# docs_fts_content

c1: EFTA00009632
c2: DataSet 7
c3: VOL00007
c4: DataSet 7/VOL00007/IMAGES/0001/EFTA00009632.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
1
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
2
WEST PALM BEACH DIVISION
3
4
5
6
7
8
IN RE: OPERATION LEAP YEAR
9
10
/
11
12
Grand Jury #07-103 (WPB)
West Palm Beach, Florida
13
Tuesday, February 6, 2007
14
15
TESTIMONY
16
OF
17
I.
.
18
19
20
21 APPEARANCE:
22
, ASSISTANT U. S. ATTORNEY
, FOREPERSON
23
,
COURT REPORTER
24
25
OFFICIAL REPORTING SERVICE
Copy 10613 of
EFTA00009632

=== Page 2 ===
2
1
PROCEEDINGS
2
- - -
3
The sworn testimony of
was taken
.
4
before the Federal Grand Jury, West Palm Beach Division,
5
701 Clematis Street, West Palm Beach, Palm Beach County,
6 State of Florida, on the 6th day of February, 2007.
7
, Registered Merit Reporter and Notary
8
Public was authorized to and did report the sworn
9 testimony.
10
Thereupon,
11
.
,
12 a witness of lawful age, having been first duly sworn by
13 the foreperson, testified on her oath as follows:
14 BY MS.
:
15
Q
Special Agent
, please state and
16
spell your name for the record.
17
A
It is
and I work for
.
18
the FBI in Palm Beach County.
19
Q
Can you spell your last name, please.
20
A
I'm sorry, it is
21
Q
And I know we have some people in the back
22
having trouble hearing you. You said that you work for
23 the FBI. Can you tell the Grand Jury what particular
24
group you are employed with?
25
A
I am with the Violent Crimes Squad here in
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=== Page 3 ===
3
1
Palm Beach County, I work primarily crimes against
2
children, but have been an agent for the last
3
approximately 10 years.
4
Q
Have you received specialized training in the
5
area of crimes against children?
6
A
Yes, I have.
7
Q
As part of your employment with the FBI have
8
you been involved in an investigation of Jeffrey
9
Epstein?
10
A
Yes, I have.
11
Q
And can you tell us who Jeffrey Epstein is?
12
A
Jeffrey Epstein is an investment advisor who
13
has a part-time residence in the town of Palm Beach, he
14
has got multiple residences across the country to
15
include a ranch in New Mexico, an island in the Virgin
16
Isles, and multiple aircrafts, two airplanes and a
17
helicopter to be exact, and --
18
Q
And where is his primary residence?
19
A
His primary residence, he has an office in New
20
York, but his primary residence I believe is the island.
21
Q
In the Virgin Islands?
22
A
Yes.
23
Q
He also has a home in New York, correct?
24
A
Yes.
25
Q
How is it that you started investigating
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=== Page 4 ===
4
1
Mr. Epstein?
2
A
The Palm Beach Police Department in March of
3
2005 initiated an investigation on Mr. Epstein involving
4
multiple underage females that had visited Mr. Epstein's
5
residence and had performed sexual massages or massages
6
for Mr. Epstein of a sexual nature.
7
Mr. Epstein paid the underage females anywhere
8
from 200 to $400, that investigation was around an 8 to
9
10-month investigation, and at that point we became
10
involved in about July of 2006.
11
Q
And once the case was presented to you by the
12
Palm Beach Police Department did the FBI open its own
13
investigation?
14
A
Yes, yes, we initiated our investigation in
15
July of 2006, we took a look at focusing in on the
16
underage minors and in our investigation we interviewed
17
many of the girls that were underage and we did an
18
independent investigation issuing Grand Jury subpoenas
19
as well as administrative subpoenas getting different
20
documents of financial records, telephone analysis,
21
flight manifests, looking to see if Mr. Epstein engaged
22
in sexual activity with these females.
23
Q
All right. And just so the Grand Jury is
24
clear, were some of the girls who went to Mr. Epstein's
25
house 18 or older?
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=== Page 5 ===
5
1
A
Yes.
2
Q
And then there were some that were under the
3
age of 18, correct?
4
A
Yes.
5
Q
And as part of the federal investigation did
6
you have to investigate what we call the interstate
7
nexus aspect of the case?
8
A
Yes.
9
Q
And can you explain to the Grand Jury what
10
that is?
11
A
We looked at -- Mr. Epstein, as I mentioned
12
earlier, has two aircrafts, and we focused in on the
13
year 2004, 2005, he took approximately 60 trips to his
14
residence in Palm Beach, the majority of that time
15
focusing in on his assistant's cell phone, which his
16
assistant's name is
, we took a look at her
17
cell phone records and the majority of the times that
18
Mr. Epstein would fly into Palm Beach Mrs. -- Ms.
19
would contact many of our underage victims either prior
20
to coming into Palm Beach, the day of, the day before,
21
even the day after, and certainly throughout the time
22
that Mr. Epstein was at his residence in Palm Beach.
23
Q
And from the interviews of the girls that have
24
been conducted, what was the subject of those telephone
25
calls?
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=== Page 6 ===
6
1
A
Can you restate the question?
2
Q
Sure. From the interviews of the girls that
3
have been conducted, what was the subject matter of the
4
telephone calls from
?
5
A
would schedule the underage girls
6
to come and work, perform the massages for Mr. Epstein,
7
so she was responsible, she as well as another
8
assistant,
,
they were his personal
9
assistants who would set up appointments for Mr. Epstein
10
for the girls to come and perform their sexual massages.
11
Q
All right. IS
also considered a
12
target of this investigation?
13
A
Yes, she is.
14
Q
And I will just -- I will spell
15
for the Grand Jury. The first name is
16
and the last name is spelled
17
and does Ms.
have a new last
18
name?
19
A
Yes, she does, she is married and her name is
20
.
21
Q
Is Ms.
at least a subject of
22
this investigation, in other words, you are
23
investigating her activity?
24
A
We are looking at that.
25
Q
In addition to those two assistants, from the
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=== Page 7 ===
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1
interviews of the girls, is there anyone else who is
2
associated with Mr. Epstein who is thought to be
3
involved in this activity?
4
A
has been referred to as his
5
companion, girl friend, personal assistant, she through
6
the testimony of the girls has engaged in sexual
7
activity with at least three of the underage minors.
8
Q
And
is
So Ms.
9
is also at least a subject of the
10
investigation, correct?
11
A
Yes, she is.
12
Q
Now, as part of this investigation you
13
mentioned that subpoenas were issued on behalf of either
14
the old Grand Jury or this Grand Jury.
15
Can you run through what subpoenas have been
16
issued and what documents have been received in response
17
to that?
18
A
Sure. we issued a Grand Jury subpoena to
19
Colonial Bank and we received financial records on
20
credit card accounts and individuals.
21
We subpoenaed washington Mutual and they did a
22
search and were unable to locate records at this time.
23
We issued a Grand Jury subpoena for Capital One and
24
served that and that is still unresolved at this time as
25
far as them providing documents to us.
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=== Page 8 ===
8
1
We have subpoenaed Chase Credit Card and we
2
have received documents from Chase. We have subpoenaed
3
two businesses that Mr. Epstein has at least partial
4
ownership or associated to, Hyperion Air, Inc. and JEGE,
5
Inc., they were issued subpoenas and they have provided
6
documentation to us.
7
We have subpoenaed Mr.
, who is a
8
pilot of Mr. Epstein's, and we have received
9
documentation from Mr.
.
We have subpoenaed DTG
10
Operations, who is doing business as Dollar Rent-A-Car,
11
and we have received car rental agreements and financial
12
records from that business.
13
We have subpoenaed Royal Palm Beach High
14
School and have received documentation regarding the
15
students' records. We have subpoenaed three or four of
16
the victims,
being the first, and we have
17
received a bathing suit from
.
18
we issued a Grand Jury subpoena to
19
,
we actually have issued
three subpoenas,
20
and we are still working on resolving her Grand Jury
21
material as well as testimony.
22
We have issued
a subpoena, we
23
have issued -- she also is one of our underage victims.
24
We've issued Reimer Employment Agency a Grand Jury
25
subpoena and we have received documentation, that is an
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=== Page 9 ===
9
1
employment agency located on the island of Palm Beach.
2
We have subpoenaed the Palm Beach Police
3
Department for their evidence in this case and we have
4
received that. By the way, that is the only thing that
5
I did not bring with me today, I brought everything
6
else, but it is rather a lot of evidence, so we will
7
probably be bringing that to you another time.
8
We have issued the Clerk of Courts of the
9
State of Florida for Grand Jury transcripts in the state
10
matter and we have received those. We have issued the
11
Good Samaritan Hospital for billing records and we have
12
received those.
13
We have issued a Grand Jury subpoena to the
14
Dalton School located in New York and at this time they
15
do not have the records we have requested or could not
16
locate those.
17
We have issued a Grand Jury subpoena to Extra
18
Touch Flowers located here in West Palm Beach and we
19
have received documentation from them. We issued a
20
Grand Jury subpoena to Bill Hammond, another pilot for
21
Mr. Epstein, we have spoken with him.
22
We have issued a Grand Jury subpoena to
23
, another one of Mr. Epstein's pilots, and we
24
have received documentation as well as spoken to him.
25
We have issued a Grand Jury subpoena to
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=== Page 10 ===
10
1
, who is the property manager currently for
2
Mr. Epstein at his Palm Beach residence, and we have
3
received documentation as well as spoken to him, and we
4
have issued a Grand Jury subpoena to
5
and have received some documentation and are still
6
awaiting a response.
7
Q
Now, you mentioned that you didn't bring with
8
you the evidence that you received from the Palm Beach
9
Police Department, but did you bring with you all of the
10
other evidence that was received in response to the
11
subpoenas?
12
A
I have.
13
Q
And is that evidence in the two boxes that are
14
here in the front?
15
A
Yes.
16
Q
We will bring all of this back to you when we
17
present the indictment, but would anyone like to look at
18
any of the documentation today?
19
A GRAND JUROR: what does the documentation
20
constitute, basically, the subpoenas?
21
THE WITNESS: It is primarily business
22
records, flight manifests, stuff that came from him
23
traveling to and from Palm Beach, credit card
24
records, the businesses as far as the rental
25
agreement which involves some of the underage girls
OFFICIAL REPORTING SERVICE
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=== Page 11 ===
11
1
with the rental cars, and flower shop, you know.
2
A GRAND JUROR: will we have an opportunity
3
later to go through these if we need to?
4
MS.
: Yes, we will bring them when
5
we present the indictment. Yes, ma'am.
6
A GRAND JUROR: If I should hold this for
7
later let me know, she mentioned the hospital
8
records were subpoenaed, could more information
9
about why they were subpoenaed be provided at this
10
time?
11
BY MS.
:
12
Q
You can answer that.
13
A
One of the girls that was an underage -- that
14
was underage at the time that is involved with
15
Mr. Epstein has had a baby and we were interested and
16
wondering if possibly he was the father of that baby,
17
which at this time we do not believe he was.
18
A GRAND JUROR: Thank you.
19
MS.
: A question?
20
A GRAND JUROR: Did the flight manifest show
21
passengers on the plane?
22
THE WITNESS: Yes, they do.
23
A GRAND JUROR: Were any of the passengers the
24
underage girls that were a target of the
25
investigation?
OFFICIAL REPORTING SERVICE
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=== Page 12 ===
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1
THE WITNESS: At this time we have not
2
associated any of these underage girls as being the
3
passengers. The flight manifests, sometimes the
4
pilot if they did not know who the passenger was
5
would put one passenger or one female, one male,
6
these were private planes and they, you know, may
7
not have felt like they can go up and ask, but we
8
don't have any evidence at this time to believe
9
that they were any of our victims.
10
MS.
: Any follow-up? Any other
11
questions from the Grand Jury? Yes, ma'am.
12
A GRAND JUROR: The records that you
13
subpoenaed from the high school, what were they
14
used for or why were they instrumental in the
15
investigation?
16
THE WITNESS: Those are the girls' school
17
records and we are just looking at the girls'
18
records.
19
A GRAND JUROR: Absenteeism?
20
THE WITNESS: Just looking at some of their
21
grades and performances and how they did in school.
22
MS.
: Ladies and gentlemen, before
23
we continue, the witness has mentioned a few names
24
of the minors and that is confidential information,
25
obviously everything that you hear within these
OFFICIAL REPORTING SERVICE
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=== Page 13 ===
13
1
walls is confidential.
2
BY MS.
:
3
Q
Now, Special Agent
, after -- in
4
addition to issuing the subpoenas, you mentioned that
5
one of the subpoenas was to the Palm Beach Police
6
Department. Did you review any of the evidence that
7
they collected?
8
A
Yes.
9
Q
And can you, for example, did the Palm Beach
10
Police Department interview any girls?
11
A
Yes, they did, they interviewed several of the
12
girls, most of the girls, they took taped statements
13
from the girls either in the form of a tape-recorder or
14
through video.
15
Q
And you have reviewed some of those
16
interviews, correct?
17
A
Yes, we have.
18
Q
And has the FBI performed any interviews?
19
A
Yes, we have, we have performed interviews of
20
past and current employees of Mr. Epstein as well as
21
focusing in on the girls, the girls that were underage
22
at the time of the sexual activity, we wanted to
23
determine with these girls, again, the sexual activity
24
that took place with Mr. Epstein as well as how old they
25
were at the time, if they traveled with Mr. Epstein, any
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=== Page 14 ===
14
1
gifts that they may have gotten, so we did reach out to
2
several of the underage minors and gathered more
3
information from them.
4
Q
And through the FBI's investigation has the
5
FBI identified additional victims that perhaps the state
6
police officers did not know about?
7
A
Yes, we are still trying to identify, get
8
first names of girls and going back and looking through
9
school yearbooks and attempting to try to locate friends
10
of friends, so we are still in the process, when you
11
interview one of the girls and you ask if any of their
12
friends went, they sometimes will give you other names,
13
so we are in the process of still uncovering victims and
14
reaching out and interviewing additional girls that we
15
believe possibly were underage at the time of this
16
sexual activity.
17
Q
If I could ask you to step outside.
18
(The witness was excused from the Grand Jury
19
room.)
20
(Questions posed by the Grand Jury.)
21
(The witness was recalled to testify before
22
the Grand Jury.)
23
BY MS.
:
24
Q
Special Agent
1 one of the Grand
25
Jurors asked whether there was any evidence of force or
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=== Page 15 ===
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1
coercion.
2
A
when talking to the girls they were told that
3
they may have to -- they were going there to perform a
4
massage, possibly model lingerie, they went there
5
sometimes on multiple occasions and they may start off
6
wearing their clothing and then he would instruct them
7
8
9
10
11
12
13
14
15
far as coercion, they were paid $200 to $400 to perform
16
these massages.
17
They are not trained in performing massages,
18
they don't -- they are not masseuses, but yet if you ask
19
if they were coerced, they were paid quite a bit of
20
money for 30 to 45 minutes work.
21
Some of the girls, being that they were minors
22
going to his residence, got in over their heads and did
23
not always return or come back, some of our victims did
24
not come back after, you know, they did go down to their
25
OFFICIAL REPORTING SERVICE
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=== Page 16 ===
16
1
2
3
4
5
6
Q
And was there one instance where Mr. Epstein
7
actually engaged in vaginal intercourse with a girl
8
against her will?
9
10
11
12
13
14
Q
A Grand Juror asked how old Mr. Epstein is.
15
A
He was 45 at the time that we are looking at
16
him at that time period.
17
Q
A Grand Juror asked if you know the proportion
18
of girls who were underage versus 18 or older.
19
A
The majority of the girls that we are looking
20
at are victims, well, all of our victims that we are
21
looking at were under the age of 18.
22
AS far as all of the girls that have been
23
interviewed, the majority definitely were under 18. To
24
give you a number, I would have to go and count, but I
25
would say in the state investigation there were over 25
OFFICIAL REPORTING SERVICE
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=== Page 17 ===
17
1
girls identified and more than a majority would have
2
been under the age of 18.
3
Q
A Grand Juror asked whether we have obtained
4
Mr. Epstein's DNA and whether there was any DNA testing
5
of the baby that you spoke of earlier.
6
A
NO, we have not.
7
Q
A Grand Juror asked how Mr. Epstein would make
8
contact with the girls, was this done via computer or in
9
some other method?
10
A
I am sorry,
, his personal
11
assistant, would contact, or on some occasions
12
would also contact the girls via their cell
13 phone and we have message pads from the residents that
14 also indicate the girls calling the home in response to
15 some of those phone calls, so they would call,
16
would call, the majority of the calls were made
17
by
to the girls arranging for these, you
18
know, can you come at this time, can you come at that
19 time.
20
Q
And is the cellular telephone a facility of
21
interstate commerce?
22
A
Yes, it is.
23
Q
And then one of the Grand Jurors asked whether
24
the assistants knew that the girls were underage or
25
committed sex acts.
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=== Page 18 ===
18
1
Did anybody, have you interviewed anybody who
2
affirmatively told you that they told
their
3
age or what was going on behind closed doors?
4
A
No, no, not at this time, not at this time.
5
Q
And what leads you to believe that she, for
6
example,
knew or should have known what was
7
going on?
8
A
There are so many girls that
9
contacted to give Mr. Epstein massages that have no
10
training in massages, and that
was aware
11
that girls were bringing other girls, you know, their
12
friends to do these massages.
13
was also making appointments for
14
legitimate massages for Mr. Epstein from legitimate
15
masseuses that would come and give him massages, so the
16
number of girls, their appearances at the time would
17
lead us to believe that
had knowledge that
18
these girls were underage.
19
Q
All right. Thank you very much. Those were
20
all the questions from the Grand Jury.
21
A GRAND JUROR: Actually, I have two more,
22
but.
23
MS.
: okay.
24
A GRAND JUROR: what was the actual age range
25
of these girls?
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=== Page 19 ===
19
1
THE WITNESS: 14 to I mean.
2
A GRAND JUROR: The other one was, how did Ms.
3
actually originally get these girls, how
4
were they brought in, I mean how were they, you
5
know, because you said she called them when he was
6
arriving, but how did these girls come into this in
7
the first place?
8
A GRAND JUROR: Could she speak louder?
9
MS.
: Special Agent
, we
10
just had a request that you speak louder.
11
A GRAND JUROR: 14 and what?
12
THE WITNESS: Our victims were 14 to 17, but
13
we have girls that are 18, we have girls that are
14
20, we have girls that are in their early 20s, and
15
your question was?
16
A GRAND JUROR: How did she originally get
17
them in in the first place?
18
THE WITNESS: We are focusing in on 2004,
19
2005, we have some evidence to show that this
20
activity was taking place even earlier than that,
21
certainly to include 2003 if you look at the
22
message pads, but focusing in on 2004, 2005, the
23
chain started with one of our minors and from that
24
minor who goes to the house, Mr. Epstein tells
25
her -- sees that she is maybe not comfortable with
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=== Page 20 ===
20
1
doing the massage the way he would like it and
2
tells her that she could bring other girls to do
3
the massages and she in fact if she brought another
4
girl she would be paid $200 for just bringing
5
another girl, so there starts the chain, and
6
Mr. Epstein would ask the girls or
would ask
7
the girls for their phone numbers so each time, you
8
know, if one of the girls brought a girl and he
9
liked her he would ask for her phone number, ask
10
her to leave the phone number, or
11
would get the phone number and then that girl would
12
maybe bring, because if you brought somebody you
13
didn't have to do the massage, but you also got
14
paid for bringing a new person, so not only if you
15
did the massage would you get anywhere from 200 to
16
400, but if you brought a new female you would
17
receive 200 or $400.
18
A GRAND JUROR: DO you know how she solicited
19
that original minor?
20
THE WITNESS: I don't. well, I know that
21
minor was approached by two individuals and we have
22
interviewed one of those individuals who we can
23
connect back to Mr. Epstein four years, possibly,
24
prior to this, and stated that his job was actually
25
to drive some of the girls to the residence and
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=== Page 21 ===
21
1
that's pretty much where we start off.
2
MS.
would the Grand Jury like
3
Special Agent
to maintain the records
4
that we received in response to the subpoenas?
5
A GRAND JUROR: Maintain versus what?
6
A GRAND JUROR: what is our choice?
7
MS.
:
I don't know that there is. I
8
guess I could maintain them, but I don't believe we
9
have secure storage in here.
10
Would you like Special Agent
to
11
maintain custody?
12
A GRAND JUROR: Yes.
13
MS.
:
You should have something to
14
swear her in as a custodian.
15
(The witness was sworn in as the custodian of
16
records.)
17
MS.
: Thank you, ladies and
18
gentlemen, I am the last person for today, so you
19
guys are free to go and we will see you probably in
20
a couple of weeks, we will be seeing a lot of you.
21
(The witness was excused from the Grand Jury
22
room.)
23
(The testimony of the witness concluded
24
before the Grand Jury.)
25
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=== Page 22 ===
22
1
CERTIFICATE OF REPORTER
2
3
4
I certify pages 2 through 21 are a true
5
transcript of my shorthand notes of the testimony of
6
before the Federal Grand Jury,
7
West Palm Beach, Florida on the 6th day of February,
8
2007.
9
Many lugel
10
11
-Notary Public
12
Commission #DD0282274
13
Expires May 8, 2008
14
15
16
17
18
19
20
21
22
23
24
25
OFFICIAL REPORTING SERVICE
EFTA00009653


c1: EFTA00027167
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027167.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
)"
Subject: RE: US V. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
Date: Thu, 22 Apr 2021 17:32:25 +0000
Attachments: 2021-04-22_Govt_letter_re_GM_request_for_adjournment_v3.docx
Draft response attached.
From:
Sent: Thursday, April 22, 2021 12:14 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
(USANYS)
Subject: FW: US V. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
FYI. Our response is due at 5 today.
From: Laura Menninger
Sent: Thursday, April 22, 2021 11:22 AM
To:
Cc:
is
is
(USANYS)
is
>; ; Jeff Pagliuca
is
>; 'Bobbi Sternheim
)'
>; Nicole Simmons
Subject: US V. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
Judge Nathan -
Pursuant to this Court's Order of April 20, 2021 (Dkt. 221), attached please find counsel's Letter Motion for an
Adjournment of the trial.
Counsel for Ms. Maxwell request redaction of their other clients' names and case numbers from this Letter Motion
pursuant to Rule of Professional Conduct 1.6 which prohibits lawyers from revealing confidential information related to a
client even where that information is publicly available. See In Re. Anonymous, 654 N.E. 2.d. 1128 (Ind. 1995) (lawyer
violated Rule 1.6 by disclosing information relating to representation of client, even though information "was readily
available from public sources and not confidential in nature"); In re Bryan, 61 P.3d 641 (Kan. 2003) (lawyer violated Rule
1.6 by disclosing, in court documents, existence of defamation suit against former client); State ex rel. Okla. Bar Ass'n V.
McGee, 48 P.3d 787, 791 (Okla. 2002) (a lawyer's duty of confidentiality attaches "to all information relating to the
representation, whatever its source").
Upon direction of the Court, counsel will file either the redacted or unredacted version of this letter on the public docket.
Best regards,
Laura Menninger
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
EFTA00027167

=== Page 2 ===
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=== Page 1 ===
Mail -
Page 1 of 2
FW: Hello
(NY) (FBI)
Fri 7/12/2019 3:28 PM
See below, can you reach out to this individual.
Original Message
From
Sent: Friday, July 12, 2019 2:31 PM
To:
(NY) (FBI)
Cc:
(NY) (FBI)
;
(NY) (FBI)
;
(NY) (FBI)
>
Subject: Re: Hello
Best way to reach
told him I contacted the FBI and he's looking forward to
speaking with you. He said the guy has a lot of information and names of other victims. Thank you all for
your hard work! Thank you
for helping me help this guy out! Be safe!
Sent via magic!
> On Jul 12, 2019, at 1:01 PM,
(NY) (FBI)
wrote:
>
>
> Thanks for reaching out. I've cc'd
who are leading this.
For future victims the best number is 1-800-CALL-FBI. The calls are tracked and then pushed out to the
investigative teams and appropriate offices. It takes a couple of minutes to get through the dial-in
instructions, but then you are speaking to a live call taker who pushes us the info. As for the victim you
are referencing, if you pass
the contact information of your fried, he can have someone on his team
go from there.
>
> Thanks for the info and have a quiet summer.
>
> Gents,
>
is a former agent originally in Newark. She references potential victims below.
contact info is:
>
>
https://outlook.office365.com/owa/?realm=nypd.org&path=/mail/search
8/28/2019
EFTA00029234

=== Page 2 ===
Mail -
Page 2 of 2
>
>
>
> Thanks,
>
>
>
Original Message
> From:
[mailto:
m]
> Sent: Friday, July 12, 2019 1:23 PM
> To
(NY) (FBI)
>
> Subject: Hello
>
> Hello! So proud of you! You've done such a phenomenal job everywhere you have been stationed!
>
> I have an investigative journalist friend I trust with my life, who was working with a female retired cop on
human trafficking. They came across a male victim who appears to be very credible and his story closely
aligns and is very possibly part of the stuff with Epstein. He was young when the abuse happened but he
has information about the entire process and specifics on high level government people; one former
friend, president. My friend is hoping to get him to the NYO ASAP to give a statement and be interviewed. My
(not that
), used to be in the USIC and feels not only is the guy
credible, his story should be vetted by better equipped entities aka FBI. I haven't been involved in this
case as I'm at Discover Financial Services and busy as heck. But
reached out to me and I watched
portions of a videotaped interview of the guy and I feel he sounds truthful but needs to speak with you
guys. Is there a direct POC I can have
contact to set this up. Someone who knows the story of
trafficking and sexual exploitation of children? I will email that person
contact information or give
his/her information. Btw, the female retired cop is now deceased and I have had a few alleged
victims reach out to me. I will refer any of them to the FBI in their area. There are a lot.
>
> I also was in contact with now murdered Arkansas Senator Linda Collins Smith. Briefly but about a CPS
corruption case. I believe the FBI is working her murder. I only knew her for a few months but it was a
shock. She had a lot of information on child trafficking. Hopefully the FBI got it. ABC wants to interview me
on my friendship with her but I'm hesitant to do it.
>
> Thank you
I do believe this guy has valuable information.
>
> Sincerely,
>
>
>
> Sent via magic!
https://outlok.office365.com/owa/?realm-=nypd.org&path=/mail/searchl
8/28/2019
EFTA00029235


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=== Page 1 ===
From:
"
)"
To:
)"
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: Epstein image & video files
Date: Fri, 16 Oct 2020 01:48:42 +0000
Embedded: Epstein_image_&_video_files.msg
Sender:
Subject: Epstein image & video files
Message-Id:
<BN3P110MB0531D556F435FB2588CAB3B992030@BN3P110MB0531.NAMP110.PROD.OUTLOOK.COM
>
To:
EFTA00028474


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=== Page 1 ===
FD-597 (Rev. 4-13-2015)
Page
-
of
I
UNITED STATES DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF INVESTIGATION
Receipt for Property
Case ID: 90A-NY-3151227
On (date) 8/15/19
item (s) listed below were:
X
Collected/Seized
Received From
Returned To
Released To
(Name)
MCC
(Street Address)
150 Park Row,
(City)
New York, NY
Description of Item (s): Nice Vision Pro DVR 1 - Model: NP 2000 -
Serial No.: 43144901 ; NiceVision DVR 1 Disk Array - -
Model: Premium 8600 - Serial No: 232476; 1 Dell Poweredge
R420 - Service Tag: 5BMQ712; (1) 2- teraby te Seagate
hard drive containing Forensic image of system disk of
Nice Vision Pro DWR 1
Received By:
Received From:
Printed Name/Title:
Printed Name/Title:
|Lientenant
EFTA00027974


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
)"
(USANYS)"
)"
Subject: RE: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Fri, 15 Oct 2021 17:33:46 +0000
Attachments: 021-10-15_GM_letter_re_MDC_legal_mail_v2_to_chiefspdf
From:
(USANYS)
Sent: Friday, October 15, 2021 1:31 PM
To:
(USANYS)
Cc:
is
(USANYS)
;
is
Subject: Re: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
I am looking on phone can you send in PDF
Sent from my iPhone
On Oct 15, 2021, at 1:29 PM,
(USANYS)
wrote:
Attached is a draft response due today at 5 pm. We still need to send this letter to
and Sophia at the
MDC to review for accuracy. Do you think you will be able to review shortly or should I send them this draft
simultaneously? We highlighted some language for your consideration about Judge Nathan's deadlines, happy to
discuss. We haven't engaged with the defense's footnote 1 about the volume of the materials delivered because that is
a little more complicated and we want to make sure any representations are fully accurate, but happy to discuss.
Thanks,
From:
(USANYS)
Sent: Friday, October 15, 2021 10:30 AM
To:
)
i
(USANYS)
V.
(USANYS)
Cc:
is
)
Subject: RE: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Thanks. (We've really got to talk to Nathan about these deadlines!)
From:
Sent: Friday, October 15, 2021 10:30 AM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
EFTA00027749

=== Page 2 ===
Cc:
is
)
Subject: RE: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
H
Judge Nathan just ordered us to respond to this letter as soon as possible but no later than 5 pm today. We've reached
out to BOP to set up a call.
Thanks,
From:
(USANYS)
Sent: Thursday, October 14, 2021 8:31 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
is
Subject: FW: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
FYI, letter filed by Bobbi Sternheim tonight.
From: BOBBI C STERNHEIM <bcsternheim@mac.com>
Sent: Thursday, October 14, 2021 7:46 PM
To:
is
(USANYS)
is
is
Cc: Christian Everdell
>; Laura Menninger
;
Jeff Pagliuca
Subject: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Good evening-
Attached is a courtesy copy of this evening's ECF filing.
Bobbi
BOBBI C. STERNHEIM, ESQ.
New York, NY 10007
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be
confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
<2021-10-15 GM letter re MDC legal mail v2 [to chiefs].docx>
EFTA00027750

=== Page 3 ===
<Ltr to Ctre Legal Mail 10-14-21.pdf>
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=== Page 1 ===
From:
To:
Subject: Epstein Related
Date: Thu, 12 Sep 2019 14:50:36 +0000
Do you have a few minutes today or tomorrow to discuss something? Specifically, a good friend of mine is the executive
producer on a 4-part Netflix series that will come out in a few months on Epstein (they had been working on the story for
18 months before we charged). He had spoken to
at one point (not sure how that worked!) and wants to see
if anyone from the office would give an interview, all backward looking. I imagine the answer is no but they are going with
this regardless, so thought I would at least make you and potentially chiefs aware of it. Wanted to start with you. I'm free
between now and noon or after 6pm tonight, or tomorrow morning or after lunch. Thanks!
EFTA00029310


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=== Page 1 ===
From: Gloria Allred
To:
Subject: FW: Urgent!
,an Epstein victim, just told me that she was able to get child care
and would like to fly to New York for the hearing Tuesday. What is your telephone number,
so that I can call you a.s.a.p.?
Date: Sun, 25 Aug 2019 05:41:10 +0000
Inline-Images: image001.png; image002.jpg
Is there a cell number for
that I can call to make travel arrangements for
? I sent
the email below and
left a voice mail for her on her office phone but she did not respond. I understand
It is the weekend ,but is there a way that I can reach her or another agent to arrange
trip from Las Vegas to New
York on Monday morning ? It would mean so much to her to attend the hearing and
does not have funds to pay
for the flight and get reimbursed after that.
Gloria Allred
Allred, Maroko & Goldberg
www.amglaw.com
www.gloriaallred.com
Martindale-Hubbell"
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2017
ALLRED, MAROKO & GOLDBERG
2018
Best Lawyers
From: Gloria Allred
Sent: Saturday, August 24, 2019 4:09 PM
To:
(USANYS)
Cc:
Subject: Urgent!
,an Epstein victim, just told me that she was able to get child care and would like to fly to
New York for the hearing Tuesday. What is your telephone number,
so that I can call you a.s.a.p.?
Sorry about the late notice.
Gloria Allred
Allred, Maroko & Goldberg
EFTA00028550

=== Page 2 ===
www.amglaw.com
www.gloriaallred.com
Martindale-Hubbell"
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2017
ALLRED, MAROKO & GOLDBERG
2018
Best Lawyers
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
EFTA00028551


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=== Page 1 ===
From:
To:
Bcc: "USAHUB-USAJournal111"
Subject: FW: Letter re GM requests for redactions and in camera proceeding
Date: Wed, 02 Dec 2020 15:25:05 +0000
Embedded: FW:_Letter_re_GM_requests_for_redactions_and_in_camera_proceeding.msg
Sender:
Subject: FW: Letter re GM requests for redactions and in camera proceeding
Message-Id:
<DM2P110MB02031AD6DCF986F2B5A5B8628CF30@DM2P110MB0203.NAMP110.PROD.OUTLOOK.CO
M>
To:
EFTA00027385


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=== Page 1 ===
From:
To:
Cc:
Subject: https://www.nytimes.com/2021/09/15/nyregion/prince-andrew-epstein-lawsuit.html
Date: Wed, 15 Sep 2021 21:31:59 +0000
FWIW
Sent from my iPhone
EFTA00027422


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=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:19:06 +0000
Inline-Images: image001.png
Thanks!
From:
Sent: Thursday, July 2, 2020 1:58 PM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congratulations!
From
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA JUSTITIA OF TOFFICE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
EFTA00027850

=== Page 2 ===
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00027851

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
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=== Page 1 ===
From: Roberta Kaplan
To:
)"
Subject: Fwd: The Estate of Jeffrey Epstein
Date: Tue, 10 Dec 2019 16:51:52 +0000
Attachments: 2019.12.03_Letter_fr_B._Moskowitz_to_S_McCawley_Re_Estate_of_Jefrey_E_Epstein.
pdf
I assume you have this.
Roberta ("Robbie") Kaplan, Esq.
Kaplan Hecker & Fink LLP
350 Fifth Avenue I Suite 7110
New York, New York 10118
From: Moskowitz, Bennet J.
Sent: Tuesday, December 3, 2019 9:36:45 PM
To: Andrew Villacastin
>; Sigrid McCawley
Cc:
>;
>; Kate L. Doniger
>; Brad Edwards
>; Julie Fink
is
is
is
is
>;
Roberta Kaplan
>; Sabina Mariella
>; Jordan Merson
>; Josh Schiller
>;
>; ; Laura Starr
>; Mariann Wang
Subject: RE: The Estate of Jeffrey Epstein
Counsel:
Please see the attached letter.
Thank you,
Bennet
Bennet J. Moskowitz*
troutman sanders
Direct:
*Licensed to practice law in New York and Connecticut
From: Andrew Villacastin
Sent: Friday, November 22, 2019 4:15 PM
To: Moskowitz, Bennet J.
>; Sigrid McCawley
Cc:
Brad Edwards
>; Julie Fink
is
Sabina Mariella
>; Jordan
Merson
>; Josh Schiller
>; Laura Starr
is
EFTA00027881

=== Page 2 ===
Mariann Wang
Subject: The Estate of Jeffrey Epstein
EXTERNAL SENDER
Counsel,
Please see attached.
Best,
Andrew
Andrew Villacastin
Associate
BOIES SCHILLER FLEXNER LLP
55 Hudson Yards
New York, NY 10001
(t)
www.bsfllp.com
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
This e-mail message (and any attachments) from Troutman Sanders LLP may contain legally privileged and confidential
information solely for the use of the intended recipient. If you received this message in error, please delete the message
and notify the sender. Any unauthorized reading, distribution, copying, or other use of this message (and attachments) is
strictly prohibited.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00027882


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=== Page 1 ===
From:
To:
Subject: Epstein Oral Argument-- Second Circuit
Date: Tue, 05 Feb 2019 16:57:01 +0000
Importance: Normal
Attachments: unnamed
EFTA00029466


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Re: Interview today at 10
Date: Mon, 12 Aug 2019 11:23:58 +0000
Thank you. Let's talk when you get in and I can give you the background.
> On Aug 12, 2019, at 7:21 AM,
(USANYS)
wrote:
,
>
> I can cover
V
>> On Aug 12, 2019, at 6:56 AM,
,
(USANYS)
wrote:
>>
>> Good morning,
>> We have an interview in the Epstein death investigation this morning at 10 and need a SA from our office to
sit in. Are any of you available? Thank you in advance.
EFTA00027092


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=== Page 1 ===
From:
(USANYS)"
To:
USANYS)"
Subject: Monthly update
Date: Fri, 05 Nov 2021 16:44:29 +0000
Attachments: Public_Corruption_Unit_November_2021.docx
Here is a draft of this, which is due today. The bold stuff is new. let me know if you have any suggestions or additions
Deputy Chief, Public Corruption Unit
Southern District of New York
Office:
Cell:
Email:
EFTA00029539


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=== Page 1 ===
From:
)"
To: Douglas Bloom
Subject: RE: Epstein
Date: Tue, 09 Jul 2019 15:35:06 +0000
Importance: Normal
Thanks very much, Doug. Hope all is well with you.
From: Douglas Bloom
Sent: Monday, July 8, 2019 4:45 PM
To:
Subject: Epstein
,
Saw you picked up the Epstein case. Congrats! Looks like a great, impactful one.
I hope all is well.
Doug
EFTA00028379


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
(USANYS)"
Subject: Epstein T&E Meeting
Date: Wed, 08 Jan 2020 14:55:12 +0000
Importance: Normal
Attachments: unnamed
EFTA00028718


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Joint letter
Date: Fri, 21 May 2021 20:54:17 +0000
Attachments: 021-05-21_Joint_letter_re_proposed_GM_pretrial_schedule_[sent_to_defensel.docx
H
Attached is the draft of the joint letter.
Best
From: Laura Menninger
Sent: Friday, May 21, 2021 3:18 PM
To:
Cc:
Subject: Joint letter
Hi
-
Checking in to see if you guys have your scheduling position statement ready for the joint letter. If you do, can you please
shoot it to us, and we can insert our segment to return to you. You can then let us know if you change anything for us to
review before we agree to sign off on filing.
Thanks so much.
-Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
EFTA00029189


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-58 United States of America V. Maxwell "Acknowledgment and Notice of Appearance FILED"
Date: Tue, 26 Jan 2021 17:20:00 +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 01/26/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Document(s): Document(s)
Docket Text:
ACKNOWLEDGMENT AND NOTICE OF APPEARANCE, on behalf of Appellant Ghislaine Maxwell,
FILED. Service date 01/26/2021 by CM/ECF.[3021043] [21-58]
Notice will be electronically mailed to:
ceverdell@cohengresser.com,
managingclerksoffice@cohengresser.com
Tammy Torres, Deputy Clerk: Tammy_Torres@ca2.uscourts.gov
Notice will be stored in the notice cart for:
Tammy Torres, Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Acknowledgment and Notice of Appearance FILED
Original Filename: Acknowledgement-Notice of Appearance 21-58.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=01/26/2021] [FileNumber=3021043-0]
bdda054041234a1be48388694da8e174c8dd]]
EFTA00028136


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=== Page 1 ===
CG
COHEN & GRESSER LLP
Mark S. Cohen
Christian R. Everdell
March 15, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
On behalf of our client, Ghislaine Maxwell, we will be filing the following reply
memoranda with accompanying exhibits:
1. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment for
Breach of the Non-Prosecution Agreement
2. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of
the Superseding Indictment as Time-Barred
3. Reply Memorandum in Support of Motion Under the Due Process Clause to Suppress
All Evidence Obtained from the Government's Subpoena to Boies Schiller and to
Dismiss Counts Five and Six
4. Reply Memorandum in Support of Motion to Dismiss Counts Five and Six of the
Superseding Indictment Because the Alleged Misstatements Are Not Perjurious as a
Matter of Law
5. Reply Memorandum in Support of Motion for a Severance of and Separate Trial on
Counts Five and Six of the Superseding Indictment
6. Reply Memorandum in Support of Motion to Strike Surplusage from the Superseding
Indictment
7. Reply Memorandum in Support of Motion to Dismiss Counts One Through Six of the
Superseding Indictment for Pre-Indictment Delay
8. Reply Memorandum in Support of Motion to Dismiss Either Count One or Count
Three of the Superseding Indictment as Multiplicitous
9. Reply Memorandum in Support of Motion to Dismiss the Superseding Indictment as
It Was Obtained in Violation of the Sixth Amendment
10. Reply Memorandum in Support of Motion for a Bill of Particulars and Pretrial
Disclosures
EFTA00028925

=== Page 2 ===
The Honorable Alison J. Nathan
March 15, 2021
Page 2
11. Reply Memorandum in Support of Motion Under the Fourth Amendment, Martindell,
and the Fifth Amendment to Suppress All Evidence Obtained from the Government's
Subpoena to Boies Schiller and to Dismiss Counts Five and Six
12. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of
the Superseding Indictment for Lack of Specificity
Several of the reply memoranda reference or discuss Confidential Information produced
in discovery and are therefore redacted pursuant to paragraph 15 of the Protective Order (Dkt.
36). In order to give the government the chance to review the proposed redactions, we will not
file on the public docket any reply memoranda that contain redactions until we are instructed to
do so by the Court. 1
The remaining reply memoranda do not contain any redactions. However, we are
mindful of the fact that the government's Omnibus Memorandum in Opposition to the
Defendant's Pre-trial Motions, to which the reply memoranda respond, has not yet been filed on
the public docket. Accordingly, we will also refrain from filing the reply memoranda that do not
contain redactions on the public docket until we are instructed to do so by the Court.
Instead, we will submit by email to the Court and the government all of the reply
memoranda and exhibits pursuant to Rule 2(B) of the Court's individual rules of criminal
practice. For the reply memoranda and exhibits that contain redactions, we will submit two
versions - an unredacted original to be kept under seal and a version for public filing with
proposed redactions.
Please contact us with any questions. Your consideration is greatly appreciated.
Respectfully submitted,
/s/ Christian R. Everdell
Christian R. Everdell
COHEN & GRESSER LLP
cc:
All counsel of record (via email)
I
For documents that the government has designated as "Confidential," we have preliminarily indicated that they be
filed under seal, as required by paragraph 15 of the Protective Order. However, because some of the exhibits are
"judicial documents," we intend to propose that those "Confidential" designations be amended consistent with our
March 9, 2021 letter to the Court.
EFTA00028926


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Epstein Documents from BOP without Green Watermark
Date: Tue, 13 Apr 2021 20:39:44 +0000
Thanks.
From:
(USANYS)
Sent: Tuesday, April 13, 2021 4:39 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: Re: Epstein Documents from BOP without Green Watermark
They emailed us PDFs.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
On Apr 13, 2021, at 4:35 PM,
(USANYS)
wrote:
Thanks again for this,
and we can talk some more about it tomorrow. In the meantime, can I ask how BOP
provided the docs to you? Do you have JEFS access? Or did they email them?
Thanks,
From:
(USANYS)
Sent: Monday, April 12, 2021 11:36 AM
To:
(USANYS)
is
(USANYS)
Subject: RE: Epstein Documents from BOP without Green Watermark
Hi
We requested these from the BOP, and they provided a set of documents, which we then produced to defense counsel.
We did not do a page by page comparison between the redacted set and the unredacted set, so we can't guarantee that
they are "comprehensive." But we can provide you with what we have, assuming that there aren't any issues with us
sharing in that way.
Best,
From:
(USANYS)
Sent: Sunday, April 11, 2021 12:27 PM
EFTA00027382

=== Page 2 ===
To:
(USANYS)
i
(USANYS)
Subject: Epstein Documents from BOP without Green Watermark
Nick and
I recall that at some point you requested a version of the Epstein FOIA documents from BOP without the translucent
green watermark they put on the withheld documents. Do you have those saved down somewhere? Although the Court
has not put in a specific order yet, I think it's likely that we'll need to produce documents without the translucent green
marking to the Court. I have versions without the watermark for some of the docs, but it looks like not all. Do you have a
comprehensive set somewhere?
Thanks,
Assistant United States Attorney
300 Quarropas Street
White Plains, NY 10601
Telephone:
EFTA00027383


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=== Page 1 ===
From:
Subject: Epstein meeting
Date: Tue, 22 Jan 2019 01:11:27 +0000
Importance: Normal
Attachments: unnamed
EFTA00029461


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=== Page 1 ===
From:
To:
Subject: Fwd: FW: Jeffrey Epstein 19 cr 490
Date: Mon, 12 Aug 2019 16:57:24 +0000
Attachments: Aug_12_letter.pdf
For info on attached.
Forwarded message
From:
Date: Aug 12, 2019 12:55
Subject: FW: Jeffrey Epstein 19 cr 490
To:
Cc:
FYI
United States Marshal
Southern District of New York
New York, NY 10007
Original Message
From:
On Behalf Of
Sent: Monday, August 12, 2019 12:47 PM
To:
Cc:
(USMS)
Subject: Jeffrey Epstein 19 cr 490
Importance: High
Please see attached letter from Judge Richard M. Berman.
(See attached file: Aug 12 letter.pdf)
EFTA00027095


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
December 31, 2019
BY FEDEX
Jason E. Foy
Foy & Seplowitz LLC
105 Main Street
Hackensack, NJ 07601
Re:
United States V. Tova Noel, No. 19 Cr. 830
Dear Counsel:
This letter provides discovery pursuant to Rule 16(a) of the Federal Rules of Criminal
Procedure, and seeks reciprocal discovery. This letter and the materials identified herein are
subject to the protective order entered in this case on December 16, 2019, and have been designated
as "Protected Materials" as defined in the order where noted below. Accordingly, the materials
and information identified herein shall not be disclosed to any third party except as set forth in the
protective order.
I.
Disclosure by the Government
Based on your request for discovery in this case, and pursuant to the Government's
obligations under Rule 16(a), enclosed are copies of the following materials, which are being
produced to all defendants and are stamped with the following control numbers:¹
Description
Bates Numbers
Classification Pursuant to
Protective Order
MCC surveillance footage
SDNY_00000001
Protected Materials
from 7/5/2019 to 8/12/2019²
1
In addition to information provided herein, please note that this Office periodically posts content
on social media platforms including Twitter, Facebook and YouTube. Members of the public may
post comments in response to the Office's postings. We do not control these user-generated
comments, nor do we monitor or regularly review such comments. You may directly access these
social media platforms in the event you believe someone may have posted information relevant to
this case.
2 The Government is producing video surveillance footage of the common area of the Special
Housing Unit for the above-referenced dates. On or about August 10, 2019, the Government seized
06.20.2018
EFTA00027732

=== Page 2 ===
Page 2
Commissary records for
SDNY_00000002-
Protected Materials
inmates at MCC
SDNY_00000020
Computer analysis for
SDNY_00000021-
Protected Materials
computers used by Noel and
SDNY_00000075
Thomas from 8/9/2019 to
8/10/2019
Count slips for 7/23/2019 to
SDNY_00000076-
Protected Materials
8/14/2019
SDNY_00000795
Death reports and photos
SDNY_00000796-
Protected Materials
SDNY_00000857
Photographs of Jeffrey's
SDNY_00000858-
Protected Materials
Epstein's cell
SDNY_00000898
Epstein general BOP records
SDNY_00000899-
Protected Materials
SDNY_00000922
Evidence custody documents
SDNY_00000923-
Protected Materials
SDNY_00000937
Health records for Jeffrey
SDNY_00000938-
Protected Materials
Epstein
SDNY_00001041
Internal MCC phone records
SDNY_00001042-
Protected Materials
SDNY_00002124
MCC logs for 7/23/2019 to
SDNY_00002125-
Protected Materials
8/19/2019
SDNY_00005010
MCC regulations and training
SDNY_00005011-
Protected Materials
SDNY_00005796
MCC staff roster
SDNY_00005797-
Protected Materials
SDNY_00005979
Office of Chief Medical
SDNY_00005980-
Protected Materials
Examiner report
SDNY_00006091
Personnel records for Noel
SDNY_00006092-
Protected Materials
and Thomas
SDNY_00006273
Prior work schedule for Noel
SDNY_00006274-
Protected Materials
and Thomas
SDNY_00006277
Psych records for Jeffrey
-8LZ90000 ANAS
Protected Materials
Epstein
SDNY_00006471
the contents of the MCC's video surveillance system. Certain cameras were not functioning, have
not been processed, or are not available. The Government is producing the available surveillance
footage that falls within Rule 16(a). However, to the extent you believe that certain additional
footage would be relevant, please contact us promptly to request that footage.
06.20.2018
EFTA00027733

=== Page 3 ===
Page 3
Reports regarding the July 23
SDNY 00006472-
Protected Materials
incident
SDNY 00006594
Special Housing Unit maps
SDNY 00006595-
Protected Materials
SDNY 00006596
Special Housing Unit roster
SDNY 00006597-
Protected Materials
SDNY 00006977
Materials returned from
SDNY 00006978-
Protected Materials
4Chan
SDNY 00006979
Apple, Inc. subscriber
SDNY 00006980-
Protected Materials
records³
SDNY 00006984
AT&T telephone records
SDNY 00006985-
Protected Materials
SDNY 00007079
Comcast telephone records
SDNY 00007080-
Protected Materials
SDNY_00007084
Sprint telephone records
SDNY 00007085-
Protected Materials
SDNY_00007103
Verizon telephone records
SDNY 00007104-
Protected Materials
SDNY 00007108
Thirty Minute Round reports
SDNY 00007109-
Protected Materials
for 7/1/2019 to 8/10/2019
SDNY 00007548
Email regarding cellmate
SDNY 00008119-
Protected Materials
SDNY_00008122
Additionally, the Government is producing the following materials only to your client:
Description
Bates Numbers
Classification Pursuant to
Protective Order
Materials produced by
SDNY_TN_00000001-
Equifax
17000000 NL ANCIS
Materials produced by
-7000000 NL ANGS
JPMorgan Chase Bank
SDNY_TN_00000149
Materials produced by
SDNY_TN_00000150-
Municipal Credit Union
SDNY_TN_00000185
Phone report of a cell phone
SDNY_TN_00000186-
with the number:
SDNY_TN_00020800
3 Apple produces subscriber records in a read-only format. To review the records, open the file
and when prompted for a password, click on "read only."
06.20.2018
EFTA00027734

=== Page 4 ===
Page 4
Pay stubs for Tova Noel
SDNY_TN_00020801-
SDNY_TN_00020826
Arrest photo of Tova Noel
SDNY_TN_00020827
CLEAR report
SDNY_TN_00020828-
SDNY_TN_00020849
BOP email records for Tova
SDNY_TN_00020850
Noel
Pre-trial supervision details
SDNY_TN_00020851-
SDNY_TN_00020852
8x10 photo of Tova Noel
SDNY_TN_00020853
Without conceding that these materials constitute discoverable materials pursuant to Rule
16(a) or Jencks Act materials, the Government is producing the following materials out of an
abundance of caution in order to assist with your trial preparation.
Description
Bates Numbers
Classification Pursuant to
Protective Order
302s and notes for witnesses4
SDNY_00007549-
Protected Materials
SDNY_00007660 &
SDNY_00007666-
SDNY_00008118
Anonymized Index (Produced
SDNY_00008123
Attorney's Eyes' Only
Under Separate Cover)
The Government recognizes its obligations under Brady V. Maryland, 373 U.S. 83 (1963),
and its progeny. The Government wishes to bring your attention to the following statements,
which could constitute Brady material:
Inmate-4 stated that on the night of August 9, 2019, the corrections officers
performed "a few rounds that night" but Inmate-4 could not recall what time.
Inmate-5 stated that Noel came by "around 10 to do the count" on the evening of
August 9, 2019.
Inmate-7 stated that on the evening of August 9, 2019, the corrections officers "did
[a] count around 10ish but not after that." Inmate-7 further stated that Inmate-7
was not really awake for the 3:00 a.m. count on August 10, 2019, "but hear[d] [the]
gate open."
4 This range excludes SDNY_00007661-SDNY_00007665, which the court has directed the
Government to withhold.
06.20.2018
EFTA00027735

=== Page 5 ===
Page 5
Inmate-11 stated that on the evening of August 9, 2019 into the morning of August
10, 2019, the "last check was made sometime between 12:30Am - 1:00AM. The
male black stayed by the door and the female black walked through the tier but did
not walk all the way in."
In addition, materials from Inmate-2 include a statement which could constitute Brady, however,
the Court has directed the Government to withhold these materials from production due to pending
ex parte litigation. The Government will produce these materials if and when the Court orders
their production. Beyond the above materials, to date, the Government is unaware of any other
Brady material regarding your client, but will provide timely disclosure if any such material comes
to light. The Government will provide material under Giglio V. United States, 405 U.S. 150, 154
(1972), and its progeny, to the extent it has not already been produced, in a timely manner prior to
trial.
II.
Materials Not Disclosed
In addition to the materials identified above, the Government is in possession of additional
records that are not discovery materials under Rule 16(a). Nonetheless, in an abundance of caution,
the Government is providing the following inventory of those materials that have not been
produced:
Financial records produced by Bank of America for accounts in the names of
Financial records produced by Citibank for accounts in the names of
Credit report records produced by Equifax in the names of
S.
Financial records produced by JPMorgan Chase Bank for accounts in the names of
Financial records produced by Municipal Credit Union for accounts in the names of
Financial records produced by Navy Federal Credit Union for accounts in the names of
Financial records produced by TD Bank for accounts in the names of
Financial records produced by Wells Fargo Bank for an account in the name of
If at any time you believe that any of the foregoing materials should be produced as Rule
16(a) materials, please promptly notify the Government.
06.20.2018
EFTA00027736

=== Page 6 ===
Page 6
III.
Disclosure by the Defendant
In light of your request for the foregoing discovery, the Government hereby requests
reciprocal discovery under Fed. R. Crim. P. 16(b). Specifically, we request that you allow
inspection and copying of: (1) any books, or copies or portions thereof, which are in the
defendant's possession, custody or control, and which the defendant intends to introduce as
evidence or otherwise rely on at trial; and (2) any results or reports of physical or mental
examinations and of scientific tests or experiments made in connection with this case, or copies
thereof, which are in the defendant's possession or control, and which the defendant intends to
introduce as evidence or otherwise rely on at trial or which were prepared by a witness whom the
defendant intends to call at trial.
The Government also requests that the defendant disclose prior statements of witnesses he
will call to testify. See Fed. R. Crim. P. 26.2; United States V. Nobles, 422 U.S. 225 (1975). We
request that such material be provided on the same basis upon which we agree to supply the
defendant with 3500 material relating to Government witnesses.
We also wish to remind you that Fed. R. Crim. P. 12.3(a) requires you to provide the
Government with written notice if the defendant intends to claim a defense of actual or believed
exercise of public authority on behalf of a law enforcement or Federal intelligence agency at the
time of the alleged crime.
The Government requests a response to our Rule 12.3 demand within the time period
allowed by the Court for the filing of motions.
IV.
Sentence Reduction for Acceptance of Responsibility
Please contact us at your earliest convenience concerning the possible disposition of this
matter or any further discovery which you may request. This Office will oppose the additional
one-point reduction under the Sentencing Guidelines available for defendants who plead prior to
the Government's initiation of trial preparations pursuant to U.S.S.G. § 3E1.1(b), in the event your
client has not entered a plea of guilty four weeks prior to trial. We will follow this policy whether
or not suppression or other pretrial motions remain outstanding after this date and even if the trial
date has not been announced by the Court four weeks in advance of the trial.
06.20.2018
EFTA00027737

=== Page 7 ===
Page 7
Please be advised, however, that pursuant to the policy of the Office concerning plea offers,
no plea offer is effective unless and until made in writing and signed by authorized representatives
of the Office. In particular, discussions regarding the pretrial disposition of a matter that are not
reduced to writing and signed by authorized representatives of the Office cannot and do not
constitute a "formal offer" or a "plea offer," as those terms are used in Lafler V. Cooper, 132 S.Ct.
1376 (2012); Missouri V. Frye, 132 S.Ct. 1399 (2012).
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
By:
/s/
Assistant United States Attorneys
06.20.2018
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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
)"
Subject: RE: Documents Per Judge Nathan's Order
Date: Thu, 22 Apr 2021 00:26:23 +0000
Attachments: 2021-04-23 Gov't letter to filings.docx;
Ex_B_2021.04.05_BSF_Reply_re_Maxwell_Rule_17(c)_Subpoena_-
Prpsd_Redact.. [Government_Proposed_Redactions].pdf;
2021.04.05_BSF_Reply_re_Maxwell_Rule_17(c)_Subpoena_[Government_Proposed_Reda
ctions].pdf;
2021.04.19_LAM_Joint_Letter_with_BSF_re_redactions_in_Rule_17_pleadings_[Governm
ent_Proposed_Redactions].pdf;
2021.04.02 Defts Resp to BSF Ltr. Motn to Quash Rule 17 Sub [Government
ed_Redactions].pdf;
Ex._A_2021.04.02_Defts_Resp_to_BSF_Ltr_Motn_to_Quash_Rule_17_Sub_-
Prpsd.[Government_Proposed_Redactions].pdf
Attached is a draft letter requesting certain redactions and proposed redactions. Any edits?
From:
Sent: Wednesday, April 21, 2021 7:01 PM
To:
>;
(USANYS)
is
Subject: FW: Documents Per Judge Nathan's Order
From: Jeff Pagliuca
Sent: Wednesday, April 21, 2021 6:55 PM
To:
Cc: Sabina Mariella
>; Sigrid McCawley
(
is
Laura Menninger
>; Nicole Simmons
Subject: FW: Documents Per Judge Nathan's Order
Here they are. I thought they were attached to the last email.
From: Sigrid McCawley
Sent: Wednesday, April 21, 2021 4:32 PM
To: Laura Menninger
>; Jeff Pagliuca
Cc: Sabina Mariella
>; Sigrid McCawley
Subject: Documents Per Judge Nathan's Order
Hello Laura and Jeff,
As we understand Judge Nathan's Order, we are directed to confer with the Government about
any redactions they are requesting to the above. Please confirm that you agree the above set of
materials can be sent to the Government pursuant to Judge Nathan's Order this afternoon.
EFTA00027160

=== Page 2 ===
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
(t) +1 954 377 4223
(m) +1 954 770 5377
www.bsfllp.com
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among
other protections, is the subject of attorney-client privilege, attomey work product or exempt from disclosure under applicable law. If the reader of this electronic message is not
the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or other use
of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this
electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
EFTA00027161


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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
(see instructions below)
To:
SDNY Victim/Witness Unit
From: AUSA
Date: November 7, 2019
Re:
United States V.
Court Docket No:
N/A (grand jury)
USAO No:
Witness Name:
Witness DOB:
(Name/DOB as printed here will be forwarded to travel agency and then to TSA and must exactly
match the witness's driver's license or other travel ID or TSA will not permit the witness to fly.)
Witness Address:
Witness TelNos (mobile):
Witness e-mail:
Witness Needed to Appear in SDNY on
Date: November 21, 2019
Time: 9 am
Witness Needed to Appear for:
Trial ( )
Date:
Grand Jury ( )
Date:
Trial/GJ Prep (X) Date: November 21, 2019
Estimated Dates Witness will Arrive: November 20, 2019 (Flying from Los Vegas to NY)
Depart: November 21, 2019 (Flying from NY to Los Vegas)
Is the person a Fact Witness and not an Expert Witness?
(Yes/No):
Yes
Current Federal Civilian or Military Employee?
(Yes/No):
No
Is the Witness Facing Criminal Charges?
(Yes/No):
No
Does the Witness Reside Outside the Continental United States?
(Yes/No):
No
Is this Witness a Victim-Witness?
(Yes/No):
Yes
Hotel Required?
(Yes/No):
Yes
Has the Witness advised you of any unusual travel expenses?
(Yes/No):
No
Unusual expenses of fact witnesses can include
special travel arrangements
care for dependent child or incapacitated family member left at home
kennel fees for pets
necessary travel companion
rev. 2019.09.18
EFTA00028801

=== Page 2 ===
extra baggage (more than one bag)
Please describe the unusual expense:
For Victim/Witness Coordinator:
1. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW is
apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should be
used. For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to court/GJ
testimony. Note that witnesses may only be brought in under the FEWS appropriation for grand
jury testimony, court testimony, or preparation for same. NB: as to grand jury, this applies only in
the relatively infrequent occasions where time in the grand jury has been scheduled and the witness
is intended to testify. Any other witness travel for investigative interviews must be covered by the
investigating component from litigative funds (it is generally more common for investigators to
travel to the witness). See 28 C.F.R. Part 21, Witness Fees; USAP 3-19.000, Fact Witnesses and
Fees and Expenses of Witnesses (FEW) Appropriation; Guiding Principles for Obtaining Witness
Services Under the Fees and Expenses of Witnesses Appropriation,
http://dojnet.doj.gov/usao/eousa/ole/usabook/witn/index.htm.
rev. 2019.09.18
EFTA00028802


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=== Page 1 ===
From:
"
)"
To: "
I"
Subject: FW: Maxwell Suppression Opinion
Date: Wed, 30 Jun 2021 15:25:34 +0000
Attachments: 20cr330_Sealed_Opinion_&_Order_6.25.21.pdf;20cr330_Order_6.25.21.pdf
pp
From:
)
Sent: Wednesday, June 30, 2021 10:01 AM
To:
)
Subject: Fwd: Maxwell Suppression Opinion
Begin forwarded message:
From:
"
)"
Date: June 28, 2021 at 10:15:00 AM EDT
To:
)"
Subject: FW: Maxwell Suppression Opinion
EFTA00027459


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: Re: Jeffrey Epstein
Date: Sun, 07 Jul 2019 20:47:17 +0000
Importance: Normal
A righteous case.
On Jul 7, 2019, at 1:08 PM,
(USANYS)
wrote:
Hey PCU - As you likely may have seen/heard at this point, last evening, we arrested Jeffrey Epstein on sex trafficking
charges. Epstein is in custody and will be presented and arraigned on an Indictment that will be unsealed tomorrow
morning.
The case is an incredibly important one - not only is the conduct extremely serious and deeply disturbing - but our
charges ensure that dozens if not more of Epstein's victims, girls who were as young as 14 at the time they were abused,
will finally have their day in court. It is an extraordinarily worthy prosecution and just the latest example of how this
unit will never shy away from bringing tough cases against powerful people who have committed grievous crimes.
Please join me and
in extending a very well-deserved congratulations to the team,
who have worked tirelessly to make this case happen (and happen so quickly). They have done us all proud, and if you
are free, we hope you join us for the press conference formally announcing the charges, which should happen Monday
morning at 11.
&
EFTA00028988


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=== Page 1 ===
From:
"
)"
To:
)"
Subject: Accepted: Epstein defense bail submission due
Date: Mon, 08 Jul 2019 20:43:38 +0000
Importance: Normal
Attachments: unnamed
EFTA00028377


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Epstein flight records
Date: Wed, 08 Jan 2020 00:56:36 +0000
For your situational awareness, wanted to let you know that the flight records we received yesterday reflect that Donald
Trump traveled on Epstein's private jet many more times than previously has been reported (or that we were aware),
including during the period we would expect to charge in a Maxwell case. In particular, he is listed as a passenger on at
least eight flights between 1993 and 1996, including at least four flights on which Maxwell was also present. He is listed
as having traveled with, among others and at various times, Marla Maples, his daughter Tiffany, and his son Eric. On one
flight in 1993, he and Epstein are the only two listed passengers; on another, the only three passengers are Epstein,
Trump, and then-20-year-old
On two other flights, two of the passengers,
respectively, were women who would be possible witnesses in a Maxwell case. We've just finished reviewing the full
records (more than 100 pages of very small script) and didn't want any of this to be a surprise down the road.
Assistant U.S. Attorney
Southern District of New York
EFTA00028716


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=== Page 1 ===
Case 20-2413, Document 107, 09/11/2020, 2929023, Page1 of 2
S.D.N.Y.
20-2413
Loretta A. Preska, J.
United States Court of Appeals
FOR THE
SECOND CIRCUIT
At a stated term of the United States Court of Appeals for the Second Circuit, held at the
Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the
1 1th day of September, two thousand twenty.
,
Plaintiff-Appellee,
ORDER
V.
20-2413
Ghislaine Maxwell,
Defendant-Appellant.
Sharon Churcher, Jeffrey Epstein,
Respondents,
Julie Brown, Miami Herald Media Company, Alan M.
Dershowitz, Michael Cernovich, DBA Cernovich Media,
Intervenors.
It is hereby ORDERED that the United States shall submit an amicus letter brief, not to
exceed ten (10) double-spaced pages, regarding (1) arguments raised by Defendant-Appellant
Ghislaine Maxwell and (2) Defendant-Appellant Ghislaine Maxwell's motion to consolidate this
appeal with United States V. Maxwell, No. 20-3061. The United States shall submit its brief no
later than Wednesday, September 16, 2020 at 3:00 pm.
It is also hereby ORDERED that the parties to the appeal shall respond to the letter brief
filed by the United States by Wednesday, September 23, 2020 at 3:00 pm.
EFTA00028060

=== Page 2 ===
Case 20-2413, Document 107, 09/11/2020, 2929023, Page2 of 2
The hearing scheduled for Tuesday, September 22, 2020 at 2:00 pm is hereby
ADJOURNED until further order of the court.
For the Court:
Catherine O'Hagan Wolfe,
Clerk of Court
UNITED STATES
SECOND
Catherine
CIRCUIT
Hapaulwolfe
OF
2
EFTA00028061


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=== Page 1 ===
From:
Subject: RE: Epstein Guards/ OIG Report
Date: Fri, 21 May 2021 20:45:44 +0000
You, as well.
From:
Sent: Friday, May 21, 2021 4:42 PM
To:
(OIG)
Subject: Re: Epstein Guards/ OIG Report
Thank you. Have a nice weekend.
On May 21, 2021, at 4:37 PM,
(OIG)
wrote:
Hi
OIG has no objections. Thanks.
From:
Sent: Friday, May 21, 2021 4:29 PM
To:
(OIG)
V.
(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:
(OIG)
is
(OIG)
EFTA00029187

=== Page 2 ===
is
(OIG)
Cc:
(USANYS)
Subject: RE: Epstein Guards/ OIG Report
Thank you,
From:
(OIG)
Sent: Friday, May 21, 2021 2:09 PM
To:
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.
From:
Sent: Friday, May 21, 2021 1:46 PM
To:
(OIG)
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
EFTA00029188


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=== Page 1 ===
CG
COHEN & GRESSER LLP
Christian R. Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
April 8, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
Enclosed with this cover letter is a form requesting permission for defense counsel to bring
their personal electronic devices and computing devices to in-person court appearances in the
above-captioned case. We respectfully request that the Court grant wi-fi access and so order the
form.
In addition, the parties have arranged for an evidence view to take place, with the
defendant present, at 500 Pearl Street the weeks of April 12-16, 2021 and April 19-23, 2021.
Because much of the evidence is in electronic format, defense counsel will need to bring into the
courthouse the following equipment to view and photograph the evidence:
1. VCR player
2. Cassette player
3. CD player
4. Adapter for a micro-VHS tape
5. Microcassette player
6. Digital camera
Accordingly, we respectfully request that the Court grant defense counsel permission to
bring these items, as well as their personal electronic devices, into the courthouse for the weeks of
April 12-16, 2021 and April 19-23, 2021.
EFTA00029241

=== Page 2 ===
The Honorable Alison J. Nathan
April 8, 2021
Page 2
Thank you for your attention to these matters.
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
cc:
All Counsel of Record (By ECF)
EFTA00029242


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
(USANYS) [Contractor]"
,
)"
"
(USANYS)"
Subject:
3500
Date: Tue, 21 Sep 2021 21:18:42 +0000
Embedded: Call_with
msg; [EXTERNAL]_Subpoena_Re_Ghislane_Maxwell_case.msg
Hey
Would you add the attached email from
and the notes from the call we just had to
3500
folder?
Thanks,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00027573


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)
[Contractor]"
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: FW: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Set/Reset Deadlines
Date: Tue, 05 Jan 2021 14:58:11 +0000
Embedded:FW:_Activity_in_Case_1:20-cr-00330-AJN_USA_v_Maxwell_Set_Reset_Deadlines.msg
Sender:
Subject: FW: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Set/Reset Deadlines
Message-Id: <142e67ad68ff4a24941853b761175d75@SN1P110MB0205.NAMP110.PROD.OUTLOOK.COM>
To:
To:
To:
EFTA00028138


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=== Page 1 ===
From:
"
(USANYS)"
To:
"
(USANYS)"
Subject: Fwd: Reuters: Prison Guards Skipped Mandatory Checks Before Epstein Death
Date: Sun, 11 Aug 2019 02:32:09 +0000
Begin forwarded message:
From:
"
(USANYS)"
Date: August 10, 2019 at 10:30:56 PM EDT
To:
(USANYS)"
,
(USANYS)"
N
(USANYS)"
>, , "
(USANYS)"
Subject: Reuters: Prison Guards Skipped Mandatory Checks Before Epstein Death
https://www.breitbart.com/politics/2019/08/10/report-prison-guards-skipped-mandatory-checks-before-jefrey-
epsteins-death/
EFTA00027859


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=== Page 1 ===
From:
To:
Subject: Monday -- tasks
Date: Fri, 31 Jan 2020 22:58:03 +0000
1.
SCFU update (10:00)
2.
MLOC update (2:00)
3.
Ray draft
4. Epstein trust documents
5. Will
6. Fed/Karl - Transfer
7. Civil Division follow-up
8.
Henley sell
9. Sex trafficking memo
EFTA00028559


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=== Page 1 ===
From:
Subject: Epstein call
Date: Wed, 09 Jan 2019 15:18:14 +0000
Importance: Normal
Attachments: unnamed
EFTA00028144


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=== Page 1 ===
From: "
To: "Berman, Geoffrey (USANYS)"
Subject: Re:
Date: Mon, 08 Jul 2019 22:24:36 +0000
Importance: Normal
Awesome, thanks.
Sent from my iPhone
On Jul 8, 2019, at 6:19 PM, Berman, Geoffrey (USANYS)
wrote:
Epstein Proposed Press Remarks v3 (large).docx>
EFTA00028282


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=== Page 1 ===
From:
To:
Cc:
Subject: Maxwell
Date: Tue, 26 May 2020 14:04:21 +0000
Hey
- Hope you had a good long weekend.
would like to schedule a call this week with the Brass and the
Maxwell/Epstein team. The team + Me/
are free during the following windows:
Wednesday 10-12
Thursday 11-12, 230 to 430
Friday 230 to 430
Do any of those work for the Brass?
Thanks,
EFTA00027457


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=== Page 1 ===
From:
To:
Subject: Epstein Meeting
Date: Mon, 06 Jan 2020 16:09:19 +0000
Importance: Normal
Attachments: unnamed
EFTA00027740


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=== Page 1 ===
From:
Subject: RE: OPR Epstein Final Report
Date: Thu, 12 Nov 2020 19:45:56 +0000
Received. Thanks,
From:
Sent: Thursday, November 12, 2020 10:07 AM
To:
Subject: OPR Epstein Final Report
Attached please find OPR's final Report in the Jeffrey Epstein matter, and a transmittal letter.
EFTA00029072


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=== Page 1 ===
From:
To:
Cc:
]"
Subject: Re: Noel et al
Date: Tue, 26 Nov 2019 00:31:08 +0000
Many thanks.
https://www.nytimes.com/2019/11/25/nyregion/jeffrey-epstein-guards-tova-noel-michael-thomas.html
Sent from my iPhone
On Nov 25, 2019, at 7:10 PM,
wrote:
From:
Sent: Monday, November 25, 2019 5:05 PM
To:
is
Cc:
Subject: Noel et al
Possible to get their ages/or DOBs? Thanks.
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
EFTA00028195


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 234 Filed 04/22/21 Page 1 of 5
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
150 East 10th Avenue
HADDON
Denver, Colorado 80203
MORGAN
PH 303.831.7364 FX 303.832.2628
FOREMAN
www.hmflaw.com
jpagliuca@hmflaw.com
April 22, 2021
The Hon. Alison J. Nathan
United States District Court Judge
Southern District of New York
40 Foley Square
New York, NY 10007
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Response to Dkt. No. 227, Government's April 21, 2021 Letter re Ms. Maxwell's
Motions to Suppress
Dear Judge Nathan:
We write in response to the government's letter about Ms. Maxwell's pending motions
to suppress and request for evidentiary hearing (Dkt. No. 227), and this Court's order stating
an intent to defer resolution of those motions and that request until after the trial on the non-
perjury counts (Dkt. No. 231). Although we appreciate the need to streamline the pretrial
process and the desire to efficiently resolve the pending disputes, we do not agree that the
government's letter provides an adequate basis to defer resolution of Ms. Maxwell's motions.
We understand the Court's desire to maintain the status quo relating to the defense motions,
but the government's response gives Ms. Maxwell no confidence that the government shares
this understanding. Indeed, the government's vague assurances are insufficient to safeguard
Ms. Maxwell's constitutional rights, to guarantee the government will not benefit from its
unconstitutional conduct, and to ensure that Ms. Maxwell's is not deprived of due process
through the introduction and use of evidence that itself was obtained in violation of due
process.
EFTA00027169

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 234 Filed 04/22/21 Page 2 of 5
The Hon. Alison J. Nathan
April 22, 2021
Page 2
The government says that this Court need not resolve Ms. Maxwell's motions to
suppress or hold an evidentiary hearing before the trial on the non-perjury counts because it
"does not intend to use these materials"-i.e., any of the materials subject to the suppression
motions-"in its case-in-chief at the trial of the non-perjury counts in this case." (Dkt. No.
227, P 1). At the same time, the government purports to "reserve[] its right to use relevant
materials from this set for any purpose permissible under the Rules of Evidence." Id. at 2. The
government's representation is not good enough, and its reservation of rights is misplaced.
It is not enough for the government to represent that it "does not intend to use [the
suppression] materials in its case-in-chief at the trial of the non-perjury counts in this case."
Id. at 1. That's because Ms. Maxwell's motions to suppress allege violations of the due
process clause, the Fourth Amendment, the Fifth Amendment, and the Second Circuit's
decision in Martindell V. International Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979). If this
Court agrees with Ms. Maxwell's arguments, not only will it suppress all 90,000-some pages
of material the government improperly obtained through its ex parte subpoena, it will also
suppress all evidence derived therefrom. See Wong Sun V. United States, 371 U.S. 471, 488
(1963); United States V. Bailey, 743 F.3d 322, 341-42 (2d Cir. 2014).
The government thus cannot avoid inquiry into its conduct simply by pledging not to
use the material itself in its case-in-chief. If Ms. Maxwell is right-and an evidentiary hearing
will show that she is-the government also cannot use any evidence it obtained "by
exploitation of the illegality." See Wong Sun, 371 U.S. at 488.
What's more, "the burden of proof on [an] attenuation claim is on the government."
United States V. Ghailani, 743 F. Supp. 2d 242, 259 (S.D.N.Y. 2010) (ordering an evidentiary
hearing to put the government to its burden of proving attenuation) (citing United States V.
EFTA00027170

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 234 Filed 04/22/21 Page 3 of 5
The Hon. Alison J. Nathan
April 22, 2021
Page 3
Oguns, 921 F.2d 442, 447 (2d Cir. 1990) ("The government bears the burden of proving that
the taint [of an illegal search] has been alleviated.")). Like a Kastigar hearing, "the
government bears 'the heavy burden of proving that all of the evidence it proposes to use was
derived from legitimate independent sources." See United States V. Allen, 864 F.3d 63, 91 (2d
Cir. 2017) (quoting Kastigar V. United States, 406 U.S. 441, 453, 461-62 (1972) (holding that
use and derivative use immunity provides protection "from the use of compelled testimony, as
well as evidence derived directly and indirectly therefrom," and reversing conviction for Fifth
Amendment violation)). "[C]onclusory denials [of taint] are insufficient as a matter of law to
sustain the prosecution's burden of proof." Id. at 94.
The government's April 21 letter, with its vague and conclusory assurances, thus
offers no reason to postpone consideration of Ms. Maxwell's motions to suppress.
The government's purported reservation of rights is also without merit. Initially, it is
not at all clear what the government means when it says it might "use relevant materials from
this set for any purpose permissible under the Rules of Evidence." (Dkt. No. 227, p 2). But if
the government means that it intends to use the suppression material for impeachment
purposes, that is all the more reason to hold an evidentiary hearing now and to resolve Ms.
Maxwell's motions before trial on the non-perjury counts.
There are at least two reasons why. First, while the constitution in certain
circumstances allows the government to use unconstitutionally-obtained evidence for
impeachment purposes, e.g., Harris V. New York, 401 U.S. 222, 223-24 (1971) (statements
secured in violation of Miranda are admissible for impeachment purposes if voluntary), the
constitution forbids admission of evidence for all purposes if the government's conduct
violated due process, e.g., New Jersey V. Portash, 440 U.S. 450, 459 (1979) (due process
EFTA00027171

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 234 Filed 04/22/21 Page 4 of 5
The Hon. Alison J. Nathan
April 22, 2021
Page 4
forbids the state from compelling incriminating statements from a defendant and "any
criminal trial use against a defendant of his involuntary statement is a denial of due process of
law" (emphasis in original) (quoting Mincey V. Arizona, 437 U.S. 385, 398 (1978)). Here, the
government violated due process when it misrepresented and misled Chief Judge McMahon in
an ex parte proceeding to circumvent the civil protective order, and it independently would
violate due process for the government to be allowed to use that evidence at all, for any
purpose. U.S. CONST. amend. V; United States V. Lambus, 897 F.3d 368, 386 (2d Cir. 2018)
("It is within the court's inherent authority to suppress evidence gathered unlawfully in order
to maintain the integrity of its own proceedings. ").
Second, unless Ms. Maxwell knows what evidence the government can use against
her, under what circumstances, and for what purpose, she cannot make a knowing and
voluntary decision about whether to testify and or to assert her right to remain silent. U.S.
CONST. amends. V, VI; Rock V. Arkansas, 483 U.S. 44, 51 (constitution guarantees a
defendant the right to testify in her defense); Brown V. Artuz, 124 F.3d 73, 78 (2d Cir. 1997)
(wavier of the right to testify must be knowing and voluntary). Ms. Maxwell's decision
whether to testify is personal and fundamental. Id. ("[T]he decision whether to testify belongs
to the defendant and may not be made for [her] by defense counsel."). And for their part,
counsel cannot effectively represent Ms. Maxwell and advise her regarding the exercise of her
right to testify unless they too know the legal ramification of testifying or remaining silent. Id.
at 79 (defense counsel must "advise the defendant about the benefits and hazards of testifying
and of not testifying"). These considerations necessitate resolution of Ms. Maxwell's motions
to suppress before the trial on the non-perjury counts.
EFTA00027172

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 234 Filed 04/22/21 Page 5 of 5
The Hon. Alison J. Nathan
April 22, 2021
Page 5
For these reasons, Ms. Maxwell respectfully requests that this Court hold an
evidentiary hearing on her motions to suppress and that it rule on the merits of her arguments
before the trial on the non-perjury counts.
Respectfully submitted,
Jeffrey S. Pagliuca
CC: Counsel of Record
EFTA00027173


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=== Page 1 ===
From:
) [Contractor]"
To:
)"
Subject: RE: Letter to mail out
Date: Tue, 22 Oct 2019 20:08:58 +0000
Will do.
From:
)
Sent: Tuesday, October 22, 2019 4:07 PM
To:
) [Contractor]
Subject: Letter to mail out
Hi
Any chance you could please mail a copy of the attached letter (re the Epstein case) to the recipient listed at the top?
Thanks!
EFTA00028808


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c3: VOL00008
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c0:
=== Page 1 ===
From:
Subject: 33216 EPSTEIN.PDF
Date: Wed, 09 Jan 2019 15:03:00 +0000
Importance: Normal
Attachments: 33216_EPSTEIN.PDF
Will put this on the share but here is his NY Sex Offender Registration.
EFTA00028143


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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To: "Berman, Geoffrey (USANYS)"
Subject: RE: Update: Jeffrey Epstein Estate/Southern Country International Bank/USVI
Date: Fri, 13 Mar 2020 14:14:39 +0000
Inline-Images: image001.jpg
That's very funny. Wires must have crossed, because we had given them people to contact (who aren't you!). I'll handle
it.
From: Berman, Geoffrey (USANYS)
Sent: Friday, March 13, 2020 10:11 AM
To:
(USANYS)
Subject: FW: Update: Jeffrey Epstein Estate/Southern Country International Bank/USVI
Ha! Now I'm getting emails from line assistants in the VI. Can you have someone call him? Thanks. Geoff
From:
(USAVI)
Sent: Friday, March 13, 2020 10:06 AM
To: Berman, Geoffrey (USANYS)
Subject: RE: Update: Jeffrey Epstein Estate/Southern Country International Bank/USVI
Mr. Berman,
Hope you are well. As referenced below, I'm working with investigators on this matter. I would love to speak with
someone in your office so that they can be aware of what we are looking at, and vice versa. Would you mind letting me
know who in SDNY I should contact? Thank you so much,
Assistant United States Attorney
District of the Virgin Islands
5500 Veterans Drive, Suite 260
St. Thomas, VI 00802
340-715-9417
From:
(USAVI)
Sent: Thursday, March 05, 2020 6:35 AM
To: Berman, Geoffrey (USANYS)
Cc:
(USANYS)
Subject: RE: Jeffrey Epstein Estate/Southern Country International Bank/USVI
Thanks so much, Geoff.
EFTA00028285

=== Page 2 ===
By all means, let's coordinate here. Your unit chiefs should contact the VI-USAO Senior Litigation Counsel,
Best wishes,
From: Berman, Geoffrey (USANYS)
Sent: Wednesday, March 04, 2020 11:04 AM
To:
(USAVI)
Cc:
(USANYS)
Subject: Re: Jeffrey Epstein Estate/Southern Country International Bank/USVI
,
thanks for the heads up. We are looking into aspects of the estate. I would like to put our unit chiefs in contact
with someone in your office in charge of the matter to coordinate. Who would you suggest? Best, Geoff
On Mar 3, 2020, at 11:15 AM,
(USAVI)
wrote:
Good afternoon and greetings from the USVI:
We are opening an investigation of the Jeffrey Epstein estate and Southern Country International Bank in the
USVI. The investigation will be worked by FBI and IRS-CI. I wanted to reach out to you, in order to make
certain that we are not interfering with any ongoing investigation that your office may have.
I am happy to discuss.
Best wishes,
U.S. Attorney for the Virgin Islands
Office of the U.S. Attorney
Ron De Lugo Federal Building
5500 Veterans Drive, Suite 260
Charlotte Amalie, St. Thomas
VI 00802-6214
340-774-5757 (front desk)
(c)
https://www.justice.gov/usao-vi
<image001.jpg>
EFTA00028286


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=== Page 1 ===
From:
=
(USANYS)"
To:
)"
Subject: Accepted: call with USA of NDGA re: Epstein
Date: Tue, 05 Mar 2019 21:30:16 +0000
Importance: Normal
Attachments: unnamed
EFTA00027747


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028192.pdf
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c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: Read: Jail where Epstein died has history of security breaches
Date: Mon, 09 Sep 2019 18:31:19 +0000
From:
Sent: Monday, September 9, 2019 2:29 PM
To:
Subject: FW: Read: Jail where Epstein died has history of security breaches
From:
Sent: Friday, September 06, 2019 5:38 PM
To:
Subject: Read: Jail where Epstein died has history of security breaches
Read the below article for
references
https://nypost.com/2019/09/05/jail-where-jefrey-epstein-died-has-egregious-history-of-security-breaches/
EFTA00028192


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=== Page 1 ===
Event: Accepted: Pre-Meeting US V Noel/Epstein FOIA
Start Date: 2021-06-28 19:45:00 +0000
End Date: 2021-06-28 20:00:00 +0000
Location:
S Office
Class: X-PERSONAL
Comment:
Date Created: 2021-06-27 23:37:04 +0000
Date Modified: 2021-06-27 23:37:04 +0000
Priority: 5
DTSTAMP: 2021-06-27 23:21:58 +0000
Attendee:
(USANYS)
EFTA00029530


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=== Page 1 ===
From:
To:
Subject: FW: [EXTERNAL] Re: Ghislaine Maxwell 02879-509
Date: Thu, 14 Oct 2021 15:33:50 +0000
Inline-Images: image003.png; image004.png
From: BOBBI C STERNHEIM
Sent: Thursday, October 14, 2021 9:50 AM
To:
Cc: Christian Everdell
Subject: [EXTERNAL] Re: Ghislaine Maxwell 02879-509
Good morning-
I am on the VTC with Ms. Maxwell who has confirmed that she has not received the hard drive
sent by the government and delivered to the MDC on Tuesday.
Further, there is legal material and books that have been delivered to the MDC and have not been given to Ms. Maxwell.
Please provide an explanation immediately.
Thank you.
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you.
On Oct 13, 2021, at 6:55 PM, BOBBI C STERNHEIM
wrote:
Good evening-
Per the govt email and FedEx tracking info (see below), two (2) FedEx envelopes sent by the government to the MDC
for Ms. Maxwell were delivered to the MDC yesterday (Tuesday 10/12) at 10:26 am.
As of this afternoon (10/13), Ms. Maxwell still had not received either FedEx..
Please immediately provide an explanation for the delay as it will be reported to the Court.
Bobbi
<Screen Shot 2021-10-13 at 6.46.32 PM.png><Screen Shot 2021-10-13 at 6.31.26 PM.png><Screen Shot 2021-10-13 at 6.26.05 PM.png>
EFTA00029297

=== Page 2 ===
Chrome File Edit View History Bookmarks Profiles Tab Window Help
S
1
1)) 94%
Wed 6:31 PM BC Sternheim
8166 1429 9130
?
ADD NICKNAME
Delivered
Tuesday, October 12, 2021 at 10:26 am
DELIVERED
Signature release on file
GET STATUS UPDATES
OBTAIN PROOF OF DELIVERY
FROM
TO
NEW YORK, NY US
Brooklyn, NY US
SEE FULL DETAILS
Personalize Your Deliveries
Need to customize this delivery?
Learn how FedEx Delivery Manager can help
EFTA00029298

=== Page 3 ===
Safari File Edit View History Bookmarks Window Help
S
1
92%
Wed 6:26 PM BC Sternheim
4
>
A fedex.com
+
FedEx
Shipping
Tracking
Design & Print
Locations
Support
Sign Up or Log In
a
TRACK ANOTHER SHIPMENT
8166 1429 9141
?
ADD NICKNAME
Delivered
Tuesday, October 12, 2021 at 10:26 am
DELIVERED
Signature release on file
GET STATUS UPDATES
OBTAIN PROOF OF DELIVERY
FROM
TO
NEW YORK, NY US
BROOKLYN, NY US
Travel History
Shipment Facts
?
?
?
?
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you.
EFTA00029299


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=== Page 1 ===
From:
)"
To:
)"
,
)"
Subject: RE:
)
- Epstein
Date: Mon, 08 Jul 2019 02:18:41 +0000
Importance: Normal
Alright alright 10:00, but that's my final offer
From:
Sent: Sunday, July 07, 2019 22:11
To:
>;
Subject: RE:
)
- Epstein
I'm free, but if possible can we do it a bit earlier, so we have time to brief the Florida approach agents? I think they fly out
Tuesday afternoon (but I could be wrong about that).
From:
Sent: Sunday, July 7, 2019 10:10 PM
To:
is
Subject: FW:
- Epstein
10:30 okay for you guys on Tuesday?
From:
Sent: Sunday, July 07, 2019 18:51
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you. Let's set a time for Tuesday
morning (the earlier the better for me). Let me know what works for you.
Thanks,
Sent from my iPhone
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
t.
f.
e.
EFTA00028370

=== Page 2 ===
www.crimlawfirm.com
On Jul 7, 2019, at 4:04 PM,
)
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak with you. I expect our schedules may
be somewhat unpredictable tomorrow; would it work to set a time to talk on Tuesday? We can schedule it for before
you meet with
if that's helpful. Or if you'd like to talk sooner, we could schedule a time later today, or check in
tomorrow about a possible afternoon discussion. Please let us know what you prefer, and we look forward to being in
touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Saturday, July 06, 2019 22:55
To:
Subject:
)
- Epstein
Begin forwarded message:
From:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
Cc:
Subject:
)
- Epstein
My former partner, Alan Ross, represented
), prior to his passing in
2018. Agent
served
with a grand jury subpoena earlier today, and as Alan's former
partner and FL Bar appointed inventory attorney, she has contacted me. Unfortunately, I am unable to meet
with her until Tuesday, but I would appreciate a few minutes of your time at your convenience as I am getting
up to speed. Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
t.
EFTA00028371

=== Page 3 ===
f.
e.
www.crimlawfirm.com
EFTA00028372


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
(USANYS)"
)"
Subject: FW: U.S. V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) -- Response to Government's Letters
re: Accuser-3's Evidence
Date: Fri, 12 Nov 2021 16:25:36 +0000
Attachments: 2021.11.11_Letter_to_Judge_Nathan_re_Response_to_Government_Letters_re_Accuser-
3_Evidence.PDF
Inline-Images: image001.gif; image002.jpg
Hi
Attached is the defense response on MV-3.
Thanks,
From: Christian Everdell
>
Sent: Thursday, November 11, 2021 11:58 PM
To: Nathan NYSD Chambers
Cc:
is
(USANYS)
is
-
>; ; Jeff Pagliuca
>; Laura Menninger
; BOBBI C STERNHEIM
Subject: [EXTERNAL] U.S. V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) -- Response to Government's Letters re: Accuser-3's
Evidence
Dear Chambers -
Attached please find Ms. Maxwell's response to the government's letters, dated November 5, 2021 and November 7,
2021, regarding Accuser-3's evidence. Pursuant to our established protocol, we are submitting the letter to the Court
under temporary seal to allow the government to propose any redactions it deems necessary.
Respectfully submitted,
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 1002
|
view bio
www.cohengresser.com
New York Paris Washington DC London
EFTA00027663

=== Page 2 ===
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00027664


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=== Page 1 ===
From:
To:
Subject: RE: SDNY DAILY NEWS CLIPPINGS; MONDAY, MAY 24, 2021
Date: Mon, 24 May 2021 17:06:06 +0000
Inline-Images: image003.png; image001.jpg
Amazing.
From:
Sent: Monday, May 24, 2021 12:15 PM
To:
Subject: RE: SDNY DAILY NEWS CLIPPINGS; MONDAY, MAY 24, 2021
Can't take this seriously:
LIVE
FOX
EPSTEIN GUARDS ADMIT TO FALSIFYING RECORDS
NEWS
channel
FOX &friends
From: Lonergan,
(USANYS)
Sent: Monday, May 24, 2021 12:09 PM
To:
Subject: FW: SDNY DAILY NEWS CLIPPINGS; MONDAY, MAY 24, 2021
From: Biase, Nicholas (USANYS)
Sent: Monday, May 24, 2021 10:08 AM
To:
Subject: SDNY DAILY NEWS CLIPPINGS; MONDAY, MAY 24, 2021
OF JUSTICE
SDNY PRESS CLIPPINGS
MELIN?
DEPARTMENT
JUSTITIA
Trump lawyer Rudy Giuliani not above the law, prosecutors say
EFTA00028711

=== Page 2 ===
How federal prosecutors are pursuing Rudy Giuliani - CNNPolitics
Epstein prison guards strike deal to avoid jail time (yahoo.com)
SEC V. Ripple heats up with battle over legal advice - FinanceFeeds
The Colonial Pipeline Ransomware Hackers Had a Secret Weapon: Self-Promoting Cybersecurity Firms - ProPublica
Trump criminal investigation looms over Manhattan DA race - New York Daily News (nydailynews.com)
Nicholas Blase
Spokesman
United States Department of Justice
Office |Southern District of New York
I
Mobile:
I
Press Office:
Nicholas Blase
Spokesman
United States Department of Justice
Office |Southern District of New York
I
Mobile:
I
Press Office:
EFTA00028712


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: FW: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Govs Motn to
Preclude Testimony of Dietz and Loftus]
Date: Sat, 13 Nov 2021 16:25:10 +0000
Attachments: 2021.11.12_Maxwell_Response_to_Gov_Motion_to_Exclude_Dietz_and_Loftus.pdf;
Ex._1.pdf; Ex._2.pdf
Inline-Images: image001.jpg
Hey
- this is the last thing for the binder. Thanks!
From: Nicole Simmons
Sent: Friday, November 12, 2021 8:55 PM
To: 'Nathan NYSD Chambers'
Cc: Jeff Pagliuca
; Laura Menninger
Subject: [EXTERNAL] U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Govs Motn to Preclude Testimony of
Dietz and Loftus]
Dear Judge Nathan:
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Response to the Government's Motion In Limine to
Preclude Expert Testimony of Dr. Park Dietz and Dr. Elizabeth Loftus along with supporting documents. Pursuant to our
established protocol, we are submitting the Motion and Exhibits to the Court under temporary seal to allow the
government to propose any redactions it deems necessary.
Regards,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
EFTA00029180


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c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
US V Epstein
Search Terms Report
Report Name: Search Terms . OPR Materials
Searchable Set: STR - Search Terms - OPR
Materials
300,000
280,000
267,137
260,000
240,000
220,000
200,000
180,000
160,000
140,000
120,000
100,000
80,000
60,000
32,986
40,000
19,512
20,000
0
Total documents with
Total documents with
Total documents without
hits
hits, including Family
hits
Results Summary
Documents in
Total documents with
Total documents with
Total documents
searchable set
hits
hits, including Family
without hits
300,123
19,512
32,986
267,137
Report Generated: 1/13/2021 7:40:20 AM
Page 1 of 4
EFTA00029246

=== Page 2 ===
US V Epstein
Search Terms Report
Report Name: Search Terms - OPR Materials
Searchable Set: STR - Search Terms - OPR
Materials
4,406
39
56
2,059
0
2
114
4
3,170
33
963
7
629
4
167
75
0
4
1,225
438
n
Report Generated: 1/13/2021 7:40:20 AM
Page 2 of 4
EFTA00029247

=== Page 3 ===
US V Epstein
Search Terms Report
Report Name: Search Terms . OPR Materials
Searchable Set:
STR - Search Terms - OPR
Materials
2,297
329
63
7,509
36
0
500 1000 1500 2000 2500 3000 3500 4000 4500 5000 5500 6000 6500 7000 7500 8000
Terms Summary
Term
Documents with hits
Documents with hits,
Unique hits
including Family
4,406
6,215
3,560
39
148
6
56
308
3
2,059
3,191
1,886
0
0
0
2
3
0
114
254
72
4
8
0
3,170
5,014
2,188
33
128
23
963
2,488
279
7
20
3
629
1,976
428
4
6
2
167
484
0
75
135
14
0
0
0
4
6
0
1,225
3,242
623
Report Generated: 1/13/2021 7:40:20 AM
Page 3 of 4
EFTA00029248

=== Page 4 ===
US V Epstein
Search Terms Report
Report Name: Search Terms - OPR Materials
Searchable Set: STR - Search Terms - OPR
Materials
Term
Documents with hits
Documents with hits,
Unique hits
including Family
438
1,156
226
0
0
0
2,297
5,132
1,217
329
1,033
210
63
575
42
7,509
15,037
5,874
36
125
7
Report Generated: 1/13/2021 7:40:20 AM
Page 4 of 4
EFTA00029249


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c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027574.pdf
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c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Subject: Call with
Date: Tue, 21 Sep 2021 21:17:58 +0000
Call with
was sold,
Could recognize her signature at the time - it was just a scroll.
Has destroyed all her notes.
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00027574


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c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00029468.pdf
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c7: images
c0:
=== Page 1 ===
From:
Subject: Accepted: Epstein Oral Argument-- Second Circuit
Date: Tue, 05 Feb 2019 17:12:13 +0000
Importance: Normal
Attachments: unnamed
EFTA00029468


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028758.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
"
)"
Cc:
)"
(USANYS)"
Bec:
"
=
Subject: RE: laptop for MDC
Date: Wed, 28 Oct 2020 18:09:07 +0000
Embedded: RE:_laptop_for_MDC.msg
Sender:
Subject: RE: laptop for MDC
Message-Id:
<SN1P110MB03036BAC150A208332BF617684170@SN1P110MB0303.NAMP110.PROD.OUTLOOK.COM
>
To:
Cc:
Cc:
EFTA00028758


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c6: pdf
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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
)"
Subject: Amazon return
Date: Thu, 11 Nov 2021 04:09:17 +0000
Embedded: [EXTERNAL]_Amazon_Ref_No_CRIM1153768_2021_(External_Case_No._20_Cr._330).nn
sg;
[EXTERNAL]_Amazon_Ref_No_CRIM1153768_2021_(External_Case_No._20_Cr._330)
(1).msg
Hey
and
Thanks again for all the help today! When you have a chance, would one of you mind adding this to the next Discovery
folder and to a folder for Amazon subpoena returns?
Thanks!
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00029579


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: RE: Epstein search warrant documents
Date: Tue, 07 Apr 2020 22:05:51 +0000
Great - thanks very much. l'll send an invite to everybody, and we'll see how many people can ultimately be on the line
but for sure there will be spots for the two of us at least.
From:
(USANYS)
Sent: Tuesday, April 07, 2020 18:05
To:
)
>;
(USANYS)
Cc:
is
Subject: RE: Epstein search warrant documents
Yes, I should be able to do this.
From:
Sent: Tuesday, April 7, 2020 5:52 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: FW: Epstein search warrant documents
- is one (or both) of you able to join this tomorrow? As we've discussed a number of times, we are not
getting any support on this from FBI at our level so I think it would be very helpful to have support up the chain.
thanks,
From:
Sent: Tuesday, April 07, 2020 15:27
To:
is
(USANYS)
is
)
is
(USANYS)
Cc:
is
is
is
is
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:
is
(USANYS)
is
is
(USANYS)
EFTA00028339

=== Page 2 ===
Cc:
i
>;
is
is
)
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:
From:
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
)
is
is
(USANYS)
Cc:
is
>;
is
is
Subject: RE: Epstein search warrant documents
Are you available tomorrow for a conference call to discuss this issue?
SSA
Watson
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:
is
(USANYS)
is
is
(USANYS)
Cc:
is
is
i
is
EFTA00028340

=== Page 3 ===
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:
-
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:
)
Sent: Wednesday, March 04, 2020 16:36
To:
>;
(USANYS)
is
i
(USANYS)
Cc:
is
is
i
is
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.
EFTA00028341

=== Page 4 ===
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.
(office)
(cell)
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
i
V.
is
)
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:
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
is
V.
(USANYS)
Cc:
is
)
is
is
is
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.
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:
is
(USANYS)
is
is
(USANYS)
Cc:
is
is
i
is
EFTA00028342

=== Page 5 ===
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.
(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:
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
i
>;
V.
(USANYS)
Cc:
is
>;
is
is
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.
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.
EFTA00028343

=== Page 6 ===
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,
From:
Sent: Saturday, February 15, 2020 16:30
To:
is
Cc:
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
EFTA00028344


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From:
(USANYS)"
To:
,
)"
Subject: v4TVPA and Forfeiture.docx
Date: Mon, 20 May 2019 18:01:18 +0000
Importance: Normal
Attachments: v4TVPA_and_Forfeiture.docx
To the extent that you have debriefed any of the victims on his home(s), can you please send me the 302 if it is ready so I
can fill in the discussion section? I couldn't find any 302s or notes of interviews on the share.
Thanks,
EFTA00027772


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
(USANYS)"
)"
Bcc:
Subject:
Date: Fri, 02 Oct 2020 00:48:08 +0000
Embedded:
Sender:
Subject:
Message-Id:
To:
To:
EFTA00029040


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=== Page 1 ===
From:
To:
Subject: RE: United States V. Ghislaine Maxwell
opens
Date: Sun, 28 Nov 2021 23:14:53 +0000
Thank you!
From:
Sent: Sunday, November 28, 2021 5:53 PM
To:
Subject: FW: United States V. Ghislaine Maxwell --
opens
Good luck!!!!
O:
C:
From:
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>; USANYS-CRIMINAL PARALEGALS <USANYS-
CRIMINALPARALEGALS@usa.doj.gov>; USANYS-INVESTIGATORS <USANYS-INVESTIGATORS@usa.doj.gov>
Cc:
Subject: United States V. Ghislaine Maxwell --
opens
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors will
do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine Maxwell
sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00029421


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c0:
=== Page 1 ===
Event: Jason Mojica Proffer (Ordered) (re Epstein)
Start Date: 2019-09-10 16:30:00 +0000
End Date: 2019-09-10 17:30:00 +0000
Organizer:
(USANYS)
Location: 500 Pearl Street - Q
Class: X-PERSONAL
Date Created: 2019-12-13 05:56:31 +0000
Date Modified: 2019-12-13 05:56:31 +0000
Priority: 5
DTSTAMP: 2019-09-04 16:05:15 +0000
Attendee:
EFTA00029357


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
(USANYS)"
Subject: Re: Epstein trustees' counsel
Date: Thu, 19 Dec 2019 18:54:10 +0000
Thanks very much,
We've forwarded to
and will get her views on how best to proceed.
Sent from my iPhone
On Dec 19, 2019, at 12:31 PM,
)
wrote:
In our call today with counsel for the respective Trustees of the Epstein estate, they asked that we convey a request to
meet with
,
and anyone else she would want to include in such a meeting, to discuss the Trustees' interest in
resolving the Government's potential civil forfeiture claims against the estate. They said they appreciated our (the line
assistants') willingness to hear their regular updates, but that they understand we're not in a position to negotiate, or
even to provide feedback on the proposed plan for the fund, and so they'd like the opportunity to elevate that
discussion and convey why they believe it would be in all parties' interests, including the victims, to engage in
meaningful discussions about a possible resolution. When you've spoken with
could you please let us know
whether she's willing to meet with them? And we can convey the response, unless you and/or she would prefer to do
so directly. If she is willing to meet with them, they were hoping to put a date and time on the calendar as soon as is
convenient for her after the holiday.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00027465


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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Laptop for Ghislaine Maxwell (Reg. No. 02879-509)
Date: Wed, 18 Nov 2020 05:15:46 +0000
that works
can call me at
and will come down
>>>
From:
To:
CC:
(USANYS)"
Date:
11/17/2020 9:09 PM
Subject: RE: Laptop for Ghislaine Maxwell (Reg. No. 02879-509)
Thank you very much. I will aim to arrive between 9am and 9:30am tomorrow morning.
From:
Sent: Tuesday, November 17, 2020 9:01 AM
To:
Cc:
is
is
is
is
(USANYS)
Subject: Re: Laptop for Ghislaine Maxwell (Reg. No. 02879-509)
That's fine.
Can come between 0600 am and 1200 pm
>>>
From:
)"
To:
CC:
(USANYS)"
Date:
11/17/2020 8:59 AM
Subject: Re: Laptop for Ghislaine Maxwell (Reg. No. 02879-509)
Good morning,
We will have a new hard drive with a new discovery production for Maxwell ready tomorrow. Would it be alright
if I brought both the laptop and hard drive to the MDC tomorrow instead of just the laptop today, please?
Thank you,
EFTA00029273

=== Page 2 ===
On Nov 16, 2020, at 2:01 PM,
)
wrote:
<!--[if mso 9] <![endif]--
Will do, thank you very much.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From:
Sent: Monday, November 16, 2020 1:59 PM
To:
Cc:
>;
is
is
is
is
(USANYS)
Subject: Re: Laptop for Ghislaine Maxwell (Reg. No. 02879-509)
Drop it off anytime between 600 am and 1200 pm.
>>>
From:
)"
To:
<
>
CC:
)"
(USANYS)"
Date:
11/16/2020 1:58 PM
Subject: Laptop for Ghislaine Maxwell (Reg. No. 02879-509)
Good afternoon,
I am planning to bring a laptop and charger for inmate Ghislaine Maxwell (Reg. No. 02879-509) to use
when reviewing discovery produced from my office. Attached please find the accompanying cover letter,
which I will hand deliver with the laptop. I am available to make this delivery tomorrow. Would you
please let me know what time I should arrive with the laptop?
My understanding from
is that I should bring the laptop to the East Building, located on
29th Street near 3rd Avenue and that I should go to the front lobby and ask for
who will then
come and retrieve the laptop. Please let me know if that is correct, or if I should take any different steps.
As always, I can be reached on my cellphone at
with any questions or concerns.
Thank you,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00029274


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=== Page 1 ===
From:
Subject: RE: 3 pm is good for the Epstein team
Date: Wed, 14 Aug 2019 13:41:35 +0000
Excellent, thank you. See you all then
From:
Subject: 3 pm is good for the Epstein team
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
t.
EFTA00027933


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: RE: Epstein/Maxwell Upload
Date: Thu, 24 Sep 2020 20:36:44 +0000
Sounds good, thanks so much.
From:
(USANYS) [Contractor]
Sent: Thursday, September 24, 2020 11:37 AM
To:
Subject: RE: Epstein/Maxwell Upload
The files look good. One thing to note is that the confidential marking is not as large and glaring as we typically use but it
is still clearly visible in the bottom left. I think I will probably need to go through to the excels and mark them individually
confidential but that shouldn't be too troublesome. Once
answers my question I will ask him to export the
productions to our discovery folder so that we can start prepping the remainder of the materials.
From:
Sent: Wednesday, September 23, 2020 5:40 PM
To:
(USANYS) [Contractor]
Subject: RE: Epstein/Maxwell Upload
Thanks!
From:
(USANYS) [Contractor]
Sent: Wednesday, September 23, 2020 5:39 PM
To:
Subject: RE: Epstein/Maxwell Upload
Yes, l'll hopefully have it done soon.
From:
Sent: Wednesday, September 23, 2020 5:26 PM
To:
(USANYS) [Contractor]
Subject: FW: Epstein/Maxwell Upload
Will, would you please review these and let me know if there's anything you think I need to check?
From:
(USANYS) [Contractor] CRozier@usa.doj.gov>
Sent: Wednesday, September 23, 2020 11:32 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
is
(USANYS)
is
)
Subject: RE: Epstein/Maxwell Upload
The production of the documents has been completed. The below are links to the production for you to review:
Deutsche Bank - https://d1pe.nss.pae.com/Relativity/go?id=1420850-2343058
JP Morgan - https://d1pe.nss.pae.com/Relativity/go?id=1420850-2343059
EFTA00028052

=== Page 2 ===
Please review the documents and let me know if anything needs to be adjusted with the production.
Thank you.
From:
(USANYS) [Contractor]
Sent: Friday, September 18, 2020 10:26 AM
To:
(USANYS) [Contractor] CRozier@usa.doj.gov>
Cc:
(USANYS) [Contractor]
is
>;
(USANYS)
is
)
Subject: RE: Epstein/Maxwell Upload
1. Yes, we want to mark all of them confidential
2. We are working on that.
3.
I suppose database load files? We want to retain the files as they are currently formatted as best we can.
4.
That won't be an issue. I don't think we will be searching through them; the purpose is just to be able to stamp
them.
Thanks!
From:
(USANYS) [Contractor] <CRozier@usa.doj.gov>
Sent: Friday, September 18, 2020 10:10 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
>;
(USANYS)
is
)
Subject: RE: Epstein/Maxwell Upload
I know you want to produce these documents can you please tell me the following:
1.
Will you placing a Confidential stamp on these documents?
2.
What bates number do you wish to use on the documents?
3.
How do you want to produce the documents (single page tiff images, database load files or PDF production).
4. Also please note that once the documents have been loaded to Relativity there is no way to run any searches for
these images since they are mostly images and video.
Please let me know if there are any questions.
Thank you.
From:
(USANYS) [Contractor]
Sent: Thursday, September 17, 2020 4:54 PM
To:
(USANYS) [Contractor] CRozier@usa.doj.gov>
Cc:
(USANYS) [Contractor]
y.
V.
(USANYS)
is
Subject: Epstein/Maxwell Upload
Hey
EFTA00028053

=== Page 3 ===
We have some materials that we need uploaded to Relativity to the Epstein database for the purpose of stamping them.
The files in question number about 40,000 and are about 300GB in size. They are currently copying onto a drive to be sent
to Relativity and should be ready by tomorrow. Do you want to see them first or can they go directly to PAE?
Folder/Subfolder in Relativity: US V. Epstein
FBI Case File
Images Seized During Search
Thanks,
Paralegal Specialist
U.S. Attorney's Office I SDNY
1 St. Andrew's Plaza
New York, NY 10007
Office:
Cell:
EFTA00028054


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=== Page 1 ===
From:
To:
Subject: August Monthly Update--corrected
Date: Thu, 15 Aug 2019 20:48:46 +0000
Attachments:
Update_w_Initials_Corrected.pdf
Thanks. I've noted the case in my database so I should catch it on my own next time around. You can delete the
earlier one I sent you.
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=== Page 1 ===
From: Goretti Moya
To:
"
"
Subject: [EXTERNAL] US V Maxwell SEALED
Date: Thu, 11 Nov 2021 00:46:05 +0000
Attachments: XLBAGmax_sealed_excerpt.pdf
EFTA00027656


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From:
)"
To:
)"
Subject: Accepted: Conference: Jeffrey Epstein
Date: Wed, 17 Jul 2019 18:04:26 +0000
Importance: Normal
Attachments: unnamed
EFTA00028083


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From:
To:
Subject: FW: JE state plea transcript
Date: Wed, 07 Aug 2019 15:56:06 +0000
Attachments: Epstein_state_plea_transcript.pdf
Just FYI, flagged this to the team yesterday re: his state plea transcript and meant to send it to you both as well.
From:
Sent: Tuesday, August 06, 2019 20:34
To:
Subject: JE state plea transcript
Check out pages 38-39 of his state plea:
Epstein counsel: "[T]here is a nonprosecution agreement with the United States Attorney's office that triggers as a result
of this plea agreement. In other words, they have signed off and said they will not prosecute Mr. Epstein in the Southern
District of Florida for any offense upon his successful taking of his plea today. That is a confidential document that the
parties have agreed to. Just in an abundance of caution, I wanted to tell the court."
[...]
The Court: "Mr. Epstein, your attorney has told me that in addition to everything, we talked about another inducement,
shall we say, to your taking this plea is that the U.S. Attorney for the Southern District of the State of Florida, federal
prosecutor, has agreed to a nonprosecution agreement with you, meaning that if you successfully complete probation and
do everything you're supposed to, they have, have agreed not to prosecute you federally, did you understand that?"
The Defendant: "Yes, ma'am."
The prosecutor then notes that SDFL people ("they") were in court for the plea.
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
"
)"
To:
"
(
)"
Subject: Accepted:
Date: Mon, 10 Jun 2019 17:43:14 +0000
Importance: Normal
Attachments: unnamed
EFTA00029505


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: Thomas - Draft Discovery Response
Date: Tue, 31 Mar 2020 19:31:32 +0000
Attachments: 2020.04.xx_Response_to_Thomas_Second_Discovery_Request_v1.docx;
Michael_Thomas _Second_Discovery_Request.pdf
Hey,
Let me know if you have any comments, thanks!
Assistant United States Attorney
Southern District of New York
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From:
To:
Cc:
Subject: Travel Confirmation Information -
Date: Fri, 10 Sep 2021 18:01:09 +0000
Attachments: VVQERK.pdf;
Good Afternoon
Attached please find your flight itinerary and hotel confirmation. Delancey Car Service will pick you up at the airport when
you arrive. If you need to locate the car, their number is 212-228-3301, confirmation # 758261. They will drop you off at
the hotel. Please give me a call when your meeting is complete and I will have the car service pick you up to take you back
to the airport.
Please let me know if you have any questions.
Regards,
Fact Witness Coordinator - FSA Contractor
U.S. Department of Justice
U.S. Attorney's Office, SDNY
New York, New York 10007
Phone:
Cell:
EFTA00027419


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=== Page 1 ===
From:
)"
To:
Cc:
(USANYS)"
Subject: RE: Epstein
Date: Thu, 25 Jul 2019 20:56:09 +0000
Thanks very much,
Please let us know if any additional reports are generated, and please let us know when the
investigation is completed. Really appreciate your help.
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From:
Sent: Thursday, July 25, 2019 3:18 PM
To:
)
Cc:
(USANYS)
Subject: Re: Epstein
Thank you. Attached please find the staff memos and photos that were taken. Please advise if you need to share this with
Main Justice so that I can make appropriate notifications on BOP's end.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
New York, New York 10007
p:
f:
>>>
)" <
> 7/25/2019 2:08 PM>>>
Thanks
Please consider this email my request for any and all documents and other materials, including photographs,
related to the investigation regarding the incident involving Jeffrey Epstein earlier this week.
EFTA00028434

=== Page 2 ===
On Jul 25, 2019, at 1:49 PM,
<
> wrote:
Hi
I left you a voicemail, but wanted to follow up via email as well.
Our Regional Office reminded me that we need a written request from your office to produce the documents you seek. It
does not have to be a subpoena. An email from you requesting the investigation documentation will suffice.
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
New York, New York 10007
p:
f:
EFTA00028435


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=== Page 1 ===
From:
"
(NY) (FBI)"
To:
(USANYS)"
Subject: Fwd: Requested Documentation
Date: Sun, 11 Aug 2019 15:02:41 +0000
Attachments: Epstein_Investigative_Reports.pdf; Additional_Psychology_Notes.pdf
-
Forwarded message
From: Tijuana Doctor <tdoctor@bop.gov>
Date: Aug 10, 2019 10:57 PM
Subject: Requested Documentation
To: "
-
(NY) (FBI)"
Cc:
Please let me know if you need anything else.
EFTA00027934


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=== Page 1 ===
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 9/2/20
SOUTHERN DISTRICT OF NEW YORK
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
MEMORANDUM
Defendant.
OPINION AND ORDER
ALISON J. NATHAN, District Judge:
On August 17, 2020, Defendant Ghislaine Maxwell filed a sealed letter motion seeking
an Order modifying the protective order in this case.¹ Specifically, she sought a Court order
allowing her to file under seal in certain civil cases ("Civil Cases") materials ("Documents") that
she received in discovery from the Government in this case. She also sought permission to
I This Order will not refer to any redacted or otherwise confidential information, and as a result it will not be sealed.
The Court will adopt the redactions to Defendant's August 17, 2020 letter motion that the Government proposed on
August 21, 2020, and it will enter that version into the public docket. The Court's decision to adopt the
Government's proposed redactions is guided by the three-part test articulated by the Second Circuit in Lugosch V.
Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the
documents in question are "judicial documents;" (ii) assess the weight of the common law presumption of access to
the materials; and (iii) balance competing considerations against the presumption of access. Id. at 119-20. "Such
countervailing factors include but are not limited to 'the danger of impairing law enforcement or judicial efficiency'
and 'the privacy interests of those resisting disclosure." Id. at 120 (quoting United States V. Amodeo, 71 F.3d 1044,
1048 (2d Cir.1995) ("Amodeo II")). The Government's proposed redactions satisfy this test. First, the Court finds
that the defendant's letter motion is "relevant to the performance of the judicial function and useful in the judicial
process," thereby qualifying as a "judicial document" for purposes of the first element of the Lugosch test. United
States V. Amodeo ("Amodeo "), 44 F.3d 141, 145 (2d Cir. 1995). Second, the Court assumes that the common law
presumption of access attaches, thereby satisfying the second element. But in balancing competing considerations
against the presumption of access, the Court finds that the arguments the Government has put forth-including,
most notably, the threat that public disclosure of the redacted sections would interfere with an ongoing grand jury
investigation-favor the Government's proposed narrowly tailored redactions.
In light of this ruling, the parties are hereby ORDERED to meet and confer with respect to proposed redactions to
the Defendant's reply letter, dated August 24, 2020 and the Defendant's August 24, 2020 letter addressing her
proposed redactions to the Defendant's August 17, 2020 letter motion. The parties are further ORDERED to submit
their proposed redactions no later than September 4, 2020; if the parties cannot agree on their proposed redactions,
they shall submit a joint letter to the Court explaining the nature of their dispute.
1
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reference, but not file, other discovery material that the Government produced in this case. For
the reasons that follow, Defendant's requests are DENIED.
Under Federal Rule of Criminal Procedure 16(d)(1), a Court may enter a protective order
only after it finds that good cause exists. Within this framework, the Federal Rules of Criminal
Procedure leave it to the discretion of the Court to determine whether modification of an existing
protective order is warranted.² To make that decision, the Court takes into account all relevant
factors, including the parties' reliance on the protective order and whether the moving party has
sufficiently substantiated a request to deviate from the status quo in the instant matter.
On July 30, 2020, this Court entered a protective order in this case, having determined
that good cause existed. Dkt. No. 36. The parties agreed that a protective order was warranted.
See Dkt. No. 35 at 1 ("The parties have met and conferred, resolving nearly all the issues relating
to the proposed protective order."). The Defendant's Proposed Protective Order included a
provision that stated that all discovery produced by the Government "[s]hall be used by the
Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and
not for any civil proceeding or any purpose other than the defense of this action." Dkt. No. 29,
Ex. A 1(a). That language was included in the Court's July 30, 2020 protective order. See Dkt.
No. 36 1(a), 10(a), 14(a). Shortly thereafter, the Government began to produce discovery.
Upon receipt of some of the discovery, the Defendant filed the instant request, which
seeks modification of the protective order in order to use documents produced in the criminal
2 In the civil context, there is a "strong presumption against the modification of a protective order." In re Teligent,
Inc., 640 F.3d 53, 59 (2d Cir. 2011) (citation omitted). Courts in the Second Circuit have applied the standard for
modification of protective orders in the civil context to the criminal context. See, e.g., United States V. Calderon,
No. 3:15-CR-25 (JCH), 2017 WL 6453344, at *2 (D. Conn. Dec. 1, 2017) (applying the civil standard for the
modification of a protective order in a criminal case); United States V. Kerik, No. 07-CR-1027 (LAP), 2014 WL
12710346 at *1 (S.D.N.Y. July 23, 2014) (same). See also United States V. Morales, 807 F.3d 717, 723 (5th Cir.
2015) (applying the standard for "good cause" in the civil context when evaluating whether to modify a protective
order entered in a criminal case); United States V. Wecht, 484 F.3d 194, 211 (3rd Cir. 2007) (same).
2
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=== Page 3 ===
case in other civil proceedings. She bases her request on the premise that disclosure of the
Documents to the relevant judicial officers is allegedly necessary to ensure the fair adjudication
of issues being litigated in those civil matters. But after fourteen single-spaced pages of heated
rhetoric, the Defendant proffers no more than vague, speculative, and conclusory assertions as to
why that is the case. She provides no coherent explanation of what argument she intends to
make before those courts that requires the presentation of the materials received in discovery in
this criminal matter under the existing terms of the protective order in this case. And she
furnishes no substantive explanation regarding the relevance of the Documents to decisions to be
made in those matters, let alone any explanation of why modifying the protective order in order
to allow such disclosure is necessary to ensure the fair adjudication of those matters. In sum, the
arguments the Defendant presents to the Court plainly fail to establish good cause. The
Defendant's request is DENIED on this basis.
Indeed, good cause for the requested modification of the protective order is further
lacking because, as far as this Court can discern, the facts she is interested in conveying to the
judicial decisionmakers in the Civil Cases are already publicly available, including in the
Government's docketed letter on this issue. See Dkt. No. 46. In the opening paragraph of her
reply letter dated August 24, 2020, the Defendant states that she is essentially seeking to disclose
under seal to certain judicial officers the following factual information:
1. Grand jury subpoenas were issued to an entity ("Recipient") after the Government
opened a grand jury investigation into Jeffrey Epstein and his possible co-
conspirators;
2. The Recipient concluded that it could not turn over materials responsive to the grand
jury subpoena absent a modification of the civil protective orders in the civil cases;
3
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3. In February 2019, the Government, ex parte and under seal, sought modification of
those civil protective orders so as to permit compliance with the criminal grand jury
subpoenas;
4. In April 2019, one court ("Court-1") permitted the modification and, subsequently,
another court ("Court-2") did not;
5. That as a result of the modification of the civil protective order by Court-1, the
Recipient turned over to the Government certain materials that had been covered by
the protective order; and
6. That the Defendant learned of this information (sealed by other courts) as a result of
Rule 16 discovery in this criminal matter.
With the exception of identifying the relevant judicial decision makers and specific civil
matters, all of the information listed above is available in the public record, including in the letter
filed on the public docket by the Government on this issue. See Dkt. No. 46. Although this
Court remains in the dark as to why this information will be relevant to those courts, so that
those courts can make their own determination, to the extent it would otherwise be prohibited by
the protective order in this matter, the Court hereby permits the defendant to provide to the
relevant courts under seal the above information, including the information identifying the
relevant judicial decision makers and civil matters.
In addition, the Government has indicated that "there is no impediment to counsel
making sealed applications to Court-1 and Court-2, respectively, to unseal the relevant
materials." Dkt. No. 46 at 3 n.5. In her reply, the Defendant asserts that she is amenable to such
a solution if the Court agrees with the Government that doing so would not contravene the
protective order in this case. To the extent it would otherwise be prohibited by the protective
4
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=== Page 5 ===
order in this matter, the Defendant may make unsealing applications to those Courts if she
wishes.
so ORDERED.
Alim D.Netto
Dated: September 2, 2020
New York, New York
ALISON J. NATHAN
United States District Judge
5
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=== Page 1 ===
From:
(USANYS)"
To:
,
(USANYS) [Contractor]"
Subject: RE: Conflict Check (2021 Annual Sweep)
Date: Thu, 23 Sep 2021 03:34:30 +0000
Attachments:
Here you go
From:
(USANYS) [Contractor]
Sent: Tuesday, September 21, 2021 4:59 PM
To:
(USANYS)
Subject: Conflict Check (2021 Annual Sweep)
Importance: High
Good afternoon,
asked me to help manage the Office's annual check for cases that might raise a conflict for a
supervisor. For example, you may be working on a case that involves ABC Corp.; and even though the case
would not create a conflict for you, if anybody in your line of supervision owns more than de minimis ABC
Corp. stock, that supervisor will have a conflict and we need to keep the case away from him or her.
Attached is a list of your cases and a list of the entities-corporations and law firms-that may create a conflict
for one of your supervisors. There is one list for the Crim Div and one list for the Civ Div.
If any of your cases involves one of those entities (other than routine subpoenas to banks and service providers),
please (using Adobe's Add Text functionality) type in the Asset ID code(s) for the pertinent entity(ies). Save and
return the form to me.
Negative responses are required.
Paralegal Specialist - Criminal Division
United States Attorney's Office
Southern District of New York
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=== Page 1 ===
Fact Witness Travel Request (Domestic Witness Travel)
AUSA, see instructions below.
To:
SDNY Victim/Witness Unit
From: AUSA
Date: November 9, 2021
Re:
United States V. Ghislaine Maxwell
Court Docket No: 20 Cr. 330 (AJN)
USAO No: 2018R01618
Witness Name:
Witness DOB:
(Name/DOB as printed here will be forwarded to travel agency and then to TSA and must exactly
match the witness's driver's license or other travel ID or TSA will not permit the witness to fly.)
Witness Address:
FL
Witness TelNos (mobile):
Witness e-mail:
Witness Needed to Appear in SDNY on
Date: December 2, 2021
Time: 12:30 PM
Witness Needed to Appear for:
Trial ( X)
Date: December 2, 2021 - December 3, 2021
Grand Jury ( )
Date:
Trial Prep ( )
Date:
Estimated Dates Witness will Arrive:
December 1, 2021 (evening)
Depart:
December 3, 2021 (evening)
Is the person a Fact Witness and not an Expert Witness?
(Yes/No):
Yes
Current Federal Civilian or Military Employee?
(Yes/No):
No
Is the Witness Facing Criminal Charges?
(Yes/No):
No
Does the Witness Reside Outside the Continental United States?
(Yes/No):
No
Is this Witness a Victim-Witness?
(Yes/No):
No
Hotel Required?
(Yes/No):
Yes
Has the Witness advised you of any unusual travel expenses?
(Yes/No):
No
Unusual expenses of fact witnesses can include
special travel arrangements
care for dependent child or incapacitated family member left at home
kennel fees for pets
rev. 2019.11.19
EFTA00027651

=== Page 2 ===
necessary travel companion
extra baggage (more than one bag)
Please describe the unusual expense:
For Victim-Witness Coordinator:
1. (For UEFW other than travel, which must be itemized and approved in advance:) This UEFW
is apparently within VWC approval authority and tentatively approved pending receipt(s) for
UEFW expenses (Yes/No):
2. Other VWC comments:
VWC Initials and Date:
Instructions to AUSA:
Use this form for all fact witnesses within the U.S. except government employees and military
personnel, for whom a Request for Armed Forces or Government-Employee Witness should
be used.
For foreign witnesses, use the International Witness Travel Request. Complete an Early or
Extended stay memo if the witness is being brought in more than 3 business days prior to
court/GJ testimony.
Witnesses may only be brought in under the FEWS appropriation for grand jury testimony that
has been scheduled and where the witness is expected to testify before the grand jury; court
testimony; or preparation for same. Any other witness travel, e.g., for investigative interviews,
must be covered by the investigating component from litigative funds. See
See generally DOJ Instruction 1300.01.01 (approved 9/28/2018) and sources referenced
therein.
rev. 2019.11.19
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=== Page 1 ===
From:
To:
Subject: RE: Draft RTC
Date: Fri, 20 Aug 2021 12:41:02 +0000
Attachments: Maxwell_RTC_v8.docx
Thanks! And really, no problem at all. I'm going to be on leave for the next two weeks, so I probably won't send your
comments to
until I'm back- - so no rush at all. I've attached the latest version, just so you have the most
recent one. Thank you so much for your help on this case!
I do know
- he's really fantastic. I used to work with him at Civil Appellate, and he's talked a lot about how great
his clerkship was. Small world!
From:
Sent: Friday, August 20, 2021 5:40 AM
To:
Subject: RE: Draft RTC
Got it, thank you. I'm so sorry for the delay in feedback. I did a quick scan a while back and thought it looked great, but
will do a closer read and get any comments to you by the end of next week (and you can blame me if you raise them with
the PC Chiefs!). Thanks for all of your great and hard work on this case.
P.S. Do you know
He asked me if I knew you a while ago, but I forgot to reach out about it.
and I both
clerked for the same judge. He is wonderful.
From:
Sent: Thursday, August 19, 2021 10:52 PM
To:
Subject: RE: Draft RTC
Hi
No problem. I sent it to the PC Chiefs yesterday, and it's headed to
after that. We aren't filing it until November,
though - we just want to have it out of the way, as we turn to MILs.
Thanks,
From:
Sent: Thursday, August 19, 2021 5:25 PM
To:
Subject: RE: Draft RTC
Thanks,
So sorry - could you please remind me when you're sending this to the PC Chiefs and when you're
supposed to file it? Thanks.
From:
Sent: Friday, August 6, 2021 7:29 PM
To:
Subject: FW: Draft RTC
EFTA00029163

=== Page 2 ===
Hi
I hope all's well! Draft RTC in Maxwell attached. The team is going to have comments, I'm sure, as will the chiefs. If you
like, I can send you wherever we land. And, of course, I'd welcome any comments you might have too, as an expert on
this.
Thanks
From:
Sent: Friday, August 6, 2021 7:28 PM
To:
Subject: Draft RTC
Hi all,
Attached is a draft RTC for your review. I've left in some comment bubbles to flag some of the judgment calls, and I'm
going to clean up the cites/do a citecheck.
Looking forward to your comments.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
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=== Page 1 ===
U.S. Department of Justice
Federal Bureau of Prisons
OPI: OGC
Program
NUMBER: 1210.21
DATE: 3/9/2000
SUBJECT: Boards of Inquiry and
Statement
Inquiry Teams
1. PURPOSE AND SCOPE. To establish procedures for the creation
and operations of Boards of Inquiry and Inquiry Teams to
investigate the facts and circumstances of any incident or
situation for such purposes as:
# ascertaining and reporting facts and circumstances,
# gathering and preserving evidence and records,
# determining the cause or causes, and
# recommending corrective steps as may be indicated in policy,
regulation, and practice.
Only the Director may create a Board of Inquiry, and only a
Regional Director or Warden (with Regional Director approval) may
create an Inquiry Team. The focus of a Board of Inquiry is to
determine the facts of an incident the Director deems significant
or unusual enough to warrant a special and higher level of
review.
When employee misconduct may have occurred, clearance must be
received from the Chief, Office of Internal Affairs (OIA), prior
to the appointment of any regional or local Inquiry Team. OIA
must investigate any incident when employee misconduct may have
occurred to ensure protection of employee rights and preservation
of evidence. To accomplish this objective, an OIA staff member
is to serve as a member of a Board of Inquiry when staff
misconduct may be involved.
Any allegations of violations of law must be reported by the
Bureau's Office of Internal Affairs, to the Department of
Justice, Office of the Inspector General (OIG) prior to the
creation of a Board of Inquiry or Inquiry Team.
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PS 1210.21
3/9/2000
Page 2
2. SUMMARY OF CHANGES. To include the requirement that Board of
Inquiry reports, or portions thereof, may have to be released
pursuant to a Freedom of Information Act (FOIA) request or
subpoena or produced in litigation.
3. PROGRAM OBJECTIVES. The expected results of this program
are:
a. Serious incidents, allegations of significant and far-
reaching breaches of policy, and allegations of misconduct will
be formally investigated.
b. Recommendations for corrective measures to improve
operations or avoid future incidents will be made.
C. The purpose, scope, and duration of each Board or Team will
be defined by the appointing authority.
d. A written report containing all pertinent findings and
recommendations will be made.
e. Appropriate records from each Board or Team will be
preserved.
4. STANDARDS REFERENCED
a. American Correctional Association 3rd Edition Standards for
Adult Correctional Institutions: None.
b. American Correctional Association 3rd Edition Standards for
Adult Local Detention Facilities: None.
C. American Correctional Association 2nd Edition Standards for
Administration of Correctional Agencies: None.
d. American Correctional Association Standards for Adult
Correctional Boot Camp Programs: None.
5. DIRECTIVES AFFECTED
a. Directive Rescinded
PS 1210.16
Boards of Inquiry and Inquiry Teams
(5/7/97)
EFTA00028724

=== Page 3 ===
PS 1210.21
3/9/2000
Page 3
b. Directives Referenced
PS 1210.17
Internal Affairs, Office of (8/4/97)
PS 1380.05
Special Investigative Supervisors Manual
(8/1/95)
PS 1600.08
Occupational Safety and Environmental Health
Manual (8/16/99)
6. RESPONSIBILITIES
a. Boards of Inquiry. The Director may appoint Boards of
Inquiry to investigate appropriate significant incidents in the
Bureau including, but not limited to:
#
allegations of significant breaches of policy, or
#
any other matter which reflects in a significant way
upon the Bureau's ability to carry out its mission.
The General Counsel may request that the Director appoint a
Board of Inquiry to investigate incidents or allegations that are
likely to result in litigation against the United States, the
Bureau, or one of its employees.
b. Regional Inquiry Teams. Regional Directors may appoint
Inquiry Teams to investigate incidents or allegations of
significant departure from policy or regulation within their
jurisdictions, or in any other instance when it would be in the
Bureau's best interest. An exception is a matter which is to be
investigated by a Board or Team appointed at a higher level.
Regional Counsel may request that the Regional Director appoint
an Inquiry Team to investigate incidents or allegations that are
likely to result in litigation against a Bureau institution or
employee under regional jurisdiction.
C. Local Inquiry Teams. Wardens, with the approval of the
Regional Director, may appoint a local Inquiry Team to
investigate incidents or allegations of significant departure
from policy or regulation at only that institution. For more
routine incidents requiring investigation, the Warden may not
appoint an Inquiry Team, but should assign staff such as an
Associate Warden, appropriate department head, or investigative
officer to investigate routine matters.
7. APPOINTMENT OF BOARDS AND TEAMS. The Director, Regional
Director, or Warden will notify in writing each person appointed
to serve as a member of the Board or Team as to:
EFTA00028725

=== Page 4 ===
PS 1210.21
3/9/2000
Page 4
# the purpose and scope of the inquiry,
#
the date the inquiry is to begin, and
# if appropriate, the date that a completed report is to be
furnished to the appointing official.
The written notification will indicate which member is to chair
the Board or Team.
The General Counsel or Regional Counsel will be consulted prior
to the creation of a Board or Team to determine whether the
appropriate legal office should initiate a request that a Board
or Team be appointed. Boards and Teams appointed at the request
of the General Counsel or Regional Counsel will include at least
one legal staff member.
a. Boards of Inquiry. In addition to Bureau staff, a Board of
Inquiry may also include non-Bureau personnel with expertise
relevant to the scope and purpose of the inquiry. An OIA staff
member is to serve as a member of a Board of Inquiry when staff
misconduct may be involved. The OIA will pay all expenses
incidental and necessary to the work of a Board of Inquiry.
b. Regional Inquiry Teams. To ensure objectivity, a regional
Inquiry Team should not consist of staff from only one
institution. The Team must be composed of personnel at the
department head level or above from any institution, any regional
office, or the Central Office. The regional office will bear all
expenses incurred (such as for travel).
C. Local Teams. A local Inquiry Team may consist of staff of
that institution at the Associate Warden and/or department head
levels. The institution will bear any expenses incurred.
d. OIA Assistance. When requested by a Regional Director,
Warden, or Inquiry Team Chair, the OIA will provide consultation
and other assistance to Boards and Teams as is necessary.
8. INSTRUCTIONS FOR ALL BOARDS AND TEAMS
a. Members must become familiar with Bureau directives
applicable to the matter being reviewed.
b. Members must review all written records, including
investigative reports, medical records, or other records
pertaining to the subject of the inquiry.
EFTA00028726

=== Page 5 ===
PS 1210.21
3/9/2000
Page 5
C. Members must visit the scene of an incident, reconstruct
the chain of events, and record their observations by notes,
photographs, audio or visual recordings, or other appropriate
means.
d. If, at any point during the inquiry, it becomes apparent
that serious criminal or administrative misconduct is involved,
OIA will be consulted to determine whether a referral to the
Office of the Inspector General or Civil Rights Division is
appropriate. If an OIA representative is not present, members
will contact the Chief, OIA, for advice before proceeding
further.
e. Members must interview witnesses or other persons having
knowledge of the incident, using the following procedures:
(1) Advise any person being interviewed of the purpose of
the interview, including the nature of the inquiry, and fully
identify all members present. An individual's right to
representation, if any, must be determined prior to the
interview. For bargaining unit members, union representational
rights will apply (see Employee Rights Article of Master
Agreement).
During the inquiry, witnesses or other persons having
knowledge of the incident must be instructed to keep all
information strictly confidential and instructed not to disclose
any information concerning the nature of the inquiry or the
information he or she has provided to anyone other than the Board
or Team, or to an appropriate union representative.
(2) If the inquiry develops information which focuses on
the person being questioned, or about to be questioned, as a
suspect in possible criminal misconduct, questioning of that
person may not proceed until the local U.S. Attorney:
# declines prosecution,
# grants use immunity, or
# recommends the interviewee be advised of his or her
Miranda Rights.
One of these conditions must be satisfied before questioning
a person suspected of possible criminal misconduct. These
contacts with the local U.S. Attorney will be coordinated through
OIA.
EFTA00028727

=== Page 6 ===
PS 1210.21
3/9/2000
Page 6
C. Members must visit the scene of an incident, reconstruct
statement. The witness will be permitted a reasonable
opportunity to prepare and review the statement before swearing
or affirming the truth of the statement. The Chair and members
will have authority to administer oaths or affirmations to
witnesses in accordance with 5 U.S.C. 303.
# For a written statement.
"I hereby declare (or certify, verify, or state) under
penalty of perjury that the foregoing is true and
correct."
# For an oral statement:
"I swear (or affirm) under penalty of perjury that the
statement I am about to make is true and correct."
(4) All employees may be required by Boards of Inquiry,
Regional Inquiry Teams, and local Inquiry Teams to answer
questions regarding their employment, even though their answers
may lead to disciplinary action up to and including removal;
however, in criminal cases, employees retain their constitutional
rights regarding avoidance of self-incrimination and may not be
disciplined for properly exercising these rights.
(5) Any visual or oral recordings made of interviews and
other proceedings will be preserved to allow a reasonable
opportunity for the resolution of any administrative review or
appeal related to the inquiry.
9. REPORTS
a. General. The Board or Team will prepare a detailed report
of its findings, including, if appropriate, recommendations. The
report must include all documents or records (or copies of them)
pertinent to the findings and recommendations. Any member of a
Board or Team may submit a separate or dissenting report.
b. Submission. The completed report, along with all working
notes and other personal records created by members as a result
of the inquiry, will be submitted to the official who appointed
the Board or Team, unless the appointing official had done so at
the request of the General Counsel or Regional Counsel. If the
Board or Team was appointed at the request of the General Counsel
or Regional Counsel, the completed report will be submitted
directly to the requesting Counsel.
EFTA00028728

=== Page 7 ===
PS 1210.21
3/9/2000
Page 7
If a report is submitted to an appointing official (rather than
to a requesting Counsel), three copies of the report will be
submitted through OIA for filing in the Director's Office, in the
Office of General Counsel, and in OIA.
C. Release of Findings or Reports. Findings or reports of all
Boards of Inquiry or Inquiry Teams will be released only upon the
Director's authorization in consultation with the General
Counsel. A Board of Inquiry report may be required to be
produced in connection with civil or criminal proceedings or a
FOIA request. A Board of Inquiry report may also be released in
connection with a Congressional inquiry.
If a subpoena or request for discovery is received in
connection with any civil or criminal proceeding that demands, or
reasonably could be construed as to demand, the production of a
Board of Inquiry report, and/or any working notes or personal
records created by members as a result of an inquiry, the
subpoena should be forwarded to the Regional Counsel who, after
consultation with the General Counsel and the Director, as
necessary, will coordinate the production of the documents or
assertion of any evidentiary privilege as appropriate with the
local U.S. Attorney's Office.
Findings or reports from Boards of Inquiry or Inquiry Teams
appointed at the request of the General Counsel or a Regional
Counsel prepared in anticipation of litigation or trial are to be
reviewed by the General Counsel before any release, since these
documents may be privileged documents protected from disclosure
by the attorney work-product privilege. The General Counsel will
make the determination of whether to assert this privilege.
/s/
Kathleen Hawk Sawyer
Director
EFTA00028729


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=== Page 1 ===
Event: Accepted: Conference: Jeffrey Epstein
Start Date: 2019-07-18 15:30:00 +0000
End Date: 2019-07-18 17:30:00 +0000
Location: Courtroom 17B, 500 Pearl
Class: X-PERSONAL
Comment:
Date Created: 2019-07-17 23:27:14 +0000
Date Modified: 2019-07-17 23:27:14 +0000
Priority: 5
DTSTAMP: 2019-07-17 18:04:24 +0000
Attendee:
)
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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 21:57:12 +0000
Great, thanks.
From:
Sent: Thursday, August 8, 2019 5:57 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: draft response to Epstein defense preservation requests
No problem, thanks, and the edits were all straightforward. Updated version attached, everything incorporated, and can
go to
- I'm out of commission the next couple hours but back after that.
thanks,
From:
(USANYS)
Sent: Thursday, August 08, 2019 16:36
To:
)
is
(USANYS)
Cc:
is
)
Subject: RE: draft response to Epstein defense preservation requests
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:
is
)
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)
is
(USANYS)
Cc:
is
)
Subject: RE: draft response to Epstein defense preservation requests
EFTA00027230

=== Page 2 ===
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
EFTA00027231


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
Subject: RE: Epstein meeting
Date: Mon, 10 Jun 2019 17:35:03 +0000
Importance: Normal
Yes, please book it.
From:
(USANYS)
Sent: Monday, June 10, 2019 1:24 PM
To:
(USANYS) [Contractor]
Subject: RE: Epstein meeting
1 tomorrow works - let me know if we should book it.
From:
(USANYS) [Contractor]
Sent: Monday, June 10, 2019 11:49 AM
To:
(USANYS)
Subject: Epstein meeting
Hey
Exec would like to get an Epstein meeting on the calendar tomorrow. Would noon, 1, or 3pm work? And if there are any
written materials that will be referenced, please send those over in advance.
Thanks very much,
0
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=== Page 1 ===
From: Bruce Barket
To:
Cc: Aida Leisenring
Tony Ricco
BRUCE
KOFFSKY
John Diaz
Subject: Re: New mcc problems
Date: Fri, 17 Jan 2020 17:07:05 +0000
Thank you for the quick reply. I understand your position regarding communicating with all counsel of record. I
assume that means your office won't be having separate communications (written or oral) with just appointed
counsel.
1. As I indicated, we will be filing a motion asking for an order allowing inspection of the location our client has
been detained for what will likely be 4 years by the time the case is tried. Being able to present mitigating
evidence to prevent Nick's execution is a "specific and pressing reason," at least in our view. We are happy to
work with the BOP on reasonable conditions for the visit.
2. I will wait to hear from her. Thanks for helping to move this alone.
3. Thank you for the update on the hearing situation. I appreciate it. Knowing what the current situation is
matters as does being to able to report back to the clients who brought the problem to my attention.
4. This is a bit of a problem. I have been writing these emails since August. I do not think I should have to spell
out how a requested visit helps in the preparation of the defense or how it will help our mitigation case. The
tension between having a record made justifying the exception against our right not to spell out the details of our
strategy was address back in August during a call that included
At that time we
reached an agreement and we haven't had a problem until now. The requests have been no more than once a
month or so and usually around court dates. We don't want to add to our workload or yours, but we can't have
our client go months without seeing family as we prepare for a death penalty trial. Nor can provide the new level
of detail being sought. Any further help you can provide would greatly appreciate.
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country road
Garden City, NY 11530
Barket Epstein.com
> On Jan 17, 2020, at 11:27 AM,
wrote:
V
> Bruce,
V
> Thanks for raising these issues with us in advance of the conference. We appreciate the opportunity to try and
address them with MCC in advance. Below are responses based on our conversation with
and
we have copied all counsel because until Judge Karas instructs us otherwise, we intend to communicate with all
counsel of record.
V
> 1 -
has advised us that allowing a tour of this kind is a security risk for the institution because, among
other things, you have asked to tour areas where many inmates will be, and the institution cannot be locked down
EFTA00028448

=== Page 2 ===
for purposes of an outside person taking a tour absent a very specific and pressing reason.
also advised
that were the Court to order such a tour, MCC would set very specific conditions and ask that the Government
also be present.
>
> 2-
has advised that she is working with SIS to get a date and time for the inspection of physical
evidence, and hopefully will be reaching out today to schedule the inspection.
>
> 3 -
has advised that upon receiving your email, she had her staff speak with
about the
heat. The staff took heat reports in the unit and found the temperature was high. The staff made adjustments and
there have not been complaints since. We have asked for another temperature reading to be taken in the unit
before Wednesday's conference to ensure the temperature is at an acceptable level.
>
>4-
has advised that she asked you for additional information that she can discuss with the Warden in
order to assess the request for a family visit, but has not heard back from you. As previously discussed, in order
for the MCC to make an exception for your client, a social visit must be necessary for preparation of the defense.
The Government is not trying to, nor does it want to be, in the middle of that assessment, but we understand
from the MCC that your most recent request was conclusory and they need more detail to make an assessment of
this new request.
>
>
>
Co-Chief, Narcotics Unit
>
>
>
Original Message
> From: Bruce Barket
> Sent: Thursday, January 16, 2020 11:43 AM
> To:
> Cc: Aida Leisenring
> Subject: New mcc problems
>
> In case we don't have enough to do on the 22nd, I intend to raise several issues about the jail. In no particular
order;
V
> 1. They are refusing to allow us to view the cells and common areas where Nick has been held for nearly 3
years. Initially, we were told we would be permitted and that photographs would be taken and reviewed by the
staff. We are going to file a motion to compel before the 22nd.
V
> 2. I have written multiple emails to
asking for an opportunity to view the physical evidence for the July
23rd suicide attempt. She has thus not responded at all
V
> 3. We wrote complaining about multiple reports of extreme heat on the tier. One or two inmates had to be
hospitalized. We have not been given an update.
V
>4. We asked for a family visit after next week's court appearance and gave the same reasons we have been
giving. This time we were asked for more detail. I sense a change in the mcc approach. My inclination is to ask
the judge to help here.
V
> I was hoping the new administration would improve the conditions while maintaining
responsiveness.
V
> Bruce Barket
> Barket, Epstein, Kearon, Aldea & LoTurco
> 666 Old Country road
EFTA00028449

=== Page 3 ===
> Garden City, NY 11530
> Barket Epstein.com
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=== Page 1 ===
AO 106 (SDNY Rev. 01/17) Application for a Search Warrant
UNITED STATES DISTRICT COURT
for the
19MAG
6573
Southern District of New York
In the Matter of the Search of
(Briefly describe the property to be searched
or identify the person by name and address)
Case No.
See Attached Affidavit and its Attachment A
APPLICATION FOR A SEARCH AND SEIZURE WARRANT
I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):
located in the
Southern
District of
New York
, there is now concealed (identify the
person or describe the property to be seized):
See Attached Affidavit and its Attachment A
The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
evidence of a crime;
contraband, fruits of crime, or other items illegally possessed;
property designed for use, intended for use, or used in committing a crime;
a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section(s)
Offense Description(s)
18 U.S.C. §§ 1591 and
Sex trafficking of minors; sex trafficking conspiracy
371
The application is based on these facts:
See Attached Affidavit and its Attachment A
Continued on the attached sheet.
Delayed notice of
days (give exact ending date if more than 30 days:
) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.
Applicant's signature
Special Agent
, FBI
Printed name and title
Sworn to before me and signed in my presence.
Date:
7.6.19
Boberdens Judge signature
City and state: New York, NY
Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and title
EFTA00028499

=== Page 2 ===
19MAG
6573
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In the Matter of the Application of the United
TO BE FILED UNDER SEAL
States Of America for a Search and Seizure
Warrant for the Premises Known and Described
Agent Affidavit in Support of
as 9 East 71st Street, New York, New York and
Application for Search and Seizure
Any Closed Containers/Items Contained Therein
Warrant
SOUTHERN DISTRICT OF NEW YORK) SS.:
,
being duly sworn, deposes and says:
I. Introduction
A. Affiant
1.
I have been a Special Agent with the Federal Bureau of Investigation ("FBI") since
2017. During that time, I have participated in numerous investigations and prosecutions of crimes
against children, including the sex trafficking of minors. I have also participated in the execution
of multiple search warrants.
2.
I make this Affidavit in support of an application pursuant to Rule 41 of the Federal
Rules of Criminal Procedure for a warrant to search the premises specified below (the "Subject
Premises") for the purpose of photographing, video-recording or otherwise documenting the
appearance of its interior, and to seize the items and information described in Attachment A. This
affidavit is based upon my personal knowledge; my review of documents and other evidence; and
my conversations with other law enforcement personnel. Because this affidavit is being submitted
for the limited purpose of establishing probable cause, it does not include all the facts that I have
learned during the course of my investigation. Where the contents of documents and the actions,
statements, and conversations of others are reported herein, they are reported in substance and in
part, except where otherwise indicated.
1
2017.08.02
EFTA00028500

=== Page 3 ===
B. The Subject Premises
3.
The Subject Premises are particularly described as a nearly 19,000 square foot
multi-story, single-family residence located at
New York, New York, and
include all locked and closed containers found therein. As detailed further herein, the Subject
Premises is believed to be owned, possessed and controlled by JEFFREY EPSTEIN, a target
subject of this investigation. A photograph of the front entrance to the Subject Premises is included
below:
Google
C. The Target Subject and the Subject Offenses
4.
The Target Subject of this investigation is JEFFREY EPSTEIN.
5.
For the reasons detailed below, I believe that there is probable cause to believe that
the Subject Premises contain evidence, fruits, and instrumentalities of violations of Title 18, United
States Code, Section 1591 (sex trafficking of minors) and Title 18, United States Code, Section
371 (sex trafficking conspiracy) (the "Subject Offenses") by the Target Subject.
2
2017.08.02
EFTA00028501

=== Page 4 ===
II. Probable Cause
A. Probable Cause Regarding the Target Subject's Commission of the
Subject Offenses
6.
On or about July 2, 2019, a grand jury in this District returned an Indictment
charging JEFFREY EPSTEIN with the Subject Offenses. A copy of the Indictment is attached
hereto as Exhibit A and is incorporated by reference.
B. Probable Cause Justifying Search of the Subject Premises
7.
As set forth in Exhibit A, from at least in or about 2002, up to and including at least
in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in the Southern
District of New York and elsewhere. During that time and continuing to the present, EPSTEIN
possessed and controlled the Subject Premises, which is described in Exhibit A as "the New York
Residence."
8.
As further set forth in paragraphs 8 through 10 of Exhibit A, from at least in or
about 2002, up to and including at least in or about 2005, EPSTEIN sexually abused numerous
minor victims at the Subject Premises. In particular, and as alleged in the Indictment, when a
victim arrived at the Subject Premises, she would be escorted to a room inside the Subject Premises
with a massage table, where she would perform a massage on EPSTEIN. 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 victims' 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. Following each encounter, EPSTEIN
or one of his employees or associates paid the victim in cash.
3
2017.08.02
EFTA00028502

=== Page 5 ===
9.
As set forth in paragraphs 12 through 13 of Exhibit A, 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 minor girls to perform "massages" and similarly engage in sex
acts with EPSTEIN. When a victim would recruit another minor girl for EPSTEIN, he paid both
the victim-recruiter and the new victim hundreds of dollars in cash. EPSTEIN knew that his
victims were underage, including because certain victims told him their age.
10.
One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of
the FBI's investigation of EPSTEIN, other law enforcement officers and I have interviewed
Victim-1. I know from my personal participation of interviews with Victim-1, my conversations
with other law enforcement officers who have interviewed Victim-1, and my review of notes and
reports of other interviews with Victim-1 that Victim-1 has provided the following information, in
substance and in part:
a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-1 on
multiple occasions in the Subject Premises. This sexual abuse all occurred when Victim-1 was
under the age of 18.
b. During that same period, Victim-1 observed multiple floors of the Subject Premises
and numerous individual rooms within the Subject Premises. Victim-1 has provided detailed
descriptions of certain aspects of the interior of the Subject Premises, including Victim-1's
1 In meetings with the Government, Victim-1 has disclosed that, approximately a decade ago, she
committed marriage fraud in order to obtain a green card and, subsequently, U.S. citizenship. She
has also disclosed personal substance abuse, primarily involving the abuse of prescription drugs,
during various periods between the early 2000s and 2019. Victim-1 has also disclosed having
worked for approximately a year at a "happy-ending" massage parlor, performing paid sex acts.
Victim-1 is currently pursuing a civil damages claim against EPSTEIN for his sexual abuse of her.
Information provided by Victim-1 has proven reliable and has been corroborated by independent
evidence, including documents and records obtained during the investigation and the accounts of
other victims whom Victim-1 has never met.
4
2017.08.02
EFTA00028503

=== Page 6 ===
memory of specific details regarding the layout, furnishings, decorations, and floor pattern of
various areas within the Subject Premises.
11.
I know from my review of publicly available corporate and property records that at
all times relevant to the Subject Offenses as alleged in the Indictment, the Subject Premises was
owned by Nine East 71st Street Corporation (the "Corporation"). The President of the Corporation
is listed as JEFFREY EPSTEIN, and no other officers or occupants are identified on the
Corporation paperwork. In or around December 2011, the Subject Premises was transferred from
the Corporation to another corporate entity, Maple, Inc., which is registered in the U.S. Virgin
Islands, where EPSTEIN was then known to and continues to reside. Though no officer of Maple,
Inc., is identified in the transfer paperwork, the signature of both the buyer and seller in the
transaction appear to be the same. Moreover, the deed lists the consideration for the transfer of
the Subject Premises as $10, an amount facially inconsistent with a fair market transfer to a third
party.
12.
I know from my participation in this investigation that EPSTEIN has continued to
possess and control the Subject Premises from at least in or about 2002 to the present. In particular,
I know from my review of Sex Offender Registration records that EPSTEIN presently lists the
Subject Premises as one of his residences. Moreover, as described in paragraph 11, above,
although ownership of Subject Premises was transferred from one corporate entity to another in
December 2011, both corporations appear to be under EPSTEIN's control, and EPSTEIN appears
to remain the sole owner and occupant of the Subject Premises.
13.
Additionally, although Victim-1 has not been in the Subject Premises since in or
around 2005, based on my review of publicly available records maintained by the New York City
Department of Buildings ("DOB"), it does not appear that there have been any significant or
5
2017.08.02
EFTA00028504

=== Page 7 ===
structural renovations to the interior of the Subject Premises since that time. In particular, the
DOB reflects only three approved alteration permits for the Subject Premises, one in or around
2011 which authorized façade restoration but expressly noted that there would be "no change to
occupancy, use egress or bulk," and two permitting the "installation of heavy duty sidewalk shed"
outside of the Subject Premises at various points, but similarly noting that there would be "no
changes in use, egress or occupancy." As such, while it is possible that certain interior decorations
have changed since 2005, it is probable that structural components of the interior, such as
Victim-1's description of the layout of rooms and floors, among other details, would remain the
same.
6
2017.08.02
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=== Page 8 ===
III. Conclusion and Ancillary Provisions
14.
Based on the foregoing, I respectfully submit that there is probable cause to believe
that photographing, video-recording, and otherwise documenting the appearance of the interior of
the Subject Premises, and seizing the items described in Attachment A, will yield evidence of the
Subject Offenses. In particular, evidence depicting the interior of the Subject Premises and
reflecting the occupancy, ownership, layout, furnishings, decorations, and floor pattern of the
Subject Premises will corroborate Victim-1's account of EPSTEIN's commission of the Subject
Offenses. I further submit that there is probable cause to believe that such evidence will be located
within the Subject Premises and therefore request the court to issue a warrant to seize the items
and information specified in Attachment A to this affidavit and to the Search and Seizure Warrant.
Special Agent
Federal Bureau of Investigation
Sworn to before me on
July BoboRths 6, 2019
THE HONORABLE BARBARA MOSES
UNITED STATES MAGISTRATE JUDGE
7
2017.08.02
EFTA00028506

=== Page 9 ===
ATTACHMENT A
I. Premises to be Searched-Subject Premises
1.
The premises to be searched (the "Subject Premises") are described as a nearly
19,000 square foot multi-story single-family residence located at 9 East 71st Street, New York,
New York, and include all locked and closed containers found therein. A photograph of the front
entrance to the Subject Premises is included below:
Google
II. Items to Be Seized
1. This warrant authorizes executing agents to photograph, video record and otherwise
document the full interior of the Subject Premises, including any items, furnishings, or possessions
therein.
2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows:
a. Evidence concerning occupancy or ownership of the Subject Premises,
including utility and telephone bills, mail envelopes, addressed correspondence,
diaries, statements, identification documents, address books, telephone
directories, and photographs of its occupant(s).
b. Evidence concerning the layout, furnishings, decorations, and floor pattern of
the Subject Premises, including photographs and blueprints of the Subject
Premises.
2017.08.02
EFTA00028507

=== Page 10 ===
EXHIBIT A
8
2017.08.02
EFTA00028508

=== Page 11 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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
EFTA00028509

=== Page 12 ===
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
EFTA00028510

=== Page 13 ===
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
EFTA00028511

=== Page 14 ===
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
EFTA00028512

=== Page 15 ===
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
EFTA00028513

=== Page 16 ===
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
EFTA00028514

=== Page 17 ===
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
EFTA00028515

=== Page 18 ===
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
EFTA00028516

=== Page 19 ===
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
EFTA00028517

=== Page 20 ===
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
EFTA00028518

=== Page 21 ===
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
EFTA00028519

=== Page 22 ===
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
EFTA00028520

=== Page 23 ===
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 & Bum
FOREPERSON
GEOFFREY S. BERMAN
United States Attorney
13
EFTA00028521

=== Page 24 ===
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
EFTA00028522


c1: EFTA00027775
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027775.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: NDGA filings
Date: Tue, 14 May 2019 20:34:22 +0000
Importance: Normal
Attachments: SDFL_NDGA_proposal,_May_10.pdf;SDFL_petitioners _proposal,_May_10.pdf;
SDFL_order,_May_13.pdf
Assistant U.S. Attorney
Southern District of New York
EFTA00027775


c1: EFTA00028607
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028607.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Date: Fri, 14 May 2021 14:52:54 +0000
Jeff,
Thanks very much for the quick response. Hope you have a nice weekend-
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, May 14, 2021 10:50 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
I just reached out to Interlochen and they do not have a color version.
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, May 14, 2021 at 10:38 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Received, thanks very much Jeff. Do you have a color copy of the photograph on page 87?
Best,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, May 13, 2021 4:41 PM
EFTA00028607

=== Page 2 ===
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Attached is what went in the mail today.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Wednesday, May 12, 2021 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on this.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Monday, April 26, 2021 10:32 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm working on it and hope to have it complete and ready in the next couple of days.
Thanks,
Jeff
EFTA00028608

=== Page 3 ===
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, April 26, 2021 at 9:28 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Could you please let us know when you expect to produce these materials?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, March 26, 2021 5:33 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Just confirming receipt. Also, I'm hopeful that we can have everything gathered by April 12th. However, I'll be out of the
office for the next week so it might be delayed. Will that be a problem?
In addition, and just for confirmation's sake, you are ok that we will make reasonable efforts to notify the
parents/students of the subpoena prior to compliance with the subpoena correct?
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
EFTA00028609

=== Page 4 ===
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, March 26, 2021 at 3:37 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
Thanks again for taking the time to speak with me this morning. As we discussed, I'm attaching a subpoena for additional
student records.
Thank you,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Sounds good. Yes, that is the best number.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 4:40 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
EFTA00028610

=== Page 5 ===
Thanks so much-let's plan to talk at 9:30 tomorrow morning, if that works for you. Is this the best number to reach you
then: 231-947-0400
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:32 PM
To:
)
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm available between 9am and 10am, and then again after 11am.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 3:41 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Are you available for a quick call tomorrow morning?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, January 7, 2021 11:10 AM
To:
Cc:
)
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
EFTA00028611

=== Page 6 ===
231-947-0400
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, January 7, 2021 at 10:37 AM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff- what is the best number to reach you this morning? Thanks.
Sent from my iPhone
On Jan 5, 2021, at 3:21 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me.
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
II
)"
Date: Monday, January 4, 2021 at 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
EFTA00028612

=== Page 7 ===
Subject: Re: Subpoena to Interlochen Center for the Arts
That would be great, thanks. Would Thursday at 11:30 work for you?
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Sure. Does Wednesday or Thursday morning work?
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Are you available for a call sometime in the next few weeks? We have one or two follow up
questions that would be helpful to talk through.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, December 30, 2020 2:37 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Sorry about the delay. Interlochen doesn't have any other documents regarding tuition payment information or
payments by Epstein or Epstein entities.
Let me know if you have any other questions.
EFTA00028613

=== Page 8 ===
Thanks,
Jeff Jocks
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
From:
Sent: Monday, November 16, 2020 3:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
is
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. I'm following up on our conversation from earlier this month to see if you have any updates on
the categories of documents we discussed.
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 11:15 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
That works for me. I will call in at 10am Monday.
EFTA00028614

=== Page 9 ===
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line:
Thanks,
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi Maurene -
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
EFTA00028615

=== Page 10 ===
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
II
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still
be grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
EFTA00028616

=== Page 11 ===
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or
determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com>, "Donnini, George B." <donnini@butzel.com>
Cc:
)"
i
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would
you please confirm that your production included all records of any tuition payments that Epstein (or his entities)
made for any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow
and will have limited availability this week, but my colleagues
and
(both cc'd) should be
able to coordinate with you as needed.
EFTA00028617

=== Page 12 ===
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
>
Cc:
is
Subject: Re: Subpoena to Interlochen Center for the Arts
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
i
)"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey
Epstein and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request
confidential.
EFTA00028618

=== Page 13 ===
Please let me know if you have any questions or would like to discuss further.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00028619


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=== Page 1 ===
From:
To:
Subject: RE: United States V. Ghislaine Maxwell
opens
Date: Mon, 29 Nov 2021 01:55:18 +0000
Thanks
!
From:
Sent: Sundav. November 28. 2021 10:27 AM
To:
Subject: FW: United States V. Ghislaine Maxwell
ens
Good luck, team!
From:
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS
>; USANYS-CRIMINAL PARALEGALS
>; USANYS-INVESTIGATORS
Cc:
Subject: United States V. Ghislaine Maxwell --
opens
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors will
do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine Maxwell
sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York. NY 10007
EFTA00029426


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=== Page 1 ===
From:
"
(USANYS) [Contractor]"
To:
)"
)"
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: Four more women accused of supplying young girls for Epstein to abuse
Date: Sun, 12 Jul 2020 23:37:40 +0000
FYI. This story in the Daily Mail today cites a Sunday Telegram story that says four other women are under
investigation for aiding Maxwell and Epstein.
https://www.dailymail.co.uk/news/article-8513823/Four-women-accused-supplying-young-girls-Epstein-
abuse.html
Chief Public Information Officer
U.S. Attorney's Office, SDNY
)
(cell)
EFTA00027462


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c3: VOL00008
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c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
(USANYS)"
,
(USANYS)"
Subject: RE: Jeffrey Epstein/FOIA matters
Date: Fri, 12 Mar 2021 16:22:49 +0000
Thanks,
Much appreciated.
From:
(USANYS)
Sent: Friday, March 12, 2021 11:18 AM
To:
Cc:
is
(USANYS)
is
(USANYS)
Subject: Re: Jeffrey Epstein/FOIA matters
Hi
I am copying
who is handling the main matter before Judge Engelmayer and who likely would
know if there are related FOIAs. I will also ask our civil clerk.
Sent from my iPhone
On Mar 12, 2021, at 10:59 AM,
)
wrote:
Hi
In connection with a criminal discovery matter,
and
and I are trying to find a list of all Jeffrey Epstein-
related FOIA lawsuits that the Civil Division has handled (either pending or historical). Our chiefs suggested that you
might be able to help us generate that list - if you have any guidance or information on how we could track this down,
we'd really appreciate your help. Or if there's someone else we should reach out to in the Civil Division instead, please
let us know.
Thanks so much-
Assistant United States Attorney
Southern District of New York
EFTA00028848


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=== Page 1 ===
From:
(USANYS)"
To:
Cc:
(USANYS) [Contractor]"
Subject: Fwd: Request for Comment
Date: Thu, 21 Oct 2021 15:54:12 +0000
Monique:
forwarded your query regarding a motion filed by Ghislaine Maxwell's counsel. As you might
anticipate, we will decline to comment on any pending litigation, and in any event, as a matter of office policy, prosecutors
in our office do not respond to media inquiries, on the record, on background, or off the record. Please direct any further
inquiries to me or my colleague,
Cc'd here.
Best,
Spokesman
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I Mobile:
I
Press Office:
EFTA00027707


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: travel approval request
Date: Tue, 28 May 2019 14:18:24 +0000
Importance: High
Good morning all,
clarified that the San Francisco trip below was actually a personal trip. He is asking about receiving a credit
card refund for cancelling his San Francisco trip due to a work-related business trip occurring the same day. Would he be
able to receive reimbursement for the $100 cancellation fee he received?
If possible, would I need to fill out a SF-1164 to process his reimbursement, or is there another form I would need to fill
out? Any info on how to proceed is appreciated. Thanks as always!
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Tuesday, May 28, 2019 9:49 AM
To:
Subject: RE: travel approval request
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, l'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-I'm sorry about that!).
EFTA00028675

=== Page 2 ===
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.
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
EFTA00028676

=== Page 3 ===
To:
Cc:
>;
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.
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:
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.
EFTA00028677

=== Page 4 ===
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
EFTA00028678


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein FOIA
Date: Thu, 01 Jul 2021 17:16:41 +0000
All,
FYI,
just called from Main (I believe she's still at Fed Programs). She said there was interest from the AG's
Office in the release and had some questions. We talked through things, and she said she'd carry the info back. She said
she or someone else from DC might follow up.
Thanks,
Subject: Epstein FOIA
Morning. Just for your awareness, I got a call regarding the FOIA litigation from one of our press counterparts at Main.
She asked if it would be okay to refer press inquiries to SDNY, I told her it wasn't a problem. Other than process
questions,
and I anticipate declining to comment anyway.
Do we have a sense of timing as to when this will happen? (I was having a hard time hearing during the call, but my
impression was tomorrow and it would be voluminous and take the Times a while to get through?) Thanks.
Spokesman
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
EFTA00029454


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: docketing today
Date: Mon, 08 Nov 2021 14:57:33 +0000
Attachments: 2021.11.08,_GM,_bail_opposition.docx
Thanks, I saw the preliminary instructions letter on the shared (attached). If everyone is ok with this, I can file to take
something off your plate. If you can send me the final bail letter, I'm happy to handle filing if that's helpful.
From:
Sent: Monday, November 8, 2021 9:54 AM
To:
Cc:
Subject: Re: docketing today
I already cite checked the bail opp and wrote the letter re prelim voir dire instructions (will circulate). I can handle
docketing later. Just waiting on feedback from
on BOP letters. Do you think I need to send to
from the
marshals?
On Nov 8, 2021, at 9:38 AM,
wrote:
(And also the two BOP letters).
From:
Sent: Monday, November 8, 2021 9:36 AM
To:
is
V.
Subject: docketing today
Team,
We have three things due today: (1) the bail opposition, (2) the letter saying we don't object to preliminary instructions,
and (3) Daubert. Looks like items 1 and 2 are done, so when we talk this morning let's discuss a timetable for getting
stuff docketed. I think
and I should probably handle 1 and 2, since
have a packed Daubert
evening, but let's coordinate.
Thanks!
Assistant United States Attorney
Southern District of New York
EFTA00028214


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=== Page 1 ===
From:
To:
Cc:
Subject: STAMPED NDO's & PEN's
Date: Fri, 19 Jun 2020 19:33:34 +0000
Attachments:
-_AT&T.pdf
Hello,
Attached hereto are your NDO's & PEN's that were submitted to Mag Court which are now stamped and signed.
Thank you,
Legal Assistant - Criminal Clerk
United States Attorney's Office
Southern District of New York
New York, New York 10007
Telephone:
Cell Phone:
Fax:
EFTA00028562


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=== Page 1 ===
From:
To:
Subject:
Notes from 2/1/21 Call with Dr. Lisa Rocchio
Date:
Monday, February 1, 2021 1:40:40 PM
2/1/21
Dr. Rocchio has not treated any victims of JE or been involved in any JE litigation
Has not spoken publicly regarding JE or anything related to his case
Forensic and clinical psychologist
Independent group psychotherapy practice for over 20 years; in addition to providing
psychotherapy, also has done legal consultation; forensic evaluations; expert testimony in
both civil and criminal matters
Most legal work involved some type of traumatic stress; in criminal arena, done battered
women homicide cases; sometimes asked to opine on ways that violence in relationship
might have impacted someone's behavior at time of crime (e.g., coercion)
In civil space, have evaluated numerous victims of sex abuse, typically by people in authority
positions; both plaintiff and defense
Has done some Title IX work for colleges consulting with both college attorneys and defense
attorneys
Involved in American Psychological Association and Rhode Island Psychological Association
Treat clients for anxiety, depression, grief; also treats adults abused as kids; do work for
PTSD first responders; workers comp cases
Doctorate at URI; clinical internship at Yale; post-doctorally worked in RI;
Clinical supervisor and instructor at Brown University school of medicine providing training
for psychology residents
Recently testified in criminal trial in Massachusetts last year; only testified twice (only
transcript for Mass. case; prior one was in rural courtroom that was not transcribed, about
20 years ago); has also been deposed
Child sexual abuse - grooming: expertise with victims; in many forensic reports, particularly
in civil arena, explain and describe grooming and offer examples of grooming process and
how perpetrators target someone with prior vulnerabilities and exploit slowly overtime to
build trust and attachment; someone could have a lot of prior vulnerabilities and might draw
conclusion that current difficulties as adult are substantially related to child sex abuse;
nature of betrayal and attachments
Delayed reporting: often common for number of reasons; sometimes people don't
conceptualize relationship as abusive, may feel loved, may not understand being abused or
exploited, may be shame or guilt; especially now, people aware that reporting is fraught with
pain and hassle for victim; afraid won't be believed and personal life will be on display;
sometimes too traumatized and think can't go through with it; number of factors that
contribute to when report; if someone has had multiple experiences of not being supported
by people who are supposed to take care of them, then why would they believe that
reaching out to someone would be helpful for them if they even realize that they are in need
of help
3502-001
Page 1 of 3
EFTA00027410

=== Page 2 ===
Trauma bonding: not phrase Dr. Rocchio uses; use the word attachment instead of bonding
but is same concept
In case testified about intimate partner violence, explained that intimate partner
violence is relationship where primary dynamic is one of coercive control and power
maintained by acts of sexual, physical, psychological abuse; abusive interactions
interspersed with neutral and positive interactions, which function to maintain the
connection and increase dependency and increase power and control of perpetrator
in intimate partner violence and child sexual abuse, great deal of dependency, even
love and affection; use psychological tools (e.g., disassociation, denial) to try to block
it/push away
to develop and grow kids need physical attention and contact, someone to think they
are special; if perpetrator exploits that and gives child what need, children are
resilient; creates trauma bond and interdependency
When someone is underage, child sexual abuse; can involve forcible rape but more typically
one of coercion and attachment; have worked with rape survivors who are victims of more
forcible attack as well as ongoing abuse
Complex trauma is repeated exploitation/abuse/violence/acts of omission and commission
during developmentally vulnerable period of child's life; separate from PTSD (e.g., single
incident rape); has experience in both
Incremental disclosure is very common; know memory is not video tape; whatever details
are most salient and relevant to victim tend to be ones that get encoded, and then what gets
moved into storage; details may blur together, but basic concept of what happened in most
cases is remembered
Extraneous details often are not; would not expect traumatic memory to always be
presented in same way with same detail each time; look for generally consistent
detail
Incremental disclosure as start to reveal memories; sometimes become more
comfortable and sometimes sparks more memories; psychological and memory
process; know from research on memory of cases where people can have entire
episodes of life and childhood that don't recall; people can have memories of things
that did not happen but much less common
Experience with teenage child sexual abuse in forensic space; both boy and girl victims
Clinically have worked with people whose mothers were sexually abusive either
independently or in conjunction with fathers; don't think has worked on forensic case where
there has been a woman perpetrator of sexual abuse; literature is clear that women can be
perpetrators of abuse
In clinical realm, if father sexually abused kid, mom who is not participating is non-offending
parent; if both involved, they are both perpetrators; involvement in facilitating is still
perpetrating behavior
Dr. Rocchio will let AUSAs know if JE victims reach out to Dr. Rocchio to assist in civil
litigation
Will try to find out if judge was asked to rule if testified as expert for any of her depositions
Assistant United States Attorney
3502-001
Page 2 of 3
EFTA00027411

=== Page 3 ===
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
3502-001
Page 3 of 3
EFTA00027412


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=== Page 1 ===
Exhibit A
EFTA00028103

=== Page 2 ===
CG
S00 Third Avenue
COHEN & GRESSER LLP
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
Christian R. Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
August 30, 2021
BY FIRST CLASS MAIL
Mr. Kenneth A. Polite, Jr.
Assistant Attorney General
Criminal Division
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, D.C. 20530-0001
Re: United States V. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Assistant Attorney General Polite:
We represent the defendant, Ghislaine Maxwell, in the above-referenced matter. This
letter constitutes a request made pursuant to United States ex. Rel. Touhy V. Regan, 340 U.S. 462
(1951), for the testimony of (1) FBI Special Agent
, (2) FBI Special
Agent
, (3) FBI Special Agent
, and (4) Task Force Officer,
Detective
at the trial in this case on November 29, 2019 at 9:00 A.M., before the
Honorable Alison J. Nathan, United States District Judge.
In accordance with 28 C.F.R. § 16.23(c), we make the following statement setting forth a
summary of the testimony we seek:
were co-case agents in charge of an investigation
into allegations of sexual abuse by Jeffrey Epstein conducted by the Palm Beach
FBI and the U.S. Attorney's Office for the Southern District of Florida from
approximately July 2006 to June 2008. We request testimony from
and
concerning the scope, timeline, and resolution of the investigation, as
well as the various investigative steps taken by the agents, including but not limited
to testimony about numerous witness interviews they conducted, physical evidence
they reviewed, documents they obtained by subpoena, and their testimony before
the grand jury.
and
are the co-case agents in charge of the current
investigation being conducted by the New York FBI and the U.S. Attorney's Office
for the Southern District of New York, which resulted in the indictment against
Jeffrey Epstein returned on July 2, 2019 (19 Cr. 490 (RB)) and the above-captioned
superseding indictment against Ms. Maxwell (S2 20 Cr. 330 (AJN)), the initial
indictment against Ms. Maxwell having been returned on June 29, 2020 (20 Cr. 330
2028844.3
EFTA00028104

=== Page 3 ===
U.S. Department of Justice
August 30, 2021
Page 2
(AJN)). We request testimony from
and
concerning the
scope, timeline, and resolution of the investigation, as well as the various
investigative steps taken by the agents, including but not limited to testimony about
numerous witness interviews they conducted, physical evidence they reviewed,
documents they obtained by subpoena, their testimony before the grand jury, and
the indictments returned by the grand jury.
The testimony of these law enforcement officers is relevant and material to the issues in
this case. Furthermore, it is Ms. Maxwell's position that the disclosure is appropriate under rules
of procedure and that disclosure, to Ms. Maxwell's knowledge, would not violate any statute or
regulations or reveal confidential sources, classified information, trade secrets, ongoing
investigations, or investigatory techniques. (28 C.F.R. $ 16.26(b)).
If you have any questions or would like to discuss further, please do not hesitate to contact
me.
Sincerely,
/s/ Christian R. 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 email)
2028844.3
EFTA00028105


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=== Page 1 ===
STATES
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 5, 2019
BY HAND DELIVERY
MCC-Metropolitan Correction Center
Legal Department
150 Park Row
New York, NY 10007
Re: United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Enclosed is discovery pertinent to the following inmate:
Jeffrey Epstein: 76318-054
Please allow him access to the materials enclosed.
Description
Bates Range
American Express Records
USAO 000001-USAO 000041
Apple Records
USAO 000042-USAO 000043
Database Searches & Property Records
USAO_000044-USAO_000964
Deutsche Bank Records
USAO 000965-USAO 002252
Epstein Arrest
USAO 002253-USAO 002278
Florida Search Warrant Photos
USAO_002279-USAO_002643
Florida Search Warrant Walkthrough Video
002644-USAO 002652
Google Records
USAO 002653-USAO 002660
Microsoft Records
USAO_002661
2019.07.06 & 2019.07.07 Search Photos
USAO 002662-USAO 003499
1 Please note that the Government is designating the pages of these materials stamped with the
following control numbers as Confidential under the Protective Order: USAO_002416,
USAO_2451, USAO_002452, USA_002509, USAO_002530, USA0_002531, USAO_002532,
USAO_002533, USAO_002535, USAO_002536, USAO_002541, USAO_002542,
USAO_002543, USAO_002547, USAO_002548, USAO_002566, USAO_002575,
USAO_002578, USAO_002579, USAO_002580,USAO_002581,and USAO_002624.
2 Please note that the Government is designating the pages of these materials stamped with the
following control numbers as Confidential under the Protective Order: USAO_002650 and
USAO_002651.
3Please note that the Government is designating the pages of these materials stamped with the
following control numbers as Confidential under the Protective Order: USAO_002817,
EFTA00028446

=== Page 2 ===
Page 2
2019.07.11 Inventory Search Photos
USAO 003500-USAO 003509
2019.07.11 Search Photos
USAO 003510-USAO_0041754
Applications & Warrants
USAO 004176-USAO 004380
Reports & Logs
USAO 004381-USAO 004445
SORNA materials
USAO 004446-USAO 004505
Travel Records
USAO 004506-USAO 004518
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
by:
Went me
Assistant United States Attorneys
Enclosure
USAO_002822, USAO_002824, USAO_002826, USAO_002827, USAO_002833,
USAO_002848,
USAO_002849,
USAO_002858,
USAO_002859,
USAO_002933,
USAO_002934, USAO_003142, USAO_003148, USAO_003153, USAO_003154,
USAO_003155, USAO_003156, USAO_003157, USAO_003177, USAO_003179,
USAO_003192, USAO_003193, USAO_003276, USAO_003300, and USAO_003327.
4 Please note that the Government is designating the pages of these materials stamped with the
following control numbers as Confidential under the Protective Order: USAO_003729,
USAO_003742, USAO_004029, and USAO_004092.
EFTA00028447


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=== Page 1 ===
Event: Epstein estate counsel call
Start Date: 2019-10-30 18:30:00 +0000
End Date: 2019-10-30 19:00:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2019-10-23 19:45:07 +0000
Date Modified: 2019-10-23 19:45:07 +0000
Priority: 5
DTSTAMP: 2019-10-23 19:38:27 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00028834


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=== Page 1 ===
STATE or DELAWARE
SECRETARY or STATE
BK-U135FG118
DIVISION OF CORPORATIONS
WILED 02:30 PM 07/18/1991
751199007 - 2268758
CERTIFICATE OF INCORPORATION
OF
HYPERION AIR, INC.
The undersigned, a natural person, for the purpose of organizing a corporation
for conducting the business and promoting the purposes bereinafter stated. under the
provisions and subject to the requirements of the laws of the State of Delaware (particularly
Chapter 1, Title 8 of the Delaware Code and the acts amendatory thereof and supplemental
thereto. and known, identified, and referred to as the "General Curporation Law of the
State of Dclaware"). hereby certifies that:
FIRST: The name of the corporation (hereinafter called the "corporation")
is HYPERION AIR, INC.
SECOND: The address, including street, number, city, and county, of the
registered office of the curporation in the State of Delaware is 32 Louckerman Square, Suite
L-100, City of Dover, County of Kent; and the name of the registered agent of the
corporation in the State of Delaware at such address is The Prentice-Hall Corporation
System, Inc.
THIRD: The purpose of the corporation is to engage in any lawful act or
activity for which corporations may be organized under the General Corporation Law of the
State of Delaware.
FOURTH: The total number of shares of stock which the corporation shall
have authority to issue is one thousand five hundred. The par value of each of such shares
is one tenth of a mill. All such shares are of one class and are shares of Common Stock.
FIFTH: The name and the mailing address of the incurporator are as follows:
NAME
MAILING ADDRESS
Albena Togias
SIXTH: The corporation is to have perpenal existence.
-1-
CO'd
2698 273 818-01
01:01 18-01-20
4 pages
11/15/06
886
500/200
31* 9SAN
2408 750 212 XVJ CO 21
Confidential Treatment Requested by
JPM-SDNY-00001788
JPMorgan Chase
EFTA00029206

=== Page 2 ===
BK 19
SEVENTH: Whenever # compromise or arrangement is proposed hotween
this corporation and its creditors or any class of them and/or between this corporation and
its stockholders of any class of them, any court of equitable Jurisdiction within the State of
Delaware may, on the application in a summary way of this corporation or of any creditor
or stockholder thereof or on the application of any receiver or receivers appointed for this
corporation under the provisions of $ 291 of Title 8 of the Delaware Code or on the
application of trustees in dissolution or of any receiver or receivers appointed for this
corporation under the provisions of 279 of Title 8 of the Delaware Code order a meeting
of the creditors or class of creditors, and/or of the stockholders or class of stockholders of
this corporation, as the case may be, to be summoned in such manner as the said court
directs. If a majority in number representing three fourths in value of the creditors or class
of creditors, and/or of the stockholders or class of stockholders of this corporation, as the
case may be, agree to any compromise or arrangement and to any reorganization of this
corporation as consequence of compromise or arrangement, the said cumpromise or
arrangement and the said reorganization shall, If sanctioned by the court to which the said
application has been made. he binding on all the creditors or class of creditors, and/or on
all the stockholders or class of stockholders, of this corporation, as the case may be, and also
on this corporation.
EIGHTH: For the management of the business and for the conduct of the
affairs of the corporation. and in further definition, limitation, and regulation of the powers
of the corporation and of its directors and of its stuckholders or any class thereof, as the
case may be, it is further provided:
1. The management of the business and the conduct of the affairs of
the corporation shall be vested in its Board of Directors, The number of
directors which shall constitute the whole Board of Directors shall be fixed by.
or in the manner provided in, the Bylaws. The phrase "whole Board" and
the phrase "total number of directors" shall be deemed to have the same
meaning. to wit, the total number of directors which the corporation would
have if there were no vacancies. No election of directors need be by written
ballot.
2 After the original or other Bylaws of the corporation have been
adopted, amended, or repealed, as the case may be, in accordance with the
provisions of 4 109 of the General Corporation Law of the State of Delaware,
and, after the corporation has received any payment for any of its stock, the
power to adopt, amend, or repeal the Bylaws of the corporation may be
exercised by the Board of Directors of the corporation; provided, bowever,
that any provision for the classification of directors of the corporation for
staggered terms pursuant to the provisions of subsection (d) of § 141 of the
General Corporation Law of the State of Delaware shall be set forth in an
7
card
7668 eec 816-01
31:51 10-01-20
500/000
311 DSAN
2408 052 212 XVJ CO 21 3002/90/11
Confidential Treatment Requested by
JPM-SDNY-00001789
JPMorgan Chase
EFTA00029207

=== Page 3 ===
BK-U13586120
initial Bylaw or in a Bylaw adopted by the stockholders entided to vote of the
corporation unless provisions for such classification shall be set forth in this
certificate of incorporation.
3. Whenever the corporation shall be authorized to issue only one
class of stock, each outstanding share shall entitle the holder thereof to notice
of, and the right to vote at, any meeting of stockholders. Whenever the
corporation shall be authorized to issue more than one class of stock, no
outstanding share of any class of stock which is denied voting power under the
provisions of the certificate of incorporation shall entitle the holder thereof
to the right to vote at any meeting of stockholders except as the provisions of
paragraph (2) of subsection (b) of 242 of the General Corporation Law of
the State of Delaware shall otherwise require; provided, that no share of any
such class which is otherwise denied voting power shall entitle the holder
thereof to vote upon the increase or decrease in the number of authorized
shares of said class.
NINTH: The personal liability of the directors of the corporation is hereby
ellminated to the fullest extent permitted by the provisions of paragraph (7) of subsection
(b) of I 102 of the General Corporation Law of the State of Delaware, as the same may be
amended and supplemented.
TENTH: The corporation shall, to the fullest extent permitted by the
provisions of $ 145 of the General Corporation Law of the State of Delaware, as the same
may be amended and supplemented, indemnify any and all persons whom it shall have
power to Indemnify under said section from and against any and all of the expenses,
liabilities, or other matters referred to in or covered by said section, and the indemnification
provided for herein shall not be decmed exclusive of any other rights to which those
indemnified may be entitled under any Bylaw, agreement, vote of stockholders or
disinterested directors or otherwise, both as to action in bis official capacity and as to action
in another capacity while holding such office, and shall continue as to a person who has
ceased to be a director, officer, employee, or agent and shall inure to the benefit of the
heirs, executors, and administrators of such a person
ELEVENTII: From time to time any of the provisions of this certificate of
incorporation may be amended, altered, or repealed, and other provisions authorized by the
laws of the State of Delaware at the time in force may be added or Inserted in the manner
and at the time prescribed by said laws, and all rights at any time conferred upon the
stockholders of the corporation by this certificate of incorporation are granted subject to the
provisions of this Article ELEVENTH.
.
7698 ECC 816-01
DECLARES BLIBI 18-01-20
1
500/400
@
377 9SAN
2408 052 212 XVJ CO 21 11/06/2006
Confidential Treatment Requested by
JPM-SDNY-00001790
JPMorgan Chase
EFTA00029208

=== Page 4 ===
BK-U135FG121
Signed on July 18, 1991
Derator
Page
2.
4.
, : :
2550 ELE 016-01
SECTIONS 01151 10-01-40
500/500
377 9SAN
2408 050 212 XVS CO 21 9002/90/11
Confidential Treatment Requested by
JPM-SDNY-00001791
JPMorgan Chase
EFTA00029209

=== Page 5 ===
A1
Comments
Date[mmddyyyy]
Box Number
Form Type = "CITADEL"
04242012
Doc Code Doc Code Doc Code Doc Code Account Numbers
086
Account Numbers
Confidential Treatment Requested by
JPM-SDNY-00001792
JPMorgan Chase
EFTA00029210

=== Page 6 ===
The Morgan Account
Account type
Account number
/
/
Account type
Account number
ONE BILOWS
Month
Date
Year
Social Security no / be ID no / Passport no
Account tife
BAC #
All Accountholders/Signers must sign this Signature Form exactly as the checks/instructions will be signed
Print (Accountholder/Signer, Trustee, Custodian Director, ek)
Title
if facsimile signature, check box
SIGN
AGRE
X
Jeffery foskin, PRESIDENT
N
Print Doint Accountholder/Signes, Trustee, Custodian, Director, et)
Title
If facsimie signature, check box
---
MERI
CPS
X
Ghislane MAXWELL, TREASURER
Print (other)
Title
if factimule signature, check box
5164
HARRY Beller, Secretary
HERE
X Havey fall
Print (other)
Title
w facimile signature check box
bidk
HERE
X
is the any existing account?
yes
no
# yes, does this card replace all other and against # 1 account)
yes
no
Signing instructions Please use back of card if necessary)
The Morgan Account
Account ype
Account number
/
/
Account -ype
Account number
CORCLE ONE -
Month
Date
Year
Social Security no / Tax ID no / Passport no
Account title
BAC #
All Accounthalders/Signers must sign this Signature Form exactly as the checks/instructions will be signed.
Print (Accountholder/Signer, Trustre, Custorian, Director, etc)
Title
# facsimile signature, check box
STEM
Jeffrey Epskin, President
HERE
X
Print Cloint Accountholden/Signer, Trustee, Custodian, Director ex)
Tide
B If facsimle signature check box
514M
Ghishive Maxwell, TREASURER
MARS
X
Print (other)
Title
If facsimile signature, check box
SIGN
HARRY Beller, Secretury
HERE
X Hyper
Print (other)
Time
* factimle signature, check box
BILM
HERE
X
is this in existing account?
E
8
- yes 3305 this card replace at other cards against the ACCOUNT
yes
8
of card di necessary.)
page
11/15/06
194
Confidential Treatment Requested by
JPM-SDNY-00001793
JPMorgan Chase
EFTA00029211

=== Page 7 ===
A1
Comments
Date[mmddyyyy]
Box Number
Form Type = "CITADEL"
04182012
Doc Code Doc Code Doc Code Doc Code Account Numbers
194
Account Numbers
Confidential Treatment Requested by
JPM-SDNY-00001794
JPMorgan Chase
EFTA00029212

=== Page 8 ===
By 453785204
The Morgan Account
JPMorgan Private Bank
Application: Business Deposit Accounts
CAS 0220476583
MORGAN USE ONLY
CAS 0220476583
US841 10/05
SCAN
Time
SCAN
HYPERION AIR. INC.
SPN
MMIA No.
SPN #:
SPN #:
7705530
Primary CAS
ACCT. #
ACCT. #
% Acct. No.
Doc. ID #
771
Doc. ID #
876
Business Checking with Interest Acct. No.
Effective Date:
Effective Date:
JP.Margan Rep. (sent package) THOMAS A. RICE
A
ACCOUNT
Title of Account
Entity Type:
Corporation
Foundation
INFORMATION
HYPERION AIR, INC.
Limited Liability Company
LLP
Partnership
Check if applicable:
Sule Proprietorship
Not for Profit
Other
B
ACCOUNT TYPE
X
Checking Account
Business Checking with Interest ACCURE*
Money Market Investment Account
Other
Available only in trusts & estates, sole programships. not-fer-profits school districts, and government organizations
C
CORPORATE
Name of Corporation/Partership/C/ Doing Business As
Type of Business
fax Identification Number (TIN)
PARTNERSHIP
INFORMATION
HYPERION AIR, INC., C/O NEW YORK STRATEGY
13-3621632
Contact Person**
Title
Telephone
Fax
**Man be Authorized
Person
Current Mailing Address
E
State
Zip Code/Country
457 MADISON AVE
NEW YORK
NY
10022
4TH FLOOR
D
CHECKS
Check Style (JPMorgan exclusive check stock):
Wallet (single check)
Newpret Desk Book (spiral binder, 3 checks/page)
Business-Style Book tring binder, 3 checks/page)
Computer Checks (ist software) Quickbooks
Other***
LASER Jet Single Voucher
***Other check styles may INCUT additional fee.
Check Imprint: Checks will be imprimed with Title of Account as 6 appears on this Application and address IS listed in the
corporated partnership information section of this application, or DES file
Please omit my address from the check imprint.
Alternate Check Delivery Address:
Name
Company
Address
City
State
Zip Code
Country
E
STATEMENTS
Reduced SGM images of the front and back of each check will be acturned with streements unless otherwise indicated
Truncate checks and do not return
F
ACCOUNT LINKING
None. Linking Agreement contained in Subdivision 1 of this application
Link for Pricing: To apply earning creditvice allowances to office mush muintanance and/or transaction charges (as listed
- my current See schedule)
Link my following hearing Basiness Checking accounts
Account Number fir lead Checking Account to be billed any mosthly maintence charges
841
Confidential Treatment Requested by
JPM-SDNY-00001795
JPMorgan Chase
EFTA00029213

=== Page 9 ===
ACCOUNT LINKING
Cashine summary and detailed account information in were consolidated statement for accounts with the sume were
Link to Minimize or Eliminate Overdraft Interest Charges: to and - interest charges secured due to - overdraft
Link my following sun-intceest hearing Checking Accounts to minimine OF chrinate overdraft interest charges within these accounts:
Account Number for lead Checking Account to be belied any overdraft interest charges
G
ONLINE ACCOUNT
X
I im a current user of Morgan OnLine/Clase Onl inc. please and this account to ay access
ACCESS
(For more
My User ID is: JEJEJEJE
regarding natine
accoss, contact your
I would like to necess my account via Morgan Octine
JPMorgan Private
(User IDs must contain N-32 characters. They cannot be the same as your
Bank
Representative)
My Choices for an Internet access Login ID:
password or SSN. They may not include special characters such as &.%.
*.etc.)
1" Choice
2nd Choice
3rd Choice
My Email Address is
H
PLEDGE
I agree that this account is an account under The General Terms for Accounts and Services and is
AGREEMENT
pledged as collateral for all of my obligations and is subject to the security interest provisions is
The General Terms for Accounts and Services. the terms of which are incorporated by reference.
The General Terms for Accounts and Services together with this application are the security
agreement under Article 9 of the Uniform Commercial Code. as amended from time to time.
I
LINKING
IPMorgan Private Bank calculates an earning credit/fee allowance on aggregated business checking account balances. This
AGREEMENT
allowance is netted against fees for maintenance and services used. as listed on my current fee schedule. If the fee allowance
is not sufficient to cover the services used, a fee is charged to the primary Business Checking Account
By linking my multiple no-interest bearing Checking accounts. I can use the combined account balances to avoid or minimize interest
charges incurred due be an overdraft in any one or more of the linked accounts Note that linking can reduce or eliminate interest
charges due to overdrafts, but does not prevent the overdrafts themselves. Each day, the collected balances in all linked accounts are
added sogether. If the net balance is negative, overdraft interest charges will be calculated on that negative balance.
I understand that linking Checking Accounts as described above may have legal, tax or other ramifications under applicable U.S. or
other laws or rules (owing to. for example, different legal enticles owning lisked accounts and incurring or paying charges on behalf
of each other or having their assets offset against each other's). By signing below. I represent that I and the other Accountholders
have consulted with our legal, financial. tax or other advisers on these examers, accept the tinkage STP created, and will manage the
accounts to prevent any negative repercussions I agree to hold harmless from and indemnify JPMorgan Private Bank and each of its
effilities. officers. directors. agents and other representatives against any liability relating in any way to was provision of account
linking services to myself or the Accountholders of the linked Checking Accounts Other terms applicable to your Accounts are
contribed in The General Terms for Accounts and Services, Account Agreements and Appendices
THIS APPLICATION MUST BE COMPLETED BEFORE MORGAN WILL BE ABLE TO PROVIDE FINANCIAL SERVICES. IF ANY SECTION IS
INCOMPLETE YOU MAY CONTACT ME TO OBTAIN ADDITIONAL INFORMATION MUST ALSO NOTIFY YOU OF ANY FUTURE CHANGES TO THE
INFORMATION IN THIS APPLICATION ABSENT NOTIFICATION THE INFORMATION CONTAINED IN THE APPLICATION WILL BE DEEMED
ACCURATE AND COMPLETE
J
MORGAN
The General Terms for Accounts and Services and Appendices along with this Application. and any additional Account Agreements.
AGREEMENT
Rate and Fee Schedules Appendices and Supplemental Forms. and all amendments and supplimeres to any of them in effect from
time to time comprise the Agreement between you and me,
By signing this Application 1 acknowledge that I have. or will and - the various documents. including but not limited to, the
General Terms the Accounts and Services, Account Agreements Raw and Fee Schedules, and Appendises. and Supplemental
Forms which compries the Agreement burneen you and the l'Apreonant") I further administrator that I will notify you
immediately if I have any cours with the Agreement Otherwise I all be Jeemed to concer with this Agreement between you and
MN I also agree the each of the Accounts I an applying the is pledged as Collateral for all of my obligations. 1 the acknowledge
this I have real and consent Bit the tusins of the JPMorgan Private Hank Privacy Policy. including the manner If which my
information is received and used and that lipin opening - - with JPMorgan Private Bank sas chent information will be
and by one (If more members of the JPMorgan Provide Bank family of computer Las listed m the Policy) in order to make
available to me all the products and NOTICES available through the IPMorgan Provate Hank I understand that you do not give tax
of legal advice. and due I am advised to consult a lawyer if tax advent about us. legal, and estate planning insues affecting my
Accounts encluding the way Accounts are inted
841
Confidential Treatment Requested by
JPM-SDNY-00001796
JPMorgan Chase
EFTA00029214

=== Page 10 ===
K
IMPORTANT TAX
A FOREIGN PERSON MAY HAVE TO COMPLETE IRS FORM W-BEN OR FORM W-BIMY. A FOREIGN PERSON"
INFORMATION
MEANS A NONRESIDENT ALIEN INDIVIDUAL A FOREIGN CORPORATION A FOREIGN PARTNERSHIP. A FOREIGN
TRUST, A FOREIGN ESTATE. AND ANY OTHER PERSON THAT IS NOT AN U.S. PERSON. IT ALSO INCLUDES A
FOREIGN BRANCH OR OFFICE OF AN U.S. FINANCIAL INSTITUTION OR U.S. CLEARING ORGANIZATION IF THE
FOREIGN BRANCH is A QUALIFIED INTERNEDIARY
FOREIGN PERSONS
I AM A FOREIGN PERSON: THEREFORE, I ACKNOWLEDGE THAT YOU ADVISE ME 10 READ THE IRS W-8
TAX STATUS
INSTRUCTIONS (ENCLOSED IN THIS PACKAGE) CAREFULLY AND THAT , HAVE BEEN ADVISED TO CONSULT
MY TAX ADVISOR. Please sign and return the attached W8 form(s).
U.S. CITIZENS AND
IF I HAVE NOT CHECKED THE FOREIGN PERSONS TAX STATUS BOX ABOVE.
RESIDENT ALIENS
UNDER PENALTIES OF PERJURY # CERTIFY, AS THE ACCOUNTMOLDER SIGNING BELOW. THAT (1) THE
TAX CERTIFICATION
NUMBER SHOWN ON THIS APPLICATION IS MY CORRECT TAXPAYER IDENTIFICATION NUMBER (OR I AM
WAITING FOR A NUMBER TO BE ISSUED TO ME). AND (2) THAT AM NOT SUBJECT TO BACK-UP
WITHHOLDING BECAUSE (A) I AM EXEMPT FROM BACKUP WITHHOLDING OR (8) I HAVE NOT BEEN NOTIFIED
BY THE INTERNAL REVENUE SERVICE (IRS) THAT . AM SUBJECT TO BACK-UP WITHHOLDING AS A RESULT
OF A FAILURE TO REPORT ALL INTEREST AND DIVIDENDS, OR (C) THE IRS HAS NOTIFIED ME THAT il AM NO
LONGER SUBJECT TO BACK-UP WITHHOLDING AND (3) AM A U.S. PERSON (INCLUDING A U.S. RESIDENT
ALIEN).
" UNDERSTAND THAT IF I HAVE BEEN NOTIFIED BY THE IRS THAT I AM SUBJECT TO BACK-UP WITHHOLDING
AS A RESULT OF DIVIDEND OR INTEREST UNDERREPORTING. AND # HAVE NOT RECEIVED A NOTICE FROM
THE IRS ADVISING ME THAT BACK-UP WITHHOLDING is TERMINATED. 1 MUST STRIKE OR CROSS OUT THE
INFORMATION CONTAINED IN ITEM 2 IN THE PREVIOUS PARAGRAPH.) THE IRS DOES NOT REQUIRE
CONSENT TO ANY PROVISION OF THIS DOCUMENT OTHER THAN THE CERTIFICATION REQUIRED TO AVOID
BACK-UP WITHHOLDING
*LIMITED LIABILITY COMPANIES ONLY. FOR FEDERAL TAX PURPOSES IF THE MEMBERS HAVE CHOSEN TO
BE CLASSIFIED AS AN ASSOCIATION TAXABLE AS A CORPORATION YOU MUST CHECK THE BOX TO THE LEFT
OF THE WORD EXEMPT TO BE EXEMPT FROM BACKUP WITHHOLDING ON INTEREST AND DIVIDEND
PAYMENTS. OTHERWISE. THE CLASSIFICATION WILL BE DEFAULTED TO A PARTNERSHIP OR AS A SINGLE
OWNER DISREGARDED AS AN ENTITY SEPARATE FROM ITS OWNER.
EXEMPT (CLASSIFIED AS AN ASSOCIATION TAXABLE AS A CORPORATION).
SIGN HERE
X
ALL ACCOUNTHOLDERS ARE REQUIRED TO SIGN BELOW
X
Signature N
09/18/06
Jeffrey Epskin, PRESIDENT
Date
Prost Name/Title
X
Ghislaire MAXWELL, TREASURE
Signature Additional Accountholder)
Print Name/Time
X
Hung full 09/18/06 Date Date
HARRY Beller, Secretary
Signature (Additional Accolacholder)
Print Name/Title
X
Signature (Addintal Accountacide)
Date
Priet Name/Tite
Deposit Accounts are with JPMorgan Chase Bank NA (if I.P Morgan Trust Company NA or Chase Bank USA, NA
841
Confidential Treatment Requested by
JPM-SDNY-00001797
JPMorgan Chase
EFTA00029215

=== Page 11 ===
A1
Comments
Date[mmddyyyy]
Box Number
Form Type = "CITADEL"
04182012
Doc Code Doc Code Doc Code Doc Code Account Numbers
1060
Account Numbers
Confidential Treatment Requested by
JPM-SDNY-00001798
JPMorgan Chase
EFTA00029216

=== Page 12 ===
JPMorgan
The Morgan Account
AIR
Private Bank
Application: Corporate/Other Organization Resolutions
I, HARRY Beller
the Secretare ior duty authorized officer) of
HYPERR
IN.
(the Diganization) duly organized
under the have of
herby certife that the is * and complete our adopted by the
all which a of the Heard of Directors was present and ching and that the molitions have 04 has and September ** invelitied and - THEN
Hoard of Decessions of the Inganization by written consent of at a dirything lack) ***
182
das
3004
in full force and effect
A. Authorized signers
In this space, please Est. by names or titles, the persons authorized to sign act pursum to the resolutions indicated below (signers must be
identified for each resultations as passed) More, each signer may act singly unless that wint B must - below and the word "yuntly" is written in,
which filicans that any two signatures that act pointly.
Jeffrey Epstein, PRESIDENT
Print Name and Title (if any) or Title buly
Shishine MAAWELL, TREASURER
Manuer Singh Singly of Signing
Print Name and Title (if any) or Title mly
Manager of Signature
HARRY Beller Secretary
Print Name and Title (if any) or Title Unly
Manner Singly or Signing
Print Name and Title (if any) or Title Inly
Manner of Signing
Print Name and Title (if any) (If Title (hily
Manner of Signing
*A photo copy of a current Driver's License or Passport and social security number are required for each signer listed above.
Please check the line to the left of any one or more of the following resolutions which have been adopted. If the line to the left of any
particular lettered subdivision is not checked, that resolution has not been adopted.
B. Banking and custody
X1. RESE M.VED. that the individuals identified above an authorized member who deposit and custody with [PMorgan Chase Hank,
N.A. DE a Morgan Affiliate (individually or collectively, "Mongan") and any - FIF assigns designating Morgan as / depository of the funds
and castadion of the securities of the Organization and to act KK) behalf of the Departmention in all respects regarding the # Ingreization's banking
and castody DÉCOUNTS with Morgan as they 100 their discretion determine
C. Investment management
2. I.VED. that the persons specified above are authorized in the cank and can behalf of the Deganization the cream an investment
management agreement designating Murgan as the Organization's investment to deliver (If mudify any allocation guideline,
mandate, IN other instruction, and to 301 ort behalf of the Organization in all respects regarding the I Ingreation's investment management
accounts with Mangan.
D. Brokerage
3. RESOLVED that those persons identified above are authorized in the name and - below of the I Dignission: to execute A brokenge
agreement with J.P. Morgan Securities Inc. and any successions (if assigns; to purchase on margies or otherwise and borrow (on a secured or
unsecured basis) from, will (including short sales III 2 margin account). and load (on a second us instructional loves) B3, and box otherwise enter into
transactions of any kind with Megan with respect the any and all securities and financial statements whatsocver in which Morgan may deal,
broker the act as countripants from time to time, to enter into any derivative with spect to the presading ONLY the counter
equiry derivatives and structured transactions (weckuding, hur not hund $19 options, surape, when caps and floors, No phodge any funds or
instruments for the purposes of securing the obligations with " your to the to establish and opente une or more
brokerage or other in connection with the foregoing activities and transactions and - act on behalf of the hyperation in all respects
regarding the 1 Deginization's brokerage accounts
E. Credit
4. RES INED. that these persons specified alson the authorized in the name and - Inhalf of the I Drganization the bornew from time
Rse time form Morgan sums of musey. for periods of time and upon terms as may to them in their descretions NAME advance: to execute mores or
other obligations to evalence borrowings to outer mão agreements with respect to Its discount with Morgan any bills of OUTES
receivable held by the 1 organization signature such terms - they eary deen proper. to apply for and obtain letters of could and Be execute applications.
signature trust musipis and all other documents in connections therewith, reserve and deliver. MIS their discribes, any purmites, indemnity
agreement or undertakings deemed necessare IN advisable to carry HAIR the purpose and avent M the foregoing resolutions: to please any of the
was any property ed the 1 Ingastration, los the purpose of Arting any of the forging HE any entered into by any other
certify . person and to endress scourities and HE to issue appropriate process of and assignments BIR turtherance thereof:
Phage NW Date
Tak
in PERM N UM, IM:
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=== Page 13 ===
JPMorgan
Private Bank
The Morgan Account
Application: Corporate/Other Organization Resolutions
F. General
X5 RES MNED. that those individuals identified in above. acting in the mannet specified theesin, are authorized to delegate the authority
granted under the foregoing resolutions to any other person by written appointment submitted to Morgan and nw such appointment shall remain
in full france and effect until Morgan shall written notice B> the contrary from the (
X 6. RESOLVED. that any transaction of the type authorized by the preceding resolutions which has been take and hereby in all respects
approved. confirmed and ratified and
X7. RES R.VED. that any resolution certified to Morgan by the Secretary, LIE other duly appremed officer of the ( Information shall remain in
Full force and effect until Mergan shall service certification of a subsequent resolution amending, supersesting or revoking it.
X& RESC R.VED. Any persons authorized to act by the proceding resultations may utilize the website provided by Morgan (the "Net") via the
Internet 24 hours a day. seven days a week to act in the manage indicated ses this resolution provided the functionality " available via the Site
Transactions requiring more than - signature by complete will not be available Val the Site. Sate usage by any Authorized Person is subject to the
website agreements and disclosures available on the website. or VIA hard copy at your respect
G. Certification of incumbency
The following certificate of incumbency must be completed when the authorized squars are identified by title only.
I also certify that the following are officers of this Organization elected 1% appointed used their are dected - appointed and that you
shall be onsided to ruly upon their continued incumbency and empowerment to act for the , liganization until you have been furnished with a duly
certified notice to the contrary:
Print Name
Title
Date
Print Name
Tisk
Date
Print Name
Title
Date
Print Name
Title
Date
I further certify that the Organization is July organized and existing and has the prover and authority to take the actives contemplated by the
foreguing resolutions
H. Signature
IN WITNESS OF WHICH I have set my hand as Secretary (or other duly authorized officer) of this Deganizations (if)
this
&
Day'of September
2006
Hang Kale
HARRY Beller, Secretary
09/18/06
Signature
Print Name and Title
Date
( Inly
Tale
INTERN IN AIR. INC
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JPMorgan Chase
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=== Page 14 ===
JPMorgan
The Morgan Account
AiR
Private Bank
Application: Corporate/Other Organization Resolutions
I, HARRY Bella
she Secretary (ve day authorized officer) of
HYPERR
N
NO
(the leganization") duty organized
under the laws of
herby certify that the following 5 a ing and complete copy of posolutions adopted by the
at which a quorum of the Homed of Directors was present and voting and that their a have not been resended September the modified and show
Board of Directors of the Organization by - written Consent THE x a meeting *
18th
day
2004
in full force and effect
A. Authorized signers
in this space, pkase list, by name or ritks. the persons authorized to sign (If att present to the resolutions indicated below (signers must be
identified in each resolution as presed) Nisn, eich signer may act singly unle is that word is created nut below and the word "pointly" is written in
which means that any two signature must act juintly.
Jeffrey Epstein, PRESIDENT
Singly
Print Name and Title (if any) or Title Only
Ghishine MAAWELL, TREASURER
Municr Singly of Sagning
Print Name and Title (if any) or Title Only
Manner of Signing
HARRY Beller. Secretary
Singly
Print Name and Title (if any) or Title Only
Mi move in segning
Print Name and Title (if any) or Title Only
Manuer of Signing
Print Name and Title (if any) (if Title Cledy
Manner of Sping
*A photo copy of a current Driver's License or Passport and social security number are required for each signer listed above.
Please check the line to the left of any one of more of the following resolutions which have been adopted. If the line to the left of any
particular lettered subdivision is not checked, that resolution has not been adopted.
B. Banking and custody
X1. RESOLVED, that the individuals identified above are authorized To enter into deprest and ustody accounts with [PMogran Chase Bank,
N.A. or a Morgan Affiliate (individually or collectively. "Morgan", and any on required requiring Morgan - 3 depository of the funds
and custodian of the securities of the Deganization and to art on behalf of the Degineration expects regarding the Organization's banking
and custody accounts with Morgan as they in their disection determine
C. Investment management
2. RESOLVED, that the persons specified above are authorized in the name and on be all of the I Registration Bo execute an investment
management agreement designating Morgan as the Organization's manager, the deliver sit modify any - allocation guidding,
mandate, or other instruction, and to act INI behalf of the Departmention in all respects regarding the ( Organization's investment monagement
accounts with Morgan.
D. Brokerage
3. RESOLVED. that those persons identified above an authorized 219 the and - behalf of the Organization: to execute a brokengs
agreement with J.P. Morgan Securities Inc and any LMT assigns. In porthase of otherwise and borner (un a secured us
unsecured basis) from, sell (including short sales in a margin account), and kind (on a secord 18 inserved basis) to, and to otherwise enter into
transactions of any kind with Morgan with respect DIA any and all security and financial # structure whaticever in which Musgin may deal,
broker or act as countryparty from time DO miss; to enter into any decraise - with respect to the forggoing, including SWIT the counter
cquity desivatives and structured transactions (including, but not limited to options. sup. what caps and Sounk by phodes any funds OF
instruments for the purposes of sucuring the Departments obligations with respect the th to establish and openite EMAIL TM more
brokerage or other accounts in consection with the forgering activities and rd. to "1" FOR behalf of the Aganization in all respects
regarding the Organization's brokengs accounts
E. Credit
4. RESOLVED, that those persons specified above in authorised is the name 200 (H) behalf of the Organization: to bornow from time
to time from Morgan stams of money, for periods of time and upon as may to them it their discretion arm advisible DO execute motes or
other obligations to evidence borrowings. an enter into agreements with respect to burnings, DE discount with Morgan any bills or motes
receivable held by the & leganization upon such terms as they may deem proper, DO apple lieu and letters of credit and Bit applications,
agreements, trust receipes and all other documents in connection therewith: - execure and deliver, - their discribution any guarantee, indemency
agreement or undertakings deemed DE adviside the carry and the purpose and insure of the forging to pledge any of the
assets or property of the Organization, fine the purpose of securing DRV of the totagoing Eig any Instruction entered into by any other
entity or person; and, to endorse sccurities and/or bis Base apprecipate purposes of attorney. locuments EXT assignments in furtherance thereof:
[PMurgan Use Only
Take
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JPM-SDNY-00001801
JPMorgan Chase
EFTA00029219

=== Page 15 ===
JPMorgan
Private Bank
The Morgan Account
Application: Corporate/Other Organization Resolutions
F. General
X5 RESOLVED, that those individuals identified in above. acting in the specified thicm. are authorized to delegate the authority
granted under the foregring resolutions to any other person by written appointment substanted ** Virgan and any such appointment shall
in full force and effect until Murgan shall name with autice Die the contrasy from the Organization:
X6 RESOLVED, that any transaction of the 7PM authorised by the proced ag resolutions which has been taken are hereby in all respects
approved, confirmed and ratified, and
X7. RESOLVED, that any resolution octified to Morgan by the Secretary, ARE other duly appe FREE officer of the Ingremization shall remain in
full force and effect until Morgan shell receive certification of . is solument superseding (if revoking is
xr RESOLVED, Any persons authorized to act by the preceding may wills the website provided by Morgan (the "Sin") vis the
Internet 24 hours a day, Seven days . werk to ACT in the manner indicated 14" ris resolucion provided the functionality @ available VII the Site
Transactions requiring flows than one signature to complete will not be svaible via the Site Sm by any Authorized Person is subject to the
website agreements and disch-sures available on the website. via hard copy at your request.
G. Certification of incumbency
The following certificate of incumbency must be completed when the authorized signess are identified by title only.
I also certify that the following are officer of the Organization elected DE oppointed - I their are elected or appointed and that you
shall be entitled to rely upon their consinued incumber acy and empowerment " act from the ( Ingrivations must you have been furnished with 2 duly
certified notice to the contract
Print Name
Title
Date
Print Name
Take
Date
Print Name
Tak
Date
Print Name
Title
Date
I further certify that this Organization is duly organized and existing and has the prover and authorise - take the actions contemplated by the
foreguing resolurions.
H. Signature
IN WITNESS OF WHICH I have set any hand - Secretary (or other duly authorized officer) of this Organization -
this
&
Day'of September
2006
Havey Kale
HARRY Beiler, Secretary 09/18/06
Signature
Print Name and Twic
Date
JPMcegia Use Only
Tak
HYPERION MR. INI.
SPN
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JPM-SDNY-00001802
JPMorgan Chase
EFTA00029220


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
,
(USANYS)"
Subject: RE: Cooperator info re Epstein
Date: Sat, 24 Aug 2019 18:38:06 +0000
Thanks. Did he provide more substance beyond he heard information relating to Epstein? If so, let's talk Monday.
From:
(USANYS)
Sent: Saturday, August 24, 2019 1:52 AM
To:
(USANYS)
Cc:
(USANYS)
in
(USANYS)
is
(USANYS)
is
(USANYS)
>;
(USANYS)
Subject: Re: Cooperator info re Epstein
Let me know if you want to meet with
and we haven't yet
decided whether to extend him a cooperation agreement.
Sent from my iPhone
On Aug 23, 2019, at 6:12 PM,
(USANYS)
wrote:
Hi
and
I just spoke with
who got a call from an aspiring cooperator at MCC named
reported that another MCC inmate known
gave him information relating to Epstein. For several
months,
has been desperately trying to figure out how he can cooperate, often relying on second- and third-hand
information that's not actionable unless another inmate also cooperates. We can also talk in person next week about
the relative quality of his information.
I leave it to you guys to follow up with
as you see fit. I'm sure someone on this email can make
available
to you, if you want, once you get a sense of what he's about. I just don't want to unilaterally sit on this.
Have a nice weekend!
Assistant United States Attorney
Southern District of New York
EFTA00027946


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=== Page 1 ===
U.S. Department of Justice
Criminal Division
Office of International Affairs
United States Embassy, London
August 4, 2021
Via Email
Ms. Deborah Hand
United Kingdom Central Authority
Home Office
London, United Kingdom
Re:
Request for Expedited Assistance in the Matter of the Prosecution of Ghislaine Maxwell;
DOJ No. CRM-182-73090
Dear Ms. Hand:
Enclosed please find a request for urgent assistance concerning the above-referenced matter.
The United States Attorney for the Southern District of New York and the Federal Bureau of
Investigation are prosecuting Ghislaine Maxwell in connection with her role in the sexual exploitation
and abuse of multiple minor girls by Jeffrey Epstein from at least in or about 1994, up to and including
at least in or about 2004. The U.S. authorities seek the following evidence from the UK with regard to a
victim/witness: school records; a birth certificate; and border and/or passport records reflecting entry
and exit from the UK.
Expedited assistance is sought in this matter as it is scheduled for trial in November 2021. Your
assistance in this matter is greatly appreciated. Please do not hesitate to contact me at
or Legal Advisor/International Affairs Coordinator
at
Sincerely,
Director
By:
U.S. Department of Justice Attaché
Enclosure
SBU -LAW ENFORCEMENT
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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
NOLLE PROSEQUI
UNITED STATES OF AMERICA
:
:
19 Cr. 490 (RMB)
-V.-
:
:
JEFFREY EPSTEIN,
:
:
Defendant.
:
:
X
1. The filing of this nolle prosequi will dispose of
this case with respect to JEFFREY EPSTEIN, the defendant.
2. On July 2, 2019, Indictment 19 Cr. 490 (the
"Indictment") was returned, charging JEFFREY EPSTEIN, the
defendant, with one count of conspiracy to commit sex trafficking
of minors, in violation of 18 U.S.C. $ 371, and one count of sex
trafficking of minors, in violation of 18 U.S.C. $ 1591.
3. On or about August 10, 2019, while the above-
captioned case was pending, but prior to any trial or other
disposition, JEFFREY EPSTEIN, the defendant, died [committed
suicide?] Attached hereto as Exhibit A is a true and correct copy
of the death certificate for the defendant.
4. In view of the death of JEFFREY EPSTEIN, the
defendant, prior to a conviction becoming final, the Government is
required to seek dismissal of the Indictment with respect to him.
EFTA00027155

=== Page 2 ===
Accordingly, I recommend that an order of nolle prosequi be filed
as to defendant EPSTEIN.
Dated:
New York, New York
August 15, 2019
/
/
Assistant United States Attorneys
Upon the foregoing recommendation, I hereby direct, with
leave of the Court, that an order of nolle prosequi be filed as to
defendant JEFFREY EPSTEIN.
Dated:
New York, New York
August , 2019
United States Attorney
Southern District of New York
so ORDERED:
Dated:
New York, New York
August
, 2019
Hon. Richard M. Berman
United States District Judge
Southern District of New York
2
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=== Page 1 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Wells Fargo Bank, N.A.
Summons and Subpoenas Department
P.O. Box 1416
Charlotte, NC 28201
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
Nicolas Roos
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
EFTA00027184

=== Page 2 ===
RIDER
(Grand Jury Subpoena to Wells Fargo Bank, 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.
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=== 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:
EFTA00027186

=== 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.
EFTA00027187

=== 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
EFTA00027188


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=== Page 1 ===
From:
"
To:
"
Cc: "Biase, Nicholas (USANYS)"
>, "Berman, Geoffrey (USANYS)"
Subject: Re: Epstein
Date: Sat, 10 Aug 2019 13:14:10 +0000
https://www.nytimes.com/2019/08/10/nyregion/jeffrey-epstein-suicide.html
Chief Public Information Officer
U.S. Attorney's Office, SDNY
On Aug 10, 2019, at 9:01 AM,
wrote:
https://www.google.com/amp/s/nypost.com/2019/08/10/convicted-pedophile-jeffrey-epstein-dead/amp./
On Aug 10, 2019, at 8:55 AM,
wrote:
New York Post is on this too. It sounds like they'll report it shortly.
Sent from my iPhone
On Aug 10, 2019, at 8:43 AM,
wrote:
I think we have to wait for BOP or USMS to issue statement.
Sent from my iPhone
On Aug 10, 2019, at 8:31 AM,
wrote:
Can we confirm to the press? Or should we refer them to BOP?
EFTA00027242

=== Page 2 ===
On Aug 10, 2019, at 8:24 AM, Berman, Geoffrey (USANYS)
wrote:
I just got a call from
that Epstein committed suicide this morning. He died on the way to
the hospital.
EFTA00027243


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=== Page 1 ===
From:
To:
Subject: Epstein victim meeting
Date: Thu, 17 Oct 2019 22:01:25 +0000
Guys,
Continue to hear positive comments coming from attendees of the meeting in Florida. FYSA, we are currently
expecting 15 victims, 3 support persons, and 8 attorneys at the meeting here on the 23rd.
EFTA00028330


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=== Page 1 ===
From:
)"
To: Andrew Patel
Cc: Jill Shellow
>, Don Yannella
,
)"
Subject: RE:
/Epstein
Date: Fri, 20 Dec 2019 15:01:10 +0000
Attachments:
Notesfrom
interview Redacted.pdf;
; Notesfro
nterview.pdf
Andy,
Attached are unredacted and redacted copies of the notes. As discussed, we intend to produce redacted copies of
the notes pursuant to the protective order, and produce Mr.
name and your contact information to
defense counsel on an AEO basis. The file name will be changed to the bates number so it will not include his
name.
I'm also copying my co-counsel
,
please include them on emails going forward. Finally,
is aware that we are providing these notes to you.
Thanks, and please feel free to give us a call to discuss.
Original Message
From: Andrew Patel
Sent: Friday, December 20, 2019 8:15 AM
To:
)
Cc: Andrew Patel
>; Jill Shellow
>; Don Yannella
Subject:
/Epstein
Please send us a copy of the disclosure that you are considering as to Mr.
Seeing the planned
disclosure about our client will help us fashion a means of addressing the concerns we discussed last night.
Many thanks,
Andy
Andrew G. Patel
Attorney at Law
Sent from my phone
EFTA00029428


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=== Page 1 ===
The Morgan Account
JPMorgan Private Bank
Application: Business Deposit Accounts
CAS 0220476622
MORGAN USE ONLY
US841 10/05
SCAN
Title JEGE, INC.
SPN
MMIA No.
SPN #:
7705808
Primary CAS
ACCT. # 739474340
Checking Acct. No.
Doc. ID # 771 4 876
Business Checking with Interest Acct. No.
Effective Date:
IP Morgan Rep. (sent package) THOMAS A. RICE
A
ACCOUNT
Title of Account
Entity Type:
X
Corporation
Foundation
INFORMATION
JEGE, INC.
Limited Liability Company
LLP
Partnership
Check if applicable:
Sole Proprietorship
Not for Profit
Other
B
ACCOUNT TYPE
Checking Account
Business Checking with Interest Account*
Money Market Investment Account
X
Other
* Available only to trusts & estates, sole progrietorships, not-for-profits. school districts. and government organizations.
C
CORPORATE/
Name of Corporation/Partership/LC Doing Business As
Type of Business
Tax Identification Number (TIN)
PARTNERSHIP
INFORMATION
JEGE, INC., C/O NEW YORK STRATEGY GROUP
51-0405649
Contact Person**
Title
Telephone
Fax
**Must be Authorized
Person
Current Mailing Address
City
State
Zip Code/Country
457 MADISON AVENUE
NEW YORK
NY
10022
FOURTH FLOOR
D
CHECKS
Check Style (JPMorgan exclusive check stock):
Wallet (single check)
Newport Desk Book (spiral binder, 3 checks/page)
Business-Style Book (ring binder. 3 checks/page)
x
Computer Checks (list software) Quickbooks
Other***
LASERJET -Single Voucher
***Other check styles may incur additional fee.
Check Imprint: Checks will be imprinted with Title of Account as it appears on this Application. and address as listed in the
corporate/ partnership information section of this application. or on file.
Please omit my address from the check imprint.
Alternate Check Delivery Address:
Name
Company
Address
City
State
Zip Code
Country
E
STATEMENTS
Reduced size images of the front and back of each check will be returned with statements unless otherwise indicated
Truncate checks and do not return
F
ACCOUNT LINKING
Note Linking Agreement contained in Subdivision I of this application.
Link for Pricing: To apply earning credits/fe allowances to offset monthly maintenance and/or transaction charges (as listed
on my current fee schedule).
Link my following non-interest bearing Business Checking accounts
Account Number for lead Checking Account to be billed any monthly maintenance charges
841
Confidential Treatment Requested by
JPM-SDNY-00002475
JPMorgan Chase
EFTA00029201

=== Page 2 ===
ACCOUNT LINKING
Combine summary and detailed account information in one consolidated statement for accounts with the same ritle
Link to Minimize or Eliminate Overdraft Interest Charges: To avoid or minimize interest charges incurred due to an overdraft
Link my following non-interest bearing Checking Accounts to minimize or eliminate overdraft interest charges within these accounts:
Account Number for lead Checking Account to be billed any overdraft interest charges:
G
ONLINE ACCOUNT
X
I am a current user of Morgan OnLine/Chase OnLine: please add this account to my access.
ACCESS
(For more
My User ID is: JEJEJEJE
regarding online
access, contact your
I would like to access my account via Morgan OnLine
JPMorgan Private
(User IDs must contain 8-32 characters. They cannot be the same as your
Bank
Representative)
My Choices for an Internet access Login ID:
password or SSN. They may not include special characters such as &. %.
*,etc.)
I* Choice
2nd Choice
3rd Choice
My Email Address is
H
PLEDGE
I agree that this account is an account under The General Terms for Accounts and Services and is
AGREEMENT
pledged as collateral for all of my obligations and is subject to the security interest provisions is
The General Terms for Accounts and Services. the terms of which are incorporated by reference.
The General Terms for Accounts and Services together with this application are the security
agreement under Article 9 of the Uniform Commercial Code. as amended from time to time.
I
LINKING
JPMorgan Private Bank calculates an earning credit/fee allowance on aggregated business checking account balances. This
AGREEMENT
allowance is netted against fees for maintenance and services used. as listed on my current fee schedule. If the fee allowance
is not sufficient to cover the services used. a fee is charged to the primary Business Checking Account
By linking my multiple no-interest bearing Checking accounts, I can use the combined account balances to avoid or minimize interest
charges incurred due to an overdraft in any one or more of the linked accounts Note that linking can reduce or eliminate interest
charges due to overdrafts, but does not prevent the overdrafts themselves Each day. the collected balances in all linked accounts are
added together. If the net balance is negative, overdraft interest charges will be calculated on that negative balance
I understand that linking Checking Accounts as described above may have legal, tax or other ramifications under applicable U.S. or
other laws or rules (owing to, for example, different legal entities owning linked accounts and incurring or paying charges on behalf
of each other or having their assets offset against each other's). By signing below, I represent that I and the other Accountholders
have consulted with our legal, financial tax or other advisers on these matters, accept the linkage so created. and will manage the
accounts to prevent any negative repercussions. I agree to hold harmless from and indemnify JPMorgan Private Bank and each of its
affiliates, officers, directors, agents and other representatives against any liability relating in any way to its provision of account
linking services to myself or the Accountholders of the linked Checking Accounts. Other terms applicable to your Accounts are
contained in The General Terms for Accounts and Services. ACCOUNT Agreements, and Appendices
THIS APPLICATION MUST BE COMPLETED BEFORE NORGAN WILL BE ABLE TO PROVIDE FINANCIAL SERVICES. IF ANY SECTION is
INCOMPLETE YOU MAY CONTACT ME TO OBTAIN ADDITIONAL INFORMATION I MUST ALSO NOTIFY YOU OF ANY FUTURE CHANGES TO THE
INFORMATION IN THIS APPLICATION. ABSENT NOTIFICATION THE INFORMATION CONTAINED IN THE APPLICATION WILL BE DEEMED
ACCURATE AND COMPLETE.
J
MORGAN
The General Terms for Accounts and Services and Appendices along with this Application and any additional Account Agreements.
AGREEMENT
Rate and Fee Schedules, Appendices and Supplemental Forms, and all amendments and supplements to any of them in effect from
time to time comprise the Agreement between you and me.
By signing this Application, I acknowicdge that I have. or will read all the various documents. including but not limited to. the
General Terms for Accounts and Services. Account Agreements. Rate and Fee Schedules. and Appendices. and Supplemental
Forms which comprise the Agreement between you and me ("Agreement"). I further acknowledge that I will notify you
immediately if have any issues with the Agreement Otherwise, I will be deemed to cancur with this Agreement between you and
me. I also agree that each of the Accounts 1 am applying for is piedged a Cullateral for all of my obligations. I also acknowledge
that I have read and consent to the terms of the JPMorgan Private Bank Privacy Policy, including the manner in which my
information is received and used and that upon opening an account with JPMorgan Private Bank my client information will be
used by one or more members of the JPMorgan Private Bank family of companies (as listed in the Policy) in order to make
available to me all the products and services available through the IPMorgan Private Bank I understand that you de not give tax
or legal advice, and that I am advised to consult a lawyer or tax advisor about tax, legal, and estate-planning issues affecting my
Accounts including the way Accounts are titled
841
Confidential Treatment Requested by
JPM-SDNY-00002476
JPMorgan Chase
EFTA00029202

=== Page 3 ===
K
IMPORTANT TAX
A FOREIGN PERSON MAY HAVE TO COMPLETE IRS FORM W-BBEN OR FORM W-SIMY. A *FOREIGN PERSON
INFORMATION
MEANS A NONRESIDENT ALIEN INDIVIDUAL A FOREIGN CORPORATION, A FOREIGN PARTNERSHIP, A FOREIGN
TRUST, A FOREIGN ESTATE, AND ANY OTHER PERSON THAT IS NOT AN U.S. PERSON. IT ALSO INCLUDES A
FOREIGN BRANCH OR OFFICE OF AN U.S. FINANCIAL INSTITUTION OR U.S. CLEARING ORGANIZATION IF THE
FOREIGN BRANCH IS A QUALIFIED INTERMEDIARY.
FOREIGN PERSONS
I AM A FOREIGN PERSON THEREFORE . ACKNOWLEDGE THAT YOU ADVISE ME TO READ THE IRS W-8
TAX STATUS
INSTRUCTIONS (ENCLOSED IN THIS PACKAGE) CAREFULLY AND THAT , HAVE BEEN ADVISED TO CONSULT
MY TAX ADVISOR. Please sign and return the attached W8 form(s).
U.S. CITIZENS AND
IF I HAVE NOT CHECKED THE FOREIGN PERSONS TAX STATUS BOX ABOVE.
RESIDENT ALIENS
UNDER PENALTIES OF PERJURY I CERTIFY, AS THE ACCOUNTHOLDER SIGNING BELOW. THAT (1) THE
TAX CERTIFICATION
NUMBER SHOWN ON THIS APPLICATION is MY CORRECT TAXPAYER IDENTIFICATION NUMBER (OR # AM
WAITING FOR A NUMBER TO BE ISSUED TO ME). AND (2) THAT I AM NOT SUBJECT TO BACK-UP
WITHHOLDING BECAUSE: (A) 1 AM EXEMPT FROM BACKUP WITHHOLDING, OR (8) I HAVE NOT BEEN NOTIFIED
BY THE INTERNAL REVENUE SERVICE (IRS) THAT I AM SUBJECT TO BACK-UP WITHHOLDING AS A RESULT
OF A FAILURE TO REPORT ALL INTEREST AND DIVIDENOS. OR (C) THE IRS HAS NOTIFIED ME THAT I AM NO
LONGER SUBJECT TO BACK-UP WITHHOLDING AND (3) I AM A U.S. PERSON (INCLUDING A U.S. RESIDENT
ALIEN).
" UNDERSTAND THAT IF I HAVE BEEN NOTIFIED BY THE IRS THAT * AM SUBJECT TO BACK-UP WITHHOLDING
AS A RESULT OF DIVIDEND OR INTEREST UNDERREPORTING. AND I HAVE NOT RECEIVED A NOTICE FROM
THE IRS ADVISING ME THAT BACK-UP WITHHOLDING is TERMINATED. I MUST STRIKE OR CROSS OUT THE
INFORMATION CONTAINED IN ITEM 2 IN THE PREVIOUS PARAGRAPH.) THE IRS DOES NOT REQUIRE
CONSENT TO ANY PROVISION OF THIS DOCUMENT OTHER THAN THE CERTIFICATION REQUIRED TO AVOID
BACK-UP WITHHOLDING.
LIMITED LIABILITY COMPANIES ONLY FOR FEDERAL TAX PURPOSES IF THE MEMBERS HAVE CHOSEN TO
BE CLASSIFIED AS AN ASSOCIATION TAXABLE AS A CORPORATION YOU MUST CHECK THE BOX TO THE LEFT
OF THE WORD EXEMPT TO BE EXEMPT FROM BACKUP WITHHOLDING ON INTEREST AND DIVIDEND
PAYMENTS. OTHERWISE. THE CLASSIFICATION WILL BE DEFAULTED TO A PARTNERSHIP OR AS A SINGLE
OWNER DISREGARDED AS AN ENTITY SEPARATE FROM ITS OWNER.
EXEMPT (CLASSIFIED AS AN ASSOCIATION TAXABLE AS A CORPORATION).
SIGN HERE
X
ALL ACCOUNTHOLDERS ARE REQUIRED TO SIGN BELOW:
X
09/18/06
Print Jeffery Name/Tite
Epstein, President
Signature (Accountrala
Date
X
04/18/06
Ghishive Maxwell, TREASURER
X
Signature Hay Additional
Date
Print Name/Title
09/18/06
HARRY Beller Secretary
Signature (Adotional Accountholder)
Date
Print Name/Title
X
Signature (Additional Accountholder)
Date
Print Name/Title
Deposit Accounts are with IPMorgan Chase Bank, N.A. or J.P. Morgan Trust Company. N.A. or Chase Bank USA. N.A.
841
Confidential Treatment Requested by
JPM-SDNY-00002477
JPMorgan Chase
EFTA00029203

=== Page 4 ===
JPMorgan
Private Bank
The Morgan Account
Application: Corporate/Other Organization Resolutions
I, HARRY Bella
the Secretary (or duly authorized officer) of JEGE,
Inc.
(the - hyanization) duly organized
under the laws of
herby certify that the following is a true and complete copy of productions adopted by the
Hound of Directors of the Organization by unanimous written consent (If at - musting held on 180 day September 306
at which a quorum of the Heard of Directors was present and voting and that these resolutions have not been rescinded (If modified and an now
in full force and effect
A. Authorized signers
In this space. please list, by names or titles, the persons authorized to sign or act pursuant to the resolutions indicated below (signers must be
identified in each resolution as passed.) Also, each signer may ACT singly unless that word is crossed use below and the word "jointly" is written in,
which means that any two signers must act jointly.
Jeffrey Epstein, President
Singly
Print Name and Title (if any) or Title Only
Manner of Signing
Shishine Matwell, Teersver
Singly
Print Name and Title (if any) or Title Only
HARRY Beller, Secure
Manner Singly of Signing
Print Name and Title (if any) or Title Only
Manner of Signing
Print Name and Title (if any) or Title Only
Manner of Signing
Print Name Title (if any) or Title Only
Manner of Signing
*A photo copy of a current Driver's License or Passport and social security number are required for each signer listed above.
Please check the line to the left of any one or more of the following resolutions which have been adopted. If the line to the left of any
particular lettered subdivision is not checked, that resolution has not been adopted.
B. Banking and custody
X1. RESOLVED, that the individuals identified above are authorized to enter into deposit and custody accounts with JPMorgan Chase Bank,
N.A. or a Morgan Affiliate (individually or collectively, "Morgan") and any SUCCESSITY or assigns designating Morgan as a depository of the funds
and custodian of the securities of the Organization and to act OR behalf of the ( liganization in all respects sugarding the I Deganization's banking
and custody accounts with Morgan as they in their diseretion determine
C. Investment management
2. RESOLVED, that the persons specified above are authorized, in the name and on behalf of the Organization to exceute an investment
management agreement designating Morgan as the Organization's investment manager, to deliver or mudify any asset allocation guideline,
mandate, or other instruction. and to act on behalf of the Organization in all respects regarding the Organization's investment management
accounts with Morgan.
D. Brokerage
3. RESOLVED. that those persons identified above are authorized in the name and on behalf of the Organization: to execute a brokerage
agreement with J.P. Morgan Securities Inc. and any successing or assigns; to purchase on margin or otherwise and bornow (on % secured or
unscured basis) from, sell (including short sales in I margin account), and lend (on 3 secured (HE unsecured basis) to and to otherwise cater into
transactions of any kind with Morgan with respect to any and all securities and financial instruments whatsoever in which Morgan may deal,
broker or act as counterparty from time to time: to enter into any derivative transactions with respect to the forguing, including DIVET the counter
equity derivatives and structured transactions (including, but not limited to options, swips, collars. caps and floors): to pledge any funds or
instruments for the purposes of securing the Organization's obligations with respect to the forgoing to establish and operate use or more
brokerage or other accounts in connection with the foregoing activities and transactions; and, to act on behalf of the ( Drganization in all respects
regarding the Organization's brokengs accounts.
E. Credit
4. RESOLVED. that those persons specified above are authorized in the name and on behalf of the Organization: to beenew from time
to time from Morgan sums of money, for purinds of time and upon terms as may to them in their discretion success advisable: DU execute notes or
other obligations to evidence borrowings, to enter into agreements with respect to bornowings, to discount with Morgan any bills or notes
receivable held by the Organization upon such terms as they may deum proper. to apply for and obtain letters of crudit and to execute applications,
agreements, trust receipts and all other documents in connection therewith: to execute and deliver, in their discretion, may guarantee, indemnity
agreement OF undertskings deemed occussary or advisable to carry our the purpose and intent of the foregoing resolutions. the place any of the
assets or property of the ( Information, for the purpose of securing any of the begguing transactions or any transacrio entered inno by any other
entity OF person, and, to endorse securities and/or to issue appropriate places of anonxy. documents or assignme RES III furtherance thereof.
JPMorgan Uw Only
Title INC.
SPN
CAS
USI5005/06
I of 2
150
Confidential Treatment Requested by
JPM-SDNY-00002478
JPMorgan Chase
EFTA00029204

=== Page 5 ===
JPMorgan
Private Bank
The Morgan Account
Application: Corporate/Other Organization Resolutions
F. General
X5. RESOLVED. that three individuals identified in above, acting in the manner specified therein, are authorized to delegate the authority
granted under the foregoing resolutions to any other person by written appointment submitted to Morgan and any such appointment shall remain
in full force and effect until Morgan shall receive written notice the the contrary form the ( leganization:
X 6. RESOLVED. that any transaction of the type authorized by the preceding resolutions which has been taken are hereby in all respects
approved. confirmed and ratified; and
X7. RESOLVED. that any resolution certified to Morgan by the Secretary, of other duly appointed officer of the 1 Drganization shall remain in
full force and effect until Morgan shall receive certification of 1 subsequent resolutions amending, superseding or revolving it.
X 8. RES DLVED. Any persons authorized to act by the preceding resolutions may utilize the website provided by Morgan (the "Siti") via the
Internet 24 hours a day, seven days a week to act in the manner indicated in this resolution provided the functionality is available via the Site.
Transactions requiring more than INDC signature to complete will not be available via the Size. Site usage by any Authorized Person is subject to the
website agreements and disclosures available on the website, or via hand copy at your request.
G. Certification of incumbency
The following curtificate of incumbency must be completed when the authorized signers an: identified by title only.
I also certify that the following are officers of this Organization elected of appointed until their successors are elected or appointed and that you
shall be entitled to rely upon their continued incumbency and empowerment to UCT for the Organization until you have been furnished with a duly
certified notice to the contrary
Print Name
Title
Date
Print Name
Titk
Date
Print Name
Title
Date
Print Name
Title
Date
I further certify that this Organization is duly organized and existing and has the perwer and authority to take the actions contemplated by the
foregroing resolutions
H. Signature
IN WITNESS OF WHICH I have set my hand as Secretary (or other duly authorized officer) of this Organization on
this
2006
Signature 18th Harry Day of September
HARRY Beller
09/18/06
Print Name and Title
Date
Use Only
Title
INC.
SPN
CAS
US15015/06
2 of 2
150
Confidential Treatment Requested by
JPM-SDNY-00002479
JPMorgan Chase
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=== Page 1 ===
From:
To:
Subject: Epstein estate counsel call
Date: Wed, 23 Oct 2019 19:38:30 +0000
Importance: Normal
Attachments: unnamed
EFTA00028833


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=== Page 1 ===
From:
To:
Subject: RE: Re: Epstein bail
Date: Fri, 02 Aug 2019 17:25:25 +0000
Yep, thanks!
From:
Sent: Friday, August 2, 2019 1:00 PM
To:
Subject: Re: Epstein bail
You should know about this opinion that came out today (slapping down
http://www.ca2.uscourts.gov/decisions/isysquery/bb8653e0-cbb3-4d19-b7e6-867e50eee9bc/2/doc/19-
1018_opn.pdf#xml=http://www.ca2.uscourts.gov/decisions/isysguery/bb8653e0-cbb3-4d19-b7e6-
867e50eee9bc/2/hilite/
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=== Page 1 ===
From:
Subject: RE: Upcoming Nineteenth Production
Date: Wed, 04 Aug 2021 19:50:02 +0000
Attachments: US_v_Maxwell_Discovery_Index.xlsx; 2021.08.04_Maxwell_Discovery_Letter.docx
Great, thank you!
The entire production has now been stamped and is ready for your review. With the exception of the FBI Recovered
Metadata (which is on a hard drive; we will ask
to make us an internal copy of the stamped version), the rest of
the production is saved here on the shared. The index is also attached and saved here. Finally, I attached a draft cover
letter for defense counsel (also saved here). I'm happy to make any changes to the production, index, or cover letter as
needed.
If it looks good to go, we can start loading the materials once the hard drives from defense arrive. Thanks so much!
From:
Sent: Wednesday, August 4, 2021 3:26 PM
To:
Cc:
Subject: RE: Upcoming Nineteenth Production
Hi
Thanks! That proposal for the stamp makes sense to me.
From:
(
Sent: Wednesday, August 4, 2021 11:08 AM
To:
Cc:
Subject: RE: Upcoming Nineteenth Production
Thanks,
!
We can definitely use the same protective order stamp for this production.
please let me know what you prefer for stamping the JPMC returns. I'm happy to coordinate!
Thanks,
From:
)
Sent: Wednesday, August 4, 2021 9:56 AM
EFTA00027294

=== Page 2 ===
To:
V.
Cc: Drescher, Sunny (USANYS) [Contractor]
>; Bohrer, William (USANYS) [Contractor]
Subject: RE: Upcoming Nineteenth Production
Thanks
I'm going to defer to
on how to stamp the JPMC returns.
My preference would be to use the same stamp we used in our most recent productions, but please let me know if that
label is too long to be workable, in which case we'll figure out an alternative.
From:
(
Sent: Wednesday, August 4, 2021 9:53 AM
To:
is
>;
Cc:
Subject: Upcoming Nineteenth Production
Hi all,
has finished pulling the FBI Recovered Metadata from the shared, so we will be able to stamp those materials soon.
They are 217 GB in size, so we should ask defense counsel for a 500GB drive for us to load the entire Nineteenth
Production onto. In the meantime, I had a couple questions regarding the remaining materials in the pending production:
1.
2. How would you like us to stamp the materials so that they comply with the correct protective order designation?
We can use "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17," as we did in the most recent
3500 production, but I wanted to confirm with you all first.
I'm happy to chat further if anything's unclear. Thanks very much, all!
Paralegal Specialist
U.S. Attorney's Office
I
SDNY
1 St. Andrew's Plaza
New York, NY 10007
EFTA00027295


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
Subject: Cooperator info re Epstein
Date: Sat, 24 Aug 2019 01:12:50 +0000
Hi
and
I just spoke with
who got a call from an aspiring cooperator
named
who's a
reported that another
as
gave him information relating to Epstein. For several months,
has been desperately trying to figure out how he can cooperate, often relying on second- and third-hand
information that's not actionable unless another inmate also cooperates. We can also talk in person next week about the
relative quality of his information.
I leave it to you guys to follow up with
as you see fit. I'm sure someone on this email can make
available to
you, if you want, once you get a sense of what he's about. I just don't want to unilaterally sit on this.
Have a nice weekend!
Assistant United States Attorney
Southern District of New York
EFTA00027941


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=== Page 1 ===
From:
To:
Subject: Updated Subpoena Log
Date: Sat, 17 Aug 2019 19:51:28 +0000
Attachments: Updated_Subpoena_Log.xlsx
Let me know if anything looks wrong
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel:
EFTA00027183


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Subject: FW: Epstein and Maxwell
Date: Mon, 06 Jul 2020 14:03:45 +0000
From: Hogeweide, Caolan
Sent: Friday, July 3, 2020 7:01 AM
To:
(USANYS)
Subject: Epstein and Maxwell
Hello,
I'm concerned that Ghislaine Maxwell will suffer the same fate as Jeffrey Epstein if kept in jail without 24 hour
supervision. There are many intelligence agencies and powerful individuals that don't want her to talk. Who
knows, maybe even prison guards or inmates are being offered money to take her out.
Please don't let Maxwell end up "killing herself"
EFTA00028756


c1: EFTA00028337
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: SDNY investigation (Rodgers)
Date: Thu, 06 May 2021 16:48:12 +0000
Hi Brendan,
Hope you're doing well. Do you have time this afternoon or tomorrow for a quick call about this case?
Thanks,
From:
Sent: Friday, June 5, 2020 3:35 PM
To:
Cc:
Subject: Re: SDNY investigation (Rodgers)
Appreciate the courtesy. Please do not pass on our contact info. That said, feel free to contact us if anything comes up in
your investigation.
Thank you. Hope you guys are all hanging in okay.
Brendan E. Ouigley
On Jun 5, 2020, at 3:19 PM
wrote:
[EXTERNAL EMAIL]
Brendan,
An attorney for an individual who has an active civil case in connection with Epstein has reached out to us to ask if we
know the current counsel for Mr. Rodgers. I assume that the attorney is seeking to serve a request or subpoena for
documents and/or testimony, though we haven't asked specifically.
I don't think we ordinarily engage on that type of question, but given that we have been in touch with you in connection
with our interview of Mr. Rodgers, if you'd like we can pass along your contact info, so that the attorney goes to you
EFTA00028337

=== Page 2 ===
rather than attempting to contact or serve Mr. Rogers directly. And if not, of course no problem, and we'll just let him
know that we're not able to comment one way or the other on the status of any counsel. Whatever you prefer.
Thanks, and hope you're well these days.
From
Sent: Friday, February 07, 2020 18:36
To:
Cc:
Subject: RE: SDNY investigation (Rodgers)
Thanks
From:
Sent: Friday, Febru
To: Quigley, Brend
Cc:
Subject: RE: SDNY investigation (Rodgers)
[EXTERNAL EMAIL]
Brendan,
As promised, attached please find a copy of the proffer agreement signed today.
thanks
Confidentiality Notice:
The information contained in this email and any attachments is intended only for the recipient[s] listed above and may be privileged
and confidential. Any dissemination, copying, or use of or reliance upon such information by or to anyone other than the recipient[s]
listed above is prohibited. If you have received this message in error, please notify the sender immediately at the email address
above and destroy any and all copies of this message.
EFTA00028338


c1: EFTA00029359
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c0:
=== Page 1 ===
From: Joe Nascimento
To:
)"
Cc:
(USANYS)"
)"
=
Subject: Re:
)
- Epstein
Date: Thu, 05 Aug 2021 20:19:12 +0000
Here you go:
First Name:
Last Name:
DOB:
Home Address:
Cell Number:
Email:
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 5, 2021, at 2:49 PM,
)
wrote:
Thanks, that sounds like a plan. Could you please send me the information below for
travel?
Her full name as it appears on her government-issued ID
Her date of birth
Her home address, cellphone number, and email address
Once I have these details, I can pass them along to our witness coordinator, who can reach out to
to make
arrangements.
Thanks,
From: Joe Nascimento
Sent: Thursday, August 5, 2021 1:18 PM
To:
Cc:
(USANYS)
is
Subject: Re:
- Epstein
EFTA00029359

=== Page 2 ===
Great, thanks for working around our schedules. Let's reserve Friday 8/20. Hopefully you can fly
up Thursday
night and she can take a late night flight home Friday to give you all day with her.
Let me know what you need from us. If its easier, feel free to communicate directly with
(
) to
make travel arrangements.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Wednesday, August 4, 2021 at 10:11 PM
To: Joe Nascimento
Cc:
(USANYS)"
"
)"
Subject: Re:
)
- Epstein
Hi Joe,
I've confirmed with the agents, and either of those days would work for us. Do you have a preference on
scheduling? Happy to work around whatever works best for your travel schedule.
Thanks,
On Aug 3, 2021, at 7:47 PM, Joe Nascimento
wrote:
Hi
,
I spoke with
and she hopes we can schedule the meeting for the 19th or 20th.
Thanks,
Joe
Sent from my iPhone
EFTA00029360

=== Page 3 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 3, 2021, at 10:03 AM, Joe Nascimento
wrote:
Of course, what time works best for you?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 3, 2021, at 10:02 AM,
)
wrote:
Hi Joe,
Hope you're doing well. Are you available for a brief call this afternoon?
Thanks,
From: Joe Nascimento
Sent: Monday, April 26, 2021 9:53 AM
To:
Cc:
(USANYS)
i
)
Subject: Re:
- Epstein
Perfect, I received the invite with the link. Unfortunately (or fortunately sometimes) WebEx has been a
part a daily part of my life the past year, so we should be OK. See you all then, let me know if you need
anything further from us in the meantime.
Sent from my iPhone
Joseph E. Nascimento, Esq.
EFTA00029361

=== Page 4 ===
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Apr 26, 2021, at 9:31 AM,
)
wrote:
Hi Joe,
Thanks very much. Let's plan for May 14th at 12 p.m., if that works for you. I'll send a WebEx link for the
videoconference shortly. Please let us know if you have any tech issues/questions about WebEx.
Thanks,
From: Joe Nascimento
>
Sent: Wednesday, April 21, 2021 1:53 PM
To:
Cc:
(USANYS)
is
Subject: Re:
- Epstein
Good afternoon,
I spoke with
,
and she can make herself available the following dates:
May 3, 4 (before 2pm), 5, 6, 12, 13 or 14.
She is going to take the day off of work, so no need to do it after-hours (thank you for the offer). Let me know if
you need additional availability.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
<image001.jpg>
EFTA00029362

=== Page 5 ===
From:
)
Date: Friday, April 16, 2021 at 1:31 PM
To: Joe Nascimento
Cc:
(USANYS)
i
)
Subject: RE:
)
- Epstein
Thanks very much - let's plan for 9:30 a.m. on Monday, if that works for you. Should I just call your desk line, or
would you prefer a different number?
Thanks,
From: Joe Nascimento
Sent: Friday, April 16, 2021 1:00 PM
To:
Cc:
(USANYS)
is
Subject: Re:
- Epstein
Hi
,
Yes, I'm free Monday morning between 9:30 and 12 or Tuesday between 11-3. If that doesn't work for
you, I can try to move something around. Let me know.
Have a nice weekend,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Apr 16, 2021, at 11:58 AM,
)
wrote:
Hi Joe,
Hope you're doing well. Are you available for a call sometime early next week? Nothing urgent, but we wanted
to talk with you about potentially scheduling an interview (by video conference) with your client for sometime
in early May.
EFTA00029363

=== Page 6 ===
Thanks,
From: Joe Nascimento
Sent: Monday, March 8, 2021 1:54 PM
To:
Cc:
is
Subject: Re:
- Epstein
Yes, 10:30 works for me. Thank you!
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
From:
Date: Monday, March 8, 2021 at 1:32 PM
To: Joe Nascimento
Cc:
Subject: RE:
)
- Epstein
Hi Joe,
Thanks, hope all is well with you. We're free for a call at 10:30 tomorrow morning, would that work for you?
Thanks,
From: Joe Nascimento
Sent: Monday, March 8, 2021 1:24 PM
To:
Cc:
is
;
Subject: Re:
- Epstein
Hi
,
I hope you are well. Please let me know if you have 5 min for a quick call.
Sent from my iPhone
EFTA00029364

=== Page 7 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 2, 2020, at 11:09 AM,
)
wrote:
Hi Joe,
Thanks for reaching out, we were planning to email you. We continue to appreciate your client's cooperation
with our investigation, and her status from our perspective has not changed. We'll be in touch going forward,
All the best,
From: Joe Nascimento
Sent: Thursday, July 2, 2020 11:07 AM
To:
Cc:
is
Subject: Re:
)
- Epstein
Good morning,
Hope you are all well. Just wanted to check in after seeing the reports of Ghislaine's arrest.
If you need
anything from us, let us know.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
EFTA00029365

=== Page 8 ===
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Feb 21, 2020, at 3:53 PM,
)
wrote:
Joe,
We very much appreciated that, and we just wanted to let you know that the lack of communication
separate from that discussion shouldn't be interpreted in any way negatively. We'll certainly be in touch
again when we're able.
thanks again,
From: Joe Nascimento
Sent: Wednesday, February 19, 2020 15:03
To:
Cc:
is
)
Subject: Re:
- Epstein
We really appreciate this email. I was able to speak with
a few weeks ago and gave the green light to
share
name and information provided with anyone necessary in your investigation. We will wait to
hear from you if you need anything further.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
EFTA00029366

=== Page 9 ===
From:
)"
Date: Monday, February 17, 2020 at 3:40 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Joe,
We just wanted to check in very briefly-we had been hopeful that we'd be able to circle back with you
earlier, but our investigation is currently still ongoing, so at the very least we wanted to let you know that we
continue to appreciate both your client's prior assistance and her willingness to assist in the future. Nothing
in our investigation since we were last substantively in touch has changed our view of your client, and we
hope to be able to be in touch with you in the coming weeks with an update. In the interim, we do continue
to view her status as we've previously conveyed, and please let us know if any issues arise on your end.
thank you,
From:
Sent: Saturday, November 30, 2019 14:42
To: Joe Nascimento
Cc:
is
Subject: Re:
)
- Epstein
Hi Joe,
Thanks for checking in-
so no issues on our end, but we
appreciate your following up.
Thanks,
Sent from my iPhone
On Nov 30, 2019, at 8:54 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check-in as
Please let us know if you need anything from us.
Thanks,
Joe
Sent from my iPhone
EFTA00029367

=== Page 10 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 9, 2019, at 9:47 PM,
)
wrote:
Joe,
We will meet tomorrow at the same place as last time- the Hilton in West Palm Beach, on
Okeechobee Blvd. My cell is
when you arrive. My colleague,
will be joining us, and he can be reached at
Thanks,
Sent from my iPhone
On Sep 4, 2019, at 10:46 PM, Joe Nascimento
wrote:
Yes, we will be there.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
EFTA00029368

=== Page 11 ===
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 5:32 PM,
)
wrote:
Hi Joe,
Thanks for letting us know. Let's plan to meet on Tuesday. Would 11:30 work?
Thanks,
From: Joe Nascimento
Sent: Wednesday, September 4, 2019 10:13 AM
To:
Cc:
is
Subject: Re:
- Epstein
Good morning,
Yes, we had to hunker down for 2 days but were spared. Thanks. For next week, the 10th, 11th
or 13th work best for me. Look forward to hearing from you.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 10:04 AM,
)
wrote:
Hi Joe,
Hope the storm missed you this week, and that you and your client are doing okay.
EFTA00029369

=== Page 12 ===
Our team is working out some scheduling issues today, and we should know more by this
afternoon. I'll plan to reach out then to discuss scheduling, if that's okay.
Thanks,
Sent from my iPhone
On Aug 30, 2019, at 9:52 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check in to see if you still planned to travel south given the storm. Current
estimates show a landing (somewhere) Tuesday with very bad weather on Wednesday.
Airports might close (which will answer my question), but that's a guess.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 21, 2019, at 2:40 PM,
)
wrote:
Hi Joe,
Thanks very much, we'll plan to see you then. We'll most likely meet at a conference space at a
hotel in West Palm Beach, and l'll let you know closer in time which location.
Thanks,
From: Joe Nascimento
Sent: Monday, August 19, 2019 6:37 PM
To:
Cc:
is
)
Subject: Re:
- Epstein
EFTA00029370

=== Page 13 ===
Hi
,
Both the time and date work for us. Let me know the location when you have it
confirmed.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 19, 2019, at 11:11 AM,
)
wrote:
Joe,
Following up on scheduling, we were wondering if your client is available for a proffer on
September 4th. We're flexible on timing that day, but we would propose meeting at 12:30
p.m., if that works.
Thanks,
From: Joe Nascimento
Sent: Wednesday, August 7, 2019 4:53 PM
To:
Cc:
is
Subject: Re:
- Epstein
Hi
I just wanted to follow up re the August 14th meeting. Is it possible to schedule for early
afternoon (anytime after 1)? I have proactive cooperation ongoing in another case involving
EFTA00029371

=== Page 14 ===
multiple jurisdictions, and they are looking to meet the morning of 8/14. I understand if your
schedule is already set, and will work around it.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
"
)"
Date: Friday, August 2, 2019 at 3:34 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Joe,
Thanks, much appreciated. If possible, it would be helpful to hold August 14th for a meeting,
and we'll follow up to firm up plans as we get closer. If there are any conflicts with that date,
please let us know, we're happy to be flexible.
Thanks,
From: Joe Nascimento
Sent: Thursday, August 1, 2019 8:10 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
,
I do not have any travel plans during the month of August, nor does
September is a
busy month with two trials set, and I will be traveling out of the country from Sept 17-30, but I
will do everything to be as flexible as possible.
EFTA00029372

=== Page 15 ===
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, August 1, 2019 at 6:10 PM
To: Joe Nascimento
Cc:
)"
"
)"
Subject: RE:
)
- Epstein
Joe,
As we start thinking about scheduling a next meeting with
we were wondering if
you could please let us know if there are any particular weeks that would not work for you or
your client for a meeting in Florida (in particular, we don't want to interfere with anyone's
summer vacation plans).
We will of course be in touch to talk about a next meeting in more detail, but in the first
instance it would be helpful to get a sense of your schedules, for planning purposes.
Thanks,
From: Joe Nascimento
Sent: Wednesday, July 17, 2019 6:25 PM
To:
Cc:
)
is
Subject: Re:
)
- Epstein
Hi
,
EFTA00029373

=== Page 16 ===
That works for me. Please call me on my cell
Thanks.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 17, 2019, at 5:58 PM,
)
wrote:
Hi Joe,
Following up, we were wondering if you were available for a call to discuss next steps. We're
available on Friday at 2:30, if that works, but let us know if there are other times that would
be more convenient for you.
Thanks,
From: Joe Nascimento
Sent: Saturday, July 13, 2019 12:39 PM
To:
Cc:
>;
)
Subject: Re:
)
- Epstein
Good afternoon,
It was a pleasure to meet you yesterday. In light of the recent filing and media reports,
EFTA00029374

=== Page 17 ===
As always, feel free to contact me at any time if we can be of further assistance. Look forward
to meeting again.
-Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, July 11, 2019 at 9:07 PM
To: Joe Nascimento
Cc:
)"
,
Subject: RE:
)
- Epstein
Hi Joe,
We will be at the Hilton in West Palm Beach, at 600 Okeechobee Blvd. Please call me when
you are here, and we will meet you in the lobby.
Thanks,
From: Joe Nascimento
Sent: Thursday, July 11, 2019 9:02 PM
To:
Cc:
is
;
Subject: Re:
)
- Epstein
Good evening,
Have you set a location for our meeting tomorrow?
Thanks,
Joe
Sent from my iPhone
EFTA00029375

=== Page 18 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 10, 2019, at 12:03 PM,
)
wrote:
Thank you, we will plan to see you then in West Palm Beach. We are still
coordinating logistics, and we will let you know that morning the address where we
should meet.
Since we will be traveling, please feel free to call my cell if you need to reach us for
any reason:
Thanks,
Sent from my iPhone
On Jul 10, 2019, at 11:39 AM, Joe Nascimento
<mailto:
wrote:
Of course
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
<x-apple-data-detectors:.//2/0>2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-
data-detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-
detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com/>
On Jul 10, 2019, at 11:34 AM,
<mailto:
wrote:
EFTA00029376

=== Page 19 ===
Joe,
Would it be possible to meet earlier, perhaps at noon on Friday? Thank you.
Sent from my iPhone
On Jul 9, 2019, at 10:51 PM, Joe Nascimento
<mailto:
<mailto:
wrote:
Can we meet Friday, early afternoon (around 1-1:30)? Please send me your proffer
letter.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
<x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-
data-detectors://2/0><x-apple-data-detectors.//2/0> Avenue<x-apple-data-
detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com
<http://www.crimlawfirm.com/>
On Jul 9, 2019, at 4:56 PM,
<mailto:
<mailto:
V
wrote:
Joe,
We ended up slotting in a few things in the interim, but we're still good for 6:30 for
sure.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Tuesday, July 09, 2019 16:43
To:
<mailto:
EFTA00029377

=== Page 20 ===
<mailto:
Cc:
mailto:
<mailto:
)
<mailto:
<mailto:
Subject: Re:
)
- Epstein
Hi
,
I got done a little earlier today - do you want to bump up our call time?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
detectors://2/0>rd<x-apple-data-detectors://2/0>
Avenue<x-apple-data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com
<http://www.crimlawfirm.com/>
On Jul 9, 2019, at 10:02 AM, Joe Nascimento
<mailto:
<mailto:
wrote:
Hi
,
Are you still free for a call?
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Miami, FL 33129
p.
f.
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com
<http://www.crimlawfirm.com
From:
"
)"
<mailto:
<mailto:
Date: Sunday, July 7, 2019 at 10:19 PM
To: Joe Nascimento
mailto:
<mailto:
EFTA00029378

=== Page 21 ===
Cc:
)"
mailto:
<mailto:
)"
<mailto:
<mailto:
Subject: RE:
)
- Epstein
Joe,
Sure, thanks - and yes, quite the weekend. If it's alright with you, let's do 10:00
a.m. on Tuesday - you can reach us at
, or we can also call you then if
that's easier, whatever you prefer.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Sunday, July 07, 2019 18:51
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
mailto:
<mailto:
Subject: Re:
)
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you.
Let's set a time for Tuesday morning (the earlier the better for me). Let me know
what works for you.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
etectors://2/0>rd<x-apple-data-detectors.//2/0>
Avenue<x-apple-data-detectors.//2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com
EFTA00029379

=== Page 22 ===
<http://www.crimlawfirm.com/>
On Jul 7, 2019, at 4:04 PM,
<mailto:
<mailto:
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak with
you. I expect our schedules may be somewhat unpredictable tomorrow; would it
work to set a time to talk on Tuesday? We can schedule it for before you meet with
,
if that's helpful. Or if you'd like to talk sooner, we could schedule a time
later today, or check in tomorrow about a possible afternoon discussion. Please let
us know what you prefer, and we look forward to being in touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
<mailto:
<mailto:
Sent: Saturday, July 06, 2019 22:55
To:
<mailto:
<mailto:
Subject:
) - Epstein
Begin forwarded message:
From:
<mailto:
<mailto:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
mailto:
Subject:
) - Epstein
My former partner, Alan Ross, represented
prior to his passing in 2018. Agent
served
with a grand jury
subpoena earlier today, and as Alan's former partner and FL Bar appointed inventory
attorney, she has contacted me. Unfortunately, I am unable to meet with her until
Tuesday, but I would appreciate a few minutes of your time at your convenience as I
am getting up to speed. Please let me know what day/time is best for you.
Look forward to speaking with you.
EFTA00029380

=== Page 23 ===
Best,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
detectors://2/0>rd<x-apple-data-detectors://2/0>
Avenue<x-apple-data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com
<http://www.crimlawfirm.com/>
EFTA00029381


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=== Page 1 ===
From:
To:
Subject: RE: JE state plea transcript
Date: Wed, 07 Aug 2019 16:07:21 +0000
That's great. Good find.
From:
Sent: Wednesday, August 7, 2019 11:56 AM
To:
Subject: FW: JE state plea transcript
Just FYI, flagged this to the team yesterday re: his state plea transcript and meant to send it to you both as well.
From:
Sent: Tuesday, August 06, 2019 20:34
To:
Subject: JE state plea transcript
Check out pages 38-39 of his state plea:
Epstein counsel: "[T]here is a nonprosecution agreement with the United States Attorney's office that triggers as a result
of this plea agreement. In other words, they have signed off and said they will not prosecute Mr. Epstein in the Southern
District of Florida for any offense upon his successful taking of his plea today. That is a confidential document that the
parties have agreed to. Just in an abundance of caution, I wanted to tell the court."
[...]
The Court: "Mr. Epstein, your attorney has told me that in addition to everything, we talked about another inducement,
shall we say, to your taking this plea is that the U.S. Attorney for the Southern District of the State of Florida, federal
prosecutor, has agreed to a nonprosecution agreement with you, meaning that if you successfully complete probation and
do everything you're supposed to, they have, have agreed not to prosecute you federally, did you understand that?"
The Defendant: "Yes, ma'am."
The prosecutor then notes that SDFL people ("they") were in court for the plea.
Assistant U.S. Attorney
Southern District of New York
EFTA00027239


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein
Date: Fri, 01 Mar 2019 18:31:12 +0000
Importance: Normal
Yes, that is fine
Original Message
From:
(USANYS)
Sent: Friday, March 1, 2019 1:30 PM
To:
Cc:
Subject: Re: Epstein
- Apologies, we are in a meeting that is running late. Can we call you a bit closer to 2?
Sent from my iPhone
On Mar 1, 2019, at 10:15 AM,
wrote:
Good morning!
Thank you for reaching out. I have some availability for a phone call today around 1:30/2 p.m. Please let me
know if that works for you. I look forward to connecting.
From:
Sent: Thursday, February 28, 2019 5:56 PM
To:
Cc:
<mailto:
Subject: Epstein
Hi
-
and I are the supervisors of the Public Corruption Unit in the Southern District of New York,
and we understand you reached out to one of the line AUSAs in our unit,
regarding our Epstein
investigation. We wanted to introduce ourselves and connect. Do you have time for a call tomorrow or Monday?
Thanks,
Deputy Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00027700


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Copies
Date: Mon, 19 Oct 2020 19:35:48 +0000
All good.
is on it. He gets frustrated, but then gets the job done. I suggest a training session for the paralegals so
they all hear the same exact instructions.
From:
(USANYS)
Sent: Monday, October 19, 2020 3:33 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: RE: Copies
Hi
I just spoke with
about this. They had originally thought the paralegals could make the copies, but they tried
and couldn't, so they asked
to. The CART analyst assigned to the Epstein/Maxwell case is out of the office today and
tomorrow, and they don't have anyone else who can make copies. The discovery deadline is 11/9, but the team is asking
the reviewers to finish by 10/31, so that they have time to review the responsiveness coding and make copies for
production. The team is worried that if the reviewers don't start within the next day or so, they won't have enough time
for the review. When
spoke with
he said he could get it done; we're deeply appreciative of the help and
sorry to monopolize so many office resources in service of this discovery deadline. Happy to discuss further by phone (I'm
available by cell anytime,
). Thanks
From:
(USANYS)
Sent: Monday, October 19, 2020 3:17 PM
To:
(USANYS)
Subject: Copies
is making them. I guess the FBI backed out.
What is the real deadline to get the full review finished?
EFTA00028672


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com"
Subject: Voucher for Trip 11164814 is late
Date: Sun, 03 May 2020 04:02:08 +0000
Importance: Normal
Dear
Your travel voucher for the trip below is now late based on your customer settings. Please submit your voucher
for this trip and mark it as Final if you have no additional expenses to claim.
Trip ID: 11164814
Traveler name:
Destination: Santa Monica
Purpose: R20NYS13444 - Epstein Investigation - Witness interview
Trip Dates: 2019-12-15 - 2019-12-18
Current status: Authorization Approved
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0013
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00029482


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c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: RE: Epstein victim notification
Date: Thu, 25 Jun 2020 16:36:24 +0000
I am sitting at my desk. 1028 anytime.
From:
)
Sent: Thursday, June 25, 2020 12:31 PM
To:
(USANYS)
Subject: Epstein victim notification
Hi
I hope you're doing well. Do you have a minute this afternoon for a short call about victim notification in this case? I'm
free anytime this afternoon except for 3, if you have a moment to discuss.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00028565


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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: Epstein iphone/ipad privilege reviews
Date: Tue, 27 Oct 2020 15:45:11 +0000
Embedded:RE:_Epstein_iphone_ipad_privilege_reviews.msg
Sender:
Subject: RE: Epstein iphone/ipad privilege reviews
Message-Id:
To:
Cc:
Cc:
EFTA00028481


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS) [Contractor]"
(USANYS)"
Subject: RE: Scanning
Date: Tue, 27 Aug 2019 20:59:40 +0000
Awesome, thank you!
From:
(USANYS) [Contractor]
Sent: Tuesday, August 27, 2019 4:51 PM
To:
(USANYS)
is
(USANYS)
Subject: Scanning
The beast has been slayed.
I organized the files out of the jumble that they were brought to us in. A few things that will 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.
EFTA00027254


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: search terms for devices
Date: Sat, 10 Oct 2020 16:24:10 +0000
Attachments: Search_Terms_for_Epstein_Electronic_Devices.docx
Yes, good call. I've added both of those, as well as the word passenger. I went through and added a few more terms that
came to mind today. Anything else you guys would like to add? I'd like to send this to
over the weekend so that we
can get the terms run through the SW returns first thing next week.
From:
Sent: Saturday, October 10, 2020 9:17 AM
To:
Cc:
Subject: Re: search terms for devices
Thanks very much. Should we add massage/masseuse?
Sent from my iPhone
On Oct 9, 2020, at 8:41 PM
wrote:
Attached is a draft list of search terms to run through the devices on Relativity. I've attached the warrant for reference.
Any thoughts/additions welcome.
Thanks,
<2020-06-26, search warrant, 20 mag 6719.pdf>
EFTA00029493


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=== Page 1 ===
From:
To:
Subject: Final Voucher 10810414(1) prepared by a travel arranger is pending your review
Date: Tue, 19 Nov 2019 23:45:40 +0000
Importance: Normal
Dear
Final voucher 10810414(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 10810414
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13179 - U.S. V. Epstein - Witness Interview
Destination: Santa Monica, CA, United States
Dates: 2019-11-13 - 2019-11-15
Current status: Pending Voucher Approval
Voucher total expenses: 1517.64
Estimated trip cost: 1583.95
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0012
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00028115


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
November 11, 2021
VIA FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the drive containing witness materials, government exhibits, and discovery
pertinent to Ghislaine Maxwell
) is
Very truly yours,
United States Attorney
by:
/s
Assistant United States Attorneys
EFTA00027711


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=== Page 1 ===
From:
To:
Subject: Jeffrey Epstein case: Federal prosecutors broke law, judge says | Miami Herald
Date: Fri, 22 Feb 2019 01:55:22 +0000
Importance: Normal
https://www.miamiherald.com/news/state/florida/article226577419.html
EFTA00029442


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 421 Filed 11/08/21 Page 1 of 1
USDC SDNY
UNITED STATES DISTRICT COURT
DOCUMENT
SOUTHERN DISTRICT OF NEW YORK
ELECTRONICALLY FILED
DOC #:
DATE FILED: 11/8/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
A conference is scheduled for November 10, 2021 to address the Defendant's motion
under Federal Rule of Evidence 412, Dkt. No. 378, the Defendant's motion in limine to exclude
under Federal Rule of Evidence 702 and Daubert V. Merrell Dow Pharmaceuticals, Inc., 509
U.S. 579 (1993), Dkt. No. 386, and the other outstanding issues that overlap with these two
motions as discussed at the November 1, 2021 conference. Dkt. No. 409.
The parties are ORDERED to confirm by 12:00 p.m. tomorrow, November 9, 2021, that
the alleged victims referenced in the Defendant's Rule 412 Motion have been notified of the
November 10 hearing and of their right to attend.
so ORDERED.
Dated: November 8, 2021
Alim D. Netto
New York, New York
ALISON J. NATHAN
United States District Judge
1
EFTA00027649


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein
Date: Tue, 20 Aug 2019 14:25:22 +0000
Hey
- Just tried your desk and cell. Would you mind giving one of us a call when you have a second? I'm at
Thanks much,
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00027228


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=== Page 1 ===
To:
Gmax
From:
Jeffrey Epstein
Sent:
Sun 10/24/2010 4:20:05 PM (UTC)
Subject:
Fwd:
Forwarded message
From: Matthew I. Menchel
Date: Sun, Oct 24, 2010 at 10:34 AM
Subject: RE:
To: Jeffrey Epstein
Jeffrey,
I very much enjoyed our talk the other night. I look forward to the possibility of working together, but regardless let's keep in touch.
Best,
Matt
Matthew I. Menchel
KOBRE & KIM LLP
www.kobrekim.com
New York
London
Hong Kong
Washington DC
Miami
From: Jeffrey Epstein [mailto:
Sent: Friday, October 15, 2010 8:08 AM
To: Matthew I. Menchel
Subject:
now that there can be no conflict. when are you next in new york
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
EFTA00027873

=== Page 2 ===
return e-mail or by e-mail to
, and
destroy this communication and all copies thereof,
including all attachments.
This e-mail message is from Kobre & Kim LLP, a law firm, and may contain legally privileged and/or
confidential information. If the reader of this message is not the intended recipient (s), or the
employee or agent responsible for delivering the message to the intended recipient (s), you are hereby
notified that any dissemination, distribution or copying of this e-mail message is strictly prohibited.
If you have received this message in error, please notify the sender immediately and delete this e-mail
message and any attachments from your computer without retaining a copy.
IRS Circular 230 disclosure: Any tax advice contained in this communication (including any attachments
or enclosures) was not intended or written to be used, and cannot be used, for the purpose of (i)
avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to
another party any transaction or matter addressed in this communication. (The foregoing disclaimer has
been affixed pursuant to U.S. Treasury regulations governing tax practitioners.)
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.
EFTA00027874


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=== Page 1 ===
From:
To:
Bcc:
Subject: RE: search terms for devices
Date: Sat, 10 Oct 2020 16:25:27 +0000
Embedded: RE:_search_terms_for_devices.msg
Sender:
Subject: RE: search terms for devices
Message-Id:
<SN5P110MB033653B89D06CA2E321745BF8A090@SN5P110MB0336.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
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=== Page 1 ===
From:
To:
Subject: Call re: Epstein FOIA
Date: Thu, 11 Mar 2021 20:29:17 +0000
Importance: Normal
Attachments: unnamed
EFTA00028664


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=== Page 1 ===
From:
To:
Subject: Palm Beach Police Reports
Date: Wed, 19 Aug 2020 15:33:05 +0000
Attachments: Palm_Beach_Police_Reports.pdf
Here's the full PDF. We have this in different formats from various sources (some of which were redacted). Here's an
unredacted version, from FBI.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00029024


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=== Page 1 ===
Event: Call with PAE re Epstein
Start Date: 2021-03-25 20:30:00 +0000
End Date: 2021-03-25 21:00:00 +0000
Organizer:
Location: Dial-in: 844-215-6902; Code:
Class: X-PERSONAL
Date Created: 2021-03-25 21:05:43 +0000
Date Modified: 2021-03-25 21:05:43 +0000
Priority: 5
DTSTAMP: 2021-03-25 19:29:31 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00027716


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=== Page 1 ===
SEAL
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 6, 2021
VIA FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the drive containing witness materials pertinent to Ghislaine Maxwell
(02879-509) is
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
/s
Assistant United States Attorneys
EFTA00028205


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: FW: Call re Maxwell
Date: Mon, 05 Apr 2021 18:26:31 +0000
1:30-3 tomorrow? (I could do the later times tonight if needed)
From:
)
Sent: Monday, April 5, 2021 2:25 PM
To:
(USANYS)
is
(USANYS)
Cc:
>;
(USANYS)
Subject: Call re Maxwell
Hi
We would like to schedule a call to chat about an issue that came up when I was reviewing the physical evidence from the
Epstein file on Friday.
,
and I are all free tonight from 6pm to 7pm, tonight from 7:30pm to 8pm, or tomorrow
from 1pm to 3pm. Is there a time in any of those windows when we could have a call, please?
Thanks,
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=== Page 1 ===
From:
"
To:
Subject: RE:
article
Date: Thu, 10 Dec 2020 16:59:25 +0000
Attachments: article.pdf
You can try right-clicking on the link, copying hyperlink, and opening it in google chrome as well.
From:
Sent: Thursday, December 10, 2020 11:40 AM
To:
Subject: FW:
article
Please open and send me whole article; I am having hard time getting full article open
From:
(USANYS)
Sent: Thursday, December 10, 2020 10:48 AM
To:
Cc: Graff, llan (USANYS)
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
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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
Subject: RE: Epstein trustees' counsel
Date: Thu, 19 Dec 2019 17:31:43 +0000
In our call today with counsel for the respective Trustees of the Epstein estate, they asked that we convey a request to
meet with
, and anyone else she would want to include in such a meeting, to discuss the Trustees' interest in
resolving the Government's potential civil forfeiture claims against the estate. They said they appreciated our (the line
assistants') willingness to hear their regular updates, but that they understand we're not in a position to negotiate, or
even to provide feedback on the proposed plan for the fund, and so they'd like the opportunity to elevate that discussion
and convey why they believe it would be in all parties' interests, including the victims, to engage in meaningful discussions
about a possible resolution. When you've spoken with
could you please let us know whether she's willing to meet
with them? And we can convey the response, unless you and/or she would prefer to do so directly. If she is willing to
meet with them, they were hoping to put a date and time on the calendar as soon as is convenient for her after the
holiday.
thanks,
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To:
Bee:
Subject: SDNY NEWS CLIPS, TUESDAY, DECEMBER 15, 2020
Date: Tue, 15 Dec 2020 19:12:58 +0000
Inline-Images: image001.png
SDNY PRESS CLIPPINGS
DISCOUNT
JUSTITIA
NYGARD
NYT: htps://www.nytimes.com/2020/12/15/world/peter-nygard-sex-trafficking-charges.html
THE GUARDIAN: https://www.theguardian.com/world/2020/dec/15/peter-nygard-canadian-fashion-mogul-arrested
CTV: https://winnipeg.ctvnews.ca/canadian-fashion-mogul-peter-nygard-arrested-in-winnipeg-1.5231922
GLOBALNEWS: https://globalnews.ca/news/7522991/canadian-fashion-mogul-peter-nygard-arrested/
HUFFPOST: htps://www.huffingtonpost.ca/entry/peter-nygard-arrest_ca_5fd8de17c5b690d5d3079c52
MAXWELL
BBC NEWS: https://www.bbc.com/news/world-us-canada-55314490
DAILY BEAST: https://www.thedailybeast.com/husband-scott-borgerson-says-ghislaine-maxwellis-a-wonderful-person-as-part-of-ast-ditch-bail-effort
REUTERS: https://www.reuters.com/video/watch/idPMGT?now=true
NY POST: https://nypost.com/2020/12/14/prince-andrew-stayed-at-epsteins-nyc-mansion-despite-denial/
AG BARR RESIGNATION
CNN: https://www.cnn.com/2020/12/14/politics/william-barr-out-as-attorney-general/index.html
NYT: https://www.nytimes.com/2020/12/14/us/politics/william-barr-attorney-general.html
NPR: https://www.npr.org/2020/12/14/811276917/willam-barr-to-steps-down-as-attorney-general
MATTERS OF INTEREST
WSJ: https://www.wsj.com/articles/an-unspecial-counsel-for-hunter-biden-11607994149
FOX: https://www.foxnews.com/politics/house-republicans-demand-hearing-big-tech-censorship-hunter-biden-stories
NY POST: https://nypost.com/2020/12/14/biden-cant-ignore-hong-kong-and-other-commentary/
THE GUARDIAN: https://www.theguardian.com/commentisfree/2020/dec/15/willim-bar-exit-bad-news-donald-trump-post-presidency-pardons
SLATE: https://slate.com/news-and-politics/2020/12/trump-medical-pardon-rudy-giuliani-covid.html
INSIDERNJ: https://www.insidernj.com/us-attorney-craig-carpenito-announces-resignation-effective-january-5th/
WAPO: https://wwwwashingtonpost.com/busnes/understanding-the-feuds-plaguing-usturkey-aliance/2020/12/15/1e19d958-3ed4-11ebb58b-16236267960_storyhml
NYDN: https://www.nydailynews.com/new-york/nysteve-banon-build-wall-case-transfer-20201214-pg4ns72kzbo3c6bmgminic75m-story.hml
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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA,
:
:
20 Cr. 330 (AJN)
V.
:
:
GHISLAINE MAXWELL,
:
:
Defendant.
:
:
X
REPLY MEMORANDUM OF GHISLAINE MAXWELL
IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO
SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA
TO BOIES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
Christian R. Everdell
COHEN & GRESSER LLP
Bobbi C. Sternheim
I aw Offices of Bobbi C Sternheim
Attorneys for Ghislaine Maxwell
EFTA00029100

=== Page 2 ===
Table of Contents
Table of Contents
i
Table of Authorities
ii
Table of Exhibits
iv
Introduction and Summary of the Argument
1
I.
The Facts
2
II.
The Government's Response to Maxwell's Motion
6
A. The Government's Defenses Are Not Credible.
7
B.
Assuming the Government's Defenses Are Worthy of Belief, the Government
Still Misled the Court.
17
III.
The Materiality of the Government's False Statements.
18
IV.
The Remedy for the Government's Misconduct.
20
A.
Pursuant to its Inherent Power, this Court Should Suppress the Evidence Obtained
from Boies Schiller and Dismiss Counts Five and Six, which are the Fruits of that
Evidence.
20
B.
At a Minimum, this Court Should Order a Hearing at which Maxwell May Inquire
into the Circumstances Surrounding the Government's Misrepresentation to
Judge McMahon
26
Conclusion
27
Certificate of Service
29
i
EFTA00029101

=== Page 3 ===
Table of Authorities
Cases
Abdell V. City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313
(
- Sept. 14, 2006)
8
Berger V. United States, 295 U.S. 78 (1935)
24
Brady V. Maryland, 373 U.S. 83 (1963)
11
Brown V. Maxwel, 929 F.3d 4 (2d Cir. 2019)
19, 20
Chemical Bank V. Affiliated FM Ins. Co., 154 F.R.D. 91
(
1994)
14, 18, 19
Elkins V. United States, 364 U.S. 206 (1960)
20
Four Star Fin. Servs., LLC V. Commonwealth Mgmt. Assocs., 166 F. Supp. 2d 805
(
2001)
25
Franks V. Delaware, 438 U.S. 154 (1978)
20, 22
V. Maxwell, 325 F. Supp. 3d 428
(
2018)
8, 15
Hampton V. United States, 425 U.S. 484 (1976)
20
In re WinNet R CJSC, 2017 WL 1373918
(
No. 16MC484(DLC), Apr. 13, 2017)
24
Martindell V. Int 'l Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979)
18, 21
McNabb V. United States, 318 U.S. 332 (1943)
20
Morales V. Portuondo, 165 F. Supp. 2d 601
(
2001)
24
Rea V. United States, 350 U.S. 214 (1956)
20
United States V. Bout, 731 F.3d 233 (2d Cir. 2013)
23
United States V. Cortina, 630 F.2d 1207 (7th Cir. 1980)
20, 22, 25, 26
United States V. Falso, 544 F.3d 110 (2d Cir. 2008)
22
United States V. Lambus, 897 F.3d 368 (2d Cir. 2018)
23, 25
United States V. Ming He, 94 F.3d 782 (2d Cir. 1996)
20
United States V. Paredes-Cordova, No. S1 03 CR. 987DAB, 2009 WL 1585776
(
June 8, 2009)
25
ii
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=== Page 4 ===
United States V. Payner, 447 U.S. 727 (1980)
20
United States V. Pena, 961 F.2d 333 (2d Cir. 1992)
25
United States V. Russell, 411 U.S. 423 (1973)
21
United States V. Schmidt, 105 F.3d 82 (2d Cir. 1997)
23
Wang V. Reno, 81 F.3d 808 (9th Cir. 1996)
2
Young V. United States, 481 U.S. 787 (1987)
24
Other Authorities
Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and
Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020)
11
U.S. Dept. of Justice, JUSTICE MANUAL, JM $ 9-11.151
15
Rules
Fed. R. Civ. P. 5.2
19
Rules of Professional Conduct, Rule 3.3(d)
24
Rules of Professional Conduct, Rule 3.8, cmt. [6A]
16
Constitutional Provisions
U.S. CONST. amend. IV
22
U.S. CONST. amend. V
21
U.S. CONST. amend. VI
26
iii
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=== Page 5 ===
Table of Exhibits
EXHIBIT J: Notes of Feb. 11, 2021 Call with AUSA
(Sealed)
EXHIBIT K: Handwritten Notes by AUSA
of Meeting and Contacts with Peter Skinner,
Stan Pottinger, and Brad Edwards
EXHIBIT L: Email String Between Peter Skinner and AUSA
, cc'ing Stan Pottinger, Brad
Edwards, and Sigrid McCawley (Feb. 29, 2016-Mar. 5, 2016) (Sealed)
EXHIBIT M: Emails between AUSA
and Chief of the Criminal Division (Mar. 3, 2016)
(Sealed)
EXHIBIT
: Emails between AUSA
and AUSA
and other AUSAs (Nov. 30,
2018-Dec. 6, 2018) (Sealed)
EXHIBIT O: Email from Stan Pottinger to AUSA
,
cc'ing Brad Edwards and Sigrid
McCawley, re Daniel Siad (Mar. 3, 2016) (Sealed)
EXHIBIT P:
Supplemental Privilege Log, Apr. 4, 2016
EXHIBIT Q: Defendant's Response in Opposition to Motion to Exceed Presumptive Ten
Deposition Limit,
V. Maxwell, No. 15-cv-07433-RWS
(
) (June 16, 2016)
iv
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=== Page 6 ===
Ghislaine Maxwell submits this reply in support of her Motion to suppress all evidence
the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and
to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena.
Introduction and Summary of the Argument
If the government meant to reassure this Court that nothing improper happened, its
Response was anything but reassuring.
The government now confesses that it had significant and substantial contact with
attorneys in 2016-while the
defamation suit against Maxwell was
on-going-as part of an effort to instigate a criminal prosecution of Maxwell for allegedly
trafficking
and others and then lying under oath. Doubling down on an increasingly
farfetched story, however, the government insists that nothing improper occurred when it
misrepresented these contacts to the Chief Judge of the Southern District of New York.
Contrary to the government's portrayal of events, what happened here is that a prosecutor
from the public corruption unit of the United States Attorney's Office, in an ex parte proceeding,
affirmatively misled Chief Judge McMahon to circumvent a Protective Order entered by one of
her colleagues. The prosecutor then exploited the material he obtained to indict Maxwell.
Had the prosecutor not affirmatively misled Judge McMahon, the government would
never have obtained the 90,000 pages of material it now possesses, material that is central-
indeed, essential-to its case against Maxwell. It would be the height of irony, not to mention
injustice, to allow the government to convict Maxwell of testifying falsely when the government
could not have indicted Maxwell but for the false statements it made to a federal judge.
"In a situation like this, the judiciary
may exercise its supervisory power to make it
clear that the misconduct was serious, that the government's unwillingness to own up to it was
more serious still, and that steps must be taken to avoid a recurrence of this chain of events."
1
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=== Page 7 ===
Wang V. Reno, 81 F.3d 808, 821 (9th Cir. 1996). For the reasons given below, the exercise of this
Court's supervisory authority is called for here.
I. The Facts
Pressed into some minimal measure of candor, the government now admits the following
facts are true:
On February 29, 2016, AUSA
,
the Human Trafficking Coordinator and
Project Safe Childhood Coordinator for the U.S. Attorney's Office for the Southern
District of New York, Ex. J, p 1, met with Peter Skinner of Boies Schiller, Stan
Pottinger, and Brad Edwards, who represented
, Ex. K, p 1.
The meeting concerned
allegations of sexual abuse and trafficking by
Jeffrey Epstein and Maxwell. Ex. J, pp 1-3.
At the meeting,
attorneys told AUSA
the following:
That Maxwell was Epstein's "head recruiter" of underage victims. Id. at 2.
That
was underage when she was brought to New York "for training
by Maxwell and Epstein [in] how to service men." Id. at 3.
That
had a pending civil lawsuit against Maxwell for defamation
alleging that Maxwell had recruited
to be trafficked and abused by
Epstein. Id. at 4, 7.
That Maxwell was asserting truth as a defense to
defamation claim.
Id. at 4, 7.
That Maxwell had photos of naked underage girls on her computer. Id. at 6.¹
1 No such photos were found on or produced from any computers associated with Maxwell.
2
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=== Page 8 ===
That Maxwell and Epstein-friend Jean Luc Brunel "took sexually explicit
photos of
regularly." Id.
That, as a birthday present, Maxwell gave Epstein a sexually explicit photo of
taken when
was sixteen. Id.
That Epstein hung the photo on one of his walls.4 Id.
That
has a note in Maxwell's handwriting with the name of another
victim. Id. at 8.5
That
was "live in" sex slave from 2000-2002.6 Id. at 3.
That there were other victims of Epstein and Maxwell, including
, id. at 7, who is apparently Accuser-1 in this case, and another woman
whose description matches
, id. at 9, who is apparently
Accuser-3.
That Accuser-1 was "highly credible." Id. at 7.
That Epstein and Maxwell used "the same MO with" Accuser-3 that they used
with
Id. at 7, 9.
And that
"wants [a] prosecution." Id. at 7.
2
Maxwell denies ever taking any photos of
, and we have seen no sexually explicit photo
of
in any of the civil or criminal document productions.
3 Not only did Maxwell not meet
until
was seventeen years old, Maxwell never
provided any such photo to Epstein, nor, to our knowledge, has any such photo ever been produced, in the
civil or criminal cases.
4
Again, we have not seen any such photo produced in any discovery, either in the civil or
criminal cases.
5 We are aware of no note in Maxwell's handwriting being produced in the
action, or the
criminal discovery.
6
was in fact living with her fiancé at the time and held multiple other jobs, as later
confirmed through depositions and documents in the
action.
3
EFTA00029107

=== Page 9 ===
The attorneys promised to send AUSA
"affidavits and depositions" to
support their request for a prosecution. Id. at 8.
Calling the meeting "intriguing," AUSA
emailed the Chief of the Criminal
Division three days later and proposed to "talk over" the facts with him. Ex. M, pp 1-
2. He agreed. Id. at 1.
In the days and weeks after the February 29 meeting, there were several emails
between
attorneys and AUSA
Exs. L &
There was also at least one phone call. Ex. K, at 4.
attorneys provided AUSA
with documents as promised. Id. at 2; see
also Ex. L, p 2.
Most importantly, the government now admits that AUSA
, the prosecutor in
charge of the case who appeared before Chief Judge McMahon on April 9, 2019, knew all of this
and still denied that Boies Schiller had any role in fomenting the investigation and claimed that
there had been no contacts between Boies Schiller and his office before November 2018, when
he claimed the investigation first began.
None of these statements by AUSA
to Judge McMahon were true.
As described above,
attorneys pressed the U.S. Attorney's Office for the
Southern District of New York to investigate and prosecute Epstein and Maxwell. Ex. J.
Then, two months after the meeting with AUSA
attorneys told Judge
Sweet-who was presiding over
defamation against Maxwell-that there was an
4
EFTA00029108

=== Page 10 ===
"ongoing criminal investigation" into Maxwell, and they withheld from discovery 57 separate
documents, invoking the "law enforcement privilege." Ex. P.⁷
In late November 2018 and early December 2018-just two months before AUSA
filed the ex parte request before Judge McMahon seeking modification of the civil
Protective Order entered by Judge Sweet-AUSA
shared with AUSA
, as
well as one other member of the trial team and the heads of the Public Corruption Unit,
everything she learned from her contacts with
attorneys. Ex.
AUSA
gave AUSA
and his colleagues: (1) nine pages of detailed,
hand-written notes from the February 29 meeting; (2) the emails she received from
attorneys; and (3) all the documents provided to her by
attorneys. Id. Some of what she
gave AUSA
included material Boies Schiller attorneys designated a short time later
as "confidential" under Judge Sweet's Protective Order, including flight records and Palm Beach
Police Department Records.
AUSA
took an active role in gathering these materials from AUSA
Copying AUSA
AUSA Kurland had emailed AUSA
,
on December 5, 2018,
to obtain all the records of the February 29 meeting with
attorneys. Id. at 1. In that
email, AUSA Kurland also asked AUSA
whether, after February 29, she met "again
with [Peter Skinner] or anyone else." Id.
7 Two other aspects to the privilege log are notable: (a) In the
litigation, Boies Schiller
did not produce its emails with the U.S. Attorney's Office to Maxwell, despite the fact that they were
directly responsive to a Request for Production of Documents Maxwell served just a couple of weeks
after those emails were sent; and (b) Peter Skinner, the Boies Schiller attorney at the AUSA
meeting who also sent emails to AUSA
after the meeting, Ex. L, is not even listed on the
privilege log, though the log purports to reflect all email communications about the "ongoing criminal
investigation" that Boies Schiller had tried to initiate just a couple of weeks earlier.
5
EFTA00029109

=== Page 11 ===
Barely twelve hours later, when AUSA
hadn't responded, AUSA
took it upon himself to follow up, emailing AUSA
"Just quickly following up on this -
we're trying to get a complete handle on the landscape - thanks!" Id.
AUSA
responded one hour later: "Just went through my files and found a folder
w/ the notes I took and the documents they brought me." Id. She turned everything over to
AUSA
and other prosecutors in the office, including one other prosecutor on this trial
team. Id. AUSA
did not answer AUSA Kurland's original question: "[D]id [she] meet
again with [Peter Skinner] or anyone else" after the February 29, 2016 meeting with
attorneys. Id. But AUSA
certainly did not deny a second meeting or a subsequent phone
call occurred. Id.
By the end of the day on December 6, 2018, AUSA
had in his possession
everything
and her attorneys provided to AUSA
as well as AUSA
,
extensive hand-written notes. He also had access to AUSA
herself for any follow up
questions. By the end of the day, AUSA
had a "complete handle on the landscape,"
just as he asked for a couple hours earlier.
When AUSA
appeared before Judge McMahon barely four months later,
however, he told her none of this, unequivocally and falsely disavowing any role by Boies
Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his
office before November 2018. Even though AUSA
had a "complete handle on the
landscape," he painted an entirely different, false picture for Judge McMahon.
II. The Government's Response to Maxwell's Motion.
Confronted with evidence of AUSA
misrepresentations to Judge McMahon,
the government has filed a Response reluctantly admitting that the U.S. Attorney's Office had
sustained contact with Boies Schiller in 2016. Even so, the government tries its best to minimize
6
EFTA00029110

=== Page 12 ===
the significance of those interactions and of AUSA
misrepresentations to an Article
III federal judge. This Court should not permit the government to whitewash its conduct.
The discovery provided to Maxwell in response to her Motion rebuts every defense the
government now offers of its conduct. And if that weren't enough, the government's defense
fails on its own terms, because if this Court were to assume its truth (an assumption the
government has not earned), AUSA
statements to Judge McMahon would still have
been demonstratively and materially false.
A. The Government's Defenses Are Not Credible.
Discovery provided to Maxwell in response to her Motion rebuts every defense the
government now offers of its conduct.
Defense 1: The February 29, 2016 meeting was only about Epstein.
AUSA
contemporaneous hand-written notes entirely undermine the
government's claim that the February 29, 2016 meeting was about Epstein only and had nothing
to do with Maxwell. Resp. at 89 &
39. See Ex. J. AUSA
notes refer to Maxwell as
Epstein's "head recruiter" of underage girls; they document allegations that Maxwell "regularly"
took sexually explicit photos of
and other underage girls, which she kept on her
computer; they allege that Maxwell gave one such photo to Epstein as a birthday present, which
he hung on his wall; they claim that Maxwell, along with Epstein, brought
to New York
to personally "train[] [her]
[in] how to service men;" and they assert that Maxwell used the
"same MO" to recruit other girls to the sex trafficking scheme. The contents of AUSA
notes belie any notion that
attorneys-who at that very moment were suing Maxwell
7
EFTA00029111

=== Page 13 ===
for defamation for denying she had trafficked and abused
focused only on Epstein
and not on Maxwell.
Despite AUSA
contemporaneous notes showing that the meeting very much
concerned Maxwell, the government now claims that "the pitch was to investigate Epstein, not
Maxwell," and that the discussion included only "passing references to Maxwell." Resp. at 89
39. The government bases this argument exclusively on a phone call prosecutors conducted
with AUSA
on February 11, 2021, five years after the February 29 meeting actually took
place. Ex. K. This Court should reject the government's revisionist history.
The best evidence of what happened on February 29, 2016-at least the best evidence the
government has produced so far-is AUSA
contemporaneous notes.8 Ex. J.; Abdell V.
City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313, at *7
Sept. 14,
2006) (denying motion to quash third-party subpoena because "contemporaneous statements of
witnesses constitute best evidence"). Although the government attached these notes to its
Response, Resp. Ex. 5, the government does not rely on them as part of its argument, choosing
instead to rely on AUSA
2021 recollection of what happened, Resp. at 62-66, 89 &
39, 92 (citing Ex. 4).
8 It appears the government does not actually want to know anything beyond what AUSA
remembers (or doesn't remember) of 2016. All the government did in response to Maxwell's Motion was
telephone AUSA
The government apparently: (1) did not search its system for any and all emails
from, to, or about David Boies, Sigrid McCawley, Stan Pottinger, Brad Edwards, or Peter Skinner; and
(2) did not interview anyone other than AUSA
such as the other attendees of the meeting
(Pottinger, Edwards, and Skinner), or any of the other AUSAs whom AUSA
talked to about her
contacts with
attorneys.
Most conspicuous, of course, is the government's failure to interview AUSA
or secure
an affidavit from him. If this Court does not grant Maxwell's Motion on the papers, only an evidentiary
hearing can address these issues.
8
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=== Page 14 ===
But in her 2021 interview, AUSA
mostly disclaimed a memory of what happened
in 2016. Ex. K. The phrases "does not recall," "does not remember," or some similar expression
of lack of memory appear at least thirty-two times in the notes of the government's 2021 call
with AUSA
Id.
Many of AUSA
disclaimers, however, are simply not credible. For example,
AUSA
claimed not to "have an independent memory of the
V. Maxwell
[defamation] lawsuit being mentioned" during the meeting, id. at 1, even though her notes are
replete with references to the lawsuit, Ex. J. After reviewing her notes, AUSA
denied
that they refreshed her memory. Ex. K, p 1.
AUSA
similarly denied remembering whether
attorneys ever provided
her with documents, id. at 6, despite the email from Peter Skinner just hours after the February
29 meeting providing AUSA
with numerous documents, Ex. L, p 1-2, and despite the
fact that AUSA
in 2018 personally delivered those documents to AUSA
,
AUSA Kurland, and one member of the prosecution team in this case, Ex.
p 1 (12/6/2018
Email to AUSA
: "Just went through my files and found a folder w/ the notes I took
and the documents they brought me. Want to come by?").
When AUSA
did claim to remember what transpired, her memory was often
inconsistent with the contemporaneous evidence. Take just one example. "To [her] knowledge,"
AUSA
said, she did "not receive[] any discovery materials from any civil case." Ex. K, p
6. That is not correct. The government admits that AUSA
received from
attorneys, and turned over to AUSA
and others in the office, including flight records
and Palm Beach Police Department Records. Resp. at 66 &
2. Both of these documents were
produced in discovery in the civil case.
9
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=== Page 15 ===
From any perspective, therefore, AUSA
2021 version of events is not worthy of
credence, nor is the government's Response to Maxwell's Motion, which adopts AUSA
version of events (to the extent she claims to remember them) while ignoring the
contemporaneous evidence of what actually happened. The record is surpassingly clear: In
February 2016 and the weeks and months after,
attorneys "pitched" a prosecution of
Maxwell and Epstein.9
Defense 2: The government was not asked to consider a perjury charge
against Maxwell.
Noting that the February 29, 2016 meeting occurred before Maxwell's two depositions
(April and July 2016), the government insists that
attorneys did not ask (indeed could
not have asked) the government to consider charging Maxwell with perjury. Resp. at 63. Again,
the documentary evidence belies this claim.
First, AUSA
contemporaneous notes say that
wants prosecution." Ex.
J, p 7. AUSA
knew what
attorneys were after, which is why she emailed the
Chief of the Criminal Division just days after the meeting to discuss the "intriguing" case, Ex.
M.
Second, in the 2021 interview with prosecutors, AUSA
did not deny that
attorneys asked her to consider a perjury prosecution. Ex. K, p 5. Instead, AUSA
said that she "does not remember one way or the other if any of the attorneys referenced
the possibility of perjury." Id.
9 There are other indications as well that
attorneys pressed AUSA
to investigate
Maxwell. For example, while AUSA
notes say Jean Luc Brunel "is wanting to cooperate," Ex.
J, p 2, they say nothing of the sort about Maxwell, instead describing her as Epstein's "head recruiter," id.
See also Ex. O.
10
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=== Page 16 ===
Third, in the same interview, AUSA
admitted that she contemplated a perjury
prosecution, and she "recalls thinking that a perjury investigation would have
challenges."
Ex. K, p 5. Left unexplained by the government in its Response to Maxwell's Motion is why
AUSA
would have contemplated a perjury prosecution if
attorneys had not
proposed one.
There are two possible explanations. Either (1)
attorneys knew in February
2016 that they were going to set a perjury trap for Maxwell, and they discussed that plan with
AUSA
at the time, or (2) there were additional communications between AUSA
and
attorneys (phone calls or even a second meeting) after Maxwell was deposed.
Either way, the government contemplated a perjury charge against Maxwell in 2016, and the
Response's insistence otherwise is not credible.
Defense 3: Maxwell's argument relies on nothing but the Daily News
article.
The government says that Maxwell's argument "is premised solely on her use of selective
snippets from a lone Daily News Article that is premised, in meaningful part, on anonymous
sources and hearsay." Resp. at 89. This claim is stunningly disingenuous, and it fails on its own
terms.
When Maxwell filed her Motion, she did not have access to the government's emails and
AUSA
contemporaneous notes, despite their obvious exculpatory value. See Brady V.
Maryland, 373 U.S. 83, 87-88 (1963). The government did not disclose these materials until
Maxwell challenged the government's candor and conduct before Judge McMahon. One
wonders whether the government would have provided them to Maxwell had she not filed this
Motion.
11
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=== Page 17 ===
The government's claim also fails on its own terms. The article is not meaningfully
anonymous. 10 Among others, the article quotes David Boies, who said:
We were saying to anyone who would listen: We've got clients who were abused.
Some of them were underage. We have the evidence. There's a whole record that's
been developed. We can establish beyond any reasonable doubt there was a massive
sex trafficking ring going on.
The article also quotes Brad Edwards, who describes in his self-published memoir the various
contacts
attorneys had with the U.S. Attorney's Office in 2016.
Finally, as detailed above, AUSA
contemporaneous notes confirm most of the
article's substance. 11 Ex. J.
Defense 4: There was only one meeting.
The government denies there was a second meeting between the U.S. Attorney's Office
and
attorneys. Resp. at 92. This denial, though, is based solely on AUSA
foggy memory and in the absence of any credible investigation. Contrary to the government's
claim, the evidence strongly suggests there was a second meeting or some further contact
between them. At the very least, this Court should hold an evidentiary hearing to find the truth.
10 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and
Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020),
https://www.nydailynews.com/new-york/ny-jefrey-epstein-maxwell-case-20201013-
jmzhl7zdrzdgrbbs7yc6bfnszu-story.html.
To the extent the article relies on unnamed sources, there is no indication those sources are
anonymous in the sense that the author is unaware of their identity. In the 2021 call, the government
apparently did not ask AUSA
whether she was one of the unnamed sources. See Ex. K.
11 The government also says the article is hearsay. Resp. at 89. This is an odd claim for the
government to make while asking this Court to credit double hearsay: someone's notes of statements
made by AUSA
during a phone call. The government's hearsay argument does nothing but
support Maxwell's request for an evidentiary hearing.
12
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=== Page 18 ===
Two of the sources in the Daily News article insisted there was a second meeting in the
summer of 2016. 12
In addition, as described above, AUSA
in 2021 said she recalls contemplating a
perjury prosecution of Maxwell. Ex. K, p 5. But if there were only the one meeting, it makes
little sense for AUSA
to have been thinking about a potential perjury prosecution in
February of 2016, before Maxwell had even been deposed (unless the plan was to set a perjury
trap for Maxwell). It is more likely that AUSA
contemplated a perjury prosecution after
a second meeting with
attorneys, which took place after at least one of Maxwell's
depositions. As reported in the Daily News, "David [Boies] was particularly frustrated by the
failure to pursue a perjury charge. "We have her dead to rights," he said. 14
This Court cannot accept without further inquiry the government's assertion that there
wasn't a second meeting or any further contact between the U.S. Attorney's Office and
attorneys. At a minimum, an evidentiary hearing is required.
Defense 5: AUSA
had no idea what was in Boies Schiller's files.
The government stands by the claim that AUSA
had "either little or no
additional information than [Judge McMahon did] in terms of what materials there are [and] who
was deposed" and, for all the government knew, the deposition transcripts would show "page
after page of people taking the Fifth." See Resp. at 70. The government's Response is not
credible.
12 Supra Note 10.
13 Supra Note 10.
14 Supra Note 10.
13
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=== Page 19 ===
For one thing, the government admits that
attorneys turned over several
documents in 2016, which were in the government's possession when AUSA
claimed
to Judge McMahon that he did not know what was in Boies Schiller's file. Moreover, by the time
AUSA
told Judge McMahon that, for all he knew, the deposition transcripts would
show "page after page of people taking the Fifth," it was already a matter of public record that
Maxwell had been deposed and that she had not invoked the Fifth Amendment. Ex. Q, p 1.
The government's argument also defies logic. The government was asking Judge
McMahon to authorize a subpoena of Boies Schiller's entire file. At a minimum, the government
had to have asked Boies Schiller about the size of the file and issues related to privilege to
determine if Boies Schiller would contest the subpoena or notify either the civil court or
Maxwell when the subpoena was issued and responsive documents produced. In fact, the
government issued two subpoenas to Boies Schiller: the first for material covered by the
Protective Order, and the second for material outside the Protective Order's reach. Clearly, the
government knew more about Boies Schiller's file than AUSA
let on.
Defense 6: The "subject of your investigation" to whom Judge McMahon
referred was Jeffrey Epstein.
According to the government, when Judge McMahon asked AUSA
"about
contacts between the United States Attorney's Office and the Boies Schiller firm prior to the
issuance of the subpoena on the subject of your investigation," Mot. Ex. E, p 2, Judge McMahon
was referring only to Epstein. Resp. at 71. This is not a plausible reading of the transcript.
After his first appearance before her, Judge McMahon haled AUSA
back to
court for one reason. "I'll be very up-front with you," she said. Mot. Ex. E, p 2.
14
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=== Page 20 ===
I want to make sure I'm not in a Chemical Bank[¹⁵] kind of situation, so I would
like to know about contacts between the United States Attorney's Office and the
Boies Schiller firm prior to the issuance of the subpoena on the subject of your
investigation.
Id. (emphasis added).
"Tellingly,"¹ Judge McMahon did not ask AUSA
about the "target" of his
investigation; she asked about its "subject." The "subject of [the] investigation" is much broader
than its "target."
"A 'target' is a person as to whom the prosecutor or the grand jury has substantial
evidence linking him or her to the commission of a crime and who, in the judgment of the
prosecutor, is a putative defendant. "A 'subject' of an investigation is a person whose conduct
is within the scope of the grand jury's investigation." The scope of an investigation, in turn,
includes not only potential defendants and potential victims, but also the conduct at issue and the
locations involved.
Were there any doubt about Judge McMahon's meaning, she put that doubt to rest in her
written order authorizing the subpoena. Mot. Ex. G, p 21. The "subject of the investigation," she
explained, was "the matters that were the subject of the
[defamation] Action." Id. And
having asked AUSA
about his office's contacts with Boies Schiller about "the
15 Chemical Bank V. Affiliated FM Ins. Co., 154 F.R.D. 91
(
1994).
16 "Tellingly," claims the government in the Response, "Maxwell omits [the phrase "subject of
your investigation'] of this question from her motion." Resp. at 70 34. Not true. On page 13 of
Maxwell's Motion, in arguing that AUSA
mislead Judge McMahon, Maxwell fully and
completely quotes Judge McMahon's question, just as she does above. Mot. at 13 (quoting Ex. E, p 2).
17 United States Department of Justice, JUSTICE MANUAL, JM $ 9-11.151, Grand Jury, Advice of
"Rights" of Grand Jury Witnesses (updated Jan. 2020), available at: https://www.justice.gov/jm/jm-9-
11000-grand-jury#9-11.151 (last accessed Mar. 11, 2021).
18 Id.
15
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=== Page 21 ===
matters that were the subject of the
[defamation] Action," and having been misled by
AUSA
response, Judge McMahon erroneously (though blamelessly) concluded that
Jothing in this record suggests to me that
or Boies Schiller had anything
to do with the Government's decision to convene a grand jury to look into the
matters that were the subject of the
Action
There is no evidence of
"collusion," to invoke a term of the moment, and it is quite clear that Boies Schiller
did not foment the Government's investigation.
Id. (emphasis added).
For her part, AUSA
shared the very concern Judge McMahon later expressed to
AUSA
:
that Boies Schiller was trying to instigate an investigation of Maxwell to
leverage its position in the
Action." Mot. Ex. K, p 3. In the 2021 call, AUSA
recalled that the
pending CVRA civil case and other civil litigation
gave [her] some pause
because she had other occasions where civil litigants have decided to report
something to the USAO because they think it will help them in their civil case.
AUSA
even mentioned this concern to the Chief of the Criminal Division. Id. If AUSA
and the Chief of the Criminal Division recognized what was going on, AUSA
can hardly feign ignorance.¹⁹
If the government means to suggest that when Judge McMahon asked about any prior
contacts concerning "the subject of your investigation," she was somehow confining her inquiry
to the time period surrounding November 2018, see Resp. at 90-91, that too is an implausible
reading of the transcript. If Judge McMahon meant "subject" to be a term of art ("subject" of the
investigation as opposed to a "target" of the investigation), then the government should have
19 Of course, if AUSA
honestly did not understand Chief Judge McMahon's question,
once she issued her opinion there could no longer be any doubt. And at that point, AUSA
would have been duty-bound to correct the misimpression he had created.
Rules of Professional
Conduct, Rule. 3.8, cmt. [6A] ("Like other lawyers, prosecutors are subject to Rule 3.3, which requires a
lawyer to take reasonable remedial measures to correct material evidence that the lawyer has offered
when the lawyer comes to know of its falsity.").
16
EFTA00029120

=== Page 22 ===
disclosed the Boies Schiller contacts for the reasons given above. And if Judge McMahon meant
"subject" to have its everyday meaning, then she was asking about something even broader:
Whether the U.S. Attorney's Office had contacts with Boies Schiller about the "subject"-i.e.,
the "conduct"-being investigated.
Nothing about the transcript supports the government's overly narrow, hindsight-based
interpretation of Judge McMahon's question.
***
For these reasons, this Court should reject the government's attempt to rewrite the history
of its investigation and its affirmative misrepresentations to Judge McMahon.
B. Assuming the Government's Defenses Are Worthy of Belief, the
Government Still Misled the Court.
Even if the government's account were worthy of belief (which it is not), that doesn't get
the government off the hook.
The government would like this Court to believe that: (1) the February 29 meeting
concerned a prosecution of Epstein only and not Maxwell; and (2) when Judge McMahon asked
AUSA
about his office's prior contacts with Boies Schiller concerning "the subject of
its investigation," Judge McMahon was referring to Epstein only and not Maxwell.
Even if those two assertions were true, however, then AUSA
still misled
Judge McMahon and misrepresented the origins of the investigation. Under the government's
version of events, "the pitch was to investigate Epstein, not Maxwell." Resp. at 89
39. If that's
true, AUSA
unquestionably should have told Judge McMahon about the February
2016 meeting when she asked him "about contacts between the United States Attorney's Office
and the Boies Schiller firm prior to the issuance of the subpoena on the subject of your
investigation"-i.e., Epstein. AUSA
did not tell Chief Judge McMahon about the
17
EFTA00029121

=== Page 23 ===
contacts with Boies Schiller on the topic of Epstein any more than he shared the contacts on the
topic of Maxwell-he simply denied any contacts had occurred, something that is demonstrably
false.
Whether Boies Schiller "pitched" a prosecution of Epstein only or of Epstein and
Maxwell as a duo, AUSA
misled Judge McMahon by denying there was any "pitch"
whatsoever.
III. The Materiality of the Government's False Statements.
The government halfheartedly suggests that "there is no reason to believe that a
description of the February 2016 meeting would have been material to Chief Judge McMahon's
analysis of whether she was facing a 'Chemical Bank kind of situation. Resp. at 91. Hardly. In
fact, there is every reason to believe Judge McMahon would have refused to authorize the
subpoena if AUSA
had not so misled her.
How do we know? Because Judge McMahon said so-at least twice.
Judge McMahon first made this clear by haling AUSA
back in for one and
only one reason: To ask him about the contacts between Boies Schiller and his office before
November 2018. So crucial was this question to Judge McMahon's decision that the transcript of
the AUSA
second appearance before her is just three pages long. Mot. Ex. E.
Judge McMahon made her thinking even clearer in her written order authorizing the
subpoena. Mot. Ex. G. On page 12 of her opinion, when attempting to reconcile Chemical Bank
with Martindell,²⁰ Judge McMahon found that "nothing in the record suggests that the
Government's investigation in this case was occasioned by Boies Schiller-a point to which I
will return later in this opinion." Mot. Ex. G, p 12.
20 Martindell V. Int 'l Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979).
18
EFTA00029122

=== Page 24 ===
Judge McMahon "returned" to that point when discussing whether Maxwell could have
reasonably relied on the Protective Order:
[T]he only thing on which Maxwell or anyone else might reasonably have relied is
that
or her lawyers would not do what the defendant in Chemical Bank
did-that is, forward discovery materials in their possession to prosecutors for the
purpose of fomenting an investigation. But I am not faced with that situation.
Nothing in this record suggests to me that
or Boies Schiller had anything to
do with the Government's decision to convene a grand jury to look into the matters
that were the subject of the
Action. On the contrary-the Government has
advised the Court that it contacted Boies Schiller as part of its search for parties
who might have been victims in its investigation; and that Boies Schiller told the
Government that it could not consensually produce at least some documents in its
files because of the existence of the Protective Order. There is no evidence of
"collusion," to invoke a term of the moment, and it is quite clear that Boies Schiller
did not foment the Government's investigation. Moreover, the Assistant United
States Attorney has represented to this Court that he has no idea what is in Boies
Schiller's files, and that for all he knows every witness who was deposed stood on
his/her Fifth Amendment rights and refused to answer questions.
Id. at 21.
Contrary to Judge McMahon's understanding, Boies Schiller contacted the government
(not the other way around); there was ample evidence of "collusion"; it was "quite clear that
Boies Schiller did
foment the Government's investigation"; and AUSA
knew
much more about what was in Boies Schiller's files than he let on.
The Chemical Bank situation Judge McMahon was worried about- when civil litigant
attempts to foment a criminal investigation of her opponent-is exactly what occurred.
Judge McMahon cannot be faulted for not knowing all the facts. AUSA
, on
the other hand, had a "complete handle on the landscape," and he withheld the truth from Judge
McMahon. Had AUSA
not misled her, it is clear Judge McMahon would not have
authorized the subpoena. 21
21 It's notable that even without the benefit of truth from AUSA
, Judge McMahon
wrongly concluded that Maxwell could not have reasonably relied on the Protective Order. In fact, the
19
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=== Page 25 ===
IV. The Remedy for the Government's Misconduct.
A. Pursuant to its Inherent Power, this Court Should Suppress the Evidence
Obtained from Boies Schiller and Dismiss Counts Five and Six, which are
the Fruits of that Evidence.
This Court has inherent authority to regulate the administration of criminal justice among
the parties. McNabb V. United States, 318 U.S. 332, 340 (1943). "Judges have an obligation to
exercise supervision over the administration of criminal justice in federal courts, a responsibility
that 'implies the duty of establishing and maintaining civilized standards of procedure and
evidence." United States V. Ming He, 94 F.3d 782, 789 (2d Cir. 1996) (quoting McNabb, 318
U.S. at 340). As the Supreme Court held in United States V. Payner, "Federal courts may use
their supervisory power in some circumstances to exclude evidence taken from the defendant by
'willful disobedience of law." 447 U.S. 727, 735 (1980) (quoting McNabb, 318 U.S. at 345)
(citing Elkins V. United States, 364 U.S. 206, 223 (1960); Rea V. United States, 350 U.S. 214,
216-17 (1956); Hampton V. United States, 425 U.S. 484, 495 (1976) (Powell, J., concurring in
judgment)). A court should invoke its supervisory power of suppression when "there has been a
fraud upon the court in addition to a violation of the defendant's rights." United States V.
Cortina, 630 F.2d 1207, 1216 (7th Cir. 1980).
In United States V. Cortina, a magistrate issued a search warrant based upon an affidavit
subscribed by FBI Agent Linda Stewart, which itself was based on the reports and investigation
of FBI Agent William Brown. Id. at 1208. Unbeknownst to Agent Stewart, Agent Brown's
Second Circuit in Brown V. Maxwell held a few months after Judge McMahon's ruling that Maxwell had
reasonably relied on the Protective Order's guarantee of confidentiality in substantial part, and it therefore
redacted sua sponte from the summary judgment material those "deposition responses concerning
intimate matters where the questions were likely only permitted-and the responses only compelled-
because of a strong expectation of continued confidentiality. 929 F.3d 4, 48, 22 (2d Cir. 2019) (citing
Fed. R. Civ. P. 5.2). So, too, has Judge Preska redacted substantial material from the documents she has
released on remand from the Second Circuit, again reflecting that Maxwell reasonably relied on the
Protective Order.
20
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=== Page 26 ===
reports were replete with misrepresentations and outright lies about the conversations he had
with, and information provided by, a confidential informant. Id. at 1212-13. The Court of
Appeals affirmed the district court's order suppressing the evidence obtained from the search
conducted under the warrant. Id. at 1213. "This search," said the Court, "never should have taken
place." Id.
The Court offered two bases for its decision. It first invoked the Franks analysis to affirm
the district court's conclusion that Agent Brown intentionally or recklessly misrepresented
material information in Agent Stewart's affidavit. Id. But the Court went further, concluding that
suppression was independently required as a matter of inherent authority. Id. at 1214-17.
Because Agent Brown lied in the affidavit (in addition to lying at the Franks hearing), "[t]he call
for the court's supervisory power under the[] circumstances is at its strongest and most
defensible." Id. at 1214.
The Court recognized that the inherent authority doctrine is not a free pass for courts to
suppress evidence or "merely [to] disagree with the method[s] of law enforcement." Id. "[T]he
federal supervisory power does not give 'the federal judiciary a 'chancellor's foot' veto over law
enforcement practices of which it (does) not approve." Id. (quoting United States V. Russell, 411
U.S. 423, 435 (1973)). Even so, inherent authority is properly invoked to "prevent[] the court
from condoning a fraud perpetrated upon it." Id. Suppression serves both to deter unlawful
governmental conduct and to protect judicial integrity. Id. (weighing "the deterrent values of
preventing the incrimination of those whose rights the police have violated and the need to
protect the integrity of the federal courts against the cost to society of excluding 'probative but
tainted evidence").
21
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=== Page 27 ===
Maxwell had a due process right to notice and an opportunity to be heard on the
government's request to modify the Protective Order and issue a subpoena to Boies Schiller.
Mot. Ex. A, 1 14 (permitting modification of the Protective Order only "for good cause shown
following notice to all parties and an opportunity to be heard"); Mot. Ex. H (Judge Netburn
denying the government's ex parte request to modify the Jane Doe 43 Protective Order in part
because the government was attempting to deprive Maxwell of notice and an opportunity to be
heard); Martindell, 594 F.2d at 294; see U.S. CONST. amend. V. Maxwell also had a privacy
interest in the materials subject to the subpoena, including most especially her deposition
transcripts. Mot. Ex. A (defining "confidential" material as that which "implicates common law
and statutory privacy interests of
Ghislaine Maxwell"); see U.S. CONST. amend. IV. The
government violated these rights when it secured an ex parte modification of the Protective
Order based on materially false statements to Judge McMahon. In resisting any sanction for its
misconduct, and in denying that Maxwell should even be afforded a hearing, the government
asks this Court to "condon[e] a fraud perpetrated upon it." See Cortina, 630 F.2d at 1214.
To be sure, AUSA
misled Judge McMahon in answering the singular question
she posed, and he did so with full knowledge of the facts. AUSA
misrepresentations
were material to Judge McMahon's decision, because she would not have modified the
Protective Order if AUSA
had been candid about Boies Schiller's role in initiating
the investigation. As Judge McMahon put it, "the only thing on which Maxwell
might
reasonably have relied is that
or her lawyers" would not approach prosecutors and
"foment the Government's investigation." Mot. Ex. G, p 21. I. That is, in fact, exactly what
happened. As in Cortina, the modification of the Protective Order "never should have taken
place." Id. When, as here, a prosecutor-from the public corruption unit no less-misrepresents
22
EFTA00029126

=== Page 28 ===
material information to a federal judge in an ex parte proceeding, "[t]he call for the court's
supervisory power is at its strongest and most defensible." Cortina, 630 F.2d at 1214.
Maxwell need not satisfy the standard of Franks V. Delaware, 438 U.S. 154 (1978) in
order to obtain relief. But even if Franks applies, Maxwell has easily met her burden. To obtain a
Franks hearing, a defendant must make a "substantial preliminary showing," United States V.
Falso, 544 F.3d 110, 125 (2d Cir. 2008) (quoting Franks, 438 U.S. at 155-56), that (i) there were
"inaccuracies or omissions" in the affidavit, (ii) "the alleged falsehoods or omissions were
necessary to the issuing judge's probable cause or necessity finding," and (iii) "the claimed
inaccuracies or omissions [were] the result of the affiant's deliberate falsehood or reckless
disregard for the truth." United States V. Lambus, 897 F.3d 368, 397 (2d Cir. 2018). Here, there
is no dispute that (i) AUSA
representations to Judge McMahon were false and
misleading, (ii) Judge McMahon would not have modified the Protective Order to authorize the
subpoena if AUSA
had been honest with her, and (3) AUSA
statements
were deliberately false, since he had a "complete handle on the landscape" months before he
appeared in front of and misled Judge McMahon.
Nor need Maxwell prove "outrageous government conduct" to obtain relief. Were that
her burden, however, Maxwell would have easily satisfied it. "The concept of fairness embodied
in the Fifth Amendment due process guarantee is violated by government action that is
fundamentally unfair or shocking to our traditional sense of justice." United States V. Schmidt,
105 F.3d 82, 91 (2d Cir. 1997). To prevail on an outrageous government conduct claim, "a
defendant must show that the government's conduct is 'so outrageous that common notions of
fairness and decency would be offended were judicial processes invoked to obtain a
23
EFTA00029127

=== Page 29 ===
conviction." United States V. Bout, 731 F.3d 233, 238 (2d Cir. 2013) (quoting United States V.
Schmidt, 105 F.3d 82, 91 (2d Cir. 1997)).
Here, it would "shock the conscience" to permit a prosecutor to make false statements to
a federal judge to circumvent another judge's duly-entered order, all in violation of the
defendant's due process, privacy, and Fourth and Fifth Amendment rights. The only way to
prevent Maxwell from suffering unconstitutional prejudice because of the government's
misconduct is to suppress the evidence the government unlawfully obtained and to dismiss
Counts 5 and 6.
***
AUSA
breached two separate but equally consequential duties: The duty of a
public prosecutor and the duty of candor.
"[T]he responsibility of a public prosecutor differs from that of the usual advocate; his
duty is to seek justice, not merely to convict." Young V. United States, 481 U.S. 787, 803 (1987).
Prosecutors are held to a higher standard, and for good reason. "[The prosecutor] is in a peculiar
and very definite sense the servant of the law, the twofold aim of which is that guilt shall not
escape or innocence suffer." Berger V. United States, 295 U.S. 78, 88 (1935).
Moreover, "[i] light of the prosecutor's public responsibilities, broad authority and
discretion, the prosecutor has a heightened duty of candor to the courts and in fulfilling other
professional obligations." ABA Criminal Justice Standards, Prosecution Function, Standard 3-
1.4 (4th ed. 2017). "While all lawyers owe a duty of honesty and candor to the Court, 'this
obligation lies most heavily upon [public prosecutors] who are not merely partisan advocates, but
public officials charged with administering justice honestly, fairly and impartially." Morales V.
Portuondo, 165 F. Supp. 2d 601, 612 (
2001).
24
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=== Page 30 ===
In turn, this already high standard ratchets up even higher when a prosecutor appears
before the court ex parte. "The duty of candor is, if anything, more critical when ex parte
applications are made to a court." In re WinNet R CJSC, 2017 WL 1373918, at *9
(
No.
16MC484(DLC), Apr. 13, 2017); see
Rules of Professional Conduct, Rule 3.3(d) ("In an ex
parte proceeding, a lawyer shall inform the tribunal of all material facts known to the lawyer that
will enable the tribunal to make an informed decision, whether or not the facts are adverse."); see
also id. cmt. [14]. And it "is not a defense to claim that, while factual statements to the Court
were materially misleading, they were not literally false. Attorneys are officers of the Court, and
our system of justice cannot operate efficiently if the Court cannot rely on the candor of counsel
presenting an application for ex parte relief." Four Star Fin. Servs., LLC V. Commonwealth
Mgmt. Assocs., 166 F. Supp. 2d 805, 810
(
2001).
AUSA
failed to live up to these standards. In an ex parte proceeding, AUSA
affirmatively misled Judge McMahon, with full knowledge of what issue concerned
Judge McMahon and what information would be material to her decision. When, as here, "there
has been a fraud upon the court," Cortina, 630 F.2d at 1216, "[t]he court has inherent authority
to regulate the administration of criminal justice among the parties before the bar
[by]
exclud[ing] evidence taken from the defendant by willful disobedience of law," id. at 1214.
United States V. Lambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent
authority to suppress evidence gathered unlawfully in order to maintain the integrity of its own
proceedings ").
25
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=== Page 31 ===
B. At a Minimum, this Court Should Order a Hearing at which Maxwell
May Inquire into the Circumstances Surrounding the Government's
Misrepresentation to Judge McMahon.
"An evidentiary hearing is normally required to address motions to suppress where a
factual issue is in dispute." United States V. Paredes-Cordova, No. S1 03 CR. 987DAB, 2009
WL 1585776, at
-
June 8, 2009); United States V. Pena, 961 F.2d 333, 339 (2d Cir.
1992) ("[A] evidentiary hearing on a motion to suppress ordinarily is required if the moving
papers are sufficiently definite, specific, detailed, and nonconjectural to enable the court to
conclude that contested issues of fact going to the validity of the search are in question."
(quotation omitted))). Here, the government has confessed enough facts to demonstrate that
Maxwell at least is entitled to a hearing.
There is no merit to the government's assertion that Maxwell is not entitled to a hearing
because she has not submitted an affidavit in support of her Motion. An affidavit is not a
prerequisite to a hearing when the government has confessed the existence of facts sufficient to
entitle a defendant to an evidentiary hearing.
Nor is an affidavit required when information at issue is peculiarly within the possession
of the government (e.g., AUSA
and AUSA
) or others who are adverse to
Maxwell (e.g., Boies, Edwards, Skinner, Pottinger). See Cortina, 630 F.2d at 1216 ("The
violation here is particularly insidious because it is difficult to uncover misrepresentations in an
[ex parte submission]. The information needed to prove such assertions false is peculiarly within
the hands of the government."). Since Maxwell was not at the February 29 meeting or copied on
any of the emails or communications that followed, the Response does not explain how Maxwell
could possibly submit an affidavit attesting to the government's misrepresentations based on
personal knowledge.
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=== Page 32 ===
The government of course does not suggest that any of its agents, such as AUSA
,
would be willing to provide an affidavit to Maxwell or otherwise speak with defense
counsel absent compulsion from this Court. Indeed, the government conspicuously did not attach
to its Response any affidavits about its interactions with Boies Schiller.
It's plain, therefore, that this Court should hold an evidentiary hearing and effectuate
Maxwell's constitutional right to compulsory process because that is the only way to get to the
truth.
22
Conclusion
For these reasons, as well as those given in the Motion, this Court should: (1) suppress all
evidence the government obtained from Boies Schiller and any other evidence derived
therefrom; or (2) suppress the April and July 2016 depositions and all evidence derived
therefrom; and (3) dismiss Counts Five and Six. Maxwell requests an evidentiary hearing on this
Motion.
Dated: March 15, 2021
22 If this Court concludes an affidavit is required before it holds a hearing, Maxwell requests
leave, as she did in her Motion, to attempt to obtain such an affidavit. But if, as is likely, none of the
participants-e.g., AUSA
, AUSA
,
Boies, Edwards, Skinner, Pottinger-voluntarily
provides an affidavit, Maxwell invokes her constitutional right to compulsory process and this Court's
authority to compel testimony in support of her defense. U.S. CONST. amend. VI.
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=== Page 33 ===
Respectfully submitted,
s/ Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON MORGAN & FOREMAN P.C.
Christian R. Everdell
COHEN & GRESSER LLP
Bobbi C. Sternheim
Law Offices of Bobbi C. Sternheim
Attorneys for Ghislaine Maxwell
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=== Page 34 ===
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 Under the Due Process Clause to Suppress All Evidence Obtained from
the Government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six upon the
following:
U.S. Attorney's Office, SDNY
s/ Christian R. Everdell
29
EFTA00029133


