney?
15
A.
No, no, no.
16
a
Anyone that works for his attorney?
17
A.
For his attorney? Yes. For his attorney,
18
the present attorney? Yes. That was an investigator
19
that it was investigated on his side, I can't remember
20 his name, but I understand it was from Roy Black's
21
office. That was his attorney. And he this
22
investigator basically asked me the same questions,
23
exactly the same questions: What did I know, what did I
24 know.
25
Q.
When did this happen?
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1
A.
This happened about ten days ago -- about a
2
week ago, ten days ago. I'm not sure what date.
3
a
Was his investigator's name --
4
A.
It's the date after I contacted you.
5
Q.
-- Paul, first name Paul?
6
A.
Paul, Paul, yes.
7
You have the last name?
8
Q.
No.
9
A.
He asked me exactly the same questions.
10
Q.
Did he offer you any money?
11
A.
Absolutely not. I would not take it.
12
Q.
Did he tell you not to speak to me?
13
A.
No. He says -- no, he told me not to speak
14
to you. He didn't say that to me. He says, It's your
15
choice. You make that decision.
16
And he says, If you hire a lawyer, you make
17
that decision.
18
And we feel that was important for us. I
19
don't want to be involved with this thing. I'm out of
20
the job three years ago, and that's why we hired
21
Mr
Murrell
He suggested that
22
Q.
Did he ask you if anybody else has been
23
contacted?
24
A.
No.
25
Q.
Did he tell you that to call him back after
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our meeting?
2
A.
No, no.
3
Q.
Were you to have any contact with him at
4
any time after our meeting?
5
A.
If I will have a contact? I have no reason
6
for it. I have no reason to call Jeffrey or anybody
7
else. This is over, I hope.
8
Q.
Well, Mr.
this is basically an
9
ongoing investigation, so obviously anything that we
10
discuss hopefully will stay between us. Because it is
11
still ongoing, I wouldn't want this out until the
12
investigation is complete.
13
A.
It's not going anywhere. Even my kids
14
don't know it.
15
Q.
He contacted you after you called
16
Mr. Epstein?
17
A.
Yes.
18
When I call him and I said, Jeffrey, what's
19
going on?
20
He said,
I don't know what's going
21
on
There's an investigation against me.
22
So then I said, Whew, thank God. I don't
23
know what's happening.
24
And then he says, I have an investigator
25
that is investigating, the same thing the police
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1
department is doing. He's going to contact you.
2
And that was the end of it.
3
I think his name was Paul. I only met him
4
for about fifteen minutes, ten minutes.
5
Q.
You met at your house?
6
A.
No, no. I don't want him at my house. We
7
met at Carrabas restaurant, but it was not open, so we
8
met outside Carrabas. It took about ten minutes.
9
Q.
Going back to the items that were found in
10
the sink, can you describe any of those massagers?
11
A.
I only saw two things: It was a big,
12
big -- I think a vibrator. Big (indicating). And it was
13
a long -- I hate to -- I'm sorry. It was a long dick, I
14
think. Rubber thing. And there was a thing you used it
15
in the back, the vibrator in the back.
16
Q.
What color?
17
A.
We always had those. Not those toys.
18
Vibrators, we have different types, one for the neck, one
19
for the back. You know the one that has a battery and
20
they move, with balls on it, vibrator. That's it.
21
That's what I find there. I never find anything else.
22
Those two things.
23
Q.
Do you remember any names of the girls that
24
might have come over for massages?
25
A.
Yes. I remember some of them. From the
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beginning?
From the end?
2
Q.
As many as you can remember.
3
A.
As many as I can remember.
4
Q.
I know it's been a while.
5
A.
It was
It was
And it was --
6
it was
It was -- how many?
7
It was also a young girl, but she was not a
8
massage therapist. She came to the house as a friend, I
9
think. I don't think she was a massage therapist. Her
10
name was -- as a matter of fact, she's in a soap opera
11
now, she's a star. Just give me a minute.
12
13
There also were men masseuses.
14
Q.
There were men too?
15
A.
There were men. A few. Not that many. A
16
few. I can't remember.
17
There was an
There was
18
a
I think every name -- girls' names. In
19
eleven years, I cannot remember.
20
Q.
That's fine.
21
d
There were girls coming and going. There
22
were girls traveling with him as massage therapists.
23
They would travel with him all over the world, because he
24
was in the plane, he got massages on the plane,
25
because -- I know because I used to supply the oils and
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=== Page 22 ===
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1
the towels for the plane.
2
Q.
Would you clean his plane too?
3
A.
No, no.
4
Q.
Did you ever travel with him anywhere?
5
A.
No, no.
6
Q.
When he went to New York or Arizona or his
7
private island?
8
A.
I've been on his island. I've been as a
9
guest, as a vacation. We just took vacations, and I went
10
to his island in the Caribbean. And I've been in New
11
Mexico. I've been at his house in London. But not as a
12
worker, just vacation.
13
Q.
As a vacation?
14
A.
Uh-huh.
15
We went to New Mexico for -- it was kind of
16
a symposium about how to clean homes. It was this lady
17
who make -- teach all the house people, housemen, and
18
they invited us to Santa Fe, New Mexico, to teach us how
19
to clean homes. That was kind of stupid.
20
&
How he wanted it to be cleaned?
21
A.
Yes We didn't get that much.
22
Q.
Can you think of anything that I haven't
23
asked you that might be relevant to this?
24
A.
I can't think of anything. Basically it's
25
the same questions that the other investigator asked me.
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Exactly the same.
2
I wish I could give you more names.
3
Allison --
4
Q.
I'm not going to ask you to do that because
5
I know it's been a long time. I can't think of stuff I
6
did last week.
7
A.
It's been a long time.
8
a
If by any chance you are contacted again by
9
his investigator again for any more questions or anything
10
or any packages that he may deliver to you --
11
A.
They have to go to Mr. Murrell.
12
Q.
I was going to say, have him contact your
13
attorney.
14
MR. MURRELL: Packages? Are we expecting a
15
delivery of something?
16
DET.
No. I'm just saying --
17
MR. MURRELL: Okay. Just making sure there
18
wasn't something I didn't know about.
19
DET.
I.e., gifts, et cetera.
20
That kind of thing.
21
THE WITNESS: No.
22
DET.
:
I would appreciate a phone
23
call just to give me a heads up.
24
THE WITNESS: I do not intend to contact
25
him at all.
J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
NON PARTY (VR) 000551
EFTA00029412

=== Page 24 ===
Page 24
1
DET.
:
Okay. I appreciate it.
2
And that's it.
3
(Thereupon, the sworn statement was
4
concluded at 1:05 p.m.)
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
NON PARTY (VR) 000552
EFTA00029413

=== Page 25 ===
Page 25
1
THE STATE OF FLORIDA,
)
2
COUNTY OF PALM BEACH.
)
3
4
5
I, the undersigned authority, certify that
6
personally appeared before me and was duly
7
sworn.
8
9
WITNESS my hand and official seal this 5th day
10
of December, 2005.
11
12
13
14
MK
15
Notary Florida
My Commission No. DD 098441
16
My Commission expires 3/7/2006
17
18
# 00098441
Expires March 7. 2006
Bonded Thru
19
Adentic Bonding Co. for.
20
21
22
23
24
25
J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
NON PARTY (VR) 000553
EFTA00029414

=== Page 26 ===
Page 26
1
CERTIFICATE
2
The State Of Florida,
)
3
County Of Palm Beach.
)
4
5
I, Susan Shelling, Registered Professional
Reporter and Notary Public in and for the State of
6
Florida at Large, do hereby certify that
was by me first duly sworn to testify the whole truth;
7
that I was authorized to and did report said sworn
statement in stenotype; and that the foregoing pages,
8 numbered from 1 to 24, inclusive, are a true and correct
transcription of my shorthand notes of said sworn
9 statement.
10
I further certify that said sworn statement
was taken at the time and place hereinabove set forth and
11 that the taking of said sworn statement was commenced and
completed as hereinabove set out.
12
I further certify that I am not an attorney or
13 counsel of any of the parties, nor am I a relative or
employee of any attorney or counsel of party connected
14 with the action, nor am I financially interested in the
action.
15
The foregoing certification of this transcript
16 does not apply to any reproduction of the same by any
means unless under the direct control and/or direction of
17
the certifying reporter.
18
IN WITNESS WHEREOF, have hereunto set my hand
and seal this 5th day of December, 2005.
19
20
21
Susan Sholling Notary Public
In and for the State of Florida
22
My Commission No. DD 098441
My Commission Expires 3/7/2006
23
24
25
J. CONSOR & ASSOCIATES REPORTING & TRANSCRIPTION
561.835.9738
NON PARTY (VR) 000554
EFTA00029415


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027305.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Request re Maxwell Laptop
Date: Tue, 10 Aug 2021 20:27:34 +0000
Hi
Hope you're doing well. Ghislaine Maxwell's attorney has informed me that Maxwell is having difficulty reviewing the
portions of her discovery that include audio recordings on the laptop my office provided for her use. The attorney seems
to think that the issue can be fixed if someone from MDC's IT department could assist Maxwell in enabling the audio jack
so that Maxwell can use headphones to listen to the recordings. Would it be possible to ask someone from IT to please
look into this issue?
Thanks very much,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00027305


c1: EFTA00027959
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027959.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(ODAG)"
Cc:
(USANYS)"
Subject: RE: Epstein/Maxwell
Date: Wed, 22 Jul 2020 20:04:56 +0000
Great. Since
and I are in different locations, I can circulate a dial in.
From:
(ODAG)
Sent: Wednesday, July 22, 2020 2:33 PM
To:
(USANYS)
is
(ODAG)
Cc:
(USANYS)
Subject: RE: Epstein/Maxwell
Thursday at noon is perfect. Should I give you a call?
From:
(USANYS)
Sent: Wednesday, July 22, 2020 1:39 PM
To:
(ODAG)
is
(ODAG)
^
Cc:
(USANYS)
Subject: RE: Epstein/Maxwell
Thanks,
Would 12pm tomorrow (Thursday) work for you? If not, we also have availability Friday morning, from
10-12:30 if anything in there works for you. Best,
From:
(ODAG)
Sent: Wednesday, July 22, 2020 1:03 PM
To:
(ODAG)
in
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein/Maxwell
Hi
,
I'm happy to assist you. I'm available Thursday or Friday to discuss what documents you are trying to
locate. Please let me know if you have availability on either of those days.
Thanks,
From:
(ODAG)
Sent: Wednesday, July 22, 2020 12:49 PM
To:
(USANYS)
Cc:
(USANYS)
is
(ODAG)
Subject: RE: Epstein/Maxwell
Thanks. OPR and
may have a better sense on document custodians than do I.
EFTA00027959

=== Page 2 ===
From:
(USANYS)
Sent: Wednesday, July 22, 2020 12:41 PM
To:
(ODAG)
Cc:
(USANYS)
is
(ODAG)
Subject: RE: Epstein/Maxwell
Thanks,
Among our questions was who, whether at ODAG, SDFL, or NDGA we should be in touch with at this point
regarding documents. I also know OPR did a significant document collection last year.
We will reach back to OPR, but if there is a particular point of contact at SDFL or NDGA on issues related to document
collection, in particular, please let us know. And if a call on those issues would be helpful, happy to set one up.
Thanks very much,
From:
(ODAG)
Sent: Wednesday, July 22, 2020 10:56 AM
To:
(USANYS)
Cc:
(USANYS)
is
(ODAG)
Subject: RE: Epstein/Maxwell
Happy to talk, but my only real role related to recusal issues and consequences. Now that the CVRA litigation is over, you
probably are best going directly to SDFL, as I don't have any of their documents. Thanks,
Associate Deputy Attorney General
Office:
Cell:
From:
(USANYS)
Sent: Tuesday, July 21, 2020 6:23 PM
To:
(ODAG)
Cc:
(USANYS)
Subject: Epstein/Maxwell
- Hope all is well. We had spoken last summer, after the Epstein case was charged, about some potential
document/discovery requests related to the SDFL investigation and the NPA, in particular. Those conversations were
largely at mooted at the time by Epstein's death, but as I'm sure you know, we've recently charged Ghislaine Maxwell and,
anticipating potentially similar issues, we were hoping to revisit those conversations. Do you have time later this week
for a quick call? If so, please let us know what might work for you.
Thanks very much,
Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00027960

=== Page 3 ===
Tel.
EFTA00027961


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c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Meeting with Geoff on Epstein
Start Date: 2019-01-29 21:50:00 +0000
End Date: 2019-01-29 22:00:00 +0000
Organizer:
Class: X-PERSONAL
Comment:
Date Created: 2019-01-29 21:21:43 +0000
Date Modified: 2019-01-29 21:21:43 +0000
Priority: 5
DTSTAMP: 2019-01-29 21:02:23 +0000
EFTA00028038


c1: EFTA00027474
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027474.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Re: Epstein search warrant documents
Date: Thu, 02 Jul 2020 23:13:10 +0000
Team has held off on raising but I'll ask them to - given (far higher) BRG budgets
has approved on other high
profile PCU cases, this seems likely to be unobjectionable. But will find out.
Sent from my iPhone
On Jul 2, 2020, at 6:48 PM,
(USANYS)
wrote:
Has
said the BRG option is viable?
On Jul 2, 2020, at 6:32 PM,
(USANYS)
wrote:
On this issue of the Epstein devices, the team got an estimate from BRG that seems reasonable in terms of both cost
and time line. At this point, I would be inclined to do this, but let's find some time to chat more about it tomorrow if
you're around or early next week if that's better. Thanks
From:
Sent: Thursday, July 2, 2020 5:11 PM
To:
(USANYS)
Cc:
(USANYS)
is
is
Subject: RE: Epstein search warrant documents
Following up on the below, I think we've given this our absolute best efforts with FBI - they are now well over a month
later than their estimate from April on when we would get the New York materials, they're also past their estimate of
getting us the New York materials from just this Monday, and we don't have anything close to an estimate on the USVI
materials, which constitute the overwhelming majority of the data and are vastly more voluminous than the New York
devices. We have kept pushing the timeline back for this option, hoping that CART will finalize, but I think at this point
we should have a vendor do it.
Attached is an estimate we got from BRG, which would get everything to us in under a month, and in Relativity-friendly
format, in a range of $85-135K. BRG has done this for our office multiple times in the past and are very effective and
efficient, and they get the materials we need. And most importantly, they estimate they can do it all in less than a
month. May we have approval to seek funding for this? The estimate is attached. Thanks very much.
From:
Sent: Tuesday, June 30, 2020 16:23
To:
(NY) (FBI)'
i
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
is
EFTA00027474

=== Page 2 ===
)
i
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
From:
)
Sent: Monday, June 29, 2020 13:00
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS)
i
(NY) (FBI)
is
)
is
)
in
(NY) (FBI)
i
(USANYS)
Subject: RE: Epstein search warrant documents
Okay thanks - good luck with the cardiologist! And if you can let us know tomorrow that would be great. Thanks
again.
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:59
To:
(USANYS) [Contractor]
is
-
Cc:
(USANYS)
is
(NY) (FBI)
V.
)
>;
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
When I'm in the office tomorrow, I will be better able to estimate. I'm at my cardiologist right now.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:56 PM,
)"
wrote:
Great, thanks. Is there even a rough estimate of when we will get the USVI materials? Or an estimate of when you'll
be able to see how many items to export, so we'll have a better sense of when we'll get those?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:55
To:
(USANYS) [Contractor]
is
)
^
>
Cc:
(USANYS)
is
(NY) (FBI)
i
)
i
)
is
(NY) (FBI)
EFTA00027475

=== Page 3 ===
is
(USANYS)
Subject: RE: Epstein search warrant documents
Yep
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:52 PM,
)"
wrote:
Okay, and I'm sorry to ask again, but to make sure, in this production, you're sending us new versions of what you
previously sent?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:50
To:
(USANYS) [Contractor]
is
)
Cc:
(USANYS)
>;
(NY) (FBI)
V.
)
i
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
You are getting both NY and USVI. The biggest stumbling block are the newer Mac items that are in APFS
(there are a bunch from the Island,) so it is difficult to estimate how long those will take until I see how many
items I have to export.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:40 PM,
)"
wrote:
Okay thanks, and just to clarify, a few days to finalize the New York materials, and then what about the USVI
materials? I think that is quite a bit more. Just looking for an estimated completion date for everything.
And on my other question - does this mean you're giving us a new, complete copy of everything from both NY and
USVI?
thanks,
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:34
To:
(USANYS) [Contractor]
is
)
>
Cc:
(USANYS)
is
(NY) (FBI)
is
)
i
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
EFTA00027476

=== Page 4 ===
I am in the process of exporting the materials (documents, spreadsheets, emails, etc) for your review as per
my discussions with
Most of the NY stuff is done, just Mac items left. This might take a few days as 1
item in particular has over 500,000 emails. We will be able to provide discovery once Defense Council has
provided drives for us to copy items over to. This goes quicker as there is no processing involved. I'll let you
know when everything is complete.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 11:03 AM,
)"
wrote:
Following up on this, I understand from
that she was able to provide you with a 12 TB drive last week - could
you please let us know when we will be able to get the materials? I expect a judge will ask us about discovery as early
as this week.
Also, the related critical question that I don't think we have clarity on is whether you're giving us a copy of everything
that was collected (including reproducing the materials that you previously gave us, but which are not searchable), or
have you and
figured out a way to categorize the prior productions so they're useful for us? We would strongly
prefer to just get everything at once in a usable format, but please let us know if you expect to produce materials
differently than that.
thanks,
From:
(NY) (FBI)
Sent: Friday, June 19, 2020 13:14
To:
(USANYS) [Contractor]
is
)
Cc:
(USANYS)
i
(NY) (FBI)
is
)
is
)
in
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
,
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK when
I can expect the drives. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
EFTA00027477

=== Page 5 ===
From:
)
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(NY) (FBI)
is
)
is
)
>;
(NY) (FBI)
is
(USANYS)
in
(USANYS)
Subject: RE: Epstein search warrant documents
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July
and September searches before moving forward with possible additional charges in the case. I know you had
mentioned you needed to push back your prior estimate of complete production by early June, by a couple weeks, so
wanted to see what the current estimate is? I don't think we've started to get anything yet but please correct me if I'm
wrong.
thanks,
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go
from there.
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
i
)
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If
we can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our
EFTA00027478

=== Page 6 ===
staffing levels will be steadily increasing over the next few weeks, but I'm going to have to push back my
estimate by a week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can
easily identify what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
Thanks for this update - we'll take a look and circle back if any questions.
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in
searchable format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to
specific devices - so if we're able to match them up by Bates number now, that might work, but otherwise I think it
makes sense for us to get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think
we've gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
)
is
(USANYS) [Contractor]
Cc:
is
V.
(NY) (FBI)
in
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial
numbers. Any questions, let me know.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
>;
EFTA00027479

=== Page 7 ===
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of
information we need is the serial number, or some other specific identifier, ideally for each device but at least for any
device that there is more than one of the same thing. So for example, we need to be able to somehow differentiate
the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the
USVI spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the
USVI list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to
reproduce all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we
aren't able to match any of the prior productions to specific devices - so if we're able to match them up by Bates
number now, that might work, but otherwise I think it makes sense for us to get everything. But let us know if any
issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
)
is
(USANYS) [Contractor]
Cc:
is
)
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I
could to convey the information. If you are confused by anything, please let me know. In the column for
approximate size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I
put what load file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If
there is no entry in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't
EFTA00027480

=== Page 8 ===
have as well as an iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to
beef them up. I will get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
>;
(NY) (FBI)
V.
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any
FBI tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which
both we and the agents can access. We're required to have the files in a format that we can produce them to defense
counsel. I've done that in many other cases and it hasn't previously been an issue. My understanding from
is
that the best way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will
process-by which I just mean converting into file formats that are loadable onto Relativity. It doesn't really have
anything to do with the taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents
earlier this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9.
Again, I understand from
that the best way forward is to just get copies of the materials in their original formats,
which I understand will be segregated and designated by device. That should work for us! I was just trying to
understand the approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
)
>;
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking
files that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity)
to do a taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
EFTA00027481

=== Page 9 ===
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what
was already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So
now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it
piece by piece as things are processed, I was unaware that you didn't want to review as things were
processed, that you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a
differentiation of methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a
while back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
in
(USANYS) [Contractor]
Cc:
is
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just
basically sending us copies of everything? I don't totally understand why we couldn't have done that eight months
ago, but regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I
assume that means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the
processing ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
>;
Cc:
is
Subject: RE: Epstein search warrant documents
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to
a particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
EFTA00027482

=== Page 10 ===
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
is
Cc:
is
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so
we make sure we get all the info we need. I think you had previously sent us a list of certain information that
unfortunately wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it
on our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data
and where the data was collected. I will work to send some hard drives to
so he can begin to copy the data
and send it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
EFTA00027483

=== Page 11 ===
From:
)
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review
the returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
i
is
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
in
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave
you. If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks-it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
i
i
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will
be back in the office on Thursday and will be able to get you the list then as I have to access some of our
systems to do so.
EFTA00027484

=== Page 12 ===
Also,
,
please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're
waiting on that list to be able to do an updated search warrant on all of those devices. Please let us know the current
timeline - and also the current timeline on producing the results from those August and September searches? I think
you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months
from our call, which would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
)
is
(USANYS)
>;
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
) [mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
i
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
is
i
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us
know, otherwise I'd propose we do:
1)
2)
3)
EFTA00027485

=== Page 13 ===
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
(NY) (FBI)
is
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
i
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but
are you at all able to assist while working remotely? This has been pending for almost two months and we still don't
have a very basic list of each device or item that was seized and searched, or for which of those we've received
materials. We're happy to have a call if that would be useful, but as a first step the most basic thing we're looking for
is the info in the template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24?
The excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we
sent on 2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you
mean by "loose media" without a specific comparison to what was seized, we don't know which items you're referring
to as "Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just
partial. For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
EFTA00027486

=== Page 14 ===
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only
is that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
The load file has no link to the native file, so when we load the data to the database, there's no way to have
the native files show up in the database. Because many of the files are too large to open in the viewer, it
effectively means that there are many files that are completely invisible to us.
-
Related, the control numbers in the load file don't match up to the native files. So we have two sets of
numbers and no way to match up anything-that is, even if we were to try to go hunt down every individual
large file in the native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to
get a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a
million documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary
record-keeping, and we need that info at the very least, as well as anything else you think would be useful. Also
attaching the SW returns for reference. And again, we're happy to meet up anytime and hash all this out in person if
that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
in
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some
points of clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies
of 3 drives (9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all
copies). All the loose media from the NY apartment is included. All the Windows machines from the NY apartment are
included. Only 2 Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the
tool they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From:
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
EFTA00027487

=== Page 15 ===
To:
(NY) (FBI)
is
(USANYS)
>;
(NY) (FBI)
>;
(USANYS)
Cc:
(USANYS) [Contractor]
i
i
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so
we can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
>;
(NY) (FBI)
y
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week?
And what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in
the two search warrant returns, with columns for whether we've dumped the contents, whether they've been
reviewed and/or transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the
attached is mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed,
transferred, and received so far, and what remains.
EFTA00027488

=== Page 16 ===
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think
FBI was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to
be able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
is
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
in
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated
we delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do
only local work. I should be able to give you an accounting of what is what. I can say, off the top of my head,
that all windows based items from the NY search have been handed over as well as all loose media. The CDs
from NY only contained pictures, no documents. There are still some Apple items from NY that need to be
produced. As far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been
produced. Still working on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e.,
which devices the materials came from, whether it's full or partial results, how many more devices we have coming,
etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are
approximately 40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even
counting at least 60+ CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices,
including multiple servers / server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of
moving pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming
week from Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be
plenty of time to schedule a productive meeting.
thanks all,
EFTA00027489

=== Page 17 ===
From:
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
is
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have
the hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also
old materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's
new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list
of which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a
modified date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we
haven't gotten any info on which folders match up to which devices, etc. And then there's another folder titled
"NYC024362" that has a modified date of 1/27/20, so I think that may be the materials we hadn't previously received?
That folder by itself has more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder
or file names whether everything on the drive is new, or whether just additional materials were saved onto it in
addition to what we already have.
, are you able to give us some guidance on this? Ultimately what we really
need is a spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that
same info - which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
<mime-attachment>
EFTA00027490


c1: EFTA00028974
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028974.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
20 Cr. 330 (AJN)
V.
:
:
GHISLAINE MAXWELL,
:
Defendant.
:
:
X
REPLY MEMORANDUM OF GHISLAINE MAXWELL
IN SUPPORT OF HER MOTION TO DISMISS COUNTS ONE THROUGH FOUR OF
THE SUPERSEDING INDICTMENT FOR LACK OF SPECIFICITY
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Christian R. Everdell
COHEN & GRESSER LLP
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
Attorneys for Ghislaine Maxwell
EFTA00028974

=== Page 2 ===
The government continues to stonewall Ms. Maxwell's requests for clarity about what it
claims she did to justify her continued incarceration and prosecution. Although the government
has dumped thousands of pages of irrelevant discovery from inapplicable time periods on Ms.
Maxwell and her counsel, it refuses to provide the most basic information about the allegations
in Counts One through Four: who, what, when, and how. Because Counts One through Four of
the superseding indictment ("Indictment") lack the basic factual information necessary for Ms.
Maxwell to prepare her defense, and the government refuses to provide any meaningful
discovery, the Court should either dismiss these counts or direct the government to answer Ms.
Maxwell's requests for particularity.
I. The Indictment Lacks the Necessary Specificity
The government attempts to justify some of the Indictment's deficiencies, e.g., lack of
names and dates, through citation to obviously inapplicable cases.
"First," the government offers United States V. Stringer, 730 F.3d 120, 124 (2d Cir.
2013), for the proposition that "the use of pseudonyms to refer to minor victims of the charged
conduct does not warrant dismissal of the indictment." Resp. at 153. The government fails to
point out, however, that Stringer was a fraud case in which the conduct was alleged to have
occurred over a 7-month period. The indictment was brought within a few years, not decades, of
the alleged crime, and the identity of the two people whose names were used in connection with
the fraud "had been revealed in the documents disclosed by the government a year" before trial.
Id. at 123.
United States V. Kidd, 386 F. Supp. 3d 364, 367 (S.D.N.Y. 2019), is equally
unpersuasive. Kidd was indicted in 2018 for crimes alleged to have occurred as late as 2018.
The case involved two alleged victims and the government produced sufficient discovery to
obviate the need for a bill of particulars. Id. at 368, 370.
1
EFTA00028975

=== Page 3 ===
The Indictment against Ms. Maxwell registers a 98 on the opacity chart. Instead of two
alleged "victims," the indictment here has different categories with three people being identified
as "Minor Victims," even though they are not minors. Additionally, an unknown number of
unexplained categories of unidentified human beings appear in the Indictment: "multiple minor
girls," "victims," "minor victims," "minor victims described herein," "some of Epstein's minor
victims," and "multiple minor victims." It is a mystery if the government claims that these
alleged people are the same, part of the alleged crime, or surplusage. Multiple "among other
thing" and "means and methods" alleged acts are bandied about in the indictment such as:
assisted, facilitated, contributed, recruit, groom, befriend, spending time, being present, help, etc.
This Indictment is subject to considerable interpretation and manipulation. Ms. Maxwell cannot
prepare a defense without knowing who her accusers are and whether they are limited to the
alleged "Minor Victims" or the rest of the universe.
"Second," the government relies on the general proposition that "Courts in the Second
Circuit have consistently upheld indictments containing a range of time rather than a specific
date." Resp. at 154. Again, the cited cases are easily distinguishable. Kidd involved a date range
ending in the year of indictment. Moreover, the quoted general language from Kidd, 386 F. Supp.
3d 364, 369, is incomplete. The court in Kidd explains the range it is referring to by the
following reference: "See United States V. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)
(holding that 'on or about June 1984' put a defendant on notice for potential crimes in July or
early August of 1984 'because the [G]overnment is not required to prove the exact date, if a date
reasonably near is established')." Id. The government fails to include this language because it is
inapposite to the suggestion that there is anything "routine" about a date range beginning 27
2
EFTA00028976

=== Page 4 ===
years ago that may be applicable to dozens of people in multiple places including a foreign
country.
United States V. Vickers, No. 13-CR-128-A, 2014 WL 1838255, at *1 (W.D.N.Y. May 8,
2014), also does not help the government. This case concerned a one count indictment in 2013. It
is patently clear from the opinion by the district court that the statements from the alleged victim
detailing the allegation had been provided to the defendant and the court which noted that the
lengthy recitation of facts in the opinion "are taken from the allegations set forth in the Affidavit
of Federal Bureau of Investigation Special Agent
submitted in support of the
May 16, 2013 Criminal Complaint (Dkt.# 1), the Indictment (Dkt.# 8), and the government's
response to the instant motions (Dkt.# 20)." 2014 WL 1838255, at *3 n.1. The dates and times
of the alleged conduct would have been fairly easy to identify given the detail provided in
discovery. Here, Ms. Maxwell has not been provided with any relevant statements by the
government or its witnesses.
The government's attempt to hide behind the general proposition that children cannot be
expected to remember dates also fails. Resp. at 155. The alleged victims here are not children,
they are adults. Moreover, a review of the case relied on by the government, United States V.
Young, No. 08-CR-285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008), demonstrates
the proper way to charge these types of allegations (which is not as the government did here):
Count One alleges that Defendant sexually abused Victim One, aged fourteen at
the time, during the daytime on a Saturday in or about the Fall of 2006; Count
Two alleges that Defendant sexually abused Victim One, aged fifteen at the time,
during the daytime on a Saturday in or about September 2007; and Count Three
alleges that Defendant sexually abused Victim Two, aged sixteen at the time, on
an evening in or about the Summer of 2006. Stated differently, the three counts
each specify a particular time of day (daytime or evening), and feature variances
in date ranges stretching from roughly four days in Count Two to thirteen days in
Count One to four months in Count Three.
3
EFTA00028977

=== Page 5 ===
Thus, the court found: the indictment "contains dates ranges for each count, stretching from
approximately four days to four months. These date ranges are well within the boundaries
permitted by the Second Circuit and other federal courts, and have been supplemented with
additional details provided by the Government. Id., at *4 (emphasis added).
To date, the only time the government has "supplemented" any information about the
accusations is when it is attempting to excuse some failure.
Here, the accusers have given statements to the government. Accuser-1 gave a statement
to the government in 2006. All three accusers have made claims against the Epstein Estate.
Presumably, the Accusers had to tell the Estate when and where any alleged abuse by Epstein
occurred. Accordingly, this is not a situation where children do not remember things. This is a
situation where the government has refused to provide basic necessary information in an attempt
to prejudice Ms. Maxwell's defense.
"Third," the indictment is not "clear" (Resp. at 155); it was purposely drafted to
maximize charges and minimize clarity. For example, the photograph of Ms. Maxwell in the
indictment is not from the time-period alleged. The pictures of the various properties were not
included for specificity, they were included to maximize pretrial prejudice. The indictment is
full of "weasel words" which are words the meaning of which are "malleable to a point where
they mean what the user wants them to mean in any given situation; they have no meaning of
their own." Abstrax, Inc. V. Hewlett-Packard Co., No. 2:14-CV-158-JRG, 2014 WL 5677834, at
*2 (E.D. Tex. Nov. 4, 2014). For example: "up to and including at least in or about,"
"contributed," "among other things," "for example in some instances," "certain victims," and
"groomed and/or abused at multiple locations including the following." Ms. Maxwell is at a loss
to understand what she is charged with and when it is alleged to have happened. She can guess at
4
EFTA00028978

=== Page 6 ===
names, but given the government's recent harbinger of a superseding indictment, likely to
attempt to fix some of these problems, Ms. Maxwell is wasting time and money playing whack-
a-mole with this Indictment.
II. This Indictment Does Not Satisfy Minimal Notice Requirements
In Hamling V. United States, 418 U.S. 87, 117-18 (1974), the United States Supreme
Court explained the circumstances in which an indictment simply setting forth the offense in the
words of the statute may not suffice:
Our prior cases indicate that an indictment is sufficient if it, first, contains the
elements of the offense charged and fairly informs a defendant of the
charge against which [s]he must defend, and, second, enables [her] to plead an
acquittal or conviction in bar of future prosecutions for the same offense. It is
generally sufficient that an indictment set forth the offense in the words of the
statute itself, as long as those words of themselves fully, directly, and expressly,
without any uncertainty or ambiguity, set forth all the elements necessary to
constitute the offence intended to be punished. Undoubtedly the language of the
statute may be used in the general description of an offence, but it must be
accompanied with such a statement of the facts and circumstances as will inform
the accused of the specific offence, coming under the general description, with
which [she] is charged. (cleaned up).
The government has failed to provide an indictment that "directly," "expressly," and "without
uncertainty or ambiguity" sets forth the allegations against her. The alleged facts are vague and
illusory and no meaningful discovery has been provided. Accordingly, Ms. Maxwell cannot
adequately defend herself, in violation of the Fifth and Sixth Amendments to the United States
Constitution.
CONCLUSION
Because Counts One through Four of the Indictment lack the basic factual information
necessary for Ms. Maxwell to prepare her defense, and the government refuses to provide any
meaningful discovery, the Court should either dismiss these counts or direct the government to
answer Ms. Maxwell's requests for particularity.
5
EFTA00028979

=== Page 7 ===
Dated: March 15, 2021
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca (pro hac vice)
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Christian R. Everdell
COHEN & GRESSER LLP
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
Attorneys for Ghislaine Maxwell
6
EFTA00028980

=== Page 8 ===
Certificate of Service
I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the
Court's individual practices in criminal cases, the Reply Memorandum of Ghislaine Maxwell in
Support of Her Motion to Dismiss Counts One through Four of the Superseding Indictment for
Lack of Specificity upon the following:
U.S. Attorney's Office, SDNY
s/ Christian R. Everdell
7
EFTA00028981


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=== Page 1 ===
From:
(USANYS)"
To:
(BOP)"
(BOP)"
Cc:
)"
)"
Subject: US V. Maxwell - Call tomorrow
Date: Thu, 04 Nov 2021 04:51:19 +0000
Attachments: 20cr330_Order_1_11.3.21.pdf
Please see attached order Judge Nathan issued. Can we please schedule a call tomorrow to discuss? Please let us know
what times work for you tomorrow.
Thanks very much,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel:
EFTA00028167


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=== Page 1 ===
From:
Jeffrey Epstein
To:
Jes Staley
Sent:
6/16/2010 9:57:56 PM
Subject:
Re:
ok
On Wed, Jun 16, 2010 at 4:54 PM, Jes Staley
wrote:
I'm w A
From: Jeffrey Epstein
To: Jes Staley
Sent: Wed Jun 16 16:34:02 2010
Subject: Re:
call me
On Wed, Jun 16, 2010 at 4:32 PM, Jes Staley
wrote:
Is she free tonight?
This email is confidential and subject to important disclaimers and
conditions including on offers for the purchase or sale of
securities, accuracy and completeness of information, viruses,
confidentiality, legal privilege, and legal entity disclaimers,
available at http://www.jpmorgan.com/pages/disclosures/emalil
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to
and
destroy this communication and all copies thereof,
including all attachments.
This email is confidential and subject to important disclaimers and conditions including on offers for the purchase
or sale of securities, accuracy and completeness of information, viruses, confidentiality, legal privilege, and legal
entity disclaimers, available at http://www.jpmorgan.com/pages/disclosures/emalil.
Confidential Treatment Requested by JPMorgan Chase
JPM-SDNY-00000928
EFTA00029430

=== Page 2 ===
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to
, and
destroy this communication and all copies thereof,
including all attachments.
Confidential Treatment Requested by JPMorgan Chase
JPM-SDNY-00000929
EFTA00029431


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=== Page 1 ===
Proceedings
245
1
the aspects of the motion we filed, and I think it's a lot for
2
the Court to have to deal with, quite frankly, and I know the
3
Court is going to try and do the best it can with the
4
situation, but I don't think it's tenable and -- I don't ask
5
for mistrials easily, I have probably asked for four in my
6
entire career, I don't see a way out of this problem.
7
(Pause.)
8
THE COURT: All right, I'm going to deny the
9
defendant's motion for a mistrial. Any issues caused by a
10
witness referring to certain individuals by their first name
11
only and by asking the Government if they may use last names
12
of certain other individuals can be cured by a jury
13
instruction, which I will give. Going forward, the Government
14
shall provide the defendant and each witness, including the
15
current witness, with a list of the individuals whose identity
16
should be protected from the public and the press, that way
17
each witness can refer to the list rather than asking the
18
Government whether a particular individual's identity is
19
protected.
20
You don't have a proposed jury instruction.
21
MS.
: Not yet, Your Honor.
22
THE COURT: I have one.
23
To the jurors: You may have noticed during
24
yesterday's testimony that the witness used first names of
25
certain individuals. That is because the names of certain
Denise Parisi , RPR , CRR
Official Court Reporter
EFTA00028270

=== Page 2 ===
Proceedings
246
1
alleged victims are being withheld from the public and the
2
press to protect the privacy of those individuals. I have
3
therefore instructed the parties to refer to those individuals
4
by their first names only; however, those full names are known
5
to the Government, the defendant, and to the Court.
6
You may also have noticed that the witness was
7
asking the Government whether she should say the last names of
8
certain individuals. Going forward, the witnesses will
9
receive a list of the individuals whose last names are to be
10
protected to which they may refer while testifying.
11
Anything else you want me to put in there?
12
MS.
: Not from the Government Your Honor.
13
THE COURT: You object?
14
MR. AGNIFILO: I do, Judge.
15
THE COURT: Your objection is noted.
16
Also, I'm going to direct that the parties shall not
17
make any speaking objections. If the basis for an objection
18
is not apparent, the parties may request a sidebar.
19
MR. AGNIFILO: Very good. Thank you, Judge.
20
THE COURT: Okay, what else?
21
MS.
: Nothing else from the Government, but we
22
would just ask for five minutes to make sure that the list is
23
correct for the current witness.
24
THE COURT: All right, we'll take a five-minute
25
break.
Denise Parisi , RPR , CRR
Official Court Reporter
EFTA00028271


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=== Page 1 ===
From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:46:40 +0000
Inline-Images: image001.png
Thanks!
From:
Sent: Thursday, July 2, 2020 1:25 PM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congrats, team!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO DONIMINA UNITED
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
STATES
OF
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
EFTA00028749

=== Page 2 ===
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
EFTA00028750

=== Page 3 ===
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
EFTA00028751

=== Page 4 ===
unless and until proven guilty.
EFTA00028752


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=== Page 1 ===
Event: Accepted: Epstein Brass Meet
Start Date: 2019-04-08 16:00:00 +0000
End Date: 2019-04-08 16:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-04-05 23:01:55 +0000
Date Modified: 2019-04-05 23:01:55 +0000
Priority: 5
DTSTAMP: 2019-04-05 22:03:06 +0000
Attendee:
EFTA00029175


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=== Page 1 ===
From: "Berman, Geoffrey (USANYS)"
To:
)"
Cc:
)"
Subject: Re: updates
Date: Sat, 06 Jul 2019 22:28:04 +0000
Importance: Normal
I will continue to forward updates as I get them.
It is really quite extraordinary that our team was able to conduct an investigation of great sensitivity and public
interest with complicated witnesses over a period of several months, resulting in an excellent indictment, and
manage to keep it all entirely covert. It has been an effort requiring enormous sophistication, judgment and
dedication, which is a testament to you all. And the case is a righteous one. Thank you all. Geoff
On Jul 6, 2019, at 5:54 PM, Berman, Geoffrey (USANYS)
wrote:
Epstein is in custody. Search warrants being executed now. Geoff
On Jul 6, 2019, at 12:44 PM, Berman, Geoffrey (USANYS)
wrote:
tells me that he is confirmed on board. Wheels up. Geoff
On Jul 6, 2019, at 11:10 AM,
)
wrote:
Good morning all-
asked me to pass along two quick updates. First, Judge Moses signed the search warrant this morning.
Second, our case agent told us that FBI received a flight manifest from CBP last night. The passengers listed are
Epstein and two pilots. Of course, that is subject to change, and I'm told that FBI will try to get confirmation of the
passengers after the flight takes off.
Assistant United States Attorney
Southern District of New York
EFTA00029514


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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Date: Thu, 11 Jul 2019 01:00:32 +0000
Importance: Normal
Yeah I saw, thanks - stupid copy / paste.
From:
Sent: Wednesday, July 10, 2019 20:58
To:
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
I think there was a typo in the second paragraph of your email cutting off the sentence.
From:
Sent: Wednesday, July 10, 2019 8:57 PM
To:
Conlon
>; Roberta Kaplan
>; ; Jenna Dabbs
>; Alexandra Elenowitz-Hess
Cc:
is
;
Subject: RE: U.S. V. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing
Hi all,
As you may already know, pursuant to the Crime Victims' Rights Act, specifically 18 U.S.C. 3771(a)(4), a crime victim has
the right to be reasonably heard at certain public proceedings in the district court, including proceedings involving
release. Accordingly, we wanted to be in touch consistent with our responsibilities and obligations-and your client's
rights-under that statute, to see whether your client would like to be heard in any fashion, whether through a
submission, a representation that we can include in our bail submission due Friday, or some other form. Of course no
requirement or obligation, but we would be happy to discuss it if that would be useful.
To the extent this information is useful in your consideration, I can say that while I don't want to prejudge the
Would it make sense to set up a brief call sometime tomorrow, if any of you want to discuss? I should be able to make
myself available whenever is convenient for you (and likely will be just me, as the remainder of the team will be traveling).
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00028354


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=== Page 1 ===
From:
"
.
(NY) (OGA)"
To:
"
(USANYS)"
Subject: RE: Epstein Assistance Request
Date: Mon, 19 Aug 2019 20:04:57 +0000
Thanks
-
On Aug 19, 2019 4:03 PM, "
(USANYS)"
wrote:
Removing
The attached spreadsheet that she worked on over the weekend has almost all of this info.
Original Message
From:
(NY) (OGA)
Sent: Monday, August 19, 2019 3:59 PM
To:
Subject: Epstein Assistance Request
Can anyone advise as to the full names and possibly dates of birth for the following BOP employees?:
?
If we could have these by 5:30 it would help in piecing together some information for our analyst helping us with the
EFTA00027226

=== Page 2 ===
case
FBI/NYPD Violent Crimes & Joint Bank Robbery Squad C-19
EFTA00027227


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: [EXTERNAL]
Date: Mon, 27 Sep 2021 17:33:41 +0000
Inline-Images: image001.png
Sure, give me a call when you're ready to chat.
From:
(USANYS)
Sent: Monday, September 27, 2021 12:42 PM
To:
Subject: Fwd: [EXTERNAL]
Let's discuss
Begin forwarded message:
From: Stuart Kaplan
Date: September 27, 2021 at 12:18:44 PM EDT
To:
(USANYS)"
Cc:
(NY) (FBI)"
Subject: [EXTERNAL]
Ms.
:
As I understand now your office has been advised that I have been formerly retained by Retired FBI Special Agent
in connection with her being subpoenaed
to testify in United States V. Ghislaine Maxwell case pending in the SDNY.
Ms.
has conveyed some concerns about her inability to properly prepare for her testimony whether for the
prosecution or defense given that she has not been given a copy of the 1A notes that were originally prepared in
preparation to the FD-302 written that she may be called to testify about. (I will be able to elaborate via tel/cal with
you).
Additionally, my client was interviewed by Office of Professional Responsibility (OPR) just prior to her retirement. This
interview was given under oath and in connection with her recollection of events of the Jeffrey Espstein investigation.
(I can of course elaborate further via tel/cal with you.)
Please feel free to reach out to me at your earliest convenience to discuss further.
In the interim, moving forward all direct or indirect contact with Ms.
should be coordinated through my
office.
Thank you.
Stuart N. Kaplan, Esq.
Managing Partner
LAW OFFICES
STUART N. KAPLAN, P.A.
A PROFESSIONAL ASSOCIATION
Tele.
Fax
I
www.stuartnkaplanpa.com
EFTA00027581

=== Page 2 ===
CONFIDENTIALITY NOTICE
This e-mail message from The Law Office of Stuart N. Kaplan, P.A., is intended only for the individual or
entity to which it is addressed. This e-mail may contain information that is privileged, confidential and
exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby
notified that any dissemination, distribution or copying of this communication is strictly prohibited. If
you received this e-mail by accident, please notify the sender immediately and destroy this e-mail and all
copies of it.
EFTA00027582


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EXHIBIT B
EFTA00028850

=== Page 2 ===
App.-0805
1
G4LMGIUC
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
2
X
3
4
Plaintiff,
5
V.
15 Civ. 7433 (RWS)
6
GHISLAINE MAXWELL,
7
Defendant.
8
X
New York, N.Y.
9
April 21, 2016
11:05 a.m.
10
Before:
11
HON. ROBERT W. SWEET,
12
District Judge
13
APPEARANCES
14
BOIES, SCHILLER & FLEXNER LLP
15
Attorneys for Plaintiff
BY: SIGRID STONE McCAWLEY
16
-and-
FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L.
17
BY: BRAD EDWARDS
-and-
18
PAUL G. CASSELL
19
HADDON, MORGAN & FOREMAN
Attorneys for Defendant
20
BY: LAURA A. MENNINGER
JEFF PAGLUICA
21
22
23
24
25
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00028851

=== Page 3 ===
App.-0806
2
G4LMGIUC
1
(Case called)
2
THE COURT: Welcome back. I have read the papers.
3
Who knows. I might have missed something, but I think I've got
4
it fairly well under control. I would be pleased to hear
5
anything anybody wants to tell me in addition to what you've
6
already given me.
7
MS. McCAWLEY: Your Honor, this is Sigrid McCawley. I
8
would like to start, if it's convenient with the Court, with
9
the pro hac vice motions that are pending because we would like
10
counsel to be able to anticipate in these proceedings. Would
11
that be all right if I started with that?
12
THE COURT: I don't care.
13
MS. McCAWLEY: Thank you. Your Honor, you have before
14
you two pro hac vice motions. My client,
/
15
would like to have counsel of record in the case be added as
16
Professor Paul Cassell and Brad Edwards. We have presented
17
those pro hacs to your Honor. This is the first time in my
18
years of practice that I've had a contested one, so I've looked
19
at the case law surrounding that and I think it is very clear
20
that a client is entitled to counsel of choice in a case.
21
In this matter she has selected these lawyers. They
22
have been working with her. They had been working on this
23
matter for many months now. We need them as counsel of record
24
in the case now because we are going to have depositions
25
throughout the country where, for example, Professor Cassell is
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00028852

=== Page 4 ===
App.-0807
3
G4LMGIUC
1
in Utah. He will be able to handle the Colorado depositions
2
and things of that nature. We are here because those pro hac
3
vice motions are being contested. The core piece of that is
4
the argument that they should not be allowed to seek
5
confidential information in this case.
6
Your Honor will remember that I was before you a
7
couple of weeks ago again trying to get the deposition of the
8
defendant, which is set for tomorrow, but still hasn't occurred
9
yet. And in order to expedite that process I agreed to the
10
protective order that was put in front of the Court and I
11
waived all of my objections to that in order to be able to
12
facilitate and move that deposition forward. That protective
13
order provides that attorneys who are actively working on the
14
case can receive confidential material.
15
My opposing counsel has interpreted that to mean that
16
that must be a counsel of record in the case. We disagree with
17
that interpretation. I wouldn't have agreed to a protective
18
order knowing that they were already working on the case. If
19
that were the situation, as your Honor can understand in this
20
case, the majority of the material has been marked
21
confidential, so it would prohibit my cocounsel from working on
22
behalf of their client.
23
Your Honor, I'm here to request on behalf of my
24
client,
,
that she be entitled to have her
25
counsel of record of choice in this matter. If your Honor will
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1
indulge me, I would like Mr. Cassell to address his pro hac
2
motion, please.
3
MR. CASSELL: Good morning, your Honor, Paul Cassell.
4
I'm a law professor.
5
THE COURT: I don't want to hear it. Sorry. No.
6
Thanks very much.
7
MR. CASSELL: Thank you, your Honor.
8
THE COURT: Anything from the defense.
9
MR. PAGLIUCA: Yes, your Honor. Jeff Pagliuca on
10
behalf of Ms. Maxwell.
11
Your Honor, I have never opposed a pro hac motion in
12
my 34 years of practice, so this is a first for me. But it is
13
clear, your Honor, that these lawyers will be witnesses in this
14
case.
15
THE COURT: This we don't know. I can't make that
16
determination now. Anything else?
17
MR. PAGLIUCA: Yes.
18
THE COURT: You may be totally right, but I don't
19
know.
20
MR. PAGLIUCA: Your Honor, here is the problem. This
21
case is about the plaintiff's false allegations.
22
THE COURT: Yes. I think I picked up on that.
23
MR. PAGLIUCA: These are the lawyers that wrote the
24
false allegations.
25
THE COURT: I think I picked up on that, too.
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MR. PAGLIUCA: These are the lawyers that admitted
2
that these were false allegations.
3
THE COURT: I know. I don't have to tell you, you
4
know, there is going to be all kinds of privilege issues, all
5
kinds of issues about whether or not they have to testify. We
6
are not at that stage. I cannot and I will not decide that
7
now.
8
What else?
9
MR. PAGLIUCA: There is a problem with the sharing of
10
confidential information with these lawyers. These lawyers
11
have both personal and professional interests.
12
THE COURT: I understand that. I get that point.
13
Anything else?
14
MR. PAGLIUCA: No, your Honor.
15
THE COURT: This is what we will do on the pro hac.
16
Everybody agrees, nobody, maybe in the world, but nobody in
17
this courtroom, including me, has dealt with this kind of
18
problem before. That's perhaps only one of a number of issues
19
that are unique about this case. That's neither here nor
20
there. Clearly, the plaintiff has the right to consult with
21
any lawyer she chooses. However, the materials here are
22
sensitive. I don't know the extent to which they have been
23
designated confidential, but I'm quite sure that a substantial
24
number of them have been, by the very nature of the case, I
25
guess. Let me put it this way. I want to be sure that we
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enforce the confidentiality appropriately.
2
Now, with those preliminary thoughts in mind I am
3
going to deny the motion at this time because I know that there
4
is a statement, some kind of a statement from the mediator in
5
the Florida action. When I get a piece of paper that says the
6
Florida action is dismissed, a court order or whatever, then
7
this motion can be renewed.
8
Also, I want an affidavit from the two lawyers that
9
there is no matter in which they are personally involved, that
10
they are making no claim, there is no claims, there is no
11
litigation in which they are involved. The reason I say that
12
is that I would not grant the application for a pro hac status
13
to a party in this or a related litigation. If I get those
14
affidavits and the statement about the closure of the Florida
15
case in which they are a party, then the application can be
16
renewed and at that point I would be probably inclined, unless
17
something else comes up or unless the defense tells me
18
something that I don't now know, I would grant the application
19
that brings us to the order itself and the meaning of the
20
order. I think active in the litigation is the key phrase.
21
The plaintiff has listed the people that she considers would be
22
appropriate and it's these two gentleman and I think one other
23
person, and that's fine. That is the definition.
24
However, I'm also going to ask the parties to agree
25
upon an order that would expand the confidentiality agreement
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to this extent, to require the plaintiff to indicate to me and
2
to the defense if there is anyone else who is going to be
3
active in the litigation. I'll tell you why I feel this way.
4
I want to be sure that we can enforce the confidential aspect
5
of that agreement, and I think that could be critical down the
6
line. That's the reason for those requests.
7
Now, we also have a motion to compel.
8
MS. McCAWLEY: Your Honor, can I just get
9
clarification very quickly because I don't want to have to come
10
back to the court so I want to make sure I'm following
11
correctly. Your ruling, because we have a deposition tomorrow
12
that counsel was going to be assisting me with, particularly on
13
the Fifth Amendment --
14
THE COURT: Can't have access unless I get these
15
materials by then. If I do, that's something else. If I do,
16
fine. Otherwise, they can't have access to the confidential
17
data. They can assist.
18
MS. McCAWLEY: Can I just point something out to the
19
Court as well.
20
THE COURT: The plaintiff can have any lawyer she
21
wants. The question is the confidential materials.
22
MS. McCAWLEY: Can I just point the Court to one more
23
issue, because this is their protective order. They now said
24
to the Court that these two individuals are witnesses or
25
potential witnesses. The protective order allows in Section G
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1
confidential material to go to deponents, witnesses or
2
potential witnesses.
3
THE COURT: That's a different issue. I have not
4
dealt with that. Obviously anybody who is a witness may have
5
access to the confidential material, because they have to buy
6
into the confidentiality order in order to do that. But they
7
are outside of it at the moment.
8
MS. McCAWLEY: Your ruling is, they cannot attend the
9
deposition tomorrow?
10
THE COURT: They can. Anybody can attend the
11
deposition that anybody wants to have, but they can't
12
participate in it. They can't have access to the confidential
13
material until we get this matter straightened out. Ok.
14
MS. McCAWLEY: I understand, your Honor.
15
MR. PAGLIUCA: Your Honor, we will be designating the
16
testimony as confidential.
17
THE COURT: You see. There you go. That's life. I
18
can't believe that this entire testimony is going to be
19
confidential. Honestly, you all are too much. Ok. If that's
20
what you do, you know that's not going to work because not all
21
of this stuff at issue is going be to confidential. No, no
22
way. What is your name? Ok. We will deal with tomorrow's
23
problem tomorrow.
24
MR. PAGLIUCA: Ok, your Honor.
25
THE COURT: The compel. Anybody want to add anything
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on that?
2
MS. MENNINGER: Yes, your Honor. Laura Menninger on
3
behalf of Ms. Maxwell. I have taken the liberty, your Honor,
4
of just making a very short little cheat sheet of the
5
outstanding issues, if I may approach.
6
THE COURT: Yes. It will be interesting to see if
7
yours is the same as the one we have prepared. Yours is much
8
longer than ours.
9
MS. MENNINGER: Your Honor, I'm happy to address all
10
of the ones on mine. I certainly am also happy to take
11
direction from the Court regarding issues that you believe to
12
still be of more interest.
13
THE COURT: As I say, I've read your papers. I would
14
be pleased to hear anything you want to add that you think is
15
not covered or you want to respond or anything like that.
16
MS. MENNINGER: Your Honor, one of the largest and
17
most significant pieces to us are the assertions by plaintiff
18
that her own communications with law enforcement are somehow
19
protected by --
20
THE COURT: I'm prepared to deal with that.
21
MS. MENNINGER: The second one, your Honor, and it
22
relates somewhat to the issues already presented on the pro hac
23
motions, are our requests for the fee agreements with all of
24
plaintiff's various 15 or so lawyers who purport to be
25
representing her. Your Honor, I can find no case law that
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1
suggests that the agreements are privileged, as plaintiff
2
argues. She has refused to identify when these individuals
3
began their representations, the nature of the representations.
4
THE COURT: There is a little confusion here, at least
5
in my mind, as to what we are talking about. I certainly
6
understand the two gentlemen whose applications I have just
7
dealt with and the third person, who I take it is affiliated
8
with the Boies firm.
9
Obviously, over time the plaintiff has probably
10
conferred with other lawyers. But who cares? Let's assume she
11
has talked to 20 more lawyers. You want all those retainers?
12
That doesn't make any sense. What is the universe we are
13
talking about?
14
MS. MENNINGER: Your Honor, I certainly understand all
15
of the members of the Boies firm that currently represent her.
16
The third individual, if I understand correctly, is a gentleman
17
by the name of Stan Pottinger. He is a lawyer of some renown.
18
He is also an author of best-selling books. He is listed quite
19
frequently on plaintiff's privilege log as being part and
20
parcel of advice being given to her on, quote/unquote, media
21 issues.
22
THE COURT: That is one.
23
MS. MENNINGER: Your Honor, there are other persons
24
listed on their privilege log. Many are listed as counsel for
25
plaintiff, but others are listed. Attorney giving advice to
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victim's --
2
THE COURT: Is what you want the retainer agreements,
3
if there are any, whatever the arrangements are, with anybody
4
on the privilege log that is listed as rendering advice?
5
MS. MENNINGER: Yes, your Honor. That, I think, would
6
be appropriate because some of our biggest issues concern the
7
privilege log.
8
THE COURT: I understand.
9
What else?
10
MS. MENNINGER: Your Honor, we have asked for, but
11
been denied by plaintiff, her own deposition testimony in the
12
Florida action. In that case the Court entered a confidential
13
order --
14
THE COURT: I'm prepared to deal with it.
15
MS. MENNINGER: Your Honor, the next topic are
16
plaintiff's medical records.
17
THE COURT: I think I understand that. There is one
18
thing, though. Are there any pre-'99 medical records?
19
MS. MENNINGER: Your Honor, the case law is quite
20
clear that injuries that were preexisting --
21
THE COURT: I'm sorry. Excuse me. Go ahead.
22
MS. MENNINGER: Plaintiff has alleged that the
23
defamation of this action triggered or caused her to reflect
24
back upon her alleged sexual abuse. She has also alleged, for
25
example, that many, several, three, I think, at last count, or
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1
four individuals had sexually abused her prior to ever meeting
2
Mr. Epstein.
3
If she has evidence that she already was suffering
4
from depression or some type of mental health disorder before
5
meeting our client, Ms. Maxwell, or Mr. Epstein, then her
6
flashbacks, if you will, could be related to other incidents
7
that she has put out in the press. And she, I believe, has
8
also told the press that she was in a drug rehabilitation
9
facility at the time that she met Mr. Epstein.
10
Obviously, to the extent she was under the influence
11
of drugs, which is what she has told the press, at the time she
12
met him, she persisted in being addicted to drugs during the
13
time that she knew Mr. Epstein, and it certainly relates to all
14
of her requests for, I believe she has requested $30 million in
15
damages, your Honor, not just from the defamation, but also
16
harkening back to what she claims were her years as a sex abuse
17
victim.
18
THE COURT: What's the basis of your statement that we
19
will call it the flashback?
20
MS. MENNINGER: Your Honor, I believe --
21
THE COURT: Because, quite frankly, I was unaware of
22
that. Is that my error? Are you telling me something that's
23
not quite right?
24
MS. MENNINGER: Your Honor, I believe that is what
25
plaintiff has alleged in her complaint. If you can give me a
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=== Page 14 ===
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moment. To the extent she is now alleging she suffers from
2
emotional distress from any preexisting --
3
THE COURT: That's from the defamation.
4
MS. MENNINGER: She claims it's from the defamation.
5
However, your Honor, if she has preexisting conditions that
6
were truly the cause of whatever emotional injury she claims
7
that she now possesses --
8
THE COURT: Correct me if I'm wrong, and perhaps
9
plaintiff will make it clear, my understanding is that the
10
injuries alleged result from the claim of the alleged
11
defamation, period.
12
MS. MENNINGER: Your Honor, she has claimed emotional
13
distress from the defamation, yes. We are requesting evidence
14
that would show that she has preexisting emotional conditions.
15
THE COURT: Not from the defamation.
16
MS. MENNINGER: Not from the defamation. From the
17
many, many other things that have occurred in her life
18
predating even her meeting Mr. Epstein and Ms. Maxwell, as she
19
has told the press, not because we told the press that.
20
Your Honor, it is difficult, if not impossible, to
21
address her claimed $30 million emotional distress from a
22
defamation statement that was a denial of her allegations
23
versus any emotional distress or emotional conditions she
24
already had before any such statement was made.
25
Similarly, your Honor, we have asked for discovery of
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her claimed prior sexual abuse. She has, again, put in the
2
press a number of statements regarding that, and I can't
3
imagine that it is to the extent she claims privacy now, those
4
might be relevant in our case both on credibility and also
5
damage issues.
6
Your Honor, we have asked for a lot of other
7
interrogatories and documents that go to her damage claims, her
8
education records, her work history. She has refused to answer
9
any questions before where she has worked. She has refused to
10
answer any questions about where she went to school. All of
11
these are appropriate under the local rule for interrogatories.
12
Finally, your Honor, we have asked for her contracts
13
with media. She has refused to disclose those. She has
14
refused to disclose her tax returns that show all of the
15
payments that she has received from various media sources.
16
THE COURT: I take it your view of any funds from the
17
media would operate to reduce her damages.
18
MS. MENNINGER: Your Honor, it also shows her motive
19
and bias in bringing this case. To the extent she has been
20
paid for her stories to the media, which she has, she has
21
admitted that she has been paid hundreds of thousands of
22
dollars for giving these stories to the media.
23
But to the extent that she is now bringing this
24
defamation claim, if she is still either planning to receive
25
more money from the media, she has a motive and bias to make
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1
her story consistent with her previous stories. She has
2
claimed $5 million in lost wages, your Honor. This is a person
3
who has worked primarily as a waitress in the last 15 years,
4
until her media sensational story was purchased from her by
5
some British press.
6
THE COURT: Anything else?
7
MS. MENNINGER: Your Honor, the other issues are
8
addressed in our papers. We have highlighted her incomplete
9
production on several fronts and her refusal to answer any
10
interrogatories. So I would rest on my papers with respect to
11
the other arguments. Thank you.
12
MS. McCAWLEY: Thank you, your Honor. I'd like to be
13
very clear here, your Honor. Discovery production, I've tried
14
to do that in our papers. But listening to opposing counsel
15
I'm concerned maybe she hasn't reviewed the documents we have
16
produced. We have clearly produced all of the media
17
communications she has, including records --
18
THE COURT: All the media.
19
MS. McCAWLEY: All of the media communications. She
20
has issued wildly broad requests in this case which we have
21
complied with. We ran over 200 search terms. Her request No.
22
5 alone seeks communications with over 100 individuals. And we
23
have complied, your Honor. This is coming from the defendant
24
who until Monday night, when you directed her to produce
25
privileged information, has only produced two e-mails in this
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=== Page 17 ===
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16
G4LMGIUC
1
case.
2
Your Honor, we have complied with our production. We
3
have produced the materials that she is saying we have not
4
produced. It's incorrect. We have produced her school records
5
that we have. We have produced her tax records that we have.
6
We have produced all of those items that we have.
7
With respect to her medical records I am going to
8
direct you to the case that is cited in our brief as the Evanko
9
case and it was a similar circumstance to here. It was a Title
10
VII case where there were emotional distress damages being
11
alleged and the Court found that the other side could not have
12
carte blanche ruling over all of her medical records from the
13
time she was born to the present. We met and conferred on two
14
hours on their discovery requests, your Honor. We agreed to
15
produce all of her medical records that we had from 1999 to
16
2002 and anything else we had that was related to the sexual
17
abuse she endured at the hands of the defendant and
18
Mr. Epstein. We have agreed to produce those.
19
We have already started producing those records from
20
the various doctors, from the treating physicians. Those are
21
in their production. Should they be entitled to things that
22
happened prior to that? Absolutely not, your Honor. They are
23
not entitled to a full-scale production of everything that's
24
happened in this young lady's life. She was abused by these
25
individuals. She shouldn't be reabused by having to disclose
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=== Page 18 ===
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17
G4LMGIUC
1
things that happened prior to her time with them. Your Honor,
2
we do object to the production of that material.
3
THE COURT: The flashback allegation.
4
MS. McCAWLEY: I think what she may be referring to, I
5
have not heard that term used, I think what she may be
6
referring to was the fact that this is a defamation claim and
7
the person who defamed my client was also an abuser, we allege.
8
So when she is defamed by the person who abused her and that
9
abuser is calling her a liar, that caused her significant
10
emotional distress. It's different than if some other
11
individual that she had not had contact with called her a liar.
12
When she is talking about a flashback, maybe that's what she is
13
referring to, but we don't have the word flashback anywhere in
14
our complaint.
15
THE COURT: No. I made that up.
16
There will be no claim by the plaintiff that the
17
defamation caused her distress by making her aware or as a
18
result of the prior sexual abuse.
19
MS. McCAWLEY: The sexual abuse by the defendants?
20
THE COURT: No.
21
MS. McCAWLEY: Sexual abuse by others.
22
THE COURT: Yes.
23
MS. McCAWLEY: No. Sexual abuse that relates to the
24
Epstein period, yes.
25
THE COURT: That I understand.
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=== Page 19 ===
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18
G4LMGIUC
1
MS. McCAWLEY: I think we are on the same page.
2
THE COURT: I think talking about the earlier period.
3
MS. McCAWLEY: Prior to Epstein, no, no, she doesn't
4
have a claim with respect to that.
5
THE COURT: Anything else?
6
MS. McCAWLEY: Your Honor, I just want to point out
7
again that our production -- you asked us to complete that. We
8
have gone through and run over 200 search terms. We have
9
produced all of those communications she has had with all of
10
those individuals. The things that we have not produced are
11
the criminal investigation records. I know your Honor is going
12
to address that. I would like to be very clear there.
13
The point there is that she has said in the motion to
14
stay papers that she filed Tuesday that she needs to have that
15
information so she can decide whether she is going to be
16
asserting her Fifth Amendment privilege. Truthful testimony
17
shouldn't have to be crafted, your Honor. She shouldn't need
18
to know what agency is investigating her in order to decide
19
whether or not she is going to be asserting her Fifth Amendment
20
privilege.
21
We do have with us, your Honor, for an in camera
22
submission, if you would like it. That is the way that courts
23
have dealt with this issue in the past. When there is a claim
24
from an agency that the disclosure of that investigation could
25
harm the investigation, we can submit that to you for in camera
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=== Page 20 ===
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19
G4LMGIUC
1
review so you are aware of the ongoing investigation. But it
2
is my view that that needs to be protected.
3
As you probably know, the history of these cases with
4
Mr. Epstein, there were a variety of things that went on in
5
that investigation, so there is reason to keep an investigation
6
in this situation protected so that they can properly
7
investigate and move forward with that without being inhibited
8
by other individuals. Your Honor, I would ask that that remain
9
protected. It's covered by her very, very broad requests,
10
which is why we had to lodge those objections. I would
11
appreciate your Honor considering our arguments with respect to
12
that issue.
13
The other things, your Honor, that she has raised is,
14
for example, she had asked for the Epstein settlement agreement
15
and that was one of the things that she asked for. We agreed
16
to produce that if we got the waiver from Mr. Epstein because
17
we can't produce it without that waiver.
18
I believe that covers it, your Honor. If you have any
19
questions, I would be happy to answer them.
20
THE COURT: Thanks very much.
21
Thank you all for all the clarification that you've
22
given me. I much appreciate it.
23
With respect to the retainers and the dates of
24
representation, that information will be provided for any
25
attorney that's listed on the privilege log.
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=== Page 21 ===
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20
G4LMGIUC
1
The plaintiff has told me that they have now supplied
2
all the education and employment records that they have. I
3
think if there is any question about that, if the defense is
4
skeptical, I would ask the counsel for the plaintiffs to make
5
that statement on the record, not necessarily here, but by way
6
of a statement to the Court and principally to the defendant.
7
On the question of residences, that's, in my view, not
8
a contention interrogatory because of the nature of this case.
9
I think it's more like listing witnesses. So I would say that
10
the plaintiff should supply all residences.
11
The Dershowitz deposition will be produced under the
12
confidentiality provision. As I read what I've been given,
13
it's to be held in confidence and it will remain in confidence,
14
but it will be produced.
15
Yes, the tax returns should be produced. 15 years
16
seems like -- I see. Ok. 15 years.
17
The medical records of the period '99 to 2002 will be
18
produced and the plaintiff will indicate whether that
19
production is complete or, if it isn't complete, when it will
20
be complete.
21
As for the pre-'99 medical records, based on where we
22
are at the moment, I do not believe that those are relevant.
23
Because the damage issue relates, in my view, solely to the
24
defamation. If that changes in any way, I will revisit that
25
issue.
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=== Page 22 ===
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21
G4LMGIUC
1
The criminal investigation. Any materials that the
2
plaintiff has with respect to any criminal investigations will
3
be turned over except for any statements made by the plaintiff
4
to law enforcement authority and those statements, if there are
5
such, will be submitted in camera, and I will review them.
6
I hope that clears up our problems. Tell me if I have
7
failed in my effort to do SO. Yes, ma'am.
8
MS. MENNINGER: Your Honor, two quick things, I think.
9
With respect to medical records, we also certainly believe that
10
the period from the time the statement was made in January 2015
11
until the present, because she has claimed emotional distress
12
from that defamation --
13
THE COURT: Sure, yes.
14
MS. MENNINGER: The problem is, we have asked through
15
interrogatory what were the names of the medical providers
16
because they have not disclosed who her medical providers were.
17
So there is no way for us to tell whether the records in fact
18
have been sought from and produced with respect to each of
19
those medical providers. I will say that other records in the
20
possession of plaintiff lists other doctors who they have not
21
asked for records from or releases.
22
THE COURT: Let's see if we can clear that up.
23
MS. McCAWLEY: We have disclosed the names. She has
24
those names. We have also disclosed records, the more recent
25
records. We have not contested that.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00028871

=== Page 23 ===
App.-0826
22
G4LMGIUC
1
With respect to the interrogatories, your Honor ruled
2
on this previously, but there is a local Rule 33.3, which is
3
why we didn't serve interrogatories in this case at this point.
4
She is deposing the plaintiff in two weeks, next week, whenever
5
it is, and can certainly ask those questions as well. But we
6
have disclosed the names of the providers.
7
MS. MENNINGER: They have not, your Honor.
8
THE COURT: Look. Wait just a moment. You two are
9
lawyers. Now, that is not an issue about which you should
10
differ. Go over in the corner right now, both of you, and
11
let's make it clear who is telling me the right story. Now.
12
I take it that I misunderstood the colloquy and that
13
this matter has been resolved.
14
MS. McCAWLEY: Your Honor, I think there was a
15
misunderstanding with respect --
16
THE COURT: I was sure.
17
MS. McCAWLEY: Dr. Olsen has been noticed for
18
deposition in Colorado already. In my view, we have disclosed
19
the doctors. Ms. Menninger says that there is other doctors
20
that have been disclosed in documents that we have not yet
21
listed to her. I think in discovery we are finding
22
additional --
23
THE COURT: You think you may not have discovered that
24
your client has had some doctors --
25
MS. McCAWLEY: In the past. We are talking about
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00028872

=== Page 24 ===
App.-0827
23
G4LMGIUC
1
years and years ago. The recent doctors we have disclosed they
2
have noticed for deposition.
3
THE COURT: What else?
4
MS. MENNINGER: Your Honor, with respect to the
5
employment and education records, as you heard plaintiff say,
6
she has disclosed, quote/unquote, what she has. Under local
7
rule 33.3, we are allowed to ask for the names of witnesses
8
with knowledge at the outset of the case, and they might be
9
custodians of records. We asked her who have been your
10
employers. She won't tell us who her employers have been. She
11
has just gone through her computer and say if I have an
12
employment record I'll give it to you, but I am not going to
13
tell you who her employers were.
14
THE COURT: She will.
15
MS. MENNINGER: Same thing with the education records.
16
We asked her to list where she had gone to school and tell us
17
where it is. She won't do it. Those are the things where my
18
skepticism arises from.
19
Largely, to the extent your Honor has ordered the
20
production of whatever materials, criminal investigation
21
materials that were not to be submitted in camera, those were
22
the ones that involved plaintiff's statements, we would like
23
the other materials that they have brought with them today to
24
give to your Honor that do not encompass their client's
25
statements to law enforcement.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00028873

=== Page 25 ===
App.-0828
24
G4LMGIUC
1
THE COURT: I don't know whether there are such. Is
2
it possible that nothing in this lawsuit is clear? Well, I
3
tried to make it clear what should be produced and what
4
shouldn't. Anything that has been submitted to any law
5
enforcement officer by the plaintiff I will take in camera.
6
Anything other than that with respect to any law enforcement
7
should be produced.
8
MS. MENNINGER: Thank you, your Honor.
9
THE COURT: Thank you, all. I think we have the
10
pleasure of your company -- do we need you next week? We are
11
up to date, aren't we?
12
MS. McCAWLEY: Your Honor, we have a motion with
13
respect to our discovery that's set for next Thursday.
14
THE COURT: That's fine.
15
MS. McCAWLEY: Just before we adjourn, because
16
Mr. Cassell had a question, and I just want to make sure that I
17
understand, with respect to tomorrow's deposition, they are
18
entitled to attend but have to leave the room if confidential
19
information is disclosed?
20
THE COURT: That's where we are at the moment, unless
21
it changes.
22
MR. PAGLIUCA: Your Honor, with regard to next
23
Thursday, both Ms. Menninger and I have other matters that are
24
previously scheduled and it would be impossible for us to take
25
care of those matters and be here at the same time. I'm
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00028874

=== Page 26 ===
App.-0829
25
G4LMGIUC
1
wondering what the Court would like to do about that.
2
THE COURT: First of all, you know how we play this
3
game. You don't ask me first. You ask your opponent first.
4
Have you done that?
5
MR. PAGLIUCA: I have not, your Honor.
6
THE COURT: Will you?
7
MR. PAGLIUCA: I certainly will, your Honor.
8
THE COURT: Now.
9
MR. PAGLIUCA: Absolutely.
10
THE COURT: You can go over to the corner, too.
11
MR. PAGLIUCA: I think we need a corner bar on this,
12
your Honor.
13
Ms. McCawley, I'm wondering if we can get a mutually
14
convenient date to hear that matter as opposed to next
15
Thursday.
16
MS. McCAWLEY: Of course.
17
MR. PAGLIUCA: That was simple enough, your Honor.
18
MS. McCAWLEY: Your Honor, one more thing. I didn't
19
realize that my counsel can submit that stipulation to you
20
because that case has been settled --
21
THE COURT: If I get something that closes that case
22
and I get the affidavit that there are no other matters in
23
which they have any claims or defenses relating to any of these
24
statements, that will do it.
25
MS. McCAWLEY: Your Honor, so I know, if we can submit
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00028875

=== Page 27 ===
App.-0830
26
G4LMGIUC
1
that by fax this afternoon, will they be able to attend the
2
deposition tomorrow?
3
THE COURT: I would think so, if I think those are
4
adequate representations and so on. The statement from a
5
mediator doesn't mean anything to me. Something that has a
6
court sign to it. That I understand. But the mediator saying
7
that it's settled doesn't work for me.
8
MR. CASSELL: Your Honor, maybe Mr. Edwards could
9
briefly explain Florida procedure. The case has been
10
dismissed, but it does not require a Court's signature.
11
Mr. Edwards can elaborate more fully on that.
12
MR. EDWARDS: Sure. If I may. There are two ways in
13
which a case can be dismissed in Florida. One is by way of a
14
court order. The other is by way of a stipulation. That is
15
what was done. There was a stipulation of dismissal signed by
16
both parties, that being the plaintiff and the defendants and
17
counsel, that has been done and that was dismissed.
18
THE COURT: That's filed in the case.
19
MR. EDWARDS: That's filed in the case and filed in
20
the court.
21
THE COURT: Do you have a copy of that?
22
MR. EDWARDS: I can get a copy of it immediately.
23
THE COURT: Give it to the defense. If they have any
24
problems, they will let me know. That sounds all right to me.
25
What do I know about Florida except that it's flat and hot.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00028876

=== Page 28 ===
App.-0831
27
G4LMGIUC
1
Your representation sounds right.
2
MR. EDWARDS: Additionally, just with respect to the
3
affidavit, there needs to be an affirmation that we have no
4
other claims that relate to the statements in this case. Is
5
that what we are saying?
6
THE COURT: I think it should be broader than that. I
7
think it should be -- look. I don't think it would be
8
appropriate if there is any possibility for either of you to
9
being a party. That's what I'm after. And having any
10
proceedings against you arising out of the situation with the
11
plaintiff. I think it would be inappropriate for you to be
12
counsel if you have the potentiality of being a party, either
13
plaintiff or defendant, in any proceedings. If I get an
14
affidavit saying that you're unaware of any claims against you
15
or any intention to make a claim arising out of the
16
circumstances surrounding this lawsuit, that should be broad.
17
I think that would satisfy me.
18
MR. EDWARDS: Ok.
19
MR. CASSELL: I'll be filing those materials this
20
afternoon, your Honor. My plan is to attend --
21
THE COURT: The defense has a thought on this.
22
MR. PAGLIUCA: Your Honor, I am looking at documents
23
from Florida. One is a docket sheet captioned: Epstein V.
24
Brad Edwards and Paul G. Cassell, Lower Tribune Cases 15 000072
25
which shows that that matter is still pending. There is
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00028877

=== Page 29 ===
App.-0832
28
G4LMGIUC
1
another case, as I understand it, Edwards V. Epstein and
2
Rothstein, which is also pending. I can confer about this,
3
your Honor.
4
THE COURT: Let's do this. When do you plan to return
5
to the snow fields?
6
MR. PAGLIUCA: There is still snow on the ground, your
7
Honor. Well, Friday night or Saturday morning is my current
8
plan.
9
THE COURT: That's great. Whatever the applicants
10
have on this subject, please turn it over. You all can work
11
out how you are going to do that. Turn it over to the defense.
12
And if there is anything you want me to do, I would be prepared
13
to do it tomorrow. But that way I hope we can get it cleared
14
up.
15
MS. McCAWLEY: Your Honor, we do have the deposition
16
of the defendant scheduled for tomorrow.
17
THE COURT: Then everybody will be having a nice time
18
together. Maybe you can all go out and have lunch, have a
19
drink, and exchange these documents and go away happy. Not
20
likely, but perhaps, depending on where you have lunch.
21
MS. McCAWLEY: Thank you, your Honor.
22
THE COURT: Anything else?
23
MS. MENNINGER: Nothing.
24
THE COURT: Thank you, all.
25
One thing. I would appreciate it if counsel would get
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00028878

=== Page 30 ===
App.-0833
29
G4LMGIUC
1
together on my request for additional coverage in the
2
confidentiality agreement.
3
MS. McCAWLEY: Sure.
4
THE COURT: Thanks a lot.
5
o0o
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00028879


c1: EFTA00028990
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028990.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
SEALED
UNITED STATES OF AMERICA
:
INDICTMENT
:
- V. -
:
19 Cr.
:
JEFFREY EPSTEIN,
:
:
19 CRIM
490
Defendant.
:
:
X
COUNT ONE
(Sex Trafficking Conspiracy)
The Grand Jury charges:
OVERVIEW
1.
As set forth herein, over the course of many
years, JEFFREY EPSTEIN, the defendant, sexually exploited and
abused dozens of minor girls at his homes in Manhattan, New
York, and Palm Beach, Florida, among other locations.
2.
In particular, from at least in or about 2002, up
to and including at least in or about 2005, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
recruited, minor girls to visit his mansion in Manhattan, New
York (the "New York Residence") and his estate in Palm Beach,
Florida (the "Palm Beach Residence") to engage in sex acts with
him, after which he would give the victims hundreds of dollars
in cash. Moreover, and in order to maintain and increase his
supply of victims, EPSTEIN also paid certain of his victims to
recruit additional girls to be similarly abused by EPSTEIN. In
EFTA00028990

=== Page 2 ===
this way, EPSTEIN created a vast network of underage victims for
him to sexually exploit in locations including New York and
Palm Beach.
3.
The victims described herein were as young as 14
years old at the time they were abused by JEFFREY EPSTEIN, the
defendant, and were, for various reasons, often particularly
vulnerable to exploitation. EPSTEIN intentionally sought out
minors and knew that many of his victims were in fact under the
age of 18, including because, in some instances, minor victims
expressly told him their age.
4.
In creating and maintaining this network of minor
victims in multiple states to sexually abuse and exploit,
JEFFREY EPSTEIN, the defendant, worked and conspired with
others, including employees and associates who facilitated his
conduct by, among other things, contacting victims and
scheduling their sexual encounters with EPSTEIN at the New York
Residence and at the Palm Beach Residence.
FACTUAL BACKGROUND
5.
During all time periods charged in this
Indictment, JEFFREY EPSTEIN, the defendant, was a financier with
multiple residences in the continental United States, including
the New York Residence and the Palm Beach Residence.
6.
Beginning in at least 2002, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
2
EFTA00028991

=== Page 3 ===
recruited, dozens of minor girls to engage in sex acts with him,
after which EPSTEIN paid the victims hundreds of dollars in
cash, at the New York Residence and the Palm Beach Residence.
7.
In both New York and Florida, JEFFREY EPSTEIN,
the defendant, perpetuated this abuse in similar ways. Victims
were initially recruited to provide "massages" to EPSTEIN, which
would be performed nude or partially nude, would become
increasingly sexual in nature, and would typically include one
or more sex acts. EPSTEIN paid his victims hundreds of dollars
in cash for each encounter. Moreover, EPSTEIN actively
encouraged certain of his victims to recruit additional girls to
be similarly sexually abused. EPSTEIN incentivized his victims
to become recruiters by paying these victim-recruiters hundreds
of dollars for each girl that they brought to EPSTEIN. In so
doing, EPSTEIN maintained a steady supply of new victims to
exploit.
The New York Residence
8. At all times relevant to this Indictment, JEFFREY
EPSTEIN, the defendant, possessed and controlled a multi-story
private residence on the Upper East Side of Manhattan, New York,
i.e., the New York Residence. Between at least in or about 2002
and in or about 2005, EPSTEIN abused numerous minor victims at
the New York Residence by causing these victims to be recruited
to engage in paid sex acts with him.
3
EFTA00028992

=== Page 4 ===
9. When a victim arrived at the New York Residence,
she typically would be escorted to a room with a massage table,
where she would perform a massage on JEFFREY EPSTEIN, the
defendant. The victims, who were as young as 14 years of age,
were told by EPSTEIN or other individuals to partially or fully
undress before beginning the "massage." During the encounter,
EPSTEIN would escalate the nature and scope of physical contact
with his victim to include, among other things, sex acts such as
groping and direct and indirect contact with the victim's
genitals. EPSTEIN typically would also masturbate during these
sexualized encounters, ask victims to touch him while he
masturbated, and touch victims' genitals with his hands or with
sex toys.
10. In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash. Victims typically were paid hundreds
of dollars in cash for each encounter.
11. JEFFREY EPSTEIN, the defendant, knew that many of
his New York victims were underage, including because certain
victims told him their age. Further, once these minor victims
were recruited, many were abused by EPSTEIN on multiple
subsequent occasions at the New York Residence. EPSTEIN
sometimes personally contacted victims to schedule appointments
at the New York Residence. In other instances, EPSTEIN directed
4
EFTA00028993

=== Page 5 ===
employees and associates, including a New York-based employee
("Employee-1"), to communicate with victims via phone to arrange
for these victims to return to the New York Residence for
additional sexual encounters with EPSTEIN.
12. Additionally, and to further facilitate his
ability to abuse minor girls in New York, JEFFREY EPSTEIN, the
defendant, asked and enticed certain of his victims to recruit
additional girls to perform "massages" and similarly engage in
sex acts with EPSTEIN. When a victim would recruit another girl
for EPSTEIN, he paid both the victim-recruiter and the new
victim hundreds of dollars in cash. Through these victim-
recruiters, EPSTEIN gained access to and was able to abuse
dozens of additional minor girls.
13. In particular, certain recruiters brought dozens
of additional minor girls to the New York Residence to give
massages to and engage in sex acts with JEFFREY EPSTEIN, the
defendant. EPSTEIN encouraged victims to recruit additional
girls by offering to pay these victim-recruiters for every
additional girl they brought to EPSTEIN. When a victim-
recruiter accompanied a new minor victim to the New York
Residence, both the victim-recruiter and the new minor victim
were paid hundreds of dollars by EPSTEIN for each encounter. In
addition, certain victim-recruiters routinely scheduled these
5
EFTA00028994

=== Page 6 ===
encounters through Employee-1, who sometimes asked the
recruiters to bring a specific minor girl for EPSTEIN.
The Palm Beach Residence
14. In addition to recruiting and abusing minor girls
in New York, JEFFREY EPSTEIN, the defendant, created a similar
network of minor girls to victimize in Palm Beach, Florida,
where EPSTEIN owned, possessed and controlled another large
residence, i.e., the Palm Beach Residence. EPSTEIN frequently
traveled from New York to Palm Beach by private jet, before
which an employee or associate would ensure that minor victims
were available for encounters upon his arrival in Florida.
15. At the Palm Beach Residence, JEFFREY EPSTEIN, the
defendant, engaged in a similar course of abusive conduct.
When a victim initially arrived at the Palm Beach Residence, she
would be escorted to a room, sometimes by an employee of
EPSTEIN's, including, at times, two assistants ("Employee-2" and
"Employee-3") who, as described herein, were also responsible
for scheduling sexual encounters with minor victims. Once
inside, the victim would provide a nude or semi-nude massage for
EPSTEIN, who would himself typically be naked. During these
encounters, EPSTEIN would escalate the nature and scope of the
physical contact to include sex acts such as groping and direct
and indirect contact with the victim's genitals. EPSTEIN would
also typically masturbate during these encounters, ask victims
6
EFTA00028995

=== Page 7 ===
to touch him while he masturbated, and touch victims' genitals
with his hands or with sex toys.
16. In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash. Victims typically were paid hundreds
of dollars for each encounter.
17. JEFFREY EPSTEIN, the defendant, knew that certain
of his victims were underage, including because certain victims
told him their age. In addition, as with New York-based
victims, many Florida victims, once recruited, were abused by
JEFFREY EPSTEIN, the defendant, on multiple additional
occasions.
18. JEFFREY EPSTEIN, the defendant, who during the
relevant time period was frequently in New York, would arrange
for Employee-2 or other employees to contact victims by phone in
advance of EPSTEIN's travel to Florida to ensure appointments
were scheduled for when he arrived. In particular, in certain
instances, Employee-2 placed phone calls to minor victims in
Florida to schedule encounters at the Palm Beach Residence. At
the time of certain of those phone calls, EPSTEIN and Employee-2
were in New York, New York. Additionally, certain of the
individuals victimized at the Palm Beach Residence were
contacted by phone by Employee-3 to schedule these encounters.
7
EFTA00028996

=== Page 8 ===
19. Moreover, as in New York, to ensure a steady
stream of minor victims, JEFFREY EPSTEIN, the defendant, asked
and enticed certain victims in Florida to recruit other girls to
engage in sex acts. EPSTEIN paid hundreds of dollars to victim-
recruiters for each additional girl they brought to the Palm
Beach Residence.
STATUTORY ALLEGATIONS
20. From at least in or about 2002, up to and
including in or about 2005, in the Southern District of New York
and elsewhere, JEFFREY EPSTEIN, the defendant, and others known
and unknown, willfully and knowingly did combine, conspire,
confederate, and agree together and with each other to commit an
offense against the United States, to wit, sex trafficking of
minors, in violation of Title 18, United States Code, Section
1591 (a) and (b).
21. It was a part and object of the conspiracy that
JEFFREY EPSTEIN, the defendant, and others known and unknown,
would and did, in and affecting interstate and foreign commerce,
recruit, entice, harbor, transport, provide, and obtain, by any
means a person, and to benefit, financially and by receiving
anything of value, from participation in a venture which has
engaged in any such act, knowing that the person had not
attained the age of 18 years and would be caused to engage in a
8
EFTA00028997

=== Page 9 ===
commercial sex act, in violation of Title 18, United States
Code, Sections 1591 (a) and (b) (2).
Overt Acts
22. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a. In or about 2004, JEFFREY EPSTEIN, the
defendant, enticed and recruited multiple minor victims,
including minor victims identified herein as Minor Victim-1,
Minor Victim-2, and Minor Victim-3, to engage in sex acts with
EPSTEIN at his residences in Manhattan, New York, and Palm
Beach, Florida, after which he provided them with hundreds of
dollars in cash for each encounter.
b. In or about 2002, Minor Victim-1 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the New York Residence over a
period of years and was paid hundreds of dollars for each
encounter. EPSTEIN also encouraged and enticed Minor Victim-1
to recruit other girls to engage in paid sex acts, which she
did. EPSTEIN asked Minor Victim-1 how old she was, and Minor
Victim-1 answered truthfully.
C. In or about 2004, Employee-1, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
9
EFTA00028998

=== Page 10 ===
a telephone call to Minor Victim-1 in order to schedule an
appointment for Minor Victim-1 to engage in paid sex acts with
EPSTEIN.
d. In or about 2004, Minor Victim-2 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the Palm Beach Residence over a
period of years and was paid hundreds of dollars after each
encounter. EPSTEIN also encouraged and enticed Minor Victim-2
to recruit other girls to engage in paid sex acts, which she
did.
e. In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-2 in order to schedule an
appointment for Minor Victim-2 to engage in paid sex acts with
EPSTEIN.
f. In or about 2005, Minor Victim-3 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the Palm Beach Residence over a
period of years and was paid hundreds of dollars for each
encounter. EPSTEIN also encouraged and enticed Minor Victim-3
to recruit other girls to engage in paid sex acts, which she
did. EPSTEIN asked Minor Victim-3 how old she was, and Minor
Victim-3 answered truthfully.
10
EFTA00028999

=== Page 11 ===
g.
In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-3 in Florida in order to
schedule an appointment for Minor Victim-3 to engage in paid sex
acts with EPSTEIN.
h.
In or about 2004, Employee-3 placed a
telephone call to Minor Victim-3 in order to schedule an
appointment for Minor Victim-3 to engage in paid sex acts with
EPSTEIN.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Sex Trafficking)
The Grand Jury further charges:
23. The allegations contained in paragraphs 1
through 19 and 22 of this Indictment are repeated and realleged
as if fully set forth within.
24. From at least in or about 2002, up to and
including in or about 2005, in the Southern District of New
York, JEFFREY EPSTEIN, the defendant, willfully and knowingly,
in and affecting interstate and foreign commerce, did recruit,
entice, harbor, transport, provide, and obtain by any means a
person, knowing that the person had not attained the age of 18
years and would be caused to engage in a commercial sex act, and
did aid and abet the same, to wit, EPSTEIN recruited, enticed,
harbored, transported, provided, and obtained numerous
11
EFTA00029000

=== Page 12 ===
individuals who were less than 18 years old, including but not
limited to Minor Victim-1, as described above, and who were then
caused to engage in at least one commercial sex act in
Manhattan, New York.
(Title 18, United States Code, Sections 1591 (a),
(b) (2), and 2.)
FORFEITURE ALLEGATIONS
25. As a result of committing the offense alleged in
Count Two of this Indictment, JEFFREY EPSTEIN, the defendant,
shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 1594 (c) (1), any property, real and
personal, that was used or intended to be used to commit or to
facilitate the commission of the offense alleged in Count Two,
and any property, real or personal, constituting or derived from
any proceeds obtained, directly or indirectly, as a result of
the offense alleged in Count Two, or any property traceable to
such property, and the following specific property:
a.
The lot or parcel of land, together with its
buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 9 East 71st Street, New York, New
York, with block number 1386 and lot number 10, owned by
Maple, Inc.
12
EFTA00029001

=== Page 13 ===
Substitute Asset Provision
26. If any of the above-described forfeitable
property, as a result of any act or omission of the defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a
third person;
(c) has been placed beyond the jurisdiction of the Court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot
be subdivided without difficulty;
it is the intent of the United States, pursuant to 21 U.S.C.
§ 853 (p) and 28 U.S.C. $ 2461 (c), to seek forfeiture of any
other property of the defendant up to the value of the above
forfeitable property.
(Title 18, United States Code, Section 1594; Title 21,
United States Code, Section 853 (p); and
Title 28, United States Code, Section 2461.)
Jumbas
Heopy S. Bunn
FOREPERSON
GEOFFREY S. BERMAN
United States Attorney
13
EFTA00029002

=== Page 14 ===
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
JEFFREY EPSTEIN,
Defendant.
INDICTMENT
(18 U.S.C. $$ 371, 1591 (a), (b) (2),
and 2)
GEOFFREY S. BERMAN
United States Attorney
Foreperson
14
EFTA00029003


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c3: VOL00008
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c0:
=== Page 1 ===
From:
)"
To: Laura Menninger <Imenninger@hmflaw.com>,
)"
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP
(ceverdell@cohengresser.com)" <ceverdell@cohengresser.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Fri, 12 Mar 2021 18:44:07 +0000
Inline-Images: image001.jpg
Counsel,
The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger <lmenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
EFTA00028183

=== Page 2 ===
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 3:44 PM
To:
)
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you. Is that the only index of physical evidence available?
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
EFTA00028184

=== Page 3 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
Code:
Best,
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
)
is
)
V.
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
)
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
EFTA00028185

=== Page 4 ===
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00028186

=== Page 5 ===
EFTA00028187


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=== Page 1 ===
From:
To:
Subject: RE: travel approval request
Date: Tue, 28 May 2019 13:49:21 +0000
Importance: Normal
Just a quick question regarding the cancelled trip for this Thursday (5/30/19). Was this trip booked through CWT by phone
or online? If either scenario, I'll need the cancelled record locator to see if it's refundable, and ask them to send me a
document stating it was refunded to your government travel card. Thanks.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Sunday, May 26, 2019 2:31 PM
To:
Subject: FW: travel approval request
Hi
I have a trip scheduled for this week that just got final approval late Friday night, so I made reservations on E2 this
weekend and wanted to let you know in case you need to do things for authorization and/or if you want to consolidate
the reservations (unfortunately I couldn't figure out how to do everything together so ended up with three different
reservations-l'm sorry about that!).
Because I had a previously-scheduled trip to San Francisco on this Thursday,
approved my second leg flight to go
straight there (rather than coming back to NYC). The reservations I made are:
Tuesday, May 28, flight from LGA to PBI
-
JetBlue, departing 1:27 p.m. (arriving 4:25 p.m.)
Tuesday, May 28, hotel in West Palm Beach
-
Hilton West Palm Beach, from May 28 to May 30
Thursday, May 30, flight from PBI to SFO (with layover in ATL)
-
Delta, departing 5:30 a.m. (arriving ATL at 7:12 a.m., departing ATL at 8:10 a.m.) arriving SFO at 10:22 a.m.
If these need to be canceled and re-booked as one itinerary, that's totally fine, I just didn't want to wait until the day
before to at least make the reservations.
Last question is, I had to cancel my New York to San Francisco flight previously scheduled for Thursday morning (because
there were no flights late enough to be after our final interviews in Florida on Wednesday, or early enough to get me back
to New York on Thursday) which incurred a $100 cancellation fee. Is it possible to be reimbursed for that?
Please let me know if any questions at all, apologies again for any inconvenience, and thanks as always.
EFTA00027756

=== Page 2 ===
From:
Sent: Friday, May 24, 2019 21:24
To:
Cc:
Subject: Re: travel approval request
Approved
Sent from my iPad
On May 24, 2019, at 7:21 PM,
wrote:
-- I have previously-scheduled travel to San Francisco next Thursday for a wedding, and the way our victims have
asked to schedule our meetings for our Florida trip, there's no flight back to New York after we expect the interviews to
end on Wednesday (so I couldn't get back to NYC to catch my Thursday morning flight). Is it permissible for me to just
book the second leg of the work trip straight to San Francisco, rather than back to New York? I'd have to take a 5:30
a.m. flight but that way we could do the interviews with all the victims we'd like to meet with. Sorry for any
inconvenience but wanted to check - thank you!
From:
Sent: Friday, May 24, 2019 16:01
To:
Subject: RE: travel approval request
Thanks
- have a great weekend.
From:
Sent: Friday, May 24, 2019 15:55
To:
Cc:
>;
is
Subject: Re: travel approval request
All approved.
Sent from my iPad
On May 24, 2019, at 2:57 PM,
wrote:
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling
allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will
either be me and
or
and
,
but we wanted to ask for permission now either way so we weren't
doing it super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to
reserve a conference room at the hotel for the interviews, please.
EFTA00027757

=== Page 3 ===
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors
for sexual activity,
and I would like to please request permission to travel for approximately three days next
week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday
night and return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West
Palm Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return
on Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00027758

=== Page 4 ===
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=== Page 1 ===
From:
To:
Subject: FW:
article
Date: Thu, 10 Dec 2020 15:49:28 +0000
From:
Sent: Thursday, December 10, 2020 10:48 AM
To:
Cc:
Subject:
article
This is the article I mentioned the other day describing comments by
:
Counsel to the Acting U.S. Attorney
United States Attorney's Office
Southern District of New York
EFTA00027441


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=== Page 1 ===
From: "Russell, Kelsey D"
To:
Cc: "Sahni, Anjan"
"Stoddart, Allison"
, "Chau, Truong"
Subject: Privileged & Confidential - JPMorgan Chase
Date: Wed, 02 Sep 2020 21:26:29 +0000
Attachments: 2020-09-02_SDNY_Letter.pdf
Privileged & Confidential
I hope this email finds you well. As discussed during our August 10, 2020 call, please find attached a cover letter
accompanying JPMorgan's production in response to the August 11, 2019, August 16, 2019, September 3, 2019, and
October 9, 2019 grand jury subpoenas. As with previous productions, you will receive a separate email with instructions
to download the production. You will receive the password under separate cover.
Please let me know if you have any questions or would like to discuss.
Thanks very much,
Kelsey
Kelsey D Russell I WilmerHale
7 World Trade Center
250 Greenwich Street
New York, NY 10007 USA
(t)
Please consider the environment before printing this email.
This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not
the intended recipient, please notify us immediately-by replying to this message or by sending an email to postmaster@wilmerhale.com-and destroy all
copies of this message and any attachments. Thank you.
For more information about WilmerHale, please visit us at http://www.wilmerhale.com.
EFTA00028533


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=== Page 1 ===
TD-D0J-00000001,TEXT\001\TD-D0J-00000001.txt
TD - DOJ - 00000306,TEXT\001\TD-D0J-00000306.txt
TD-D0J-00000466,TEXT\001\TD-D0J-00000466.txt
EFTA00028819


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
)"
)"
Subject: Re: JE FOIA review in SDNY (?)
Date: Wed, 12 Jun 2019 02:27:09 +0000
Importance: Normal
Checking
Sent from my iPhone
On Jun 11, 2019, at 10:14 PM,
wrote:
We heard second-hand from a colleague that our civil division is processing a FOIA request relating to the Epstein
investigation (but unclear on specifics). Obviously this is the first we've heard of it, and understandable that there
wouldn't be cross-communication since the criminal investigation is still covert (and not widely known even among
assistants), but it still is a little puzzling in terms of why such a review would be venued here. Do you who the right
person would be in civil to ask about FOIA processes there? We're happy to reach out if that's appropriate, or if you
prefer to do it at the supervisor level certainly no objection from us.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00029018


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=== Page 1 ===
From:
To:
Subject: FW: MCC Interviews - Update
Date: Tue, 13 Aug 2019 15:29:48 +0000
I confirmed this with
:
There are at least 7 officers (not counting
and
)
and 2 supervisors that should have been aware that Epstein
did not have a cellmate on Friday, but did not reassign him one. We reached out to 3 of those officers yesterday, but they
refused to meet with us without their union rep.
From:
Sent: Tuesday, August 13, 2019 11:23 AM
To:
Cc:
;
Subject: RE: MCC Interviews - Update
Can we confirm that one of the co's who would not meet with FBI without union rep was the CO who did not assign a new
cellmate to JE when the old cellmate was moved out?
From:
Sent: Monday, August 12, 2019 8:49 PM
To:
Cc:
;
Subject: MCC Interviews - Update
This afternoon, OIG, FBI, and the USAO-SDNY conducted voluntary interviews with the following MCC employees. The
interviews were each about 2 hours. A high-level summary of each is below.
Interview of
-
is an operations lieutenant at MCC, and is responsible for overseeing the operations of the prison during
his duty shifts.
-
On the morning of August 10, 2019,
arrived at 5:30 a.m. to relieve the outgoing lieutenant,
At 6:33 a.m.,
heard a radio call for medical staff at the SHU.
responded to the SHU, where he saw
Officer
who said that Epstein had hung himself.
went into Epstein's cell, and Epstein was on the
ground, on top of two mattresses, and Officer
was performing CPR.
then started CPR until
medical staff came.
-
asked Officer
where Epstein's cellmate was, and she said he left, and that he didn't have one
overnight.
told Officer
that she knew Epstein was supposed to have a cellmate, and Officer
stuttered, then said she didn't know.
- Officer
admitted to
that they did not conduct the 3 a.m. and 5 a.m. counts; and Officer
said
"we messed up" and "we didn't do the counts" and "it's not her fault."
was not aware the cameras were
not working in SHU.
Interview of
-
has worked at the MCC since May 2019, but has a lengthy BOP career. He's the institution duty officer
and has responsibilities relating to multiple units. Among other things, he helps inmates make telephone calls,
EFTA00027104

=== Page 2 ===
including legal calls and calls from within the SHU.
had spoken to Epstein briefly on multiple occasions. Epstein asked for assistance making a personal
call.
got Epstein his pin number a few days before Epstein's death, but Epstein had not activated it.
took Epstein to the SHU showers to make the phone call. Epstein told
he was calling his mother.
dialed a number provided by Epstein, and
overhead Epstein making small talk with a male
individual.
whose shift was over, left Epstein with two SHU officers - Officer
and a male officer -
,
and told them to return Epstein to his cell after 15 minutes. Because Epstein's pin was not activated,
dialed the number on the MCC line for legal conversations, which is not recorded.
-
was not on duty when Epstein's body was discovered. He says he was not aware that Epstein's cellmate
had moved, and he did not know the camera system was not working.
Interview of
-
oversees the whole prison, and all of the lieutenants of particular units (such as SHU) report to him.
-
stated that on multiple occasions following Epstein's apparent attempted suicide, he spoke to the
lieutenants that report to him about how Epstein needed a cellmate at all times. All of those commands were
made orally.
-
said they were aware that
had court, which was not out of the ordinary. No one briefed him
on the fact that
personal property was being collected or that he was moved.
-
did not learn that Epstein's cellmate moved until after Epstein's apparent suicide was discovered.
-
was not working when the evening rounds and counts occurred. He was aware there was work
being done on the videos but wasn't told why.
Today, FBI and OIG agents also attempted to interview
and
(the officers who discovered
Epstein), but they did not agree to speak with agents and agents were unable to
(An individual who
the agents believe was
answered the phone but then claimed he wasn't
and hung up.) Agents also
contacted four of the officers on duty on Friday August 9, 2019, but they would not speak with agents without their union
representatives. We will continue conducting interviews over the next few days. Finally, FBI has not completed their
analysis of the video evidence yet.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00027105


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=== Page 1 ===
From:
To:
Subjec
has invited new collaborators to 'Epstein Death' folder on Box
Date: Mon, 18 Nov 2019 21:09:30 +0000
has invited 1 collaborator(s) to 'Epstein Death' folder:
Epstein Death
Epstein Death
Collaborated Folder
View Folder
Collaborators Invited:
About Box Privacy Policy . Edit Notification Settings . 900 Jefferson Avenue, Redwood City, CA 94063, USA
C 2019
This is an official notification from the USAfx File Exchange system.
EFTA00029191


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=== Page 1 ===
Event: Accepted: Epstein discovery deadline
Start Date: 2019-10-31 21:00:00 +0000
End Date: 2019-10-31 21:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-07-31 16:55:31 +0000
Date Modified: 2019-07-31 16:55:31 +0000
Priority: 5
DTSTAMP: 2019-07-31 16:15:55 +0000
Attendee:
EFTA00028076


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=== Page 1 ===
LexisNexis®
21-58, United States of America V. Maxwell
US Circuit Court of Appeals - 02nd Circuit
This case was retrieved on 04/21/2021
Header
Case Number: 21-58
Date Filed: 01/12/2021
Date Full Case Retrieved: 04/21/2021
Status:
Misc: (0) 0: ; Appeal
Participants
Litigants
Attorneys
United States of America
Assistant U.S. Attorney
Appellee USA
Appellee USA
United States Attorney's Office for the Southern District of New
York
United States Attorney's Office for the Southern District of New
York
New York, NY 10007
AttorneyLabel:
Esq., -
Appellee USA
United States Attorney's Office for the Southern District of New
York
United States Attorney's Office for the Southern District of New
York
New York, NY 10007
AttorneyLabel:
Appellee USA
United States Attorney's Office for the Southern District of New
York
United States Attorney's Office for the Southern District of New
York
New York, NY 10007
AttorneyLabel:
Assistant U.S. Attorney
EFTA00027565

=== Page 2 ===
Page 2 of 2
21-58, United States of America V. Maxwell
Litigants
Attorneys
Appellee USA
United States Attorney's Office for the Southern District of New
York
United States Attorney's Office for the Southern District of New
York
New York, NY 10007
AttorneyLabel:
Esq., Assistant U.S. Attorney
Appellee USA
United States Attorney's Office for the Southern District of New
York
United States Attorney's Office for the Southern District of New
York
New York, NY 10007
AttorneyLabel:
Proceedings
Availability
Date
#
Proceeding Text
Details
04/13
/2021
SEALED SUPPORTING EXHIBIT TO OPPOSITION, on
behalf of Appellee United States of America in 21-58, 21-
770, FILED. Service date 04/12/2021 by
email.[3077576][66] [21-58, 21-770]
Free
04/15
/2021
MOTION, to be relieved as attorney, on behalf of
Appellant Ghislaine Maxwell in 21-58, 21-770, FILED.
Service date 04/15/2021 by CM/ECF. [3078116] [21-58,
21-770]
Free
04/15
CERTIFICATE OF SERVICE, for Notice of Motion to
/2021
Withdraw As Appellate Counsel and Affirmation of
In Support Of Motion To Be
Relieved As Counsel, on behalf of Appellant Ghislaine
Maxwell in 21-58, 21-770, FILED. Service date
04/15/2021 by CM/ECF.[3079010] [21-58, 21-770]
Free
04/16
NOTICE OF APPEARANCE AS ADDITIONAL
/2021
COUNSEL, on behalf of Appellee USA United States of
America in 21-770, 21-58, FILED. Service date
04/16/2021 by CM/ECF. [3079459] [21-770, 21-58]
04/16
ATTORNEY
for Appellee United States of
/2021
America, in case 21-58
for Appellee United
States of America, in case 21-770
ADDED.[3079848]
[21-58, 21-770]
Free
04/19
/2021
REPLY TO OPPOSITION. on behalf of Appellant
Ghislaine Maxwell in 21-770, 21-58, FILED. Service date
04/19/2021 by CM/ECF.[3080288][76] [21-770, 21-58]
Copyright © LexisNexis CourtLink, Inc. All Rights Reserved.
*** THIS DATA IS FOR INFORMATIONAL PURPOSES ONLY ***
End of Document
EFTA00027566


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
)"
Subject: RE: draft response to Epstein defense preservation requests
Date: Thu, 08 Aug 2019 20:36:19 +0000
Attachments: 2019-08-05_JE_letter_to_defense_re_preservation_requests.ebddocx.rc.docx
Sorry for the delay. Combined edits from both of us, attached. Can you take a look and clean up - we would then like to
give
at least the option of weighing in before we send to defense counsel.
From:
Sent: Thursday, August 8, 2019 11:44 AM
To:
(USANYS)
is
(USANYS)
Cc:
in
)
Subject: RE: draft response to Epstein defense preservation requests
Wanted to bump this from Tuesday, especially since I know you guys are out tomorrow - hopefully we can send it out
today? Happy to incorporate any edits etc. Thanks.
From:
)
Sent: Tuesday, August 06, 2019 15:01
To:
(USANYS)
in
(USANYS)
Cc:
is
)
Subject: RE: draft response to Epstein defense preservation requests
This has been in the works for a little while, due to various other things that have come up in the interim, but we didn't
want it to get lost given the discovery motion schedule. The attached is based on our conversations with
including
his email with suggested language for the prefatory language, and responds to the two attached defense letters. Happy to
discuss anytime and to incorporate comments and suggestions.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00027917


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=== Page 1 ===
From:
"
)"
To:
Cc:
"rweingarten@steptoe.com"
)"
)"
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Date: Thu, 11 Jul 2019 23:15:02 +0000
Importance: Normal
Attachments: US_v_Epstein,_19_Cr_490_(RMB),_Government_response_to_sealing_request.pdf
To the Chambers of Judge Berman:
Attached please find a courtesy copy of the Government's response to the defendant's letter motion relating to sealing,
filed this evening in the above-captioned case. Defense counsel is copied.
Thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00028417


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=== Page 1 ===
From:
To:
Subject: FW: Prisoner-related Questions USA V. Maxwell
Date: Mon, 01 Nov 2021 21:24:10 +0000
From:
Sent: Monday, November 1, 2021 5:07 PM
To:
Subject: Fwd: Prisoner-related Questions USA V. Maxwell
More information you need for the issues raised today in court
Deputy United States Marshal
Southern District of New York
Due to Ghislaine Maxwell's enhanced security measures at MDC Brooklyn (which has been determined by BOP), the
USMS must transport the prisoner before all other court productions for the day because her movement later in the day
would lead to delays in other in-custody court productions that have been scheduled. The USMS does not provide
additional clothing to prisoners when they are produced for Court. The clothing of prisoners transported from BOP are
given to them by the facility; not the USMS. Lastly, the USMS does not provide prisoners with utensils for the food they
come over from MDC with. The USMS does not provide prisoners with their lunches as the facility gives it to them
without utensils. Usually, the lunch items prisoners have been given do not require the use of utensils.
EFTA00029286


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein
Date: Fri, 12 Jul 2019 11:24:14 +0000
Importance: Normal
Today we are interviewing one employee
referenced in indictment), the Today Show NY victim,
and two Florida victims.
We are also likely to file bail response at 5 pm, the current deadline. Epstein is supposed to submit his financial
info under seal by 9 am. We had asked for 24 hours from receiving that info to put in our brief, but judge has not
ruled - may be waiting to see what they put in.
We are aiming to get you a draft between 12 and 1.
Sent from my iPhone
EFTA00029521


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=== Page 1 ===
From:
"
To:
Subject: FW: Epstein
Date: Wed, 10 Jul 2019 20:54:19 +0000
Importance: Normal
Just go this email.
From: Joseph Walsh
Sent: Wednesday, July 10, 2019 4:51 PM
To:
Subject: Epstein
Is Former U.S. Attny'. Joyce Vance correct in saying 'because there is no statute of limitations w/ these crimes;
there is no limitation on the Obstruction of Justice tenets of the case as well.' ? Thanks, jw
https://www.amazon.com/dp/1983209848/ref=sr_1_2?s=books&uie=UTF8&qid=1529548656&sr=1-
2&keywords=11%2F11+-+Retribution++Jos.+R.+Walsh
EFTA00028361


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=== Page 1 ===
From:
"
)"
To:
"
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
,
)"
Subject: RE: Maxwell testifying witness 3500
Date: Mon, 21 Jun 2021 13:59:11 +0000
Thanks!
From:
(USANYS) [Contractor]
Sent: Monday, June 21, 2021 8:56 AM
To:
)
Cc:
is
(USANYS)
is
Subject: RE: Maxwell testifying witness 3500
Hey
These materials are all saved in their respective locations - witness and 3500 folders.
Thanks,
From:
Sent: Saturday, June 19, 2021 7:50 PM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
i
Subject: Maxwell testifying witness 3500
Hi
Would you please save the attached pdfs in the respective witness and 3500 folders for the testifying witnesses in each
pdf's file name on the Epstein share drive?
Thanks,
EFTA00029140


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=== Page 1 ===
From:
)"
To: Jill Greenfield
Cc:
)"
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Date: Tue, 06 Oct 2020 19:20:41 +0000
Inline-Images: image001.jpg; image002.png; image003.png
Hi Jill,
Following up on our conversation, I was wondering if you had any updates on the testing issue we discussed. Our team is
planning to get tested tomorrow in order to make sure we have results before flying, but please let us know as soon as
you can if that timing is a problem for some reason.
In addition, my cell phone number is
and my phone will be working while I'm traveling. I'll also be
reachable by email.
Thanks,
From:
Sent: Monday, October 5, 2020 10:36 AM
To: Jill Greenfield ;
Cc: Louise Scott
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Hi Jill,
Thank you very much for letting us know. We want to make sure your client is as comfortable as possible. It would be very
useful to our investigation to have more members of our team present for the interviews, but we will of course defer to
her comfort level. Let's discuss on our call tomorrow and make a final plan for the interviews then.
The process on our end does not require that we be tested before we depart.
and I are asymptomatic, have never
been symptomatic, and have not come into contact with anyone who was symptomatic or a known carrier, so we have not
been tested. That said, if you/your client would like us to get tested before we leave the U.S., there is a clinic near our
office that has been able to provide results within a day or two, so we could go there to get tested this week.
Best,
Assistant United States Attorney
Southern District of New York
From: Jill Greenfield
Sent: Monday, October 5, 2020 6:18 AM
To:
is
Cc: Louise Scott
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Hi
I spoke to my client over the weekend. I I suspect you will get rather more out of her if the number is kept to 2. I think otherwise she
may be overwhelmed.
As part of the process at your end will you be taking tests before leaving the US?
Kind Regards,
Jill
Jill Greenfield
Partner
EFTA00028129

=== Page 2 ===
Click here for information relating to Covid-19 business impacts
f
in
From:
Sent: Friday, October 2, 2020 9:44 AM
To: Jill Greenfield
is
)
Cc: Louise Scott
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Thanks very much, Jill.
We are obtaining a waiver of the quarantine requirement from the UK government so that we will not be required to
isolate. If your client is not comfortable with four of us attending, we will of course defer to her preference and have a
smaller number travel to the UK. Please let us know what she prefers.
Meeting at your office works for us, thank you. We do not yet know whether the Met Police will need to be in the
building, but we will let you know as soon as we learn those details.
Is there a good time on Monday or Tuesday of next week when we might schedule a call?
Best,
Assistant United States Attorney
Southern District of New York
From: Jill Greenfield
Sent: Friday, October 2, 2020 4:40 AM
To:
is
Cc: Louise Scott
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Many thanks
I will need to check with my client re 4 members of your party attending. Are you not having to isolate?
I can organise meeting rooms at my office.
I am happy to have a call next week to finalise matters.
Could you confirm if the Met police will also need to be in the building?
Kind regards,
Jill
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
EFTA00028130

=== Page 3 ===
f
in
From:
Sent: Thursday, October 1, 2020 9:21 PM
To: Jill Greenfield
is
)
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Thanks, Jill. A few follow-up questions for you:
First, we are obtaining clearance for four members of our team to travel to London. Those would be
myself, FBI
Special Agent
and FBI Task Force Office
All four of us were on the video call with your client the
other day, so she has seen our faces. Please let us know if she is not comfortable with that group, so that we can plan
accordingly.
Second, would you like to meet at your offices, or would you like us to look into other arrangements?
Third, would you be available for a call next week in preparation for our trip?
Best,
Assistant United States Attorney
Southern District of New York
From: Jill Greenfield
Sent: Thursday, October 1, 2020 3:42 PM
To:
Cc:
Subject: Re: Epstein [FFW-DOCS.FID6003375]
Great, I should warn you that we may be going into lockdowns in London. Very tricky
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
f
in
Sent from my iPhone
On 1 Oct 2020, at 19:37,
wrote:
Hi Jill,
Thanks very much. Let's block off those dates for now and plan to meet then, if that's okay, and we will let you know if
for some reason those dates are not approved or if that's an issue.
Thanks,
From: Jill Greenfield
Sent: Thursday, October 1, 2020 2:29 PM
EFTA00028131

=== Page 4 ===
To:
Cc:
Subject: Re: Epstein [FFW-DOCS.FID6003375]
Hi. Apologies. I pressed and have just had confirmation for 14,15 and 16 if possible?
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
Sent from my iPhone
On 1 Oct 2020, at 17:31,
wrote:
Hi Jill,
Thanks for letting us know. Do you think you'll be able to let us know today about the dates we've proposed?
Apologies for pestering, but we can't move forward with travel arrangements without them, and the process we're
initiating requires a considerable amount of lead time before traveling once we start it.
Thanks very much,
From: Jill Greenfield
Sent: Wednesday, September 30, 2020 2:16 PM
To:
Cc:
Subject: Re: Epstein [FFW-DOCS.FID6003375]
I'm aware. That's fine. They may also need to be in the building.
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
Sent from my iPhone
On 30 Sep 2020, at 19:11,
wrote:
Thanks very much, Jill. In addition, we have learned that our embassy would be required to notify the Met Police that
we are meeting with your client. We wanted to check with you to make sure you are okay with us making that
notification, which we are told is standard practice for interviews conducted abroad.
Thanks,
Sent from my iPhone
On Sep 30, 2020, at 1:26 PM, Jill Greenfield
wrote:
EFTA00028132

=== Page 5 ===
Ok - understood - let me find out
thanks
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
From:
Sent: Wednesday, September 30, 2020 6:22 PM
To: Jill Greenfield
Cc:
is
(USANYS)
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Hi Jill,
With apologies for pressing, I wanted to follow up on these dates. As it turns out, we'll need proposed dates before
we can move any further in the approval process. If you could please let us know whether these dates work for you
as soon as you can, we'd be very grateful.
Thanks,
From:
Sent: Tuesday, September 29, 2020 3:29 PM
To: 'Jill Greenfield'
Cc:
is
(USANYS)
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Hi Jill,
Thanks very much for taking the time to (virtually) meet with us last week, we very much appreciated the chance to
speak with your client. We have been working on seeking approvals for a potential meeting with your client in
London in the coming weeks. Although we won't know whether the meeting is ultimately approved until we
complete the process, we are working on the issue in the hopes of making this possible.
It would be very helpful to us in the approval process to be able to propose specific dates for a meeting. We would
suggest that we set aside three days for successive meetings, if that works. Would you and your client be available
for meetings on October 14th, 15th, and 16th? Alternatively, we would propose the 20th, 21ˢᵗ, and 22nd.
If you could please let us know your availability, we'd very much appreciate it, and we'll keep you updated when we
have more information.
Thanks very much,
From: Jill Greenfield
Sent: Wednesday, September 16, 2020 4:04 AM
To:
Cc:
is
(USANYS)
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Hi
I rather assumed that you were not able to travel given the inherent difficulties with that and how you would be able to meet
with people in the UK without having to self-isolate first.
Let me know when is good for you for a video conference call.
Kind regards
Jill
EFTA00028133

=== Page 6 ===
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
From:
Sent: Wednesday, September 16, 2020 12:23 AM
To: Jill Greenfield
Cc:
is
(USANYS)
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Jill,
Thanks very much for reaching out. We would be glad to schedule a videoconference with your client to discuss her
questions and concerns. Are there particular dates and times that would work best for you and your client?
We are in the process of looking into the current rules on travel for government employees, and will let you know
as soon as we have more information. Our team is willing to travel if we are permitted to, but we're not yet certain
whether that is possible.
Thank you,
Assistant United States Attorney
Southern District of New York
From:
Sent: Tuesday, September 15, 2020 2:18 PM
To: Jill Greenfield
Cc:
is
V.
(USANYS)
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Jill,
We're very gratified to hear that your client is willing to speak with us, and we would be happy to answer her
questions as best we can.
In terms of logistics, I recently moved to a new position within our office and so the current team has been
updated - the investigation is now being handled by
and
whom you've spoken with previously, as
well as new addition
who also has extensive experience in these types of cases-they're all copied
here. They'll follow up with you to schedule a time for the discussion, and they can let you know the latest status
on any anticipated approvals for Government foreign travel (which I believe currently is prohibited for us,
otherwise we would be happy to travel to meet in person).
Thank you very much for your continued assistance in connection with our investigation, and I expect
and
will be in touch shortly as well.
thanks again,
From: Jill Greenfield
Sent: Tuesday, September 15, 2020 13:46
To:
Subject: Epstein [FFW-DOCS.FID6003375]
Hi
EFTA00028134

=== Page 7 ===
My client would like to speak to you to discuss matters. This would be in the form of her asking how you would manage this.
She did also ask if you were travelling to the UK at any point so. I said not but if I am wrong please do let me know.
Thanks
Jill
Jill Greenfield
Partner
Click here for information relating to Covid-19 business impacts
Fieldfisher, Riverbank House,
www.fieldfisher.com
We do not intend to change our bank details. If you receive any communication that any of our bank details have changed, telephone us and speak to your contact at our
office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstances.
This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact the sender immediately, destroy the email
and any attachments and do not use, copy, store or disclose this email and any attachments for any purpose. Fieldfisher does not accept service of documents by electronic
means without express prior agreement.
For details about what personal information we collect and why, please see our Privacy Notice on our website at www.fieldfisher.com.
Fieldfisher is the trading name of Fieldfisher LLP, a limited liability partnership registered in England and Wales (registered number OC318472) and is authorised and
regulated by the Solicitors' Regulation Authority. A list of its members and their professional qualifications is available at its registered office, Riverbank House,
We use the term partner to refer to a member of Fieldfisher LLP or an employee or consultant with equivalent standing or qualifications.
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=== Page 1 ===
From:
"
To:
Subject: Crim report
Date: Wed, 11 Sep 2019 15:06:38 +0000
Attachments: Short_Update_Rpt_12-7-18.docx
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
EFTA00029308


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=== Page 1 ===
From:
To:
Subject: 19-2221 United States of America V. Epstein "Certified Copy Mandate ISSUED"
Date: Wed, 21 Aug 2019 14:09:44 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 08/21/2019
Case Name:
United States of America V. Epstein
Case Number: 19-2221
Document(s): Document(s)
Docket Text:
CERTIFIED COPY OF ORDER, dated 08/21/2019, determining the appeal to SDNY, ISSUED. [Mandate]
[2637838] [19-2221]
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: Certified Copy Mandate ISSUED
Original Filename: mandate.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=08/21/2019] [FileNumber=2637838-0]
[c8d0d6bed95163911cbf4027990af2ec05835d19c4cf3a7e67f9d6fd336dcb075a5c5041959da5196b7ba2d4437b9
c2b6045e8969f9f79bbf57afdcbd24653dd]|
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=== Page 1 ===
From:
Sent:
Tuesday May 27 2008 12:24 PM
To:
Subject:
RE: Mtg
We have spoken to the parents and a family attorney for
but she does not
want to speak with us. The Agents will keep at it this week in hopes that they
will be able to locate and interview her. I'll email you as soon as I have more
to report.
It appears
We spoke with her mother and asked her to have
contact us.
1018
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=== Page 1 ===
LexisNexis®
21-58, United States of America V. Maxwell
US Circuit Court of Appeals - 02nd Circuit
This case was retrieved on 04/14/2021
Header
Case Number: 21-58
Date Filed: 01/12/2021
Date Full Case Retrieved: 04/14/2021
Status:
Misc: (0) 0: ; Appeal
Proceedings
Availability
Date
#
Proceeding Text
Details
04/09
NOTICE OF HEARING DATE ACKNOWLEDGMENT,
/2021
on behalf of Appellant Ghislaine Maxwell, FILED.
Service date 04/09/2021 by CM/ECF. Note: Listed counsel
must log on to CM/ECF in order to view the attachment.
[3074153] [21-58]
Free
04/12
/2021
MOTION, to seal document, on behalf of Appellee USA
United States of America in 21-58, 21-770, FILED.
Service date 04/12/2021 by CM/ECF. [3075291] [21-58,
21-770]
Free
04/12
/2021
OPPOSITION TO MOTION, on behalf of Appellee USA
United States of America in 21-770, 21-58, FILED.
Service date 04/12/2021 by CM/ECF. [3075763] [21-770,
21-58]
Free
04/13
ACKNOWLEDGMENT AND NOTICE OF
/2021
APPEARANCE, on behalf of Appellant Ghislaine
Maxwell, FILED. Service date 04/13/2021 by
CM/ECF.[3076442] [21-58]
Free
04/13
/2021
MOTION ORDER, granting motion to seal document filed
by Appellee USA United States of America in 21-58,
FILED. [3076657][65] [21-58, 21-770]
Copyright © LexisNexis CourtLink, Inc. All Rights Reserved.
*** THIS DATA IS FOR INFORMATIONAL PURPOSES ONLY ***
End of Document
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=== Page 1 ===
From: "
(USANYS)"
To: "
(USANYS)"
Cc: "
(USANYS) 4"
Subject:
Date: Mon, 01 Feb 2021 15:04:49 +0000
Embedded: RE:
; RE:
(1).msg; RE:
(2).msg;
Re:
EFTA00029250


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=== Page 1 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Citibank
Legal Service Intake Unit (LSI)
One Court Square, 31st Floor
Long Island City, NY 11120
Fax: (347)809-6937
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: 10:00 a.m.
to testify and give evidence in regard to an alleged violation of :
18 U.S.C. §§ 201, 371, 1001, 1346, 1519, 2
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:
Please see attached rider. Personal appearance is not required if the requested records are (1) produced on or
before the return date to Assistant U.S. Attorney
of the United States Attorney's Office, 1 St.
Andrew's Plaza, New York, NY 10007. Tel:
, email:
, and (2)
accompanied by an executed copy of the attached Declaration of Custodian of Records. Ref No. 2019R01059.
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 17, 2019
Geoffey S. with
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
IIIIII UNITED COURT
Assistant United States Attorney
FOR
One St. Andrew's Plaza
THE
RICT
YORK
New York, New York 10007
or
NEW
Telephone:
Email:
rev. 02.01.12
EFTA00027214

=== Page 2 ===
RIDER
(Grand Jury Subpoena to Citibank, dated August 17, 2019)
Ref. No. 2019R01059
REQUEST:
For the following account, and any other account controlled by the account holder of one of the below
accounts:
Please provide any and all documents, to include, but not limited to those identified below, for the period
January 1, 2019 until the present:
a. Account opening documents, including applications and signature cards;
b. Records of account holders for debit and credit cards liked to the accounts;
c. Account statements and ledgers;
d. Images of checks (both front and back) deposited in account;
e. Images of canceled checks (both front and back) drawn on account;
f. Images of cashier's checks (both front and back) and depositing bank account information;
g. Account deposit slips, withdrawal slips, debit & credit memos, and cash tickets;
h. Detailed wire transfer records, ACH transfer records (including routing/account numbers funds
transferred to/from), money orders, and traveler's check records;
i. All credit card and line of credit records, including, but not limited to: applications, monthly
statements, billing slips, and records evidencing the source of payment (copies of checks, ACH
records (including routing/account numbers funds transferred to/from), or cash received slips);
j. Customer information associated with the account, including name(s), address(es), telephone
number(s), e-mail address(es), and any other identifying or contact information.
INSTRUCTIONS FOR PRODUCTION OF DOCUMENTS:
1. All transactions-based information, include wire and ACH transfers, withdrawals/deposits,
charges/payments, and bank account activity should be provided in electronic spreadsheet
format (either Microsoft Excel or similarly compatible format). Specifically:
a. For wires and other types of transfers, the account holder name, account number, and bank
name of both the originator and beneficiary of the transaction should be clearly stated in
separate fields.
b. Cash and check transactions should be indicated within a transaction type field.
i. Check transactions should include the name of the payee in the recipient
field. Additionally, check images should be attached in graphic data files in a commonly
readable, non-proprietary format with the highest image quality maintained, and named in
a manner that uniquely associates them with the relevant transaction record(s).
ii. Cash withdrawals should be indicated with CASH written in the recipient field.
iii. Cash deposits should be indicated with CASH written in the sender/originator field.
EFTA00027215

=== Page 3 ===
c. Field headers should be included for each column of data, and a data dictionary or other
explanation of the contents of each column provided.
2. Where more than one account is being requested, each account's transaction records should be
returned in a separate file.
3. All document images are to be produced in electronic PDF format. Where images of checks,
deposit slips, withdrawal slips, or cash tickets are being produced, they should be produced no
more than two per page.
4. In lieu of an appearance you may comply with this subpoena by providing the requested
information, along with a business records certification pursuant to Fed. R. Evid. 803(6) to
Assistant U.S. Attorney
of the United States Attorney's Office, 1 St. Andrew's
Plaza, New York, NY 10007. Tel:
, email:
EFTA00027216

=== Page 4 ===
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 17, 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.
EFTA00027217

=== Page 5 ===
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 17, 2019
Re:
Grand Jury Subpoena
This letter describes the procedure for requesting reimbursement for subpoenaed records.
12 CFR part 219 (subpart A), issued by the Board of Governors of Federal Reserve System under section
1115 of the Right to Financial Privacy Act (12 U.S.C. $ 3415), sets the rates and conditions for reimbursement of
costs directly incurred by financial institutions in assembling or providing customer financial records to a
government authority pursuant to the Act. No costs are reimbursable if the records are those of a corporation or a
partnership comprised of more than five individuals.
If reimbursement is authorized, and the estimated billing to the government will exceed $500, advance
permission is necessary from
at
If the subpoenaed records indicated on the rider are eligible for reimbursement, please complete section B
of the enclosed form OBD-211, which will serve as your invoice, and return it with a copy of the subpoena to the
following address:
U.S. Attorney's Office - SDNY
Accounts Payable
86 Chambers Street, 3rd floor
New York, NY 10007
(212) 637-2662
Please send your invoice to the above address within 60 days of the submission of the subpoenaed records.
If no invoice is received within 120 days, funds will not be available to pay the invoice.
Thank you for your cooperation in this matter.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
By:
/s/
Assistant United States Attorney
Enclosure: OBD- 211
EFTA00027218


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: FW: United States V. Maxwell
Date: Mon, 26 Oct 2020 19:50:57 +0000
Attachments: 2020.10.25 xwell_Letter.pdf_SDNY_GM_00332929-SDNY_GM_00332931.pdf
SDNY_GM_00332932-SDNY_GM_00332935.pdf;SDNY_GM_00332936-
SDNY_GM_00332942.pdf
Below is Chris's email. The materials we sent are attached. We are happy to discuss whenever best for you both. Thanks!
From: Christian Everdell
Sent: Monday, October 26, 2020 1:59 AM
To:
(USANYS)
>; Mark S. Cohen
>; Laura
Menninger
>; Jeff Pagliuca
>; Bobbi Sternheim
(
Cc:
is
)
Subject: RE: United States V. Maxwell
Thank you,
We request unredacted copies of these reports and the notes. Please let us know why you think these redactions are
warranted given the protective order.
Regards,
Chris
From:
(USANYS) [mailto:
Sent: Sunday, October 25, 2020 12:07 PM
To: Christian Everdell; Mark S. Cohen; Laura Menninger; Jeff Pagliuca; Bobbi Sternheim
(
)
Cc:
);
)
Subject: United States V. Maxwell
Counsel,
Please see attached.
Best,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00029147

=== Page 2 ===
EFTA00029148


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: RE: Noel/Thomas FOIA Disclosure
Date: Thu, 24 Jun 2021 15:07:29 +0000
Attachments:062421_So_Ordered_Letter_Granting_Extension_Times_v_BOP,_20cv833.pdf
All,
Per the attached, the Court granted the one-week extension in the Epstein FOIA. So the production is now due next
Friday, July 2. Please let me know if you foresee any issues with that date.
Please also let me know if you need anything else from me in terms of the processes we discussed yesterday. We are
working with BOP to finalize the production, but please let me know if I should take steps beyond that (e.g., letting
additional people know about the production, etc.).
Also, does anyone want to see the production before it goes out?
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 6:08 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Thank you,
I have no edits, subject to anything else
have.
From:
(USANYS)
Sent: Wednesday, June 23, 2021 6:00 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Hi all,
The Times consented to the one-week request. I think it is likely the Court will approve it. I plan to file the attached letter,
which includes the changes we discussed on the phone, around 6:30. Please let me know if you have any issues or
concerns. I'll let you know as soon as the Court rules.
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 5:12 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
EFTA00029063

=== Page 2 ===
Hi all,
We now have a 5:45 call scheduled with the Times. Please let me know before then if there's any other info I can share
with them. I'm attaching a draft extension request letter here for review. Please let me know if this looks okay, or if we
need to discuss anything,
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 3:46 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Hi all,
I just spoke with
, who spoke with
I can make this request, but I am not sure it will be successful. Before I
speak to the Times about it, I need to know a little bit more info about what I can share with the Times and what is going
on. Could someone please give me a call at
? I need to connect with the Times as soon as possible because
we will need to put in the request today to PAE.
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 3:02 PM
To:
(USANYS)
Cc:
(USANYS)
V.
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Hi
Could I give you a quick call on this?
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 2:57 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: Noel/Thomas FOIA Disclosure
Hi
We understand you had been planning to make the Noel/Thomas FOIA disclosure on Friday. We just ran this by
and she'd like you to ask for a brief (1-2 week) extension to enable us to confer internally regarding the interviews, which
were just completed, to confirm we agree they've fulfilled that requirement of their deferred prosecution agreements.
She's going to speak with
about it as well. Is this doable?
Thanks,
EFTA00029064

=== Page 3 ===
Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
Desk
Cell
EFTA00029065


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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: Breaking News: A federal judge denied Jeffrey Epstein bail, rejecting his request to stay in his
mansion under guard until his sex-trafficking trial.
Date: Thu, 18 Jul 2019 23:19:28 +0000
There should be two. He appealed twice.
From:
Sent: Thursday, July 18, 2019 6:58 PM
To:
Subject: RE: Breaking News: A federal judge denied Jeffrey Epstein bail, rejecting his request to stay in his mansion under
guard until his sex-trafficking trial.
l'll grab it, but thank you!
From:
Sent: Thursday, July 18, 2019 17:04
To:
Subject: Re: Breaking News: A federal judge denied Jeffrey Epstein bail, rejecting his request to stay in his mansion under
guard until his sex-trafficking trial.
Would you like me to get the EDNY filing?
On Jul 18, 2019, at 4:11 PM,
wrote:
perfect thanks
From:
Sent: Thursday, July 18, 2019 14:08
To:
Subject: RE: Breaking News: A federal judge denied Jeffrey Epstein bail, rejecting his request to stay in his mansion
under guard until his sex-trafficking trial.
Attached. You should also get the Boustani appellate filing(s) from EDNY. I can do that if you'd like.
From:
Sent: Thursday, July 18, 2019 2:04 PM
To:
Subject: RE: Breaking News: A federal judge denied Jeffrey Epstein bail, rejecting his request to stay in his mansion
under guard until his sex-trafficking trial.
Awesome, thank you
From:
Sent: Thursday, July 18, 2019 13:03
To:
Subject: Re: Breaking News: A federal judge denied Jeffrey Epstein bail, rejecting his request to stay in his mansion
under guard until his sex-trafficking trial.
EFTA00028155

=== Page 2 ===
Enjoy the appeal. (I have a sample opposition. So does EDNY in the Boustani case.)
On Jul 18, 2019, at 12:50 PM,
)
wrote:
Thanks man
From:
Sent: Thursday, July 18, 2019 12:29
To:
Subject: FW: Breaking News: A federal judge denied Jeffrey Epstein bail, rejecting his request to stay in his mansion
under guard until his sex-trafficking trial.
Congratulations.
From: The New York Times <nytdirect@nytimes.com>
Sent: Thursday, July 18, 2019 11:39 AM
To:
Subject: Breaking News: A federal judge denied Jeffrey Epstein bail, rejecting his request to stay in his mansion under
guard until his sex-trafficking trial.
Add nytdirect@nytimes.com to your address book.
Add nytdirect@nytimes.com to your address book.
The New York
The New York Times
Breaking News Alert
July 18, 2019
NYTimes.com
»
BREAKING NEWS
A federal judge denied Jeffrey
Epstein bail, rejecting his request to
stay in his mansion under guard until
his sex-trafficking trial.
Thursday, July 18, 2019 11:38 AM EST
Mr. Epstein, the financier facing sex-trafficking charges, had requested to await trial under
home detention at his Upper East Side mansion.
The judge said Mr. Epstein, who owns property in Paris and has a private plane, would be
detained in jail until his trial on charges that he sexually abused and trafficked dozens of
EFTA00028156

=== Page 3 ===
underage girls in the early 2000s.
Read More »
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EFTA00028157


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Epstein recent flight records
Date: Thu, 08 Aug 2019 01:19:03 +0000
Thanks guys, this is all helpful. I think the only things we are still missing are the description of the premises
(and photo) and our basis for believing he owned the island at the time of the charged conduct.
Sent from my iPhone
On Aug 7, 2019, at 6:08 PM,
wrote:
Epstein had a current driver's license on him at the time of his arrest. The driver's license lists Little St James, St Thomas,
VI 00802 as his address. He has also registered Little St James as his primary residence with the Sex Offender Registry.
From:
Sent: Wednesday, August 07, 2019 5:58 PM
To
Subject: Epstein recent flight records
UC Customs and Border Protection records show the following recent flight information for Epstein as it
relates to St. Thomas.
6/11/2019 flight from St Thomas to Teterboro.
5/18/2019 flight from St Thomas to West Palm Beach.
5/5/2019 flight from St Thomas to Teterboro.
4/14/2019 flight from St. Thomas to West Palm Beach.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Offic
Cell:
Fax:
EFTA00028534


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 74 Filed 11/23/20 Page 1 of 2
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
November 23, 2020
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter to provide an update regarding the
defendant's conditions of confinement at the Metropolitan Detention Center ("MDC") pursuant to
the Court's Order dated August 25, 2020. (Dkt. No. 49). Over the past three months, the
Government has had multiple conversations with MDC legal counsel regarding the defendant's
conditions of confinement. This update is based on information provided to the Government by
MDC legal during those conversations.
Last week, a staff member who was assigned to work in the area of the MDC where the
defendant is housed tested positive for COVID-19. In response, the MDC implemented the same
quarantine protocols that apply whenever an inmate has potentially been exposed to the virus.
Specifically, on November 18, 2020, the defendant was tested for COVID-19 using a rapid test,
which was negative. That same day, the defendant was placed in quarantine. As with any other
quarantined inmate, the defendant will remain in quarantine for fourteen days, at which point she
will be tested again for COVID-19. If that test is negative, she will then be released from
quarantine. To date, the defendant has not exhibited any symptoms of COVID-19.
During her time in quarantine, the defendant will be housed in the same cell where she was
already housed before she was placed in quarantine, and medical staff and psychology staff will
continue to check on the defendant every day. Like all other MDC inmates in quarantine, the
defendant will be permitted out of her cell three days per week for thirty minutes. During that
time, the defendant may shower, make personal phone calls, and use the CorrLinks email system.
In addition, the defendant will continue to be permitted to make legal calls every day for up to
three hours per day. These calls will take place in a room where the defendant is alone and where
no MDC staff can hear her communications with counsel.
On November 18, 2020, the Government provided the MDC with a laptop for the defendant
to use to review discovery. During quarantine, the defendant has been and will continue to be
permitted to use that laptop in her isolation cell to review her discovery for thirteen hours per day,
EFTA00027268

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 74 Filed 11/23/20 Page 2 of 2
Page 2
seven days per week. Accordingly, the defendant is receiving the same amount of time to review
her discovery and the same amount of time to speak with her lawyers as she received before
entering quarantine. The defendant will not, however, be permitted to meet in person with her
lawyers until she tests out of quarantine.
After the defendant tests out of quarantine, she will resume the same schedule that the
MDC implemented approximately three months ago. Specifically, from 7am to 8pm every day,
the defendant will be permitted out of her isolation cell. During those thirteen hours, the defendant
will have access to a computer on which to review her discovery outside of her cell. Also during
the day, the defendant will be permitted to, among other things, make legal calls, make personal
calls, access CorrLinks, and shower. From 8pm to 7am, the defendant will remain in her isolation
cell. The defendant will also be permitted to have in-person visits with her attorneys up to three
days per week for multiple hours per visit. On days when the defendant does not have in-person
legal visits, she will have access to legal calls for up to three hours per day.
As was the case three months ago, the defendant continues to have more time to review her
discovery than any other inmate at the MDC, even while in quarantine. The defendant also has as
much, if not more, time as any other MDC inmate to communicate with her attorneys, even while
in quarantine.
As noted above, over the past three months, the Government has repeatedly communicated
both with MDC legal counsel and defense counsel regarding the defendant's conditions of
confinement. Whenever the defense has raised a concern on this topic, the Government has
immediately contacted MDC legal counsel to inquire about and, where appropriate, to address the
concern. The Government will continue to keep those lines of communication open and will
remain responsive to any concerns raised by the defense regarding the defendant's conditions of
confinement. Should the Court have any questions or require any additional details regarding this
topic, the Government will promptly provide additional information.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By:
Maurene Comey / Alison Moe / Lara Pomerantz
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324
Cc: All Counsel of Record (By ECF)
EFTA00027269

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 78 Filed 12/01/20 Page 1 of 2
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
December 1, 2020
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The parties jointly submit this letter in response to the Court's November 24, 2020 order
directing the parties to meet and confer regarding the defendant's request that the warden of the
Metropolitan Detention Center ("MDC") report directly to the Court and counsel on the
defendant's conditions of detention. (Dkt. No. 76). Over the past week, the Government has
spoken with MDC legal counsel regarding the defendant's conditions of confinement and has tried
to gather additional information regarding the concerns raised by the defendant, which the
Government has shared with defense counsel. The Government has also conferred with defense
counsel three times regarding the same, as well as the defense's request relating to MDC Warden
Heriberto Tellez. The parties have been unable to reach agreement. Our respective positions
follow.
The Government respectfully submits that the Court should allow MDC legal counsel to
respond directly in writing to the Court and defense counsel regarding the concerns defense
counsel has raised relating to the defendant's conditions of confinement. The Government
understands that MDC legal counsel is prepared to submit a letter by this Friday, December 4,
2020. Such a letter is the appropriate next step at this time, as it will allow the Court to hear
directly from MDC legal counsel who can address the defendant's conditions of confinement. The
letter will allow the Court to ascertain whether further inquiry, including a personal appearance by
the Warden or other MDC personnel, is necessary. Moreover, the Government does not
understand the concerns raised by the defense to implicate the defendant's access to legal materials
or her ability to communicate with her counsel. As noted in the Government's letter dated
November 23, 2020, the defendant continues to have more time to review her discovery than any
other inmate at the MDC. The defendant also has as much, if not more, time as any other MDC
inmate to communicate with her attorneys. (Dkt. No. 74).
The defense disagrees. As communicated to the Government, the defense's position is as
follows: Warden Heriberto Tellez should appear before the Court to directly address concerns
regarding Ms. Maxwell's conditions of confinement, which specifically target her. On October
29, 2020, the defense emailed a letter to Warden Tellez detailing the onerous and restrictive
conditions, including but not limited to concerns regarding the supplemental camera; excessive
EFTA00027270

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 78 Filed 12/01/20 Page 2 of 2
Page 2
searching (e.g., weekly body scan, 15-minute interval flashlight checks at night, and open-mouth
inspection) despite being surveilled 24/7 by a dedicated three-guard security detail and two
cameras; and the reason she is not being moved to the day room, which we understood was the
original plan (and would reduce searching). Receipt of the letter was acknowledged, but to date
there has been no response and little, if any, redress to the most serious conditions. Upon
information and belief, decisions concerning Ms. Maxwell's specialized detention are made by
Warden Tellez, or from others outside the MDC. A report from the MDC Legal Department would
provide second-hand information. Accordingly, Warden Tellez should be directed to provide a
first-hand accounting to the Court and counsel why Ms. Maxwell is being detained under such
individualized conditions.
Your consideration is greatly appreciated.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By: s/
Maurene Comey / Alison Moe / Lara Pomerantz
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324
Cc: All Counsel of Record (By ECF)
EFTA00027271

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 88 Filed 12/07/20 Page 1 of 2
DIPARTMENT
OF
U.S. DEPARTMENT OF JUSTICE
Federal Bureau of Prisons
THEOTA
BNOWN BA
Metropolitan Detention Center
BURRAU
OF
80 29h Street
USDC SDNY
Brooklyn, New York 11232
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 12/7/20
December 4, 2020
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Ghislaine Maxwell, Reg. No. 02879-509
Dear Judge Nathan:
This letter is written in response to your order dated December 2, 2020, concerning Ghislaine
Maxwell, Reg. 02879-509., an inmate currently confined at the Metropolitan Detention center in Brooklyn,
New York. You expressed various concerns regarding Ms. Maxwell's confinement and well-being.
The Bureau of Prisons' (BOP) policies and procedures are designed to ensure staff and inmates can
work and live in a safe and secure environment. In determining Ms. Maxwell's current housing
assignment, MDC Brooklyn considered various factors including Ms. Maxwell's expressed concern for
her safety and well-being amongst the general inmate population. We have discussed our decision with
Ms. Maxwell several times and provided her with guidance as to how to address any concerns through
her Unit Team or the BOP's Administrative Remedy Program, 28 C.F.R. SS 542.10 - 542.19. To date,
staff have addressed her complaints in accordance with BOP policies.
In her current assignment, Ms. Maxwell, like other inmates housed at MDC Brooklyn, is allowed
access to the common area of the housing unit from 7:00 AM through 8:00 PM, daily. She has access to
recreational space, social calls, television, shower, legal telephone calls, email, computers, and discovery
material. A discovery laptop is available to her from 8:00 AM through 5:00 PM. When Ms. Maxwell
returns to her cell at 8:00 PM, like other inmates she has access to drinking water, snacks she purchased
through the commissary, and discovery material. Since August 3, 2020, Ms. Maxwell has been able to
purchase items from the full commissary list. She receives commissary every second week like all other
inmates.
MDC Brooklyn correctional staff utilize flashlights when viewing inmate cells overnight to ensure
EFTA00027272

=== Page 6 ===
Case 1:20-cr-00330-AJN Document 88 Filed 12/07/20 Page 2 of 2
inmates are breathing and not in distress. Inmates in BOP custody are subject to searches, including
body scanners, and inmates may be searched prior to moving from one area of the facility to another.
The removal of Ms. Maxwell's face mask complies with the BOP's COVID-19 Pandemic Response Plan.
Since Ms. Maxwell's arrival, she has been provided three (3) meals a day in accordance with BOP
policy and its National Menu. Food Service staff have addressed Ms. Maxwell's requests. Ms. Maxwell is
served her breakfast upon entering the common area of the housing unit at 7:00 AM; at noon she is
served her lunch; and at 5:00 PM she is served dinner. Her medical records show that she currently
weighs 134 lbs., which fluctuates plus or minus 2 lbs. Health Services staff make regular rounds of her
housing unit and she has been instructed on how to request medical care through the sick call
procedures. Furthermore, while there has been a number of inmates whom have tested positive for
COVID-19, Ms. Maxwell remains in good health and is not in contact with those individuals. The BOP
staff is assigned to Ms. Maxwell's unit do not come in contact with the other individuals whom have
tested positive. Lastly, the temperature of Ms. Maxwell's cell is checked three times daily to ensure it is
in compliance with national standards.
In accordance with the BOP's COVID-19 Pandemic Response Plan, inmates are allotted 500
minutes per month of social telephone calls, which Ms. Maxwell has used throughout her time at MDC
Brooklyn. While Ms. Maxwell has received one legal video conference, she continues to have full access
to legal telephone calls and in person legal visits. Pursuant to the District Courts guidance, legal
telephone calls are scheduled through the Federal Defenders, who should be afforded an opportunity to
address any concerns Ms. Maxwell's attorneys have with the legal calls.
I trust this has addressed your concerns.
Respectfully submitted,
/s/ Sophia Papapetru
Sophia Papapetru
Staff Attorney
MDC Brooklyn
Federal Bureau of Prisons
/s/ John Wallace
John Wallace
Staff Attorney
MDC Brooklyn
Federal Bureau of Prisons
EFTA00027273

=== Page 7 ===
Case 1:20-cr-00330-AJN Document 92 Filed 12/08/20 Page 1 of 2
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 12/8/20
SOUTHERN DISTRICT OF NEW YORK
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
On December 4, 2020, the Court received a letter from MDC legal counsel responding to
the concerns that the Defendant raised in her November 24, 2020 letter. See Dkt. Nos. 75, 88;
see also Dkt. No. 78. The Defendant responded to the MDC legal counsel's letter on December
7, 2020, reiterating her request that the Court summon Warden Heriberto Tellez to personally
respond to questions from the Court regarding the Defendant's conditions of confinement. See
Dkt. No. 91. Having carefully reviewed the parties' submissions, along with the MDC legal
counsel's December 4, 2020 letter, the Court DENIES the Defendant's request to summon the
Warden to personally appear and respond to questions. This resolves Dkt. No. 75.
Notwithstanding this, as originally provided in Dkt. No. 49, the Government shall
continue to submit written status updates detailing any material changes to the conditions of Ms.
Maxwell's confinement, with particular emphasis on her access to legal materials, including
legal mail and email, and her ability to communicate with defense counsel. The updates shall
also include information on the frequency of searches of the Defendant.
The Court hereby ORDERS the Government to submit these written updates every 60
days. Furthermore, the Government shall take all necessary steps to ensure that the Defendant
1
EFTA00027274

=== Page 8 ===
Case 1:20-cr-00330-AJN Document 92 Filed 12/08/20 Page 2 of 2
continues to receive adequate access to her legal materials and her ability to communicate with
defense counsel.
so ORDERED.
Alim D.Netto
Dated: December 8, 2020
New York, New York
ALISON J. NATHAN
United States District Judge
2
EFTA00027275

=== Page 9 ===
Case 1:20-cr-00330-AJN Document 116 Filed 01/15/21 Page 1 of 2
CG
800 Third Avenue
COHEN & GRESSER LLP
New York, NY 10022
7400
USDC SDNY
DOCUMENT
Christian R. Everdell
ELECTRONICALLY FILED
+1 (212) 957-7600
DOC #:
ceverdell@cohengresser.com
DATE FILED: 1/15/21
January 14, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write on behalf of our client, Ghislaine Maxwell, to respectfully request that the Court
order the Bureau of Prisons to give Ms. Maxwell access to the laptop computer provided by the
government so that she can review discovery on weekends and holidays.
At the request of defense counsel, the government provided Ms. Maxwell with a laptop
computer to review the voluminous discovery, which was produced on a series of external hard
drives. Currently, Ms. Maxwell is given access to the laptop only on weekdays. On weekends
and holidays, Ms. Maxwell must use the prison computer on her floor to review discovery.
However, the prison computer is not equipped with the software necessary to read large portions
of the discovery recently produced by the government. As a result, Ms. Maxwell loses several
days of review time every weekend and every holiday because she does not have access to the
laptop. If Ms. Maxwell is to have any hope of reviewing the millions of documents produced in
discovery so that she can properly prepare her defense by the July 12, 2021 trial date, she must
have access to the laptop every day, including weekends and holidays.
Defense counsel has raised this issue with the government and it has no objection to Ms.
Maxwell having access to the laptop seven days a week. At the request of defense counsel, the
government has contacted officials at the MDC on several occasions in the past few weeks to
request that they lift this restriction, but without success.
There is no principled justification for this restriction. Ms. Maxwell was given access to
the laptop every day (including weekends and the Thanksgiving holiday) for the entire 14-day
period that she was quarantined in her isolation cell in November-December 2020 because she had
come into close contact with a member of the MDC staff who had tested positive for COVID. In
addition, the laptop is kept in a locker in the same room where the prison computer is located, so it
EFTA00027276

=== Page 10 ===
Case 1:20-cr-00330-AJN Document 116 Filed 01/15/21 Page 2 of 2
The Honorable Alison J. Nathan
January 14, 2021
Page 2
would not require any change in Ms. Maxwell's movements to give her the requested access.
Furthermore, on at least three occasions since she was released from quarantine, Ms. Maxwell's
security team gave her the laptop to review discovery on the weekend.
There is clearly no actual impediment preventing the MDC staff from providing Ms.
Maxwell access to the laptop on weekends and holidays. Given the millions of documents that
Ms. Maxwell must review before trial in order to prepare her defense, it is critical that she be
given as much time as possible with the laptop to review the discovery. We therefore respectfully
request that the Court order the BOP to give Ms. Maxwell access to the laptop on weekends and
holidays during the hours that she is permitted to review discovery.
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
(212) 957-7600
cc:
All Counsel of Record (By ECF)
The unobjected-to request is
GRANTED. The Bureau of
Prisons is ORDERED to give the
Defendant access to the laptop
computer on weekends and
1/15/21
holidays during the hours that she
Alim Netto
is permitted to review discovery.
so ORDERED.
ALISON J. NATHAN
United States District Judge
EFTA00027277

=== Page 11 ===
Case 1:20-cr-00330-AJN Document 131 Filed 02/05/21 Page & of 3
DIPARTMENT
OF
U.S. DEPARTMENT OF JUSTICE
*
Federal Bureau of Prisons
THERE
USDC SDNY
Metropolitan Detention Center
OF
DOCUMENT
BURRAU
ELECTRONICALLY FILED
DOC #:
80 29h Street
DATE FILED: 2/2/21
Brooklyn, New York 11232
January 25, 2021
BY ECF
Having considered the request
submitted by the Bureau of Prisons
The Honorable Alison J. Nathan
2/2/21
("BOP") that the Court vacate its
United States District Court
Southern District of New York
Alim
Netto
January 15, 2021 Order, Dkt. No. 117,
as well as the Government's and the
40 Foley Square
New York, NY 10007
Defendant's responses, Dkt. Nos. 129,
ALISON J. NATHAN
United States District Judge
130, the Court hereby DENIES the
BOP's request to vacate the Order.
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
so ORDERED.
Ghislaine Maxwell, Reg. No. 02879-509
Dear Judge Nathan:
This letter is written in response to Order granted on January 15, 2021, concerning Ghislaine
Maxwell, Reg. 02879-509., an inmate currently confined at the Metropolitan Detention Center ("MDC") in
Brooklyn, New York. The MDC Brooklyn respectfully requests that Your Honor vacate the Order given
MDC Brooklyn was not given the opportunity to object to defense counsel's claims, although the objection
had been reiterated to the U.S. Attorney's Office numerous times.
Defense counsel expressed various concerns regarding Ms. Maxwell's confinement limiting her
access to discovery. However, Ms. Maxwell has received a significant amount of time to review her
discovery. On November 18, 2020, the Government provided the MDC Brooklyn with a laptop for Ms.
Maxwell to use to review discovery. Ms. Maxwell has been and will continue to be permitted to use that
laptop to review her discovery for thirteen (13) hours per day, five (5) days per week. In addition to the
Government laptop, she has access to the MDC Brooklyn discovery computers. Although defense counsel
has indicated that the MDC Brooklyn discovery computers are not equipped to read all of her electronic
discovery, the computers are capable of reviewing most of the electronic discovery. Despite defense
counsel's claim that Ms. Maxwell's lacks sufficient time to fully review her discovery, her consistent use of
Government laptop and MDC Brooklyn's discovery computers undercuts this claim.
Moreover, Ms. Maxwell continues to have contact with her legal counsel five (5) days per week, three
(3) hours per day via video-teleconference and via telephone; this is far more time than any other MDC
inmate is allotted to communicate with their attorneys.
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=== Page 12 ===
Case 1:20-cr-00330-AJN Document 131 Filed 02/05/21 Page 3 of 3
We respectfully request that Your Honor vacate the order of January 15, 2021, and allow the
institution to resume the prior schedule of laptop access, Monday through Friday, 7:00 AM - 8:00 PM.
Respectfully submitted,
/s/ Sophia Papapetru
Sophia Papapetru
Staff Attorney
MDC Brooklyn
Federal Bureau of Prisons
EFTA00027279

=== Page 13 ===
Case 1:20-cr-00330-AJN Document 129 Filed 02/01/21 Page 1 of 2
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
February 1, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in response to the Court's January 25, 2021
order allowing the parties to respond to a letter from legal counsel at the Metropolitan Detention
Center ("MDC") also dated January 25, 2021. (Dkt. No. 117). In particular, MDC legal counsel
asks the Court to vacate its January 15, 2021 order directing the MDC to permit the defendant to
use a laptop to review discovery on weekends and holidays. While the Government has no
objection to the defendant's request for additional laptop access, the Government also generally
defers to the MDC regarding how it manages its inmate population. The Government will continue
to defer to the MDC here, particularly because the defendant has had ample access to discovery
even without laptop access on weekends and holidays.
Given the volume of discovery in this case, which totals more than two million pages, the
Government and the MDC have both made significant efforts to ensure that the defendant has
extensive access to her discovery materials. Since the Government made its first discovery
production in August 2020, the defendant has had exclusive access to a BOP desktop computer in
the MDC on which to review her discovery. When the defendant complained of technical issues
reviewing portions of her discovery on that desktop computer, the Government produced
reformatted copies of discovery materials and instructions regarding how to open particular files.
Because the defendant continued to complain that she was unable to review certain discovery files
on the desktop computer, the Government agreed to provide a laptop for the defendant to use in
her review of discovery. On November 18, 2020, the Government hand delivered the laptop to
the MDC for the defendant's exclusive use.
As the Court is aware, the defendant has received, and continues to receive more time to
review her discovery than any other inmate at the MDC. In particular, the MDC permits the
defendant to review discovery thirteen hours per day, seven days per week. On weekdays, the
MDC permits the defendant to use the laptop during her thirteen hours of daily review time. On
weekends and holidays, the MDC would ordinarily only allow the defendant to use the BOP
desktop computer, which provides access to much of the discovery material. While, as noted
above, the Government has no particular objection to the defendant's request for weekend access
EFTA00027280

=== Page 14 ===
Case 1:20-cr-00330-AJN Document 129 Filed 02/01/21 Page 2 of 2
Page 2
to the laptop, the Government generally defers to the judgment of the MDC in managing inmates
at its facility, and sees no reason to depart from that practice here. In this respect, the Government
notes that the trial date remains approximately six months away, the BOP was already affording
the defendant access to the laptop for some 65 hours a week, and the BOP was further providing
weekend access to a desktop computer should the defendant wish to spend more than 65 hours
each week reviewing discovery.
Respectfully submitted,
AUDREY STRAUSS
United States Attorney
By: s/
Maurene Comey / Alison Moe / Lara Pomerantz
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324
Cc: All Counsel of Record (By ECF)
EFTA00027281

=== Page 15 ===
Case 1:20-cr-00330-AJN Document 158 Filed 02/05/21 Page 1 of 2
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
February 4, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter to provide an update regarding the
defendant's conditions of confinement at the Metropolitan Detention Center ("MDC") pursuant to
the Court's Order dated December 8, 2020. (Dkt. No. 92). Over the past two months, the
Government has had multiple communications with MDC legal counsel regarding the defendant's
conditions of confinement. This update is based on information provided to the Government by
MDC legal counsel through those communications.
The defendant continues to receive more time to review discovery than any other inmate
at the MDC. Specifically, the defendant is permitted to review her discovery thirteen hours per
day, seven days per week. During the entirety of that time, the defendant has access to a desktop
computer provided by the MDC on which to review discovery. Additionally, pursuant to the
Court's January 15, 2021 Order, the defendant also has access to a laptop computer provided by
the Government on which to review discovery for the full thirteen hours per day, seven days per
week. Also during those thirteen hours per day, the defendant may use the MDC desktop computer
to send and receive emails with her attorneys.
The defendant also has as much, if not more, time as any other MDC inmate to
communicate with her attorneys. Due to the elevated number of COVID-19 cases within the MDC,
in-person visits have been suspended since in or about December 2020. While in-person visits are
suspended, the defendant has had regular video-teleconference ("VTC") calls with her counsel. In
particular, the defendant has VTC calls with her counsel every weekday for three hours per call.
If defense counsel requires additional time to speak with the defendant, counsel may request to
schedule an additional phone call on Saturdays as needed. All of these VTCs and telephone calls
take place in a room where the defendant is alone and where no MDC staff can hear her
communications with counsel.
The defendant's legal mail is processed in the same manner as mail for all other inmates at
the MDC. All inmate mail is sent to the MDC's mail room, where every piece of mail is processed
EFTA00027282

=== Page 16 ===
Case 1:20-cr-00330-AJN Document 158 Filed 02/05/21 Page 2 of 2
Page 2
before being provided to the inmate recipient. Due to the large number of MDC inmates and the
volume of mail received at the MDC, this process can take multiple days. As noted above,
however, the defendant is able to send and receive emails with defense counsel every day and has
regular communication with counsel via VTC.
MDC staff conduct two pat-down searches of the defendant per day: once when she is
moved from her isolation cell to the day room each morning, and once when returns from the day
room to her isolation cell each night. As part of those searches, the defendant is required to remove
her mask and open her mouth briefly so that MDC staff, who remain masked during the searches,
can confirm she has not hidden contraband in her mouth. These pat-down and mouth searches are
consistent with MDC's policy that all inmates be searched whenever they move to a different
location within the jail facility. Previously, the defendant attended VTC conferences in a separate
part of the MDC, requiring that she be searched when taken to and from her VTC calls with
counsel. Recently, however, the MDC changed the location of the defendant's VTC calls so that
the defendant does not need to leave her unit in order to attend VTC calls with her counsel, thereby
reducing the number of searches. During the suspension of visitation, the defendant has not been
strip searched. When visitation resumes, the defendant, like all other inmates, will be strip
searched after any in-person visit.
In addition, MDC staff search the defendant's cell for contraband once per day. MDC staff
also conduct a body scan on the defendant once per week to check for any secreted contraband.
At night, MDC staff are required to confirm that the defendant is not in distress every fifteen
minutes. To do so, staff point a flashlight to the ceiling of the defendant's cell to illuminate the
cell sufficiently to confirm that the defendant is breathing every fifteen minutes. The MDC
continues to assess that these searches are all necessary for the safety of the institution and the
defendant.
Should the Court have any questions or require any additional details regarding this topic,
the Government will promptly provide additional information.
Respectfully submitted,
AUDREY STRAUSS
United States Attorney
By:
Maurene Comey / Alison Moe / Lara Pomerantz
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324
Cc: All Counsel of Record (By ECF)
EFTA00027283

=== Page 17 ===
Case 1:20-cr-00330-AJN Document 196 Filed 04/06/21 Page 1 of 6
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
April 6, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter to provide an update regarding the
defendant's conditions of confinement at the Metropolitan Detention Center ("MDC") pursuant to
the Court's Order dated December 8, 2020. (Dkt. No. 92). This update is based on information
provided to the Government by MDC legal counsel regarding the conditions of the defendant's
confinement over the last two months.
The defendant continues to receive more time to review discovery than any other inmate
at the MDC. Specifically, the defendant is permitted to review her discovery thirteen hours per
day, seven days per week. During the entirety of that time, the defendant has access to both a
desktop computer provided by the MDC and a laptop computer provided by the Government on
which to review discovery. Also during those thirteen hours per day, the defendant may use the
MDC desktop computer to send and receive emails with her attorneys.¹ This discovery review
1 Per BOP policy, all inmate emails are routinely purged every six months. In response to
complaints from the defendant and defense counsel regarding prematurely deleted emails, MDC
staff examined the defendant's inmate email account. That examination revealed that the
defendant had herself deleted some of her emails and had archived others. That examination
revealed no evidence to suggest that MDC staff deleted any of the defendant's emails.
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=== Page 18 ===
Case 1:20-cr-00330-AJN Document 196 Filed 04/06/21 Page 2 of 6
Page 2
takes place in a day room that is separate from the defendant's isolation cell. Accordingly, the
defendant is permitted out of her cell from 7am to 8pm every day. While in the day room, the
defendant has exclusive access to the MDC desktop computer, the laptop, a television, a phone on
which to place social or attorney calls, and a shower. The defendant is also permitted outdoor
recreation every day, although she has the option of declining such recreation time if she wishes.
The defendant also has as much, if not more, time as any other MDC inmate to
communicate with her attorneys. Currently, the defendant receives five hours of video-
teleconference ("VTC") calls with her counsel every weekday, for a total of 25 hours of attorney
VTC calls per week. At times, unexpected incidents, such as institution-wide lockdowns or short
staffing, delay the defendant's arrival to her VTC call with counsel by up to 30 minutes. When
such delay occurs, however, the MDC permits the defendant to make up for any missed time either
by extending that day's VTC call or by permitting the defendant extra time on the next day's VTC
call. All of these VTC calls take place in a room where the defendant is alone and where no MDC
staff can hear her communications with counsel. During these VTC calls, MDC staff place a
camera approximately 30 feet away from the door to the room where the defendant conducts the
VTC calls. The camera has a full view of the door to the VTC room, but the camera cannot view
either the defendant or her attorneys while the door is closed during VTC calls. The camera does
not capture any sound from the defendant's VTC calls with her attorneys. In other words, the
camera records who enters and exits the VTC room, but it does not record activity inside the VTC
room. The defendant is also permitted to use the phone in the day room to place phone calls to her
attorneys as needed.
In addition, defense counsel now have the option of meeting with the defendant in person
at the MDC. On or about February 16, 2021, the MDC resumed in-person visitation. As a result,
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=== Page 19 ===
Case 1:20-cr-00330-AJN Document 196 Filed 04/06/21 Page 3 of 6
Page 3
in-person attorney visits are now available seven days per week. The MDC has placed HEPA air
filters in its attorney visiting rooms to improve air quality during visits. Additionally, the
defendant has received the COVID-19 vaccine and is now fully vaccinated. The Government
understands that defense counsel have thus far declined to meet with the defendant in person and
instead rely on VTC calls, email, and supplemental phone calls to communicate with their client.
The option of in-person visits remains available seven days per week should defense counsel wish
to meet with the defendant in person.
The defendant's legal mail is processed in the same manner as mail for all other inmates at
the MDC. All inmate mail is sent to the MDC's mail room, where every piece of mail is processed
before being provided to the inmate recipient. Due to the large number of MDC inmates and the
volume of mail received at the MDC, this process can take multiple days. As noted above,
however, the defendant is able to send and receive emails with defense counsel every day and has
regular communication with counsel via VTC, which can be supplemented by phone calls.
Like any other inmate, the defendant is patted down by MDC staff whenever she is moved
to a different part of the facility. Typically, these searches include at least two pat-down searches
of the defendant per day: once when she is moved from her isolation cell to the day room each
morning, and once when returns from the day room to her isolation cell each night. In addition,
when the defendant elects to attend outdoor recreation, she is searched two additional times: once
when she is moved to the recreation area, and once when she returns to the day room from the
recreation area. MDC staff also conduct a body scan, which is a non-invasive machine scan, on
the defendant once per week to check for any secreted contraband. Because those scans take place
in a different part of the facility than the day room, the defendant is patted down two additional
times when these weekly scans occur: once when she is moved to the scan area, and once when
EFTA00027286

=== Page 20 ===
Case 1:20-cr-00330-AJN Document 196 Filed 04/06/21 Page 4 of 6
Page 4
she returns to the day room from the scan area. As part of every pat-down search, the defendant
is required to remove her mask and open her mouth briefly so that MDC staff, who remain masked
during the searches, can confirm she has not hidden contraband in her mouth. These pat-down
and mouth searches are consistent with MDC's policy that all inmates be searched whenever they
move to a different location within the jail facility. In the absence of in-person visitation, the
defendant has not been strip searched. If the defendant receives in-person visits, then she, like all
other inmates, will be strip searched after any in-person visit.
In addition, MDC staff search the defendant's cell for contraband once per day. At night,
MDC staff are required to confirm every fifteen minutes that the defendant is not in distress. To
do so, every fifteen minutes, staff point a flashlight to the concrete ceiling of the defendant's cell
to illuminate the cell sufficiently to confirm that the defendant is breathing. At night, MDC staff
have observed that the defendant wears an eye mask when she sleeps, limiting the disturbance
caused by the flashlight. Additionally, MDC staff have observed that the defendant regularly
sleeps through these nighttime wellness checks. The MDC continues to be of the view that all of
these searches are necessary for the safety of the institution and the defendant.
The Government also inquired regarding certain complaints defense counsel raised in
February 2021 regarding the defendant's food, water, and physical wellbeing. In response, MDC
2 Following defense counsel's complaint in its February 16, 2021 letter of an inappropriately
conducted pat-down search, the MDC conducted an investigation and found that, contrary to the
defendant's claim, the search in question was in fact recorded in full by a handheld camera. After
reviewing the camera footage, the MDC concluded that the search was conducted appropriately
and the defendant's complaint about that incident was unfounded. MDC legal counsel further
confirmed that all pat-down searches of the defendant are video recorded. Following this incident,
MDC staff directed the defendant to clean her cell because it had become very dirty. Among other
things, MDC staff noted that the defendant frequently did not flush her toilet after using it, which
caused the cell to smell. In addition, the defendant had not cleaned her cell in some time, causing
the cell to become increasingly dirty. MDC staff directed the defendant to clean her cell in
response to the smell and the dirtiness, not as retaliation for complaining about a particular search.
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=== Page 21 ===
Case 1:20-cr-00330-AJN Document 196 Filed 04/06/21 Page 5 of 6
Page 5
legal counsel informed the Government that the defendant's meals arrive in containers that are
both microwavable and oven safe. Currently, the defendant's meals are heated in a thermal oven.
The tap water available in the MDC is provided by New York City. As a result, on occasions
when the City has conducted maintenance near the MDC, the water has been temporarily shut off.
During those periods, MDC staff have provided all inmates, including the defendant, with bottled
water. After the water is turned back on, the water is sometimes cloudy or brown and needs to run
for several seconds before becoming clear. MDC staff have not observed any instance in which
the water in the defendant's cell did not clear after being run for several seconds. MDC legal
counsel emphasized that MDC staff, including the legal staff, drink the same tap water from the
same water system as the defendant while in the institution.
MDC medical staff monitor the defendant daily and weigh the defendant at least once per
week. During her time at the MDC, the defendant's weight has fluctuated between the 130s and
the 140s. The defendant's lowest observed weight was 133 pounds in July of 2021. Since then,
her weight has fluctuated but has never been lower than 134 pounds. Most recently, when the
defendant was weighed last week, her weight was 137.5 pounds. The defendant is 5' 7", meaning
that even her lowest weight of 133 pounds resulted in a BMI of 20.8, which is considered a normal
weight for a person of the defendant's height. MDC staff have not observed the defendant
experience any noticeable hair loss. As noted above, the defendant has received a COVID-19
vaccine and is now fully vaccinated. In short, MDC medical staff assess that the defendant is
physically healthy.
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=== Page 22 ===
Case 1:20-cr-00330-AJN Document 196 Filed 04/06/21 Page 6 of 6
Page 6
Should the Court have any questions or require any additional details regarding this topic,
the Government will promptly provide additional information.
Respectfully submitted,
AUDREY STRAUSS
United States Attorney
By:
Menture
Maurene Comey / Alison Moe / Lara Pomerantz
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324
Cc: All Counsel of Record (By ECF)
EFTA00027289


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c7: images
c0:
=== Page 1 ===
From:
To:
)"
Subject: FBI Case File - Epstein
Date: Tue, 22 Jan 2019 15:33:16 +0000
Importance: Normal
I placed the materials on the disc you left on my desk here
I believe this is where it belongs, but let me know if you'd like the folder renamed/moved elsewhere. Should I create a
case file for this case and keep physical records or would you like the disc back?
Best,
Paralegal
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00029470


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c0:
=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
)"
Subject: RE:
Date: Tue, 23 Jul 2019 17:37:02 +0000
Circling back regarding
who we initially thought we'd be able to meet with months ago but then
obviously didn't, I spoke again with her lawyer today and he suggested contacting her directly. He also said he'd let her
know that
would be trying to reach out to her. He provided her current number as:
if you could please try her this week? Her attorney said she's not great at following up, but we can give it a shot
and hope for the best. Let me know if any other info would be helpful, and thanks very much.
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
U.S. Department of Justice
Office of Professional Responsibility
950 Pennsylvania Avenue, N.W., Suite 3266
Washington, D.C. 20530
November 12, 2020
Audrey Strauss
United States Attorney's Office
Acting United States Attorney
for the Southern District of New York
1 St. Andrew's Plaza
New York City, NY 10007
Dear Ms. Strauss:
Enclosed is the Office of Professional Responsibility (OPR) Report of Investigation into
the U.S. Attorney's Office for the Southern District of Florida's Resolution of Its 2006-2008
Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the
Investigation. An Executive Summary appears at the beginning of the report. Although OPR's
investigation did not involve your Office, we are providing you with the Report because it may be
relevant to ongoing litigation being handled by your Office.
In addition, because this matter has received extraordinary public attention and has been
the subject of Congressional inquiries, the Department of Justice is today publicly releasing the
Executive Summary. The Department does not plan to publicly release the full report at this time,
but will provide it to Congress upon its request. Congress may choose to release the full report to
the public. In addition, it is possible that all or parts of the report may become public through the
processing of Freedom of Information Act requests.
Please do not hesitate to contact me if you have any questions about this matter.
Sincerely,
Director and Chief Counsel
Enclosure
cc:
Chief, Public Corruption Unit
(w/ enclosure)
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=== Page 1 ===
From: Peter Brightbill <pbrightbill@gmail.com>
To:
Subject: Congrats and a Caution re: Maxwell Indictment & Apprehension
Date: Thu, 02 Jul 2020 17:28:04 +0000
Mr.
:
I am a former prosecutor (Kings County DA, 1987-91, 1996-99) and helped lay the foundation for that Office's Crimes Against Children
Bureau by setting up and hosting the first meeting of the NYPD Pedophilia Squad with prosecutors and Detective-Investigators from my
Office in 1996. Preet Bharara speaks very highly of you.
Congratulations to you, Geoff Berman,
and your outstanding team of dedicated line prosecutors who put this case together,
as well as to the FBI agents and NYPD detectives who worked it.
Please realize that there is a great deal of apprehension amongst the public at large, and extending to some individuals in law enforcement
and corrections, that the MCC is not a secure facility and that Jeffrey Epstein's death there last summer was a homicide. Knowing, as I do,
of the manpower, training and management problems which have plagued the BOP and seem to be endemic at the MCC, concerns about
Ms. Maxwell's safety are not unfounded.
I hope that your Office will seek remand and that Maxwell will be kept isolated in a private cell and monitored 24/7 by multiple cameras
with all approaches to her cell covered and no blind spots, and that the feed from same will be monitored by a team of federal Marshalls
assigned to your Office.
As I told BJ Pak when his Office contacted me a few years ago, I believe that the victims of the Epstein-Maxwell criminal organization or
conspiracy were badly failed by Alex Acosta. I am happy to see that more competent and independent prosecutors are, at last, close to
bringing their victims some measure of justice, however belated.
Yours very truly,
Peter
Peter Basta Brightbill
Published Work Sample
Linked In
IMDB
m
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=== Page 1 ===
From:
)"
To:
(USANYS) 1"
Subject: FW: Richardson
Date: Wed, 21 Aug 2019 17:12:34 +0000
Embedded:t_c_with_counsel_for_Bill_Richardson,_re:_JE_case.msg
things are a struggle right now.
From:
)
Sent: Wednesday, August 21, 2019 13:09
To:
(USANYS)
is
>;
Cc:
(USANYS)
Subject: RE: Richardson
Hey I spoke to
and
about this, but just to keep everyone in the loop, I did talk to Jeff on Sunday and did
(what I thought was) a fairly standard witness / subject / target distinction, noting we didn't have sufficient information to
put him into the witness or target boxes, and that we didn't currently intend to subpoena him or request to speak with
him based on the investigation at this time. So I didn't specifically say he was a subject, but I noted the three categories
and said we didn't have enough information for witness or target. I also said that there weren't specific allegations that
we need to hear his side of at this time, and I think my intended point was conveyed, which was that we weren't currently
asking for anything from him-not that there are no allegations at all, which obviously there are, publicly. I did not say
that there is no allegation that the government is actively investigating; I just would never say to an attorney what we are
or aren't investigating. In any event, my contemporaneous notes are attached, I typed and sent them less than ten
minutes after our conversation, which lasted all of four minutes. I'm really sorry for any difficulties this causes us.
After talking with
about it, I also just spoke to Jeff and expressed my view that the statement does not fully
accurately reflect our conversation, and that our press office could respond to questions about it or he could clarify, and
he said he would get back to me with how he proposed to address the discrepancies.
From:
(USANYS)
Sent: Wednesday, August 21, 2019 12:05
To:
is
>;
Cc:
(USANYS)
Subject: FW: Richardson
Has anyone talked to Jeff Brown and is this accurate?
From: Biase, Nicholas (USANYS)
Sent: Wednesday, August 21, 2019 12:01 PM
To:
(USANYS)
>;
(USANYS)
Cc: Margolin, James (USANYS) [Contractor]
>; Dearden, Dawn (USANYS)
Subject: Richardson
Richardson has given the following statement to the press, true and accurate?:
EFTA00028546

=== Page 2 ===
Governor Bill Richardson offered his assistance in the Jeffrey Epstein investigation - through his lawyer, Jeff Brown of
Dechert LLP - to the US Attorney for the Southern District of New York. In response to this offer, Mr. Brown was informed
by the Assistant US Attorney responsible for the case that Governor Richardson is neither a target, subject, nor witness in
the case and that there is no allegation against Governor Richardson that the government is actively investigating.
"It's fair to conclude that the federal prosecutors investigating this matter do not believe the Governor participated in or
witnessed the criminal activity Jeffrey Epstein is alleged to have committed," said Mr. Brown.
Governor Richardson hopes that the investigation continues so that Epstein's victims can finally have their day in court
and see the justice they deserve.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
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=== Page 1 ===
From:
(USANYS)"
To:
(NY) (FBI)"
(USANYS)"
,
(NY) (OGA) (FBI)"
Cc:
"
(USANYS)"
Subject: RE: Response to Epstein Touhy Requests
Date: Wed, 04 Sep 2019 00:13:11 +0000
Importance: Normal
Great. Thank you!
From:
(NY) (FBI)
Sent: Tuesday, September 3, 2019 4:40 PM
To:
(USANYS)
is
(NY) (OGA) (FBI)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Response to Epstein Touhy Requests
Here is
info:
Tel:
Email:
From:
(USANYS) [mailto:
Sent: Tuesday, September 03, 2019 12:08 PM
To:
(NY) (OGA)
is
(NY) (FBI)
Cc:
(USANYS)
is
(USANYS)
Subject: Response to Epstein Touhy Requests
Hey guys -
AUSA
in our Civil Division and copied here, is handling the Touhy requests from Epstein's lawyers and wanted to
make sure that he spoke with the right FBI POC about the request to FBI (attached). Could you provide us with the
contact information for
? Thanks!
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=== Page 1 ===
From:
To:
(USANYS)"
Cc:
(USANYS)"
(OIG)"
Subject: RE: Epstein Guards/ OIG Report
Date: Fri, 21 May 2021 20:37:01 +0000
Hi
OIG has no objections. Thanks.
From:
(USANYS)
Sent: Friday, May 21, 2021 4:29 PM
To:
>;
(OIG)
is
(OIG)
Cc:
(USANYS)
Subject: RE: Epstein Guards/ OIG Report
Hi
Per our conversation just now, attached is a draft of the letter we intend to submit shortly. As you'll see in the first bullet
point, we reference the DOJ-OIG review. We do not plan to make mention of a report, although if asked at a court
conference whether there will be a report, we plan to say that we don't know, and that OIG's normal process is to prepare
a report but we don't know whether it will be made public or not.
Please let us know if you have any objections to the language in the letter. Thanks again for the speedy response, we very
much appreciate it.
From:
(USANYS)
Sent: Friday, May 21, 2021 2:10 PM
To:
is
(OIG)
is
(OIG)
Cc:
(USANYS)
Subject: RE: Epstein Guards/ OIG Report
Thank you,
From:
Sent: Friday, May 21, 2021 2:09 PM
To:
(USANYS)
is
(OIG)
is
(OIG)
Cc:
(USANYS)
Subject: RE: Epstein Guards/ OIG Report
,
I'm following up internally and will get back to you, or have someone from OIG get back to you. Thanks.
EFTA00028709

=== Page 2 ===
From:
(USANYS)
Sent: Friday, May 21, 2021 1:46 PM
To:
is
(OIG)
is
(OIG)
Cc:
(USANYS)
Subject: Epstein Guards/ OIG Report
Hi
We were hoping you could assist us with getting in touch with the OIG lawyer who is responsible for preparing the report
on Epstein's suicide. We have been trying to get in touch with
who was previously handling the
investigation, but understand he may have left the office. The time sensitivity is that we plan to file a public letter by close
of business today regarding reaching a deferred prosecution agreement with the two guards on duty that night who have
been charged with falsifying records. The guards have agreed to sit for an interview with our office and DOJ-OIG, and
we'd like to state in the letter that the interviews would occur as part of an ongoing OIG investigation that we expect
would lead to a public report. However, we don't want to make this representation unless DOJ-OIG is comfortable with it.
I'm happy to discuss by phone if convenient.
Thanks very much,
Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
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=== Page 1 ===
From:
To:
Bcc: "USAHUB-USAJournal111"
Subject: Notes from 10/26/20 call with GA USAO re Maxwell
Date: Mon, 26 Oct 2020 19:50:52 +0000
Embedded: Notes_fron_10_26_20_call_with_GA_USAO_re_Maxwell.msg
Sender
Subject: Notes from 10/26/20 call with GA USAO re Maxwell
Message-Id:
<SN5P110MB05429B45F625ABCB7B95625092190@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
To:
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=== Page 1 ===
IN THE WESTMINSTER MAGISTRATES' COURT BETWEEN:
THE GOVERNMENT OF THE UNITED STATES OF AMERICA
-v-
JULIAN PAUL ASSANGE
DECLARATION OF MAUREEN P. BAIRD
I, MAUREEN P. BAIRD, hereby declare under penalty of perjury the following:
1. From March 1989 through September 2016, I was employed by the Department of
Justice, Federal Bureau of Prisons, and served in many capacities. My last three
positions held were; Warden, Federal Correctional Institution, (FCI) Danbury,
Connecticut (2009-2014), Senior Executive Service (SES) Warden, Metropolitan
Correctional Center (MCC), New York (2014-2016), and SES Warden, United States
Penitentiary, (USP), Marion, Illinois (2016-Retired).
2. In my capacity as Warden, at these institutions, I was responsible for the overall
operation and entire components of each prison. I am fully knowledgeable of the
operations policies of the Bureau of Prisons, (BOP) and very specifically familiar with
the operations of the Communication Management Unit at USP Marion.
3. Since my retirement from the Bureau of Prisons, I have maintained contact with many
former colleagues. I have kept abreast of new policies and laws that directly impact the
Bureau of Prisons. Since early 2017, I have worked as an independent prison consultant
and have provided expert witness testimony.
1
EFTA00028003

=== Page 2 ===
4. A copy of my resume which includes my relevant work experience has been provided to
Counsel in this case.
5. I was contacted by Mr. Assange's solicitors and asked to provide a declaration focused
on topics within my expertise in response to the Declaration submitted by Dr.
,
Administrator of the Psychology Services Branch of the Bureau of Prisons,
dated August 24th 2020 and the Fourth Supplemental Declaration of
Assistant United States Attorney, Alexandria, Virginia, dated September 3rd 2020. I was
asked to provide my expert opinion as someone who worked many years in the same
federal prison system as Dr.
I will provide my opinion based on my
experience regarding conditions of confinement in the Bureau of Prisons for inmates
assigned Special Administrative Measures (SAMs), offenders assigned to the
Communications Management Unit (CMU), and inmates housed in
solitary/isolation/restrictive housing units.
6. In preparation for this declaration, in addition to the Declaration of Dr
and
,
I also reviewed previously submitted Declarations prepared by
, dated January 17th 2020 and February 19th 2020 as well as two
Affidavits submitted by
Justice Advocacy Group, LLC,
Alexandria, Virginia, the Affidavit of
Attorney, New York, New York
and two Statements of
,
Attorney, Washington, DC dated and 18th October
2019 and 18th July 2020
7. I am advised, Mr. Assange is pending extradition to the United States for his alleged
criminal activity charging: Conspiracy to Receive National Defense Information,
Obtaining National Defense Information, Disclosure of National Defense Information,
2
EFTA00028004

=== Page 3 ===
and Conspiracy to Commit Computer Intrusion. If a conviction of these charges results
in the United States, he faces a potential lengthy sentence without the possibility of
parole.
Declaration of
(September 3rd, 2020)
Special Administrative Measures
8. In reviewing
documents, he makes several references to the possibility
of Mr. Assange being placed under Special Administrative Measures, (SAMs),
authorized by the Attorney General and implemented by the wardens of the facility where
the offender is housed. As the former Warden of MCC New York, which housed SAMs
inmates pending trial in the Southern District of New York, I am very familiar with the
restrictions which accompany a SAMs Order. I agree, in part, with the information
provided by
specifically, his description of SAMs and the usual
restrictions placed on an offender under SAMs. The restriction of social visits, telephone
calls, correspondence, access to other inmates, and placement in a restrictive form of
housing is commonplace for SAMs inmates.
9. In the Affidavits prepared by
he provides in great detail, the effects and
outcome of SAMs imposed on inmates. I agree with the references and the accurate
descriptions provided by
in his affidavits regarding the effects of SAMs on
inmates and the conditions of confinement associated with these measures.
10. In his Fourth Supplemental Declaration dated September 3rd 2020,
challenges some of the assertions regarding SAMs provided by
For anyone
to suggest that an inmate assigned under SAMs, would be able to participate in group
3
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=== Page 4 ===
counseling is baffling to me. The main premise of assigning SAMs, is to restrict a
person's communication and the only way to accomplish this is through isolation. For
example
lists a variety of programs available to inmates assigned to the
ADX. I don't doubt all of these programs exist, but I believe they are available only to a
select group of inmates housed at that facility. Even if the Warden, Unit Team,
Lieutenant or Captain wanted to allow SAMs inmates to participate in certain group
programs, they do not have the legal authority to sanction such an action. All of these
robust programs which
says are available, they would be meaningless and
non-existent to
if he were assigned under SAMs. There may be certain
courses/programs available to inmates assigned SAMs, but I believe all of those would be
some type of self-study, which could be completed by an inmate, housed alone in his
prison cell.
11. Inmates assigned SAMs, whom I had responsibility for, were always housed alone, in the
most restrictive housing unit, more isolated than what most individuals would deem
solitary confinement to be. During my 18-months at MCC New York, I conducted, at a
minimum, weekly tours of the 10-South housing unit, where SAMs inmates were
confined. Inmates were in solitary confinement, technically, for 24-hours per day. There
was absolutely no communication, by any means, with other inmates. The only form of
human interaction they encountered was when correctional officers opened the viewing
slot during their inspection rounds of the unit, when institution staff walked through the
unit during their required weekly rounds, or when meals were delivered through the
secure meal slot in the door. One-hour recreation was offered to inmates in this unit each
day; however, in my experience, often times an inmate would decline this opportunity
4
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=== Page 5 ===
because it was much of the same as their current situation. The recreation area, in the
unit, consisted of a small barren indoor cell, absent any exercise equipment. During my
tenure at MCC New York, I had a stationary exercise bicycle placed in the designated
recreation cell. I am uncertain if that bicycle is still in place.
12. As with most restrictive housing units within the federal prisons, there is a limited list of
commissary items for inmates to purchase on their designated shopping day. The
products available for purchase are much more condensed than the commissary items
available to inmates in a general population housing unit. Telephone calls to immediate
family members were allowed once per month; however, as with any SAMs inmate, the
call must be scheduled in advance and coordinated through BOP staff and agents from
the Federal Bureau of Investigation (FBI). All telephone calls must be live monitored by
an FBI agent. Similar telephone calls, the inmate's limited social visits with immediate
family members also required live audio monitoring by the FBI. The vast majority of
inmates under SAMs at MCC New York, were not United States citizens, nor did their
families reside in this Country. This made it very difficult for their families to visit and
due to the time differences, difficult to arrange for telephone calls.
13. There are two very differing views presented by
and
(July 16,
2020, Affidavit, Section 50-51), with regard to an inmate's due process rights to
challenge SAMs. I would agree with
stance, that application of SAMs, in a
legal sense, affords the opportunity for inmates to challenge its implementation, but it is
likely more of a circular argument. Inmates are required to receive notification of the
restrictions and the basis for SAMs at the time of initial implementation and again when
restrictions are being renewed. In his January 17, 2020, Declaration, section 99,
5
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=== Page 6 ===
states an inmate may challenge the SAMs through the BOP's Administrative
Remedy Program. During my 28 years with the BOP, there were times that I was
responsible for responding to Administrative Remedies. With certainty, I declare, for the
purpose of challenging a SAMs, it would be a futile process. The BOP exercises no
control/jurisdiction over SAMs imposed by the Attorney General. Wardens are bound to
abide by the SAMs imposed on an inmate. An inmate's only possibility of having his
SAMs reconsidered, would be for him to exhaust the Administrative Remedy process, so
he could file a motion with the Court.
14.
also points out in section 66, of his Fourth Supplemental Declaration, that
inmates' First Amendment rights are not violated under SAMs. He provides the example
that these inmates' have access to "free-flowing incoming and outgoing mail." As I
explain in my report, all mail for inmates classified under SAMs, is carefully reviewed
prior to ever reaching the intended recipient. Regardless of how innocuous something
may appear, if it does not meet with the approval of the reviewer, for any reason, that
piece of mail will be immediately rejected.
15.
provides in his Declaration the avenues for inmates to object to any SAMs
renewal. He advises an inmate will meet with his unit team and the supervising law
enforcement agency case agent, where he will be afforded the opportunity to present
evidence and/or discuss issues and provide information indicating there is no need to
extend SAMs, or why a modification to the restrictions are justified. The information is
compiled by the case manager and forwarded to the Warden through the institution's
legal department. All of this, in most cases, is an exercise in futility where a
recommendation for continued SAMs is involved. As a former senior executive of the
6
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=== Page 7 ===
BOP, I do not know of any warden who would recommend discontinuing SAMs at the
possible risk of serious harm to others resulting or the potential for threats to national
security. It is not realistic and I can say with near certainty, it is not going to happen.
16. Likewise, in other scenarios suggested by
as avenues of appeal available
for an inmate, they are futile. He advises an inmate can object to his SAMs during his
twice-yearly unit team reviews, initial classification review, and when his progress report
is being prepared by his case manager. Having been a case manager for several years,
early on in my BOP career, it is unrealistic to think these avenues would provide anything
more than an outlet for an inmate under SAMs to vent his frustration. A case manager
may listen to his concerns: however, even if the case manager believed a change in status
was warranted, there is no possible way, that they would initiate a recommendation for
removal of the restricted measures. This type of recommendation is far above their
authority of a case manager or any member of an inmate's unit team.
17.
asserts these SAMs are imposed in, "up to one year" increments, with the
time-requirements the same for any extension beyond one year. During my term as
Warden at MCC New York, I have never seen an inmate have SAMs removed, only
extended.
18.
states that SAMs are not imposed for punitive reasons, but rather to
minimize a threat to national security or for other reasons not applicable in this case. By
strict definition of SAMs, it is correct to state it is not punitive, but the effects and
consequences of these administrative measures through my experience, are tortuous for
the recipient, and while technically not intended, feel punitive to those who have these
measures enforced upon them. Placement in this type of isolation, for any extended time
7
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=== Page 8 ===
period is dehumanizing. In my opinion, any person with a conscience and an ounce of
compassion, would believe these extreme tactics utilized for any reason are cruel and
inhuman. Humane prison conditions, in my psyche, require more than just providing
basic necessities such as; food, clothing, shelter, medical care and safety to an inmate.
19. In his Fourth Supplemental Declaration, in section, 67,
implies that as
long as these basic needs are met, there is not a violation of an inmate's Eighth
Amendment rights. As a human being, and secondly, a warden, I had to justify in my
own mind, that this form of treatment against another, was out of necessity. I would
rationalize for myself, that because, I did not make the decision on who was subjected to
SAMs, I had no control over the implications and effects of these extreme measures.
Inmates under SAMs would often ask me why they were being punished so severely.
The majority of inmates I encountered under SAMs, were charged with an act of
terrorism against the United States. However, regardless of the criminal charges levied
against them, all SAMs inmates endured identical conditions. There was not a section for
terrorists and a separate section for large-scale drug offenders. If
is
extradited and subjected to SAMs, he will be treated similarly to all other prisoners under
SAMs. I have witnessed first-hand, these unduly harsh conditions experienced by
inmates under SAMs.
20. I know from my time at MCC New York, as Warden, even if I wanted to make
concessions, as a way to make living conditions more humane, I was restricted from
doing so. Small concessions, such as adding items to the commissary list for certain
holidays, was within my purview, however; the things that were substantial and mattered,
those things which could make a real difference, were not within my authority.
8
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=== Page 9 ===
Florence ADX
21. In section 28, of his Fourth Supplemental Declaration,
accurately states
prison designations (post-sentencing), are decided by the BOP and many factors go into
the decision on where an offender will serve his sentence. As a former Designator for the
BOP, I clearly understand all the factors considered when determining placement for a
sentenced inmate. It is also my belief, as
states, the BOP's philosophy is
to secure inmates in the least restrictive environment commensurate with an inmate's
security needs. The problem with those inmates that are assigned SAMs, there are
limited choices. If the inmate isn't gravely ill, requiring placement at a Federal Medical
Center, regardless of the length of sentence, or any other factors, as suggested by
, I don't believe there are other options, except for placement at the ADX. As
provides in his second Affidavit dated July 16, 2020, if a conviction results
and
is assigned SAMs, he will very likely be housed in the Special Security
Unit (H Unit), at the ADX facility. I would agree with
assessment that if
convicted,
could potentially spend the remainder of his life in this very
restrictive housing unit, where he would be deprived of some very basic human needs.
22.
provides several exhibits which depict the desolate and degrading conditions
associated with placement at the ADX for an inmate who has imposed SAMs. In one
example, (Exhibit 13, Affidavit of
, dated July 16, 2020),
quoted
one former ADX Warden as stating, how the ADX Supermax Prison is a "Fate Worse
Than Death", that was "Not Built For Humanity".
former Warden of the
ADX and previous collegue of mine, was a very respected and relied upon, BOP
Administrator.
9
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=== Page 10 ===
23. In section 45, of
Fourth Supplemental Declaration, he states that
inmates incarcerated in H Unit at the ADX have the opportunity to participate in a multi-
phase program, that was designed primarily for inmates under SAMs. His summary is
absent any detail or description of what this program actually is. Based on what he
provided, I interpreted his portrayal of the "Program," as the actual Special Security
Housing Unit and not really a program at all. Any program involvement that would
encompass other inmates, would not only violate the conditions of SAMs, it would defy
the entire reasoning and intent of the assigned administrative measures.
24. In section 102, of his first Declaration, and in sections 28-29 of his fourth Supplemental
Declaration,
suggests not all inmates, post-conviction, who are under
SAMs, are housed at the Administrative Maximum Security United States Penitentiary,
(ADX), Florence, Colorado. He provides that if medically necessary, a SAMs offender
may be housed at a federal medical facility. He further contends, most inmates subject to
SAMs are housed at the ADX, but there may be circumstances that warrant housing
elsewhere. As someone who spent the majority of her adult life working for the BOP and
as a former Designator, who decided where inmates would serve their sentences, absent a
medical requirement, or a protected Witness Security Case, I am not familiar with any
alternative long-term options, aside from the ADX, for offenders under SAMs. Federal
Medical Centers, in my experience, are reserved for the very ill inmates, usually those
who have a life-threatening illness that requires on-going medical treatment not available
at other federal prisons. These medical facilities may also have an in-patient
psychiatric/mental health unit designed to house inmates who suffer from severe mental
illness.
10
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=== Page 11 ===
25. In the affidavit of
,
she provides a very detailed account of the experience of
her client, Mostafa Kamel Mostafa, who is currently incarcerated at the ADX, assigned to
H-Unit, with SAMs assigned. I reviewed her Affidavit and based on my experience with
the BOP, especially my time spent as Warden at MCC New York, I find her descriptive
account of what life has been like for her client, Mr. Mostafa to be believable and
credible.
26. I arrived to MCC New York in 2014, after being promoted to Senior Executive Service
Warden from my former position as Warden of the FCI Danbury federal prison. I had
not previously worked at a facility where inmates assigned SAMs were housed. I clearly
remember Mr. Mostafa through my meetings with him during my rounds of the 10-South
SAMs Unit. I remember he was disabled, having gone through a bilateral amputation of
both forearms. I recall how difficult it was for him to attend to his basic hygiene needs
and how isolation in the 10-South unit was having detrimental effects on his mental well-
being. Until recently, I did not know that Mr. Mostafa was serving a life sentence at the
ADX and that SAMs was still in place in his case.
27.
provides a history of the legal challenges Mr. Mostafa has experienced and
provides a correlation to his conditions of confinement and that which would be
experienced by Mr. Assange, if extradited and placed under SAMs by the Attorney
General. I agree with her description of the devastating effects caused by isolation as a
result of SAMs. Similar to everything I previously provided in this report regarding
SAMs, she also provides in her statement. To describe the setting of the ADX and MCC
New York for inmates assigned to prolonged SAMs as unduly harsh, is an
understatement. In section 34 of her Affidavit,
provides the findings of the
11
EFTA00028013

=== Page 12 ===
High Court of Justice, Queen's Bench Division, specifically comments regarding the
High Court's views on a lengthy period of incarceration at the ADX in isolation.
28. The conditions of confinement experienced by Mr. Mostafa as outlined in detail in
Affidavit, are the same conditions shared by other inmates who are assigned
under SAMs. Should Mr. Assange be extradited to the United States and assigned
SAMs, his fate will be equal to that of Mr. Mostafa. I am uncertain how the BOP has
been able to continue with these types of isolation units, given all the studies, reports and
findings of the horrific physical and psychological effects they have on inmates.
29. With the Court's decision in Cunningham V. Federal Bureau of Prisons, generated by
inmates at the ADX and further explained in great detail in
report, some
accommodations have been made to help negate the effects of long- term isolation on an
inmates' emotional well-being. This decision does not contribute to the well-being of
those offenders under SAMs. As I explained throughout my report, the very premise of
SAMs is to prevent their contact with the outside world and especially, with other
inmates.
Communications Management Unit
30. There are extensive discussions in
Declarations and
Affidavits regarding the possibility of a Communication Management Unit (CMU)
placement for Mr. Assange, if a conviction results in the charges against him. There are
two federal prisons which have a CMU, the United States Penitentiary (USP) Marion,
Illinois and the USP Terre Haute, Indiana. I was the Warden for a brief time at the
Marion facility and was responsible for overseeing the CMU at that institution.
12
EFTA00028014

=== Page 13 ===
31.
and
provide very detailed descriptions of CMUs and each
offer their opinions about these types of prison environments. CMUs are a separate
prison within a prison, where almost every aspect of their prison life occurs within that
housing unit. I believe both individuals provide valid assessments of certain aspects of
the CMUs; however, I accept
description as more closely depicting the
realities and accuracies of these types of restrictive housing units. CMUs are not as
restrictive as the conditions associated with an inmate assigned under SAMs, but they are
far more limited than what is available at a mainline institution. At the Marion prison, a
small outdoor recreation area is available to the inmates; however, it does not remotely
offer the same exercise or recreational accommodations found at a regular prison facility.
There are tables set up in the outdoor recreation cages, where inmates can participate in
board or card games. There is limited space for outdoor walking and short of walking in
circles, or a short horizontal pattern, it is difficult for an inmate to engage in any
meaningful and healthy outdoor exercise.
32. Contrary to
assertion, inmates in CMUs are not afforded the same
opportunities as those available to inmates in general population, to communicate with
others, outside of the prison environment. Similar to the restrictive measures of SAMs,
all outside communication of these inmates must be live monitored by an FBI agent. All
telephone calls need to be scheduled in advance and an agent must be available to listen
and record any call with an inmate's family members. This is not as easily accomplished
as it appears. Agents are not always available on certain days or at certain times, and the
inmate's counselor must also be available to coordinate any telephone calls. All
13
EFTA00028015

=== Page 14 ===
incoming and outgoing mail is carefully scrutinized before delivery to the intended
recipient.
33.
accurately describes how social visiting in CMUs is limited and restrictive in
comparison to inmates in general population at other BOP facilities. Programs within
CMU's are also very limited and do not offer the same opportunities as those afforded to
inmates housed in the general population of the main section of the institution. During
my regular weekly rounds of the Marion CMU, I often had a barrage of complaints from
these inmates pertaining to the absolute boredom they experienced and lack of
meaningful programs in the unit.
34. The majority of inmates I encountered in the CMU, similar to what
depicts,
were convicted of domestic and international terrorist crimes, violent crimes against
others, threatening public officials and sometimes associated with anti-government
groups. The English language was not the first language of the majority of the inmates in
this unit, some did not speak English and Arabic was primarily the language in which
they conversed. A large contingent of these inmates were Muslim and some would only
associate with other inmates of the same ethnic and religious background.
35. Both
and
describe how inmates can appeal their placement in
a CMU. As
correctly points out, an inmate has the ability to challenge the
CMU decision through the BOP's Administrative Remedy Program. This four-tiered,
mainly internal, appeals process has various requirements, and is arduous and lengthy, as
suggested by
It often results in a denial of whatever remedy the inmate is
requesting. I would confidently state that it is unlikely any inmate has ever been
successful in his appeal to be transferred out of the CMU. Inmates in the CMU receive
14
EFTA00028016

=== Page 15 ===
bi-annual Program Reviews, which are informal, scheduled meetings where they meet
with members of their unit team and discuss amongst other things, their continued
placement in the CMU. As Warden, I would meet with the CMU unit team staff and
discuss each case to determine if we believed there was a continued need for these types
of restrictive measures. A recommendation was then forwarded from the Warden to the
BOP's Counter-Terrorism Unit and finally to the BOP's Assistant Director of
Correctional Programs, for a final decision. During my assignment at USP Marion, I
recall only one time, where I made a recommendation for an inmate to be transferred out
of the CMU, but that recommendation was met with a denial. I do not recall any inmate
ever being transferred out of the CMU, other than a transfer to the sister-CMU at the USP
Terre Haute. Every individual must determine for themselves, if these procedures afford
an inmate due process or it is just a circumstance of which an inmate has no control or
recourse.
Declaration of Dr.
dated August 24th 2020
36. In her Declaration, Dr.
provides a detailed overview of mental health services
offered in the BOP. She accurately describes the types of inmates the BOP houses and
provides a plethora of programs offered to the inmate population through the institutions'
Psychology Services Departments.
37. Dr.
criticizes the findings made by
regarding psychologists
staffing levels throughout the BOP. She points out the BOP was recently authorized and
has started to recruit for 48 new psychologist positions. I believe the BOP is well-
intended on hiring additional psychologists to fill these vacancies. The problem, which
Dr.
does not mention, is the difficulty the BOP has in recruiting qualified
15
EFTA00028017

=== Page 16 ===
mental health professionals. Psychologist positions have always been considered "hard
to fill positions" in the BOP, presenting a significant challenge for the Agency.
Psychologists in the communities are often not interested in working in a prison
environment, the salaries offered are lower than what is offered in the private sectors, and
many federal prisons are located in very rural areas, all making a job as a psychologist
with the BOP, unattractive and difficult to successfully recruit. Often times, the Agency
would offer sign-on bonuses as a means to capture the attention of prospective
psychologists. Dr.
believes the BOP's staffing level of psychologists is
adequate and improving. I would only agree with Dr.
summation, if and
when, the BOP hires all of these new psychologists, and fills most of their current vacant
mental health staff positions, which will likely not occur anytime soon, or ever. For
purposes of the current staffing conditions, I find the information presented by
is accurate and realistic.
38. With regards to staffing levels in the BOP in general, there are opposing views between
and
The numbers with respect to staff to inmate ratios are
fluid and the BOP continues in their quest to recruit qualified staff. The Agency is
currently offering a 10% retention bonus for corrections officers at specific "hard-to-fill"
locations. The federal prisons in Florence, Colorado, including the ADX are on this list
with 16 other federal facilities.
in section 16 of his most recent
,
Supplemental Declaration refers to how all BOP staff, with the exception of a few, are
considered law enforcement and receive identical training as correctional officers. While
technically accurate, some of these staff have not received specific correctional officer
training since they began their careers several years ago. In his second Affidavit, in
16
EFTA00028018

=== Page 17 ===
section 13,
provides a very detailed and accurate explanation of how the BOP
handles staff shortages. The BOP utilizes this system of "Augmentation", throughout the
country on a regular basis. In my view, the BOP is continues to operate federal prisons,
while dangerously under-staffed. Position vacancies have been an ongoing challenge for
many years, and I see no quick resolution to this problem.
39. The Office of the Inspector General (OIG) (Exhibit 5 in Second Statement of
), criticized the BOP's staffing levels in their July 2017 Review of the Federal
Bureau of Prisons' Use of Restrictive Housing for Inmates with Mental Illness Report.
The OIG report demonstrated how the BOP was understaffed in mental health services
and not meeting the treatment needs of inmates with mental illness. The BOP's standard
is to have one psychologist for every 500 assigned inmates. Institutions reviewed during
OIG's inspection, fell significantly short in meeting this standard. As of October 2015,
during a time I was still employed with the BOP, the OIG found that only 57% of its
authorized Psychiatrist positions were filled. This Report further offers a detailed
description regarding the psychological damage and effects long term isolation can have
on inmates.
40. Dr.
and
both refer to the 2014 report, Federal Bureau of Prisons:
Special Housing Unit Review and Assessment. In my opinion, the findings of the report
stand for themselves. Dr.
implies in section 37, of her Declaration, that
inmates are content at the ADX. She bases this assumption solely on inmates not
wanting to transfer to another federal prison. In my years of working in the prisons,
inmates would often express to me, they did not want to be transferred to another prison,
as just the idea of a transfer, to an unknown destination was in itself, anxiety-provoking
17
EFTA00028019

=== Page 18 ===
and frightening. Remaining at their current prison, regardless of the conditions
experienced, was a better option than having to start the process over again at a prison
which could end up being worse.
41. A variety of programs are provided in Dr.
Declaration, many of which I am
familiar with, having worked in many federal prisons during my career and three
Regional Offices. No doubt the BOP offers some viable inmate programs, including
residential programs, especially those available to inmates with mental health concerns.
There are specific programs designed to address Mr. Assange's diagnoses of Depression,
Anxiety, Asperger's Syndrome and others. The problem with this, as Dr.
also
points out, is that some of these specialized residential programs, such as the Skills
Program are only offered at a limited number of federal prisons. The Skills Program is
offered at the Federal Correctional Institution, Danbury, Connecticut and the Federal
Correctional Complex, Coleman, Florida. The security levels of these institutions are
Low and Medium Security, respectively. Mr. Assange would not qualify for placement
at either of these institutions, as he would likely be classified as a High Security Level
offender, making him ineligible for placement at Danbury or Coleman.
42. Irrespective of all of these programs available to inmates in the BOP, if a SAMs
assignment were placed on Mr. Assange, the restrictions which accompany this, will rule
out any possibility for him to engage in such activities and programs. The SAMs will
override the need for programs and will dictate what is allowed for Mr. Assange during
any period of incarceration. Safety and security will always be the primary goal of the
Agency and all other matters are secondary.
18
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=== Page 19 ===
43. Dr.
makes reference to the psychological assessments of two medical
professionals who purported Mr. Assange would be an extreme high risk for suicide, if he
were extradited. I have reviewed these assessments, and similar to the concerns
expressed by the medical professionals, Mr. Assange's mental health and continuous
thoughts of harming himself are very troubling. All staff receive training on how to
respond to potentially suicidal inmates; however, we realize if a person wants to commit
suicide or in the course of events leading up to suicide, the individual changes their mind,
it unfortunately in most cases is too late, and the person is unable to be revived. The
example of August 2019 suicide of Jeffrey Epstein, at the MCC New York, comes to
mind.
44. Suicides in prison often occur in solitary confinement and during pre-trial status. With
the likelihood of Mr. Assange being housed in solitary confinement, he would be at
greater risk for suicide and/or self-harm. There are cameras on the ranges of the Unit,
but, as with the case of Jeffrey Epstein, those cameras malfunction, are not always
operable or left unattended.
45. If an instance occurred where Mr. Assange was in the act of committing suicide, staff in a
restrictive housing unit cannot render immediate assistance and would need to wait until
more staff arrive at the scene. It takes time for staff to respond to an emergency and they
are prohibited for their own safety, from entering the cell until enough staff are present.
The outcome would likely result in the death of death of Mr. Assange.
46. I do agree with Dr.
that the BOP has a robust suicide prevention program and
employs dedicated staff to treat offenders who present with mental health concerns. If
extradited to the United States, it is paramount that Mr. Assange's psychiatric reports
19
EFTA00028021

=== Page 20 ===
transfer with him, (these reports are not always provided by the transferring agency).
These reports would allow staff to be aware of his mental health history. During the
intake screening process, upon entering any federal facility, one of the prison
psychologists would assess him, through a series of questions, and determine Mr.
Assange's risk of suicide. This is where the systems of safeguard have proven not to be
effective. One of the primary tools utilized in a suicide assessment is the reliance on an
inmate to self-report in a truthful manner how he is feeling. When inmates are dishonest
about their suicide intentions, and they often are, (as in the case of Jeffrey Epstein), other
cues to determine the risk of self-harm may be missed which could result in a dire
outcome. If the assessment determines there is a present risk of taking his life, he would
be placed on suicide watch. Individuals who are on suicide watch, remain in that status
until the risk of suicide has significantly subsided.
47. As a former warden, I've personally had the unfortunate experience of receiving that
phone call, informing me of an inmate's successful suicide. In two of the cases I recall,
although other inmates were aware of the individuals' propensity and plans for suicide,
they failed to report it to staff. This could have made the difference between life or death
for those inmates. Regardless of how robust the Bureau of Prisons' Suicide Prevention
Program is, the Agency cannot prevent someone who is intent on committing suicide, and
too often inmates slip through the cracks.
48. Further in her Declaration, Dr.
provides a summation of when the BOP utilizes
restrictive housing for inmates and the reasons why an inmate would be placed in this
type of restrictive setting. She states the obvious reasons, such as the need to curtail the
actions of violent or aggressive inmates; however, she also infers restrictive housing is
20
EFTA00028022

=== Page 21 ===
utilized for inmates who are deemed a security threat or for those who cannot be safely
housed with other inmates in general population. This is a catch-all phrase that allows for
BOP staff to place any offender in restrictive housing based on their belief of any safety
concern.
49. An offender, with criminal conduct similar to Mr. Assange would be placed in restrictive
housing, regardless of any SAMs assignment, upon his arrival at every federal prison
throughout his entire term of imprisonment. The length of time he would remain in this
restrictive setting is impossible to predict. There have been many studies, investigations,
reports completed on the effects of prolonged placement in isolation. I have even
referenced an OIG report in this Declaration, which discusses this subject at length.
From my experience, of close to three decades of working in federal prisons, I would
agree that long term isolation can have serious negative effects on an inmate's mental
health. There are very limited programs offered to inmates in these restrictive settings,
including mental health programs. There may be occasional one-on-one intervention
with a mental health professional, but often that intervention will take place by
attempting to communicate through a steel door or the food slot built into the door. With
the limited number of Psychology Staff, time simply does not permit any type of
extensive individualized counseling with inmates in restrictive housing. It would take a
minimum of two staff, and sometimes more, depending on the security and custody level
of the inmate, to shackle the inmate, unlock his cell and escort him to another secure
location. If psychologists were to engage in this type of counseling, they would spend
their entire shift focusing solely on this limited group of inmates. It is not feasible to
expect that, especially given the already high demands of their caseloads, coupled with a
21
EFTA00028023

=== Page 22 ===
shortage of psychology staff as well as psychology staff being utilized to fill in for vacant
correctional officers' posts.
50. All of these policies which effect how the BOP manages and cares for mentally ill
inmates are specific and thorough. However, policies, regardless of how meaningful and
well-intended they are, for the reasons cited in the last paragraph, are not always carried-
out and coincide with what occurs in actual practice.
Declaration of Truth and Continuing Duty to Court
51. I understand that my primary duty is to the Court. I have complied with that duty and
will continue to comply with that duty. I have set out in my statement what I understand
from those instructing me to be the issues in respect of which my opinion as an expert is
required. All the matters on which I have expressed an opinion are within my field of
expertise.
52. I have done my best, in preparing this statement, to be accurate and complete. I have
mentioned all matters that I regard as relevant to the opinions I have expressed.
53. I have not included in this statement, anything which has been suggested to me by
anyone, including lawyers instructing me, without forming my own independent view of
the matters. At the time of signing the statement, I consider it to be complete and
accurate. I will notify those instructing me if, for any reason, I subsequently consider that
the report requires any correction or qualification.
54. I understand that this report will be evidence that I would be prepared to give under oath,
subject to any correction or qualification I may make before swearing to its veracity. I
confirm that I have made clear which facts and matters referred to in this report are
within my own knowledge and which are not. Those that are in my own knowledge I
22
EFTA00028024

=== Page 23 ===
confirm to be true. The opinions I have expressed represent my true and complete
professional opinions on the matter to which they refer.
55. I, Maureen Baird, attest under penalty of perjury that, on this 11th day of September
2020, this document is true and accurate to the best of my knowledge, information, and
belief.
narm Baid
Maureen P. Baird
23
EFTA00028025


c1: EFTA00027962
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027962.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
90A-NY-3151227 Serial 47
FD-1057 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Electronic Communication
Title: (U) FD-597/ Items 1B20, 1B21
Date: 08/20/2019
From: NEW YORK
NY-C19
Contact:
212-384-1000
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Synopsis: (U) FD-597/ Items 1B20, 1B21
Enclosure (s) : Enclosed are the following items:
1. (U) FD-597/ Items 1B20, 1B21
Details:
On 08/15/2019, SA
seized items 1B20 and 1B21 from the
MCC, 150 Park Row, New York, NY from Lt. T. Doctor at approximately
4:45pm. The FD-597/ Receipt for Government Property is attached in a 1A
package.
UNCLASSIFIED
EFTA00027962


c1: EFTA00027510
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027510.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein search warrant documents
Date: Mon, 06 Jul 2020 13:18:51 +0000
The team says it's not a PDF, it's indecipherable data.
From:
(USANYS)
Sent: Monday, July 6, 2020 8:53 AM
To:
(USANYS)
Subject: RE: Epstein search warrant documents
With respect to the iphone seized from Epstein, for which FBI gave us an extraction, are we not into it because FBI can't
get in, or is there a transmission issue with the way FBI sent us the extraction?
From:
(USANYS)
Sent: Monday, July 6, 2020 8:49 AM
To:
(USANYS)
Subject: RE: Epstein search warrant documents
Pretty sure it's everything. The estimate references 57 devices, as noted below, I think we're now up to 62, but we're into
one of them, so really 61. We can get an updated estimate for the 61 if that would be helpful, but given how much
business the PC unit gives
he should be good to us on that
From:
(USANYS)
Sent: Monday, July 6, 2020 8:44 AM
To:
(USANYS)
Subject: RE: Epstein search warrant documents
What is the estimate for? All of these? Just UVI?
From:
(USANYS)
Sent: Friday, July 3, 2020 2:50 PM
To:
(USANYS)
Subject: RE: Epstein search warrant documents
Yes, there are a total of 62 devices which can be divided into three main buckets based on how/where we obtained them,
the second and third of which are by far and away the biggest:
1 Phone and 1 iPad seized from Epstein at the time of his arrest on July 6, 2019. The FBI first delivered copies of
the extractions from these devices last week. We were able to review the iPad, but we have not been able to
open the iPhone data. IS THIS AN FBI TRANSMISSION ISSUE WITH THE IPHONE DATA, OR IS IT THAT IT WAS UN-
OPENABLE?
33 electronic devices seized from the New York residence on July 11, 2019. These include multiple hard drives,
multiple computers, multiple USB drives, and multiple iPads. We currently have extractions from/access to none
of them.
27 electronic devices seized from the Virgin Islands residence on August 12, 2019. These include multiple
computers, multiple iPads, and multiple USB drives. We currently have extractions from/access to none of them.
EFTA00027510

=== Page 2 ===
From:
(USANYS)
Sent: Friday, July 3, 2020 1:51 PM
To:
(USANYS)
Subject: Re: Epstein search warrant documents
Can you have the team summarize status of different buckets of devices for me? I'll push this to resolution,
possibly through vendor.
On Jul 2, 2020, at 7:13 PM,
(USANYS)
wrote:
Let's discuss. I just don't have a lot of confidence that is going to get this done.
Sent from my iPhone
On Jul 2, 2020, at 6:35 PM,
(USANYS)
wrote:
Ok. Audrey is also prepared to call
about pushing this issue if need be.
On Jul 2, 2020, at 6:32 PM,
(USANYS)
wrote:
On this issue of the Epstein devices, the team got an estimate from BRG that seems reasonable in terms of both cost
and time line. At this point, I would be inclined to do this, but let's find some time to chat more about it tomorrow if
you're around or early next week if that's better. Thanks
From:
Sent: Thursday, July 2, 2020 5:11 PM
To:
(USANYS)
Cc:
(USANYS)
>;
is
Subject: RE: Epstein search warrant documents
Following up on the below, I think we've given this our absolute best efforts with FBI - they are now well over a
month later than their estimate from April on when we would get the New York materials, they're also past their
estimate of getting us the New York materials from just this Monday, and we don't have anything close to an
estimate on the USVI materials, which constitute the overwhelming majority of the data and are vastly more
voluminous than the New York devices. We have kept pushing the timeline back for this option, hoping that CART
will finalize, but I think at this point we should have a vendor do it.
Attached is an estimate we got from BRG, which would get everything to us in under a month, and in Relativity-
friendly format, in a range of $85-135K. BRG has done this for our office multiple times in the past and are very
effective and efficient, and they get the materials we need. And most importantly, they estimate they can do it all in
less than a month. May we have approval to seek funding for this? The estimate is attached. Thanks very much.
From:
)
Sent: Tuesday, June 30, 2020 16:23
To:
(NY) (FBI)'
is
(USANYS) [Contractor]
EFTA00027511

=== Page 3 ===
Cc:
(USANYS)
is
(NY) (FBI)
is
is
i
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
From:
Sent: Monday, June 29, 2020 13:00
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS)
i
(NY) (FBI)
V.
is
i
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Okay thanks - good luck with the cardiologist! And if you can let us know tomorrow that would be great. Thanks
again.
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:59
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
is
(NY) (FBI)
is
is
is
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
When I'm in the office tomorrow, I will be better able to estimate. I'm at my cardiologist right now.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:56 PM, "
)"
wrote:
Great, thanks. Is there even a rough estimate of when we will get the USVI materials? Or an estimate of when you'll
be able to see how many items to export, so we'll have a better sense of when we'll get those?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:55
To:
(USANYS) [Contractor]
is
EFTA00027512

=== Page 4 ===
Cc:
(USANYS)
is
(NY) (FBI)
is
is
is
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Yep
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:52 PM,
)"
wrote:
Okay, and I'm sorry to ask again, but to make sure, in this production, you're sending us new versions of what you
previously sent?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:50
To:
(USANYS) [Contractor]
is
)
Cc:
(USANYS)
i
(NY) (FBI)
is
is
is
(NY)
(FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
You are getting both NY and USVI. The biggest stumbling block are the newer Mac items that are in APFS
(there are a bunch from the Island,) so it is difficult to estimate how long those will take until I see how
many items I have to export.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:40 PM,
)"
wrote:
Okay thanks, and just to clarify, a few days to finalize the New York materials, and then what about the USVI
materials? I think that is quite a bit more. Just looking for an estimated completion date for everything.
And on my other question - does this mean you're giving us a new, complete copy of everything from both NY and
USVI?
thanks,
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:34
To:
(USANYS) [Contractor]
is
)
Cc:
(USANYS)
is
(NY) (FBI)
is
EFTA00027513

=== Page 5 ===
is
is
(NY)
(FBI)
in
(USANYS)
Subject: RE: Epstein search warrant documents
I am in the process of exporting the materials (documents, spreadsheets, emails, etc) for your review as per
my discussions with
Most of the NY stuff is done, just Mac items left. This might take a few days as
1 item in particular has over 500,000 emails. We will be able to provide discovery once Defense Council
has provided drives for us to copy items over to. This goes quicker as there is no processing involved. I'll let
you know when everything is complete.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 11:03 AM,
)"
wrote:
Following up on this, I understand from
that she was able to provide you with a 12 TB drive last week - could
you please let us know when we will be able to get the materials? I expect a judge will ask us about discovery as
early as this week.
Also, the related critical question that I don't think we have clarity on is whether you're giving us a copy of everything
that was collected (including reproducing the materials that you previously gave us, but which are not searchable), or
have you and
figured out a way to categorize the prior productions so they're useful for us? We would strongly
prefer to just get everything at once in a usable format, but please let us know if you expect to produce materials
differently than that.
thanks,
From:
(NY) (FBI)
Sent: Friday, June 19, 2020 13:14
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
i
(NY) (FBI)
i
is
i
(NY)
(FBI)
is
(USANYS)
>
Subject: RE: Epstein search warrant documents
,
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK
when I can expect the drives. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
EFTA00027514

=== Page 6 ===
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(NY) (FBI)
is
-
in
is
(NY) (FBI)
is
(USANYS)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July
and September searches before moving forward with possible additional charges in the case. I know you had
mentioned you needed to push back your prior estimate of complete production by early June, by a couple weeks, so
wanted to see what the current estimate is? I don't think we've started to get anything yet but please correct me if
I'm wrong.
thanks,
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
To:
(USANYS) [Contractor]
is
)
Cc:
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go
from there.
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
To:
(USANYS) [Contractor]
is
>
Cc:
(NY) (FBI)
is
)
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
EFTA00027515

=== Page 7 ===
,
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If
we can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our
staffing levels will be steadily increasing over the next few weeks, but I'm going to have to push back my
estimate by a week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can
easily identify what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
Thanks for this update - we'll take a look and circle back if any questions.
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in
searchable format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to
specific devices - so if we're able to match them up by Bates number now, that might work, but otherwise I think it
makes sense for us to get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think
we've gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial
numbers. Any questions, let me know.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
EFTA00027516

=== Page 8 ===
To:
(NY) (FBI)
is
(USANYS) [Contractor]
<Christopher.Rozier@usdoj.gov>
Cc:
is
)
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of
information we need is the serial number, or some other specific identifier, ideally for each device but at least for any
device that there is more than one of the same thing. So for example, we need to be able to somehow differentiate
the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the
USVI spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the
USVI list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to
reproduce all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we
aren't able to match any of the prior productions to specific devices - so if we're able to match them up by Bates
number now, that might work, but otherwise I think it makes sense for us to get everything. But let us know if any
issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
)
is
(USANYS) [Contractor]
Cc:
is
)
V.
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I
could to convey the information. If you are confused by anything, please let me know. In the column for
EFTA00027517

=== Page 9 ===
approximate size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column,
I put what load file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight)
If there is no entry in that column, that data has yet to be transferred. There are 2 Macs and a DVR you
don't have as well as an iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what
I can to beef them up. I will get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
)
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
<Christopher.Rozier@usdoj.gov>
Cc:
is
>;
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a
format such that we can view them using a system we have access to. We're not able to get web-enabled access
through any FBI tool, so we asked for the materials to be transferred in a loadable format so we could put them on
Relativity, which both we and the agents can access. We're required to have the files in a format that we can
produce them to defense counsel. I've done that in many other cases and it hasn't previously been an issue. My
understanding from
is that the best way to do it now is just for us (the U.S. Attorney's Office) to get the original
files, which our vendor will process-by which I just mean converting into file formats that are loadable onto
Relativity. It doesn't really have anything to do with the taint review-we have to have access to the docs in our
systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents
earlier this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9.
Again, I understand from
that the best way forward is to just get copies of the materials in their original
formats, which I understand will be segregated and designated by device. That should work for us! I was just trying
to understand the approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
EFTA00027518

=== Page 10 ===
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking
files that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity)
to do a taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you
insisted you do the taint review in Relativity, I warned you that it was adding months worth of work on top
of what was already done, and that Relativity was incapable of viewing everything. You insisted we do it
this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get
it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it
piece by piece as things are processed, I was unaware that you didn't want to review as things were
processed, that you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a
differentiation of methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a
while back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
)
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
<Christopher.Rozier@usdoj.gov>
Cc:
is
)
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just
basically sending us copies of everything? I don't totally understand why we couldn't have done that eight months
ago, but regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I
assume that means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the
processing ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
is
Cc:
is
)
Subject: RE: Epstein search warrant documents
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it
to a particular device. Problem now is how to get the data to
since he is teleworking.
EFTA00027519

=== Page 11 ===
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
in
Cc:
is
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so
we make sure we get all the info we need. I think you had previously sent us a list of certain information that
unfortunately wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload
it on our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already
been processed. I think what we talked about on the phone a month ago was getting, for example, data from one
device to make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data
and where the data was collected. I will work to send some hard drives to
so he can begin to copy the data
and send it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
EFTA00027520

=== Page 12 ===
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to
review the returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
i
)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave
you. If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks-it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for
complete transmission of the search warrant returns is no longer likely? If so could you please let us know what the
current estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
i
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
EFTA00027521

=== Page 13 ===
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I
will be back in the office on Thursday and will be able to get you the list then as I have to access some of
our systems to do so.
Also,
,
please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're
waiting on that list to be able to do an updated search warrant on all of those devices. Please let us know the
current timeline - and also the current timeline on producing the results from those August and September
searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it
a couple months from our call, which would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
)
is
(USANYS)
>;
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
in
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
) [mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
i
(USANYS)
V.
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor] <Christopher.Rozier@usdoj.gov>;
)
i
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
Rozier can also join anytime tomorrow. So whenever is good on your end.
EFTA00027522

=== Page 14 ===
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us
know, otherwise I'd propose we do:
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
(NY) (FBI)
is
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago,
but are you at all able to assist while working remotely? This has been pending for almost two months and we still
don't have a very basic list of each device or item that was seized and searched, or for which of those we've received
materials. We're happy to have a call if that would be useful, but as a first step the most basic thing we're looking for
is the info in the template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24?
The excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we
sent on 2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you
EFTA00027523

=== Page 15 ===
mean by "loose media" without a specific comparison to what was seized, we don't know which items you're
referring to as "Windows machines," and we can't tell whether the entirety of any particular item has been
transferred, or just partial. For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
The data we've received has no way to put any emails and attachments together. So if an email says, "see
the attached flight records," for example, we have no way of linking that up with the records themselves.
Not only is that a big problem for us in review, it's going to be a huge problem for producing the documents
to defense counsel.
-
The load file has no link to the native file, so when we load the data to the database, there's no way to have
the native files show up in the database. Because many of the files are too large to open in the viewer, it
effectively means that there are many files that are completely invisible to us.
-
Related, the control numbers in the load file don't match up to the native files. So we have two sets of
numbers and no way to match up anything-that is, even if we were to try to go hunt down every individual
large file in the native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need
to get a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more
than a million documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary
record-keeping, and we need that info at the very least, as well as anything else you think would be useful. Also
attaching the SW returns for reference. And again, we're happy to meet up anytime and hash all this out in person if
that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
>;
(NY) (FBI)
>;
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some
points of clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3
copies of 3 drives (9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were
all copies). All the loose media from the NY apartment is included. All the Windows machines from the NY apartment
are included. Only 2 Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the
tool they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
NYO CART Coordinator
EFTA00027524

=== Page 16 ===
Senior Forensic Examiner
(office)
(cell)
From:
) [mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor] <Christopher.Rozier@usdoj.gov>;
i
<
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so
we can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
i
)
is
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
EFTA00027525

=== Page 17 ===
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together
to have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next
week? And what I think would be most helpful to facilitate that would be a spreadsheet of each separate device
referenced in the two search warrant returns, with columns for whether we've dumped the contents, whether
they've been reviewed and/or transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the
attached is mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed,
transferred, and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I
think FBI was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get
those to be able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
>;
)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
>;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they
mandated we delete old stuff (about 400 TB worth). Now that they are working on replacing the network,
we can do only local work. I should be able to give you an accounting of what is what. I can say, off the top
of my head, that all windows based items from the NY search have been handed over as well as all loose
media. The CDs from NY only contained pictures, no documents. There are still some Apple items from NY
that need to be produced. As far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac
has been produced. Still working on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e.,
which devices the materials came from, whether it's full or partial results, how many more devices we have coming,
etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are
approximately 40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even
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counting at least 60+ CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices,
including multiple servers / server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of
moving pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming
week from Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be
plenty of time to schedule a productive meeting.
thanks all,
From:
)
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
is
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have
the hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also
old materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's
new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of
what we're getting, and what has been completed, without some kind of identification or labeling system, along with
a list of which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a
modified date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we
haven't gotten any info on which folders match up to which devices, etc. And then there's another folder titled
"NYC024362" that has a modified date of 1/27/20, so I think that may be the materials we hadn't previously
received? That folder by itself has more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the
folder or file names whether everything on the drive is new, or whether just additional materials were saved onto it
in addition to what we already have.
,
are you able to give us some guidance on this? Ultimately what we
really need is a spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying
that same info - which device, and what materials from it - are being given to us with each data transfer. Otherwise
I think organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
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