# docs_fts_content

c1: EFTA00031094
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031094.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: PAE and Litigation priorities
Date: Wed, 14 Oct 2020 14:25:59 +0000
Embedded: RE:_PAE_and_Litigation_priorities.msg
Sender:
Subject: RE: PAE and Litigation priorities
Message-Id:
<BN3P110MB0468608C87F9139E44EBDFA8FC050@BN3P110MB0468.NAMP110.PROD.OUTLOOK.COM
>
To
Cc
EFTA00031094


c1: EFTA00030173
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030173.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Subject: warrant application
Date: Sun, 07 Jul 2019 12:06:47 +0000
Attachments: 20190707_image_075103.pdf
FBI New York
VCAC/Human Trafficking
EFTA00030173


c1: EFTA00030605
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030605.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: GM -- search warrant returns
Date: Tue, 20 Oct 2020 19:58:15 +0000
Embedded: RE: GM -- -_search _warrant_returns.msg
Sender:
Subject: RE: GM -- search warrant returns
Message-Id:
<SN5P110MB0542D4437862DDBC826AB95C921F0@SN5P110MB0542.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
Cc:
Cc:
EFTA00030605


c1: EFTA00031424
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031424.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
,
Subject: Victim list
Date: Mon, 12 Apr 2021 19:58:36 +0000
Attachments: Epstein.xlsx; maxwell.xlsx
Hi All,
let me know you guys were looking for the victims in Epstein and Maxwell. Attached is all that's in VNS. Hope this
helps. Please let me know if you need anything more.
Thank you,
Victim Witness Assistant
U.S. Department of Justice
U.S. Attorney's Office, SDNY
One St. Andrew's Plaza
New York, New York 10007
EFTA00031424


c1: EFTA00031856
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031856.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Cc; Arraignment NYSD <Arraignment@nysd.uscourts.gov>,
Subject: RE: Signed warrant
Date: Tue, 30 Jun 2020 16:15:28 +0000
Attachments: Exhibit A - Maxwell signed indictment.pdf; Exhibit B -
Maxwell_arrest_warrant_signed.pdf
Inline-Images: image001.jpg
Thank you very much. I don't see the exhibits to the affidavit in the pdf you sent, so I am attaching them here to make
sure they are saved in the Court file with the affidavit and warrant.
Thank you again,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
From:
Sent: Tuesday, June 30, 2020 11:58 AM
To:
is
Cc: Arraignment NYSD <Arraignment@nysd.uscourts.gov>;
Subject: FW: Signed warrant
Good morning
Your Signed warrant and application is attached.
Have a great day
UNITED STATES COURT
Arraignment Unit Clerk
United States District Court
Southern District of New York
500 Pearl Street
New York NY 10007
Phone
8
FAX: 2
EFTA00031856

=== Page 2 ===
Fro
Sent: Tuesday, June 30, 2020 11:50 AM
To:
Subject: FW: Signed warrant
From:
)
Sent: Tuesdav. June 30. 2020 11:42 AM
Td
Cc:
>;
Subject: FW: Signed warrant
Good morning,
Would it be possible to get stamped copies of this warrant reflecting the docket number, please?
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York NY 10007
From:
Sent: Monday, June 29, 2020 5:58 PM
To:
)
y
Subject: FW: Signed warrant
From
Sent: Monday, June 29, 2020 5:36 PM
To:
Subject: Fwd: Signed warrant
Get Outlook for iOS
From: KHP_Warrants NYSD
Sent: Monday lune 29. 2020 5:31:08 PM
T
Cc
Su
EFTA00031857

=== Page 3 ===
From
Sent: Monday, June 29. 2020 8:56 PM
To
Arraignment NYSD <Arraignment@nysd.uscourts.gov>
Cc.
P_Warrants NYSD
Subject: Signed warrant
Get Outlook for iOS
EFTA00031858


c1: EFTA00031909
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031909.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: I have the Epstein team here
Date: Mon, 06 Jan 2020 17:34:05 +0000
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00031909


c1: EFTA00029992
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029992.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Visit of Attorney General William P. Barr
United States Attorney's Office for the Southern District of New York
October 10, 2019
MCC-Epstein Investigation
and
will present on
their investigation into the events at the Metropolitan Correctional
Center on August 9-10, 2019, the night that Jeffrey Epstein committed
suicide. In the last two months, our Office, along with agents from the
FBI and DOJ-OIG, have interviewed more than 40 witnesses, including
27 MCC employees and 16 inmates at MCC; reviewed records from the
MCC as well as financial records for the relevant employees; conducted
searches of the cellphones used by certain of the relevant prison guards,
and reviewed dozens of hours of the limited videotape evidence the FBI
has thus far been able to recover in the face of technical data recovery
issues.
The investigation has determined principally that the two prison officers
responsible for the SHU area during the night of August 9 and early
morning hours of August 10 - Michael Thomas and Tova Noel - did not
conduct any of the required institutional "counts" at 12 a.m., 3 a.m., and
5 a.m., nor did they conduct most of the "rounds" they were required to
conduct every 30 minutes. In particular, it appears that no prison official
observed Epstein from approximately 9:30 pm on the evening of August
9 until his body was discovered at approximately 6:30 a.m. the next
morning. Thomas and Noel also falsified numerous forms, indicating
that they had performed the required rounds and counts overnight
although they did not actually do so. Instead, Thomas and Noel were
performing other tasks, using the computer, talking, or sleeping during
their overnight shift. In addition, the investigation has determined that,
contrary to MCC policy and a directive from the Chief Psychologist and
then-Warden, Epstein was left without a cellmate from the morning of
August 9 through his death on the morning of August 10. It is not clear
that either Thomas or Noel was specifically made aware of the directive,
although Thomas had been on duty in the SHU during Epstein's prior
suicide attempt and they were both trained on MCC policy and had the
ability to assign Epstein a new cellmate.
The case is being handled by the Office's Public Corruption Unit, led by
Co-Chiefs
EFTA00029992

=== Page 2 ===
Visit of Attorney General William P. Barr
United States Attorney's Office for the Southern District of New York
October 10, 2019
Nine Trey Prosecution
will be presenting on this
important gang-violence prosecution, which culminated in a trial
conviction last week.
In the spring of 2018, our Office began an investigation into high-
ranking members of the Nine Trey Gangsta Bloods, a violent set of the
Bloods gang. Working with our law enforcement partners from the
NYPD, HSI, and ATF, the team built a racketeering case against some
of the highest ranking and most violent members of Nine Trey. Our
investigation resulted in charges against 14 members and associates of
the gang, including its leaders and shooters.
Nine Trey was responsible for distributing large amounts of heroin and
fentanyl, as well as brazen acts of violence across New York City,
including two shootings in Times Square, a shooting inside the Barclays
Center, and other shootings, robberies, and slashings near residential
housing complexes. Our investigation included the use of multiple
cooperating witnesses, including a world-famous rap artist, who
promoted the gang through his music and used the gang for protection
and to taunt rivals.
Of the 14 defendants, nine pled guilty; three pled guilty pursuant to
cooperation agreements; and two were convicted of racketeering and
narcotics offenses following trial.
The case is being handled by the Office's Violent & Organized Crime
Unit, led by Co-Chiefs
and
Co-Chief, Violent &
Co-Chief, Violent &
Organized Crimes Unit
Organized Crime Unit
EFTA00029993

=== Page 3 ===
Visit of Attorney General William P. Barr
United States Attorney's Office for the Southern District of New York
October 10, 2019
"Hard Knocks" Prosecution
will present on this far-reaching sex-trafficking operation,
which they have investigated and prosecuted in partnership with the FBI
and NYPD.
The investigation began when the FBI's Child Exploitation and Human
Trafficking Task Force received a tip from a non-profit organization
about the sex trafficking of minor victims in and around New York City.
Many of these minor victims were residing, or had resided, at a particular
foster care facility in Westchester County, the Hawthorne Residential
Treatment Facility. The investigation expanded as minor victims
identified other minor victims and particular pimps for whom they had
worked, including pimps who had used significant violence to force them
into prostitution.
As part of this investigation, the team has charged 19 defendants in eight
separate cases, involving dozens of victims. To date, 13 have been
convicted, including two following jury trials.
The case is being handled by the Office's General Crimes Unit, led by
Co-Chief
and Acting Co-Chief
Co-Chief, General Crimes Unit
Acting Co Chief, General Crimes Unit
EFTA00029994


c1: EFTA00031355
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031355.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10621156 approved by
, now awaiting further
approval
Date: Fri, 13 Sep 2019 01:38:28 +0000
Importance: Normal
Dear
Travel authorization 10621156 has been approved by
now awaiting further approval.
Trip ID: 10621156
Traveler name:
Purpose: R19NYS13832 - U.S. V. Epstein (2018R0618) - Victim Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-09-09 - 2019-09-10
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
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# T0007
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.
EFTA00031355


c1: EFTA00030967
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030967.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: RE: RE:
Date: Wed, 21 Aug 2019 18:09:45 +0000
Come by
From:
Sent: Wednesday, August 21, 2019 2:00 PM
To:
(USANYS)
Subject: FW: RE:
l'll come chat with you - this is the proposed correction.
From: Brown, Jeffrey
Sent: Wednesday, August 21, 2019 13:20
To:
Subject: Re: RE:
Governor Bill Richardson offered his assistance in the Jeffrey Epstein investigation through his lawyer, Jeff
Brown of Dechert LLP, to the US Attorney for the Southern District of New York. In response to this offer, Mr.
Brown was informed by the Assistant US Attorney responsible for the case that Governor Richardson is neither
a target, subject, nor witness in the case and that there is no allegation against Governor Richardson about
which the government is seeking a response from Gov. Richardson at this time.
"It's fair to conclude that the federal prosecutors investigating this matter do not believe at this time the
Governor participated in or witnessed the criminal activity Jeffrey Epstein is alleged to have committed," said
Mr. Brown.
Furthermore, Governor Richardson has never been contacted by any party to a lawsuit involving Epstein, nor
by any law enforcement investigating Epstein. Governor Richardson hopes that the investigation continues so
that Epstein's victims can finally have their day in court and see the justice they deserve.
Jeffrey Brown
Dechert LLP
1095 Avenue of the Americas
New York, New York 10036
Direct:
Fax:
On Aug 21, 2019, at 1:12 PM,
)
wrote:
Hey no attachment, please re-send? Thanks.
EFTA00030967

=== Page 2 ===
From: Brown, Jeffrey
Sent: Wednesday, August 21, 2019 13:00
To:
Subject:
is this the edit you are looking for? I apologize again for this.
Jeffrey Brown
Dechert LLP
1095 Avenue of the Americas
New York, New York 10036
Direct:
Fax:
This e-mail is from Dechert LLP, a law firm, and may contain information that is confidential or privileged. If
you are not the intended recipient, do not read, copy or distribute the e-mail or any attachments. Instead, please
notify the sender and delete the e-mail and any attachments. Thank you.
This e-mail is from Dechert LLP, a law firm, and may contain information that is confidential or privileged. If
you are not the intended recipient, do not read, copy or distribute the e-mail or any attachments. Instead, please
notify the sender and delete the e-mail and any attachments. Thank you.
EFTA00030968


c1: EFTA00030515
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030515.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Epstein discovery deadline
Start Date: 2019-10-31 21:00:00 +0000
End Date: 2019-10-31 21:00:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2019-07-31 16:22:53 +0000
Date Modified: 2019-07-31 16:22:53 +0000
Priority: 5
DTSTAMP: 2019-07-31 16:01:56 +0000
Attendee:
)
i
)
Alarm: Display the following message 15m before start
Reminder
EFTA00030515


c1: EFTA00030174
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030174.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Epstein
Date: Sun, 07 Jul 2019 15:55:25 +0000
Importance: Normal
thanks man : )
From:
Sent: Sunday, July 07, 2019 11:27
To:
Subject: Re: Epstein
Congrats!
Sent from my iPhone
On Jul 7, 2019, at 11:12 AM,
wrote:
It is indeed
From: G
Sent: Sunday, July 07, 2019 10:45
To:
Subject: Epstein
I assume this is you?
https://www.google.com/amp/s/www.nytimes.com/2019/07/06/nyregion/jefrey-epstein-arrested-sex-
trafficking.amp_html
Sent from my iPhone
EFTA00030174


c1: EFTA00031093
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031093.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Ce:
Subject: SDNY NEWS CLIPS, OCTOBER 6, 2020
Date: Tue, 06 Oct 2020 15:14:58 +0000
Inline-Images: image001.png
OFFICER OF
SDNY PRESS CLIPPINGS
THE
ENITED
DEPARTMENT
JUSTITIA
EPSTEIN: https://www.bnnbloomberg.ca/bnp-paribas-hit-with-subpoena-seeking-to-trace-epstein-funds-1.1503892
HERNANDEZ, ET AL
PAGESIX: https://pagesix.com/2020/10/05/party-stunt-lands-tekashi-6ix9ine-associate-kooda-b-in-jail/
MATTTERS OF INTEREST
WSJ: https://www.wsj.com/articles/irs-investigating-nras-wayne-lapierre-for-possible-tax-fraud-11601923467
POLITICO: https://www.politico.com/news/2020/10/06/eric-holder-william-barr-weaponized-doj-426747
NYPOST: https://nypost.com/2020/10/05/no-nypd-cops-disciplined-for-violating-mask-rules-despite-complaints/
NYT: htps://www.nytimes.com/2020/10/05/us/politics/attorney-general-bar-coronovirus.html
DAILYNEWS: https://www.nydailynews.com/new-york/nyc-crime/ny-nypd-commisioner-dermot-shea-20201006-rgyfwtzr6bctngcyahru34gia-story.html
HUFFPO: https://www.hufpost.com/entry/e-jean-carroll-trump-rgpe-allegation_n_5f7c72dac5b612290057854c
NYT: htps://www.nytimes.com/2020/10/05/nyregion/eric-trump-investigation-election.html
TPM: ttps://talkingpointsmemo.com/news/the-justice-department-moy-hove-violated-attorney-genera-bors-own-policy-memo
WAPO: https://www.washingtonpost.com/politics/2020/10/05/trumps-barrgge-new-claims-voter-fraud-have-been-disproven/
DOJ Week in Review-last week's video
EFTA00031093


c1: EFTA00030602
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030602.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: Copies
Date: Mon, 19 Oct 2020 19:35:49 +0000
Embedded: RE:_Copies.msg
Sender:
Subject: RE: Copies
Message-Id:
<CY1P110MB05680A9747309EC082DB24668F1E0@CY1P110MB0568.NAMP110.PROD.OUTLOOK.COM
>
To:
Cc:
EFTA00030602


c1: EFTA00031851
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031851.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
(USANYS) 8"
Subject: RE: Press Conference Advisory, Thursday, July 2, 2020, 12:00 p.m.
Date: Thu, 02 Jul 2020 18:32:01 +0000
Thank you, sir!
From:
(USANYS) 8
Sent: Thursday, July 2, 2020 10:57 AM
To:
is
is
Subject: Fwd: Press Conference Advisory, Thursday, July 2, 2020, 12:00 p.m.
You are American heroes. Congratulations!
Sent from my iPhone
Begin forwarded message:
From: "Press-Office, SDNY (USANYS)"
Date: July 2, 2020 at 9:49:14 AM EDT
Subject: Press Conference Advisory, Thursday, July 2, 2020, 12:00 p.m.
<U.S. V. Ghislaine Maxwell Indictment.pdf>
EFTA00031851


c1: EFTA00031423
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031423.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: Reminder -- Monthly Updates
Date: Tue, 07 Jul 2020 01:18:04 +0000
Attachments: :PC_Unit_-- Short_Form_Update.7.6.20.docx
See attached for PCU.
From:
(USANYS)
Sent: Monday, July 6, 2020 7:56 AM
To:
(USANYS)
is
(USANYS)
>;
(USANYS)
is
(USANYS) 1
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
(USANYS)
i
(USANYS)
is
(USANYS) 6
i
(USANYS)
(USANYS)
is
(USANYS) 3
is
)
1
is
(USANYS)
Subject: Reminder -- Monthly Updates
Good morning!
If anyone has not sent John their monthly updates, please do so today. Thanks very much.
Chief, Criminal Division
United States Attorney's Office, SDNY
EFTA00031423


c1: EFTA00031384
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031384.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(NY) (FBI)"
To:
)"
Cc:
)"
(USANYS)"
Subject: RE: New Investigation
Date: Thu, 06 Dec 2018 23:08:39 +0000
Attachments: export_report.pdf
Thanks! Attached is the clear report.
From:
)
[mailto:
Sent: Thursday, December 06, 2018 5:46 PM
To:
(NY) (FBI)
>;
Cc:
is
(USANYS)
Subject: RE: New Investigation
Thanks for taking the time to meet today-attached are the documents we mentioned.
From:
(NY) (FBI)
Sent: Thursday, December 6, 2018 1:40 PM
To:
is
)
Cc:
is
(USANYS)
Subject: Re: New Investigation
I am still in NJ. I have everything we have downloaded to CD.
at the office. I can bring it when we meet.
Original message
From:
:
Date: 12/6/18 1:38 PM (GMT-05:00)
To:
)"
Cc:
)"
N
(USANYS)"
i
(NY) (FBI)"
Subject: Re: New Investigation
I'm in the proffer and do not have the disc with me. If I'm not mistaken
may still be in NJ. If I finish up
over here earlier then expected I'll ran back and grab it.
On Dec 6, 2018, at 12:59,
)
wrote:
Hi all-looking forward to meeting this afternoon. If you're able to bring over a copy of the files on this case (we'll take
as much stuff as possible!), we'd really appreciate it. CD or drive are both fine.
Thanks!
EFTA00031384

=== Page 2 ===
From:
Sent: Tuesday, December 4, 2018 7:19 PM
To:
is
(USANYS)
is
(NY)
(FBI)
Cc:
Subject: RE: New Investigation
No worries at all, and I'll make 4:30 work.
From:
Sent: Tuesday, December 04, 2018 19:16
To:
is
,
(USANYS)
is
(NY) (FBI)
Cc:
Subject: Re: New Investigation
I have child care issues in the mornings typically, and getting in by 11:00 is often difficult as I live in Suffolk
County. 4:30 works better for me. Sorry about that!
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
From:
Sent: Tuesday, December 4, 2018 7:06:28 PM
To:
;
(USANYS);
(NY) (FBI)
Cc:
)
Subject: RE: New Investigation
I unfortunately have calls at 4:00 and 4:30. Could we do earlier before 11:00? I'm also concerned that if the proffer
ends up going late we'll be out of luck. Or I can move the 4:30 if
preferable for everybody. Sorry about that.
From:
Sent: Tuesday, December 04, 2018 19:04
To:
is
(USANYS)
is
;
(NY) (FBI)
Cc:
Subject: Re: New Investigation
11:00 will not work for me. Me and
are good for 4:00 on Thursday though. The proffer should be
done by then.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
EFTA00031385

=== Page 3 ===
From:
)
Sent: Tuesday, December 4, 2018 6:34:53 PM
To:
;
(USANYS);
(NY) (FBI)
Cc:
)
Subject: RE: New Investigation
do Thursday, particularly since schedules seem to be tough next week.
would it make sense to meet before
your proffer, so we can have a specified time? We could meet at 11:00.
thanks,
From:
Sent: Tuesday, December 04, 2018 15:54
To:
(USANYS)
>;
(NY) (FBI)
Cc:
is
)
Subject: Re: New Investigation
Hey guys,
Thursday I have a proffer at SNDY with SA
at 12:00. I can meet after that if you guys want depending
on how long this proffer goes. That may be the best option for us because Monday-Wednesday of next week
we may be tied up with a take down in the office.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
From:
(USANYS)
Sent: Tuesday, December 4, 2018 3:30:14 PM
To:
(NY) (FBI);
Cc:
);
Subject: RE: New Investigation
Thursday works for me.
Next week I am good Monday-Tuesday and Thursday-Friday.
From:
(NY) (FBI)
Sent: Tuesday, December 04, 2018 3:23 PM
To:
(USANYS)
i
Cc:
is
Subject: RE: New Investigation
Hey
EFTA00031386

=== Page 4 ===
The only day I'd be free this week would be Thursday. Next Wednesday is not good, but any other day next week I
should be ok right now.
I'm also working on putting everything we currently have onto a disk for you, so I should have that for you when we
meet.
From:
(USANYS) [mailto:
Sent: Tuesday, December 04, 2018 2:14 PM
To:
(NY) (FBI)
is
(NY) (OGA)
Cc:
is
)
Subject: RE: New Investigation
good speaking with you. I understand that you and
were just assigned the case yesterday and are just
starting to dig in. As we discussed I think it makes sense for us all to get into a room together son and chat.
When works for you guys?
From:
(USANYS)
Sent: Monday, December 03, 2018 5:51 PM
To:
,
(NY) (FBI)
is
(NY) (OGA) (FBI)
Cc:
)
is
)
Subject: New Investigation
and
We got the package you dropped off today. Thank you. CC'ing the other members of the team on this email.
Best,
Assistant United States Attorney
Human Trafficking Co-Coordinator
Violent & Organized Crime
Southern District of New York
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From:
"
)"
To:
)"
)"
Bcc:
"
Subject: RE: Brunel
Date: Fri, 12 Feb 2021 20:46:34 +0000
Embedded: RE:_Brunel.msg
Sender:
Subject: RE: Brunel
Message-Id:
M>
To:
To:
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=== Page 1 ===
From:
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:30:27 +0000
Inline-Images: image001.png
Congrats!!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
ENTTED QUI PRO DOMINA JUSTITIA OF JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
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.
EFTA00030347

=== Page 2 ===
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 [1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
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.
EFTA00030348

=== Page 3 ===
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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From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
Subject: RE: Noel/Thomas FOIA Disclosure
Date: Wed, 23 Jun 2021 21:12:19 +0000
Attachments: 062321_Times_v_BOP_20cv833_Extension_Request.docx
Hi all,
We now have a 5:45 call scheduled with the Times. Please let me know before then if there's any other info I can share
with them. I'm attaching a draft extension request letter here for review. Please let me know if this looks okay, or if we
need to discuss anything,
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 3:46 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Hi all,
I just spoke with
, who spoke with
I can make this request, but I am not sure it will be successful. Before I
speak to the Times about it, I need to know a little bit more info about what I can share with the Times and what is going
on. Could someone please give me a call at
?1 need to connect with the Times as soon as possible because
we will need to put in the request today to PAE.
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 3:02 PM
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
Subject: RE: Noel/Thomas FOIA Disclosure
Hi
Could I give you a quick call on this?
Thanks,
From:
(USANYS)
Sent: Wednesday, June 23, 2021 2:57 PM
To:
(USANYS)
EFTA00029702

=== Page 2 ===
Cc:
(USANYS)
is
(USANYS)
Subject: Noel/Thomas FOIA Disclosure
Hi
We understand you had been planning to make the Noel/Thomas FOIA disclosure on Friday. We just ran this by
and she'd like you to ask for a brief (1-2 week) extension to enable us to confer internally regarding the interviews, which
were just completed, to confirm we agree they've fulfilled that requirement of their deferred prosecution agreements.
She's going to speak with
about it as well. Is this doable?
Thanks,
Chief, Public Corruption Unit
U.S. Attorney's Office
Southern District of New York
Desk
Cell
EFTA00029703


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From:
)"
To:
(USANYS)"
Subject: RE: Marshals Intake Form
Date: Wed, 22 Jul 2020 21:01:24 +0000
Thank you!
From:
(USANYS)
Sent: Wednesday, July 22, 2020 17:00
To:
>; USANYS-INVESTIGATORS
Subject: RE: Marshals Intake Form
See attached.
From:
Sent: Wednesday, July 22, 2020 4:46 PM
To: USANYS-INVESTIGATORS
Subject: Marshals Intake Form
Please process the following:
Requestor's Phone Number:
Name / Alias(es): Ghislaine Maxwell
Court Number: 20 Cr. 330 (AJN)
USAO Number: 2018R01618
USMS Number: 02879-509
Arrest Date: 07/02/20
Date of Birth:
Documents: Email
Photo:
Email
Remarks:
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 28, 2020
By Electronic Mail
Christian Everdell, Esq.
Bobbi Sternheim, Esq.
Mark Cohen, Esq.
Law Offices of Bobbi C. Sternheim
Cohen & Gresser LLP
33 West 19th Street-4th Fl.
800 Third Avenue
New York, NY 10007
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
We write in response to your letter of October 13, 2020 setting forth "requests for
discovery, inspection, and copying, in accordance with the guarantees of the Fourth, Fifth, and
Sixth Amendments, Rule 16 of the Federal Rules of Criminal Procedure, the Federal Rules of
Evidence, and such other laws and rules as may be applicable." The letter lists 22 specific requests
(the "Requests"). The letter also makes a general request for materials pursuant to Brady V.
Maryland, 373 U.S. 83 (1963) and Kyles V. Whitley, 514 U.S. 419 (1995), followed by 10 "specific
Brady requests."
As an initial matter, we take seriously our disclosure obligations, including those arising
under Rule 16, Brady and its progeny, and Giglio V. United States, 405 U.S. 150 (1972) and its
progeny, and we intend to comply fully with those obligations. We intend to do so irrespective of
whether you specifically request such material, or how you characterize that material. Indeed, as
you are aware, we have already made substantial productions pursuant to Rule 16 and otherwise
in this case. The Government will continue to fulfill all of its obligations going forward.
However, your unilateral assertion that particular items constitute "Brady materials" does
not itself render those materials subject to disclosure, let alone immediate disclosure some nine
months before trial. To the contrary, a substantial amount of the materials sought in the Requests
are plainly material to which you are entitled, if at all, solely pursuant to Title 18, United States
EFTA00030569

=== Page 2 ===
Code, Section 3500 (hereinafter "3500 material") or Giglio V. United States, 405 U.S. 105 (1972)
and its progeny (hereinafter "Giglio material"). As you are aware, it is the standard practice in this
District that such material is produced shortly in advance of trial, a practice that has been widely
held to be sufficient to satisfy the requirement that Giglio be produced "in sufficient time that the
defendant will have a reasonable opportunity to act upon the information efficaciously." United
States V. Rodriguez, 496 F.3d 221, 226 (2d Cir. 2007). Immediate disclosure of such material is
not warranted simply because the defendant prefers it. See, e.g., United States V. Wey, 15 Cr. 611
(AJN), 2017 WL 237651, at *23 (S.D.N.Y. Jan. 18, 2017) (denying defendant's motion for
immediate disclosure of Giglio material as defendant "fails to articulate any persuasive reason why
immediate disclosure is required in this case, and the Court otherwise sees no basis to deviate so
substantially from the typical practice"); United States V. Thompson, 13 Cr. 378 (AJN), 2013 WL
6246489, at *9 (S.D.N.Y. Dec. 3, 2013) (denying request for early production of Jencks Act
material); United States V. Hernandez, No. 09 Cr. 625 (HB), 2010 WL 26544, at *6 (S.D.N.Y. Jan.
6, 2010) (declining to order immediate disclosure of Giglio material, because the Government
stated it would provide both Giglio and Jencks Act material "shortly before trial"); United States
V. Davis, No. 06 Cr. 911 (LBS), 2009 WL 637164, at *14 (S.D.N.Y. March 11, 2009) ("The Second
Circuit has held that a request for immediate or early disclosure [of Giglio material] has no basis
in the law.").
Consistent with that well-established practice, we intend to begin producing any 3500 and
Giglio material substantially closer to trial. As we have indicated in prior letters to you and the
Court, the Government is prepared to produce all statements and impeachment material for
witnesses it expects to call at trial as early as four weeks prior to trial. Additionally, the
Government is prepared to produce any statements by witnesses who it does not expect to call at
trial as early as eight weeks prior to trial, subject to restrictions to protect those individuals' privacy
to be negotiated by the parties. We note that, to date, the parties have not engaged in any
discussions about a schedule for pretrial disclosures, but we are prepared to discuss such a schedule
at your convenience.
In return, we reiterate our request that the defendant disclose prior statements of any
witnesses she 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 such material relating to Government witnesses, and we are amenable
to discussing a schedule for all parties' pretrial disclosures. We also reiterate our request for
reciprocal discovery under Fed. R. Crim. P. 16(b).
With respect to your remaining requests, we endeavor to respond directly to those below.
By voluntarily providing this information, the Government is not limiting its evidence, arguments,
or legal theories at trial in any way. If you have any questions or would like to confer further,
please let us know and we will be happy to arrange a call or meeting to confer further at a mutually
convenient time.
Request 1 - Any Oral, Written, or Recorded Statements Made by the Defendant: As
noted in your request, the Government has produced statements made by the defendant in prior
civil proceedings, as well as statements made at the time of her arrest. The Government is not
aware of any other statements the defendant has made to law enforcement.
2
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=== Page 3 ===
Request 2 - Statements of Alleged Co-Conspirators: To the extent that your request
seeks disclosure and identification of any statements of alleged co-conspirators that the
Government intends to introduce at trial, this request is premature and without legal basis. To the
extent the materials the defendant seeks may fall within the Jencks Act, the Jencks Act provides
that "[i]n any criminal prosecution brought by the United States, no statement or report in the
possession of the United States which was made by a Government witness or prospective
Government witness (other than the defendant) shall be the subject of subpoena, discovery, or
inspection until said witness has testified on direct examination in the trial of the case." 18 U.S.C.
§ 3500(a). In addition, Rule 16 exempts from production, prior to trial, the materials the defendant
seeks: "[T]his rule does not authorize the discovery or inspection of reports, memoranda, or other
internal government documents made by an attorney for the government or other government agent
in connection with investigating or prosecuting the case. Nor does this rule authorize the discovery
or inspection of statements made by prospective government witnesses except as provided in 18
U.S.C. $ 3500." Fed. R. Crim. P. 16(a)(2). In light of these provisions, requests for discovery of
Jencks Act materials in advance of trial are uniformly denied in this District. Indeed, there is no
legal basis to order the disclosure of statements of Government witnesses before their direct
testimony at trial. See In re U.S., 834 F.2d 283, 284-87 (2d Cir. 1987) (issuing a writ of mandamus
reversing District Court's order directing the Government "to produce all oral statement made by
the defendants and coconspirators that the Government planned to offer at trial as admissions of a
defendant" under Fed. R. Evid. 801); United States ex rel. Lucas V. Regan, 503 F.2d 1, 3 n.1 (2d
Cir. 1974); United States V. Sebastian, 497 F.2d 1267, 1268-69 (2d Cir. 1974); United States V.
Percevault, 490 F.2d 126, 132 (2d Cir. 1974).
Further, disclosure of any statements of alleged co-conspirators would necessitate the
identification of co-conspirators. You identify no authority for the proposition that the
Government is required to identify all known co-conspirators in connection with the charged
conspiracy that the Government may seek to prove at trial, and to the contrary, courts in this district
routinely deny similar requests. See, e.g., United States V. Castro, No. 08 Cr. 268 (NRB), 2008
WL 5062724, at *2 (S.D.N.Y. Nov. 25, 2008) ("An indictment need not identify all alleged co-
conspirators, nor specify the nature, time and place of every overt act the defendant or others
allegedly took in furtherance of a conspiracy, nor must it set forth all the evidence the government
intends to introduce."); United States V. Trippe, 171 F. Supp. 2d 230, 240 (S.D.N.Y. 2001)
("[D]emands for particular information with respect to where, when, and with whom the
Government will charge the defendant with conspiring are routinely denied."); United States V.
Fruchter, 104 F. Supp. 2d 289, 313 (S.D.N.Y. 2000) (denying "Defendants" request for names of
all aiders, abettors, unindicted co-conspirators, and confidential informants" as "nothing more than
a request for a witness list").
That said, as previously stated, we intend to produce all Jencks Act and Giglio material in
advance of trial and remain available to confer generally regarding a mutual schedule for pretrial
and trial-related disclosures, including witness statements or Giglio material.
Request 3 - Prior Criminal Records of the Defendant: The Government is not aware
of any prior convictions or arrests of the defendant.
3
EFTA00030571

=== Page 4 ===
Request 4 - Any Books, Papers, Documents, Data, Photographs, Tangible Objects,
Buildings, or Places, or Copies or Portions of Any of These Items: The Government did not
seize any documents or tangible items from the defendant, including through a search warrant. As
you are aware from discovery, the Government has obtained a number of tangible items during its
investigation through various means, including search warrants executed at properties of Jeffrey
Epstein. We have already produced copies of many of those items in discovery, and, as we
previously advised in August 2020, if you wish to inspect any of the physical evidence referenced
in the produced materials, including items listed on search inventories, please let us know, and we
will make arrangements for you to do so.
Request 5 - Results or Reports of Any Physical or Mental Examination and of Any
Scientific Test or Experiment: The Government is unaware of any physical or mental
examination or scientific tests or experiments to which you are entitled. The Government is
continuing to review files and will produce such materials to which you are entitled at the
appropriate time.
Request 6 - A Written Summary of Any Testimony the Government Intends to
Introduce at trial under Federal Rules of Evidence 702, 703, or 705: To the extent the
Government intends to call any expert to testify at trial, the Government will provide appropriate
notice reasonably before trial, as is the standard practice in this District. The Government is
prepared to engage in good faith discussions with you about a mutual schedule for pretrial and
trial-related disclosures, including expert notice.
Request 7 - The Identities of Minor Victim-1, Minor Victim-2, and Minor Victim-3
(the "Minor Victims"): Such disclosure would be entirely premature nine months before trial.
Indeed, in August, after the defendant sought an order directing the Government to disclose to
defense counsel the identities of the Minor Victims, Judge Nathan ruled that the request was
premature, noting that production of discovery had just begun and the "parties have not yet
engaged in discussions regarding an appropriate schedule for pretrial disclosures, including
witness lists and $ 3500 material." (Dkt. 49 at 1). Judge Nathan ordered that the parties "meet
and confer on an appropriate schedule" "[f]ollowing the close of discovery." (Id. at 2). The
deadline for the production of Rule 16 discovery set by the Court is November 9, 2020. (Dkt. 25).
The Government is prepared to engage in good faith discussions with the defense about an
appropriate schedule for disclosure of 3500 material.
Request 8 - The Complete Birthdays of the Minor Victims: In our discovery transmittal
letter dated August 13, 2020, the Government included the months and years of birth for each of
the Minor Victims so as to enable the defendant to evaluate whether she will make any motions or
legal arguments relating to the ages of the victims. You have not identified why you need
additional information regarding each of the Minor Victims at this time, the relevance of such
information to this case, or the basis under which such information would be subject to disclosure
or discovery at this time. Such information will be included in 3500 material for the Minor Victims
which will be produced reasonably in advance of trial.
Request 9 - All Written and Oral Communications Concerning the Negotiations
Relating to the Non-Prosecution Agreement ("NPA") Signed by Epstein on September 24,
4
EFTA00030572

=== Page 5 ===
2007: Your request does not articulate a basis in law for your assertion that you are entitled to the
materials listed in Request 9-including communications between various Government and law
enforcement entities and Epstein's attorneys and communications between and among "any
government employees"-or that such materials fall within the scope of Rule 16 or any other
disclosure obligation. Nor is the Government aware of any basis in law for this request. We note,
in this respect, that neither the defendant nor the U.S. Attorney's Office for the Southern District
of New York is a party or signatory to the NPA, nor is the defendant or this Office named therein.
As noted in the Government's letter of October 7, 2020 (Dkt. 63), although the Government
does not believe it has any obligation to gather or review emails sent or received by attorneys at
the United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") as part
of its separate, prior investigation and prosecution of Jeffrey Epstein, as set forth in greater detail
in that letter, the Government intends to gather certain martials from USAO-SDFL and conduct
targeted searches of that material aimed at identifying potential Giglio or 3500 material for victims
or witnesses relevant to this prosecution. See Dkt. 63 at 7. To the extent that review reveals such
material, it will be produced at the appropriate stage in the litigation and according to any schedule
set for pre-trial disclosures.
Request 10 - A Complete Copy of the Diary: The Government has produced all pages
of the diary in the Government's possession. The Government has never reviewed or possessed
any other portions of the diary. To the extent this request calls for information that is not currently
in the Government's possession or which is not subject to disclosure, you identify no legal basis
or authority for this request, and we are not aware of any authority requiring us to obtain and/or
disclose this information.
Request 11 - A Complete, Unredacted Copy of FBI 302 Bearing Bates Numbers
SDNY_GM_00114982-00114993: The Government has produced this particular version of the
document in the form in which it received the document in response to a subpoena, which included
redactions. To the extent the Government separately has access to an unredacted version of the
same FBI 302, the Government will produce that unredacted version, as well as all other statements
and impeachment material for witnesses, at the appropriate time, as discussed herein.
Request 12 - All Versions and Drafts of "The Billionaires Playboy Club": The
Government has produced all versions of "The Billionaires Playboy Club" in the Government's
possession of which we are currently aware. The Government has produced these materials in the
form in which it received those materials in response to a subpoena. To the extent this request
calls for information that is not currently in the Government's possession or which is not subject
to disclosure, you identify no legal basis or authority for this request, and we are not aware of any
authority requiring us to obtain and/or disclose this information.
Request 13 - Documents and Materials Related to the Minor Victims: As to your
requests for documents and materials under Requests 13(a) through (f), the Government has
produced any such materials relating to the Minor Victims listed in the Indictment that are in the
Government's possession and that fall within the scope of Rule 16. As noted in the Government's
October 7, 2020 letter (Dkt. 63), the Government is continuing to review files created and
maintained by other offices for material that may be responsive to these requests and will produce
5
EFTA00030573

=== Page 6 ===
any material identified through that review as appropriate. Additionally, as you know, the
Government is preparing a production of responsive materials from electronic devices seized
during searches of Epstein's New York and Virgin Island residences. To the extent the
Government identifies any additional materials that it intends to introduce at trial, the Government
will promptly produce such materials.
With regard to your many requests for material that might fall within the scope of the
Government's Giglio obligations, as you know and as set forth above, the uniform practice in this
District, which the Government intends to follow, is to produce Giglio and Jencks Act materials
simultaneously and shortly before trial. As noted above, this practice has been widely held to be
sufficient to satisfy the requirement that Giglio be produced "in sufficient time that the defendant
will have a reasonable opportunity to act upon the information efficaciously." Rodriguez, 496
F.3d at 226. Immediate disclosure of such material is not warranted simply because the defendant
prefers it. See, e.g., Hernandez, 2010 WL 26544, at *6; Davis, 2009 WL 637164, at *14. As noted
above, the Government is prepared to produce all statements and impeachment material for
witnesses it expects to call at trial as early as four weeks prior to trial, and statements for witnesses
who it does not expect to call at trial as early as eight weeks prior to trial.
The Government notes that, in response to your request for any submissions to the Epstein
Victims' Compensation Program made by the Minor Victims or any other witness who has alleged
that the defendant engaged in or facilitated improper sexual conduct at any time, the Government
plays no role in administering that program. As such, the Government is not in possession of any
submissions to this program. To the extent this request calls for information that is not currently
in the Government's possession or which is not subject to disclosure, you identify no legal basis
or authority for this request, and we are not aware of any authority requiring us to obtain and/or
disclose this information.
You have also requested under Request 13(i) "[a]ll communications between or among
[the Minor Victims or other witnesses who allege that the defendant engaged in or facilitated
improper sexual conduct], or between these individuals and counsel for any other such individual,
including but not limited to, emails, text messages, social media posts, and other correspondence."
The Government does not understand the basis for this request, and you identify none. To the
extent this request calls for materials that are not currently in the Government's possession or
which are not subject to disclosure, you identify no legal basis or authority for this request, and we
are not aware of any authority requiring us to obtain and/or disclose this information.
As to your request for "public statements made by these individuals concerning" Epstein
or the defendant, the Government is unaware of any authority that such material falls within the
scope of Rule 16 or that the Government is otherwise required to collect and provide materials that
are publicly available.
As to your request for records or reports of any physical, medical, mental, or psychological
examinations of these individuals, to the extent any such materials exist and are in the
Government's possession, they will be produced as part of the Government's production of Jencks
Act and Giglio material at the appropriate stage in the litigation.
6
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As to your request for all "written and oral communications between the government and
the attorneys for those individuals [certain victims]," the Government is unaware of any authority
that entitles you to these materials. To the extent such materials constitute Giglio or Jencks Act
materials, the Government will produce such materials at the appropriate time. Your request does
not articulate a basis in law for your assertion that you are entitled to such material at this time, or
that you are entitled to any such communications that do not constitute Giglio or Jencks Act
material.
Request 14 - All Written and Oral Communications and Other Documents
Concerning Meetings between the United States Attorney's Office for the Southern District
of New York and Specified Attorneys for the Minor Victims and Other Witnesses: Your
request does not articulate a basis in law for your assertion that you are entitled to such material.
The Government is unaware of any authority that entitles you to these materials.
Request 15 - Complete FBI Case File Regarding the Investigation of
for Obstruction of Justice: As noted in our discovery transmittal letter dated August
21, 2020, this file has no relation to your client and has no bearing on the charges in this case. The
Government is not aware of the relevance of such records to the conduct at issue in this case, and
you have not identified the relevance of such records, although we are willing to discuss the basis
for any such request at your convenience.
Request 16 - Copies of the Prosecution Memo and Indictment Drafted as Part of the
United States Attorney's Office for the Southern District of Florida ("USAO-SDFL"): The
Government is unaware of any authority that entitles you to the documents that you seek under
this request. To the contrary, Rule 16 exempts from disclosure "internal government documents
made by an attorney for the government or other government agent in connection with
investigating or prosecuting the case." Fed. R. Crim. P. 16(a)(1)(F)(2); see also United States V.
Armstrong, 517 U.S. 456, 463 (1996) ("[U]nder Rule 16(a)(2), [a defendant] may not examine
Government work product in connection with his case."); United States V. Ghailani, 687 F. Supp.
2d 365, 369 (S.D.N.Y. 2010) (concluding that an internal government memorandum fell within
Rule 16(a)(2) of the Federal Rules of Criminal Procedure and was therefore "protected against
disclosure regardless of its materiality.").
Request 17 - E-mails, Text Messages, Letters, or Other Written Communications To
or From the Defendant: To the extent the Government identifies material that is discoverable
under Rule 16 and responsive to this request, the Government will promptly produce such
materials. In particular, the Government has seized and worked to extract data from approximately
62 electronic devices in connection with search warrants executed at Epstein's properties. As
noted in the Government's discovery transmittal letter dated October 20, 2020, we anticipate
producing only the materials designated responsive to the terms of the search warrants. The
Government has directed its vendor to download these materials from the electronic database on
which they are stored and to have those materials ready for production to you by November 9,
2020.
Request 18 - Medical Records or Reports Concerning Epstein: The Government is not
aware of the relevance of such records to the conduct at issue in this case, and you have not
7
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identified the relevance of such records. The Government is unaware of any authority that entitles
you to these materials, and you provide none.
Request 19 - Subpoenas and Voluntary Requests for Production of Documents Issued
in Connection with or Related to this Case, and All Evidence Obtained By Subpoena or
Voluntary Production: The Government is unaware of any authority that entitles you to the
grand jury subpoenas and voluntary requests for documents that you seek under this request, and
you provide none. To the extent you seek evidence obtained by the Government "by subpoena or
from voluntary production (to the extent it has not already been produced)," the Government has
produced all subpoena returns that fall within the scope of Rule 16 that the Government has
received through the date of the indictment. The Government has also endeavored to make clear
in its productions which materials were obtained pursuant to subpoena. To the extent the
Government identifies or receives additional subpoena returns, the Government will promptly turn
over materials that fall within the scope of Rule 16. To the extent such subpoena returns contain
Giglio material or 3500 material, the Government will produce that material at the appropriate
time as agreed to by the parties and the Court. Similarly, the Government has produced and will
continue to produce materials obtained by voluntary production to the extent such materials fall
within Rule 16. To the extent such materials contain Giglio material or 3500 material, the
Government will produce such materials closer to trial on the agreed upon schedule.
Request 20 - Evidence the Government Intends to Introduce Pursuant to Federal
Rule of Evidence 404(b) or as Background of the Conspiracies: With respect to any evidence
the Government may seek to offer pursuant to Rule 404(b), as you are aware, Rule 404 requires
only that "reasonable notice of the general nature of any such evidence" be provided sometime
"before trial." Fed. R. Evid. 404(b)(2)(A)-(B). In this Circuit, that provision typically is construed
to require notice several weeks before trial. See United States V. Giffen, 379 F. Supp. 2d 337, 345
(S.D.N.Y. 2004) (in the "absence of any threat to the safety of prospective witnesses and the
Rule 404(b) evidence [is important to] th[e] action," courts in this District have generally found
that disclosures made approximately 30 to 45 days prior to trial constitute "reasonable notice" to
defendants) (quoting United States V. Nachamie, 91 F. Supp. 2d 565, 577 (S.D.N.Y. 2000); Giffen,
379 F. Supp. 2d at 344 (Rule 404 does not obligate the Government to provide "unduly early
notice" because "early disclosure presents a significant burden on preparation of the Government's
case.").
Here, and consistent with the requirements of Rule 404, the Government intends to identify
such evidence and provide notice substantially closer to trial. As noted throughout, the
Government is amenable to a discussion about a joint schedule for pretrial disclosures, including
404(b) notice, at your convenience.
Requests 21 and 22 - Information about the Grand Jury that Indicted this Case: A
grand jury sitting in White Plains, New York that was empaneled in November 2019 returned
Indictment 20 Cr. 330 (AJN) and Superseding Indictment S1 20 Cr. 330 (AJN). No grand jurors
participated remotely in any session relevant to this case. To the extent your request seeks "a list
of grand jurors, their attendance dates, [or] the reasons for any absence," as well as information on
persons present during grand jury proceedings, the Government is not aware of any authority that
entitles you to the information you seek under these requests. Grand jury proceedings are not
8
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governed by Rule 16 and therefore are not discoverable. Disclosure of information related to grand
jury proceedings is not authorized by Rule 16 and is permitted only when "ordered upon a showing
of particularized need." See United States V. Sells Engineering, 463 U.S. 418, 443 (1983) ("[w]e
have consistently construed [Rule 6(e)]
to require a strong showing of particularized need for
grand jury materials before any disclosure will be permitted"); see also Dennis V. United States,
384 U.S. 855, 869-870 (1966). This is because grand jury proceedings are afforded a "presumption
of regularity" that may be dispelled only by particularized proof of irregularities in the grand jury
process. United States V. Leung, 40 F.3d 577, 581 (2d Cir. 1994).
"[S]pecific Brady requests": The Government recognizes its obligations under Brady and
its progeny and will provide timely disclosure if and when such material comes to light. With
respect to your requests under the section titled "Exculpatory Evidence," the Government is not
aware of any evidence suggesting that Maxwell was not involved in or aware of the conduct alleged
in the Indictment. The Government will provide timely disclosure if it learns of any such material.
Certain of your requests suggest your view that any evidence that Epstein sexually abused or
assaulted a victim, but without the knowledge or participation of the defendant, is somehow
exculpatory. We note that your request is neither limited in time to the period charged in the
Indictment nor limited to victims who claim to have been minors at the time of their abuse. You
identify no basis in law for such a broad request, nor is the Government aware of one. Your request
fails to explain how, for example, evidence that a witness alleges that she was sexually abused by
Epstein, "with or without the involvement" of the defendant, but who was not a minor at the time
of the alleged sexual abuse, or who claims to have been abused years after the conduct charged in
the Indictment, is somehow exculpatory. As noted in the Government's letter of October 20, 2020,
the well-established law of this Circuit generally precludes a defendant from offering evidence
that a defendant did not participate in criminal conduct on a particular occasion-or of their law-
abiding conduct during uncharged periods or uncharged events-to rebut the Government's
evidence with respect to the charged crimes or events. Dkt. 65; see, e.g., United States V. Scarpa,
897 F.2d 63, 70 (2d Cir. 1990) ("A defendant may not seek to establish his innocence
through
proof of the absence of criminal acts on [other] specific occasions."). To the extent that you wish
to provide us grounds or any authority as to why such information would be exculpatory, please
do so.
You also request evidence concerning witnesses who contacted the Government or law
enforcement about sexual abuse by Epstein or the defendant who were determined not to be
credible, as well as "negative" investigative efforts to verify information provided by any and all
witnesses. We are unaware of any authority requiring the production of such information. If you
would like to clarify your request, and the authority for it, we will consider it further.
Many of your additional specific requests for material appear to fall within Giglio and
Jencks Acts materials, rather than Brady, including, for example, the requests for impeachment
evidence, Giglio information, evidence of bias or motive to lie, contradictory statements of any
prospective government witness, and evidence of criminal investigations or misconduct of any
government witness. As described above, the Government intends to follow the uniform practice
in this District, and produce before trial Giglio and Jencks Act materials for witnesses it expects
to call at trial, as well as any statements by witnesses who it does not expect to call at trial. The
Government has noted a proposed schedule in this letter. We are amenable to discussing an
9
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alternative schedule for mutual pretrial disclosures. We also reiterate our request that the
defendant disclose prior statements of witnesses she 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 such material relating to Government
witnesses.
To the extent you are requesting that the Government produce items beyond its Brady and
Rule 16 obligations, the Government has no such obligation at this time. See Weatherford V.
Bursey, 429 U.S. 545, 559 (1977). As you know, in all federal criminal cases, it is Rule 16 that
principally governs pretrial discovery. Rule 16 is not "intended to provide the defendant with
access to the entirety of the government's case against him." See, e.g., Percevault, 490 F.2d at
130. Nor does Rule 16 "entitle a criminal defendant to a broad and blind fishing expedition among
items possessed by the Government on the chance that something impeaching might turn up."
United States V. Delacruz, No. 14 Cr. 815 (KBF), 2015 WL 2211943, at *1 (S.D.N.Y. May 12,
2015) (internal quotation marks omitted).
If there are any specific anticipated defenses that would bear upon the Government's
ongoing review for items that may be material to preparing the defense, you are welcome to outline
such defenses.
Conclusion
The Government remains available to confer further on any of the topics outlined above.
The Government also requests that the defendant confirm whether she has, to date, met her
reciprocal disclosure obligations under Rule 16(b) and we renew our request for reciprocal
disclosure from the defendant.
Very truly yours,
Acting United States Attorney
By:
Assistant United States Attorneys
10
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
March 16, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These discovery materials
are stamped with control numbers SDNY_GM_02743101 through SDNY_GM_02743102 Please
note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective
Order in this case. 1 This letter is itself designated as "confidential," because it includes
information regarding records designated as "confidential" under the Protective Order. An
index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
Manifest of items seized by FBI
SDNY GM 02743101
SDNY GM 02743101
Florida
Confidential
1
Files in PDF format designated as "confidential" under the protective order have been stamped
"confidential." However, certain files cannot be individually labeled as confidential on the
documents themselves due to their file format.
EFTA00030108

=== Page 2 ===
Page 2
Manifest of items seized by FBI New
SDNY_GM_02743102
SDNY_GM_02743102
York
Confidential
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by
Assistant United States Attorneys
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=== Page 1 ===
July 13, 2021
Prep
AUSAs
&
SA
Det.
Prepared for trial testimony.
previously undisclosed, clarifying, or different recollections
below:
recalls that
drove a white car when
knew her
explained that GM's hair was longer when
knew GM than it is in the photograph
she identified during prior meeting. Facial features are the same, but GM's hair was
longer when
knew her.
recalls receiving approximately $300 the first time she went to JE's with
recalls her mother's cellphone number that JE's employees would call was
recalls GM asking
to get a cellphone so that she would be more easily reachable
recalls that sometimes her friends would drive her to JE's house, and JE would pay
them about $100 for driving
believes that she received the Massage for Dummies book in one of the FedEx
packages from JE
estimates she may have been about 16 when GM saw her nude in the massage room
believes JE told her to massage the fat bald man who she had sex with for money at
JE's house
SH was physically abusive and would beat
up if they could not get drugs.
has been clean for 8 months. She has used alcohol recently, but has not used hard
drugs.
does not remember what questions the FBI asked during her 2007 interview with
them.
did not know whether she was able to sue GM, but she knows she is not able
to after participating in the victim compensation fund.
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=== Page 1 ===
Event: Accepted: FBI / SDNY Epstein update mtg
Start Date: 2020-01-08 18:00:00 +0000
End Date: 2020-01-08 19:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-01-08 02:28:10 +0000
Date Modified: 2020-01-08 02:28:10 +0000
Priority: 5
DTSTAMP: 2020-01-07 21:44:38 +0000
Attendee:
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=== Page 1 ===
From: Figgins Law Office
To:
Cc:
Subject: USA V. Michael Thomas, et al.; Motion to Compel Discovery
Date: Fri, 10 Apr 2020 19:57:28 +0000
Attachments: Michael_Thomas_Motion_to_Compel_Discovery.PDF
Counsel,
Please see attached Defendant, Michael Thomas, Motion to Compel Discovery that was
refiled. Motion was also filed via ECF.
Law Offices of Montell Figgins, LLC
17 Academy Street, Suite 305
Newark, NJ 07102
140 East Ridgewood Ave, Suite 415
Paramus, NJ 07652
Montell Figgins Attorney At Law
This email communication and any files transmitted with it contain privileged and confidential information from the Law
Offices of Montell Figgins, LLC and are intended solely for the use of the individuals or entity to whom it has been addressed.
If you are not the intended recipient, you are hereby notified that any dissemination or copying of this email is strictly
prohibited. If you have received this email in error, please delete it and notify the sender by return email.
EFTA00031575


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein
Date: Fri, 03 Jan 2020 22:31:05 +0000
They didn't. Sarah Koch called to ask if we could meet at some point this month and didn't ask about anything specific.
That was about it from CBS.
From:
(USANYS)
Sent: Friday, January 3, 2020 5:29 PM
To:
(USANYS)
Subject: Re: Epstein
Ha, I only know because someone else sent it to me earlier - I take it they never reached out to us for comment?
Sent from my iPhone
On Jan 3, 2020, at 5:22 PM,
(USANYS)
wrote:
LOL, so much for my inside info. Thanks.
From:
(USANYS)
Sent: Friday, January 3, 2020 5:21 PM
To:
(USANYS)
Cc:
(USANYS)
is
)
is
is
(USANYS) [Contractor]
Subject: Re: Epstein
It's on the death - there is a promo on their website.
Sent from my iPhone
On Jan 3, 2020, at 5:09 PM,
(USANYS)
wrote:
FWIW - we've heard that 60 Minutes might run a feature on Epstein this Sunday night. The info came from a different
outlet, so no details as of yet, but will let you know if we get anything further.
Public Affairs
EFTA00031907

=== Page 2 ===
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
EFTA00031908


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=== Page 1 ===
From:
To:
Subject: Request for Information Relating to Jeffrey Epstein
Date: Thu, 30 Apr 2020 19:51:10 +0000
Importance: Normal
Attachments: unnamed
-- Do not delete or change any of the following text. --
Join Webex Meeting
Meeting number (access code): 470 899 616 Meeting password: RxPNmCtV685
Join from a video system or application
Dial 470899616@khf.webex.com
You can also dial 173.243.2.68 and enter your meeting number.
Join by phone
Tap to call in from a mobile device (attendees only)
+1-415-655-0001 US Toll
Global call-in numbers
Can't join the meeting?
If you are a host, go here to view host information. IMPORTANT NOTICE: Please note that this Webex service allows audio and other information
sent during the session to be recorded, which may be discoverable in a legal matter. By joining this session, you automatically consent to such recordings. If you do not consent to
being recorded, discuss your concerns with the host or do not join the session.
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.
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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: Epstein Bail Letter
Date: Wed, 10 Jul 2019 00:22:49 +0000
Importance: Normal
Attachments: 2019-07-08,_JE,_detention_memo,_final.docx
Here you go!
From:
(USANYS)
Sent: Tuesday, July 9, 2019 4:44 PM
To:
)
Subject: Epstein Bail Letter
Could you send me a word doc of you bail letter in Epstein? I am preparing a written detention app based on risk of flight
and would love to crib some of your case law/rhetoric. Thanks!!!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, New York 10007
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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Epstein-related Touhy request
Date: Fri, 15 May 2020 21:19:40 +0000
Importance: Normal
Attachments: unnamed
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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: Automatic reply:
Date: Mon, 26 Aug 2019 13:48:30 +0000
I am currently on trial before the Honorable Ronnie Abrams. I will be checking email at the end of each trial day. If you need immediate
assistance in connection with United States V. Epstein, 19 Cr. 490 (RMB), please contact AUSA
at
For all other matters,
please contact AUSA
at
Thank you.
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Pros memo
Date: Mon, 02 Dec 2019 18:16:41 +0000
Attachments: MCC_Pros_Memo_v10.doc
From:
(USANYS)
Sent: Monday, December 2, 2019 9:46 AM
To:
(USANYS)
Subject: Pros memo
Can you send me your pros memo/DP memo for the MCC case?
-
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
Tel:
Fax:
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=== Page 1 ===
Event: Call/Meeting on Epstein
Start Date: 2018-12-07 16:00:00 +0000
End Date: 2018-12-07 17:00:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Date Created: 2018-12-07 02:59:25 +0000
Date Modified: 2018-12-07 02:59:25 +0000
Priority: 5
DTSTAMP: 2018-12-07 02:48:09 +0000
Attendee:
(USANYS) [Contractor]
i
(USANYS)
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=== Page 1 ===
From:
To:
Cc: "Mark S. Cohen"
'Jeff Pagliuca'
Laura Menninger
"BOBBI C STERNHEIM"
,
Subject: RE: Letter
Date: Thu, 29 Oct 2020 02:20:54 +0000
Attachments: 2020-10-28_Letter_to_GM_counsel_re_Rule_16_and_Brady_(final).pdf
Inline-Images: image001.jpg; image002.jpg
Counsel,
Please see attached.
Best,
From:
Sent: Wednesday, October 14, 2020 11:04 AM
To: Christian Everdell
;
is
(USANYS)
Cc: Mark S. Cohen
>; 'Jeff Pagliuca'
>; ; Laura Menninger
BOBBI C STERNHEIM
Subject: RE: Letter
Chris,
We are continuing to review the requests in your letter, and we intend to provide you with a written response to those
requests as soon as we are able. We note, though, that your letter makes dozens of broad requests - including at least
one request that Judge Nathan has already denied. As a result, although we fully intend to respond in sufficient time to
permit you to make any motion you deem appropriate in December consistent with the Court's schedule, we do not
anticipate being able to do so on or before October 21, 2020.
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From:
Sent: Wednesday, October 14, 2020 9:26 AM
To: 'Christian Everdell'
)
;
(USANYS)
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=== Page 2 ===
Cc: Mark S. Cohen
;
'Jeff Pagliuca'
Laura Menninger
; BOBBI C STERNHEIM
Subject: RE: Letter
Received, thank you.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From: Christian Everdell
Sent: Tuesday, October 13, 2020 11:38 PM
To:
Cc: Mark S. Cohen
'Jeff Pagliuca'
; Laura Menninger
>; BOBBI C STERNHEIM
Subject: Letter
Please see the attached letter.
Regards,
Chris
Christian Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
New York
Paris
Washington DC
London
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
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=== Page 1 ===
July 13, 2021
t Prep
AUSAs
&
SA
Det.
Prepared for trial testimony.
previously undisclosed, clarifying, or different recollections
below:
provided AUSAs with a list of medications she currently takes [list attached]
son recently reminded her that
had been invited to travel to an island.
does not have a specific clear memory of this now.
also recalls that her son may have gone to Palm Beach with
once because he
came home and showed her pictures of gargoyles, which she recalls were taken at the
Palm Beach property.
estimates that
was traveling to Palm Beach for work for approximately two
and a half years when she was a teenager.
did not see the contents of the packages
received, but she remembers
having books about massage and promiscuous clothing after receiving those
packages.
recalls the following callers to her phone regarding
work in Palm Beach:
Two male voices:
One was a car service or driver picking
up
The second
remembers calling to say he was sending a car to pick
up
Two female voices:
One named
called multiple times.
One with an accent called multiple times.
believes this woman's
name was something like Giselle Maxine
recalls the female caller with an accent being particularly unpleasant in her tone
during one call, during which the female caller said that
and her friends were
supposed to be at the house for a party.
assumed that meant
and her friends
were supposed to set up for some party.
did not realize that
had been sexually abused by Jeffrey Epstein until the FBI
knocked on
door in or about 2007 as part of an investigation.
never
explicitly told
what happened to her with Epstein, and no one from law enforcement
ever explicitly told
what happened either, but
gathered over the years from
behavior, law enforcement interactions, and civil suits that Epstein must have
abused her.
After
went to GA, at some point
told
that
and
were
getting cocaine from the house they were cleaning in Palm Beach.
didn't say who
actually gave them cocaine.
told
that
was cleaning houses.
Since
has gotten out of jail in 2020,
has spoken with him a handful of times about
his son.
told
that he was subpoenaed, but he otherwise did not tell her anything
else.
told
recently that
asked her for money.
EFTA00029869

=== Page 2 ===
Clonary epam / mg John
Oxycodone /Acetanimopten 10/325 AS
Needed
montelukast 10 mg. Ttal pm.
Amitripty line 10mg/ tab Pm
Huticasene Nasal. spray each mostril
Breztri luhalr.
Albuterol sulfate inhaler 2x daily
XTampya 27mg ER. 2x daily


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=== Page 1 ===
From:
)"
To:
)"
Cc:
(USANYS)"
)"
Subject: Welcome to the team!
Date: Tue, 15 Dec 2020 20:08:35 +0000
Attachments: 2020-04-10_GM_prosecution_memo.pdf;1 2020-05-
22,
and_perjury_supplement.docx; 2019.12.19_memo_re_co-
conspirator_investigation.pdf; 2019-06-17,
_prosecution_memo.docx
Hi
We officially received the green light from the powers that be to add you as the "law guy" to the Maxwell team. We're
thrilled to have you and are very excited to work with you!
To start getting you up to speed, we'd like to schedule a call for this Thursday. I'm generally available from 12pm to 2pm
and after 3:30pm on Thursday. Are there times in there that would work for you?
In the meantime, l'll get you added to the share, and I've attached some of the key memos that you should read when you
have time as an introduction to the case.
Thanks very much for jumping on board!
EFTA00031823


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=== Page 1 ===
From:
=
(USANYS)"
To:
(USANYS) [Contractor]"
i
(USANYS)"
Subject: Call/Meeting on Epstein
Date: Fri, 07 Dec 2018 02:48:11 +0000
Importance: Normal
Attachments: unnamed
EFTA00029653


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=== Page 1 ===
From:
)"
To: Alex Conlon
, Roberta Kaplan
Subject: RE: Transcript from yesterday's conference
Date: Fri, 13 Dec 2019 18:08:40 +0000
This is helpful and interesting, thanks very much for sending. Among other things, notable that Judge Failla assumes, even
were punitive damages to be excluded, a claim "for millions upon millions of dollars."
Separately, Robbie, I noticed near the end of the conference you mentioned, at p. 27, that: "They [the estate and/or the
trustees?] have identified the sole beneficiary as Mr. Epstein's brother." I'm wondering if you might have a recollection of
what the estate has said or represented to you about that? And if you recall whether any discussion of beneficiaries was
in connection with the will versus the trust versus the estate, etc. Just if you feel comfortable sharing any of that
information, of course-no obligation at all. And if it's more convenient to relay in real time, rather than drafting up an
email, please don't hesitate to give a call. No emergency or rush, but did want to ask.
thanks,
From: Alex Conlon
Sent: Thursday, December 12, 2019 18:34
To:
Cc: Roberta Kaplan
Subject: Transcript from yesterday's conference
Hi there,
Attached is the transcript from yesterday's conference that Robbie described in the call today.
Take care,
Alex
Alex Conlon Kaplan Hecker & Fink LLP
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.
EFTA00030438


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE:
Date: Tue, 26 Jan 2021 21:56:07 +0000
Embedded: RE:_.msg
Sender:
Subject: RE:
Message-Id:
<SN1P110MB0285F8F37DBF717CD7FA83598CBC9@SN1P110MB0285.NAMP110.PROD.OUTLOOK.CO
M>
To:
Cc:
EFTA00031619


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=== Page 1 ===
FROM THE DESK OF
JOE TITONE
ATTORNEY
621 SE 5th Street
Pompano Beach, FL 33060
954/729-6490
JOETITONE@BELLSOUTH.NET
February 10, 2019
The Department of Justice
Office of Professional Responsibility
950 Pennsylvania Avenue
Washington, DC 20530-0001
Attention: Assistant Attorney General Stephen E. Boyd
Re: Investigation of
Misconduct in Prosecution
Re: Jeffrey Epstein
Dear Mr. Boyd:
I represent
, a longtime associate of Jeffrey Epstein.
My client
is willing to give testimony in the above
investigation. I believe
testimony will be helpful to your
investigation and will include details of obstruction of justice.
To be transparent; my client is currently suing Jeffrey Epstein; in State
Circuit Court in Miami, Florida. Case #14-21348CA 01 (34). Jeffrey Epstein's
attorney is Mr. Scott Link, 1555 Palm Beach Lakes Boulevard, Suite 930, West
Palm Beach, FI 33401.
I am copying Mr. Link as you may want a response from Mr. Link.
EFTA00031320

=== Page 2 ===
Page 2
Kindly contact me if you desire to speak to my client.
Respectfully,
Joe Titone, Attorney
Cc: Us Senator Ben Sasse (R-Nebraska)
Scott Link, Attorney
Rudy Giuliana
EFTA00031321

=== Page 3 ===
FL 331
JOE TITONE ATTORNEY
621 SE 5TH Street
11 FIEIB 2019 PM 11.1
EFTA00031322
Pompano Beach, FL 33060
USA
Ave Department of Justice
FOREVER
o ffice of Professional Responsibility
950 Pennsylvania RAYED ave.
W ashington DC DOJ 20530-000)
attn: asst attorney
20530 Stephen 9001 Royd E


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=== Page 1 ===
From:
(USANYS)"
To:
SANYS)"
Subject: Automatic reply: Tartaglione / Epstein
Date: Tue, 03 Dec 2019 20:25:11 +0000
I will be out of the office through December 5, 2019 on business travel. I will be checking e-mail and voicemail. If you
need immediate assistance, please contact the other AUSA assigned to the matter.
EFTA00030560


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Cc:
)"
(USANYS)"
Subject: RE: Discovery Requests
Date: Fri, 29 Jan 2021 21:38:36 +0000
Inline-Images: image001.jpg; image002.jpg
Thanks
I'll let defense counsel know and will ask them for another drive if they want those ranges again.
From:
(USANYS) [Contractor]
Sent: Friday, January 29, 2021 4:34 PM
To:
>;
(USANYS) [Contractor]
Cc:
>;
(USANYS)
Subject: RE: Discovery Requests
Hey
Will do on uploading the materials. As for those ranges, we've already produced them twice - once in the third
production (08-21-2020) and once in the reproduction with shortened file names (09-03-2020). We would not be able to
reproduce them again through their FTP link as they total about 15GB, if not more.
Thanks,
From:
Sent: Friday, January 29, 2021 4:09 PM
To:
(USANYS) [Contractor]
i
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: FW: Discovery Requests
Hi
and
Please see below. Would you please use the link to send Maxwell's counsel a copy of everything you prepared in response
to point 6 of their earlier email? And would you also please take a look at the bates ranges in their most recent email
(below) and let me know (a) if we already produced them, and (b) whether you can re-produce them using the FTP link?
Thanks,
From: Christian Everdell
Sent: Friday, January 29, 2021 3:53 PM
To:
is
is
(USANYS)
Cc:
is
is
is
Subject: RE: Discovery Requests
EFTA00030912

=== Page 2 ===
-
Thanks for the follow-up. Please send the documents to the FTP link below:
https://cohengresser.sharefile.com/r-r16397a3bc183400da73b80cbfa69f256
Also, we are missing the Bates ranges listed below.
SDNY_GM_00167911 through SDNY_GM_00168477
SDNY_GM_00168488 through SDNY_GM_00169165
SDNY_GM_00169184 through SDNY_GM_00169491
SDNY_GM_00169505 through SDNY_GM_00169735
We had discussed these ranges several months ago and I believe you had agreed to reproduce them in the 11/9
production. But we do not appear to have received them. Can you send these ranges via the FTP site as well?
Thanks,
Chris
From:
) [mailto:
Sent: Friday, January 29, 2021 10:31 AM
To: Christian Everdell;
);
(USANYS)
Cc: Mark S. Cohen; Bobbi Sternheim; Jeff Pagliuca; 'Laura Menninger'
Subject: RE: Discovery Requests
Chris,
Following up on this, we have now prepared all of the items you requested in point 6 below for production to you. Our
paralegals have sent a copy of the materials to the MDC for your client. Would you like to provide us with an FTP link for
this production, or would you like us to prepare a CD for you instead?
Thanks,
Assistant United States Attorney
Southern District of New York
From:
Sent: Monday, January 25, 2021 3:56 PM
To: 'Christian Everdell'
is
)
>;
(USANYS)
Cc: 'Mark S. Cohen'
>; 'Bobbi Sternheim'
>; ; 'Jeff Pagliuca'
>; 'Laura Menninger'
Subject: RE: Discovery Requests
EFTA00030913

=== Page 3 ===
Chris,
Following up on point 6 below, our paralegals have re-stamped the materials you identified with a Bates range overlap
and are prepared to reproduce those materials to you. The materials are small enough to produce via your FTP site.
Would you like to send us a link to where you would like those materials uploaded? Alternatively, we can load the
materials to a CD and send it to you.
We are still waiting to hear back from our vendor about the remaining issues you identified in point 6.
Thanks,
Assistant United States Attorney
Southern District of New York
From:
Sent: Sunday, January 17, 2021 10:05 PM
To: C
i
)
is
(US
is
V.
is
Subject: RE: Discovery Requests
Chris,
Below please find our responses.
1. As we have recently discussed, Ms. Maxwell now has access to the 4TB drive containing a full set of the discovery
produced to date. It took a significant amount of time to create this copy due to the volume of discovery and
delays on the part of our vendor, who assisted in creating the copy.
2. As we have recently discussed, Ms. Maxwell now has a drive containing the contents of the CD produced on
November 18, 2020.
3. As I conveyed to you over the phone and in a recent email, the materials produced from the Subject Devices all
contain metadata indicating the "NYC" CART Evidence Number of the device from which each document was
extracted. In our November 18, 2020 discovery letter, we provided you with a chart setting forth which "NYC"
CART Evidence Number corresponds with which Subject Device in our warrants. If you still need a detailed index
of all 1.2 million documents with the specific Subject Device indicated, please let me know, and I will ask one of
our paralegals to compile one.
4. We produced the FBI report bearing Bates number SDNY_GM_02050812-14 in the form in which it was
recovered from one of Epstein's devices. In other words, we did not apply any redactions to that document;
rather, the redactions existed on the document at the time the document was found during the FBI's search of
Epstein's devices. We are not aware of any legal basis for your request for a log of redactions. If you have any
EFTA00030914

=== Page 4 ===
legal authority on that point, we would be happy to consider it. As a courtesy, I will note that our office did not
apply redactions to any material that was identified responsive during the searches of Epstein's devices.
5. We are aware of our discovery obligations, have complied with them, and will continue to comply with them. We
are not aware of any legal basis for your request that we inform you of what, if any, documents have been
withheld or the basis for their withholding. If you have any legal authority on that point, we would be happy to
consider it. As a courtesy, I will note that we have provided you with all records we received from AT&T and all
records we received from David Rodgers. As to your inquiry about the Bates ranges on the Rodgers documents
beginning with Bates number "28", I note that the folder containing the Rodgers subpoena returns in our August
5, 2020 production included two documents. The first (SDNY_GM_00005532-5649) is the document you
referenced in your email inquiry. The second (SDNY_GM_00005650-5676) is 27 pages long, accounting for the
first 27 pages of the production from Rodgers. We produced those two documents in the form in which we
received them.
6. Our paralegals are working on the issues you identified with Bates ranges and metadata load files. I will reach
back out to you once I have an update on the status of those issues.
7. We do not have a more detailed index of the November 9 and November 18 productions beyond what we have
provided to you.
8. We are not aware of any legal basis for your request for copies of grand jury subpoenas. Nor are we aware of any
legal basis for your request that we identify the date range of documents we requested in each subpoena. If you
have any legal authority for those requests, we would be happy to consider it.
9. The court filings that appear to be referenced in the Daily Beast article you sent are an application for a search
warrant and a search warrant filed in the District of New Hampshire. We produced both documents to you in
discovery on August 5, 2020. The DNH judge issued a sealing order in connection with the warrant and
application. As you can see at Bates No. SDNY_GM_00000621, the sealing order automatically expired on
December 30, 2020. Our understanding is that the District of New Hampshire unsealed the filing of its own
accord in conformity with the clear language of that sealing order. Our office took no affirmative steps to unseal
or otherwise release these filings.
Best,
Assistant United States Attorney
Southern District of New York
From:
Sent: Thursday, January 7, 2021 4:13 PM
To:
is
is
(USANYS)
Cc: Mark S. Cohen
>; Bobbi Sternheim
>; Jeff Pagliuca
is
Subject: Discovery Requests
EFTA00030915

=== Page 5 ===
We write to raise a number of discovery issues. Please let us know your position on these issues at your earliest
convenience.
1. In our email correspondence on 11/18/2020, you agreed to create a new hard drive containing the entire discovery
production. We provided you with a 4TB hard drive for that purpose on 11/20/2020. It is very important for Ms.
Maxwell to have this drive as soon as possible to prepare her defense. Do you have an update on when the drive
will be ready?
2. We also informed you that the CD produced on November 18, 2020 did not work on the prison computer at the
MDC (as you know, the laptop provided to Ms. Maxwell does not have a CD drive). Accordingly, we asked you to
include the material on the CD in the new 4TB hard drive. We followed-up with you about this issue on December
30, 2020. Given that the new hard drive is still not ready, we ask that you download the material on the CD onto
a separate thumb drive or hard drive and provide it as quickly as possible to Ms. Maxwell at the MDC so that she
can review the materials this weekend. Alternatively, you can provide an external CD drive to Ms. Maxwell at
the MDC so that she can read the files on the MDC computer. We will provide whatever media device you
require to facilitate this production.
3. Unlike the November 9, 2020 discovery cover letter, the November 18, 2020 discovery cover letter (attached) does
not correlate the Bates numbers to the particular "Subject Device" from which the documents were recovered.
Instead, the cover letter indicates that the documents came from "SDNY_PROD015" or "SDNY_PROD016." We do
not know what those terms refer to. We request that the government produce a list that correlates the Bates
numbers for all of the documents in SDNY_PROD015 and SDNY_PROD016 to the particular devices from which the
documents were recovered.
4. We request that the government provide an unredacted version of the FBI report, dated December 6, 2006,
bearing Bates number SDNY_GM_02050812-14 (attached). We also request that the government produce a log
identifying all of the redacted documents in the discovery and the bases for each of the redactions.
5. There are a few documents that seem to be missing from the discovery. For example, the AT&T documents
(SDNY_GM_00001015-3637) do not seem to include subscriber information for the various phone numbers. Also,
the flight logs produced by David Rodgers begin at Bates number "Rodgers000028," suggesting that
Rodgers000001-000027 were not produced to us. Please produce these documents to us or provide an
explanation why you are not producing them to us. Please confirm whether there are other documents that were
removed from the grand jury subpoena productions that we have not yet identified and the basis for their removal.
6. There are a few Bates number/metadata issues with some of the documents:
a. There is an overlap between the fourth and fifth document productions. The fourth production ends at
SDNY_GM_00328863, the fifth production begins at SDNY_GM_00328070. We propose renumbering the
range from the fifth production (i.e., renumber SDNY_GM_00328070-328863).
b. The metadata load files (*.DAT) for PROD011 had a number of gaps which are detailed in the attached Excel
file. We propose that you send us a new DAT file covering only the missing documents.
C. The metadata load files (*.DAT) for PROD015 had a gap from SDNY_GM_00723971 to SDNY_GM_00723981.
We propose that you send us a new DAT file covering only the missing documents.
7. To the extent that the government has created an index of the documents produced on November 9 and
November 18 that is more detailed than the production cover letters, we request that you provide a copy to the
defense.
8. We request that the government provide copies of the grand jury subpoenas for documents issued by the
government in this case. Also, please identify the date range of documents you requested in each subpoena.
EFTA00030916

=== Page 6 ===
There is one other issue we'd like to raise. An article in the Daily Beast on Monday referenced the search warrant affidavit
for the cell-site simulator used to track Ms. Maxwell's cellphone before her arrest (https://www.thedailybeast.com/how-
the-fbi-tracked-down-ghislaine-maxwell-alleged-madam-of-jeffrey-epstein). The article stated that the affidavit appeared
in a "newly unsealed court filing." I don't recall this affidavit being unsealed or referenced in anything that was filed on
the court docket. Please confirm whether or not the government unsealed this affidavit or any other materials from the
criminal discovery, and whether any discovery materials were released pursuant to FOIA requests.
Regards,
COHEN & GRESSER LLP
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
CG
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
EFTA00030917


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=== Page 1 ===
From:
)"
To: Laura Menninger <Imenninger@hmflaw.com>,
)"
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, "Christian R Everdell - Cohen & Gresser LLP
(ceverdell@cohengresser.com)" <ceverdell@cohengresser.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Tue, 16 Mar 2021 22:40:19 +0000
Attachments: 2021.03.16_Maxwell_Discovery_Letter.pdf;
SDNY_GM_02743101_[CONFIDENTIAL].xlsx;
SDNY_GM_02743102_[CONFIDENTIAL].xlsx
Inline-Images: image001.jpg
All,
Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding
discovery cover letter. We are sending a copy of these files to the MDC for your client as well.
In response to your questions, the FBI has informed me of the following:
Regarding the Highly Confidential nude/partially nudge images to be reviewed at 500 Pearl:
There are three categories of these images:
Approximately 2,100 electronic images and videos seized from Epstein's electronic devices (which have not
been previously provided to you)
Approximately 3,400 electronic images from discs seized from Epstein's residences in 2019 (which have
previously been provided to you and your client for review at the MDC)
Approximately 7 hard copy nude images located in the file from the FBI Florida office's investigation of
Epstein (which have not been previously provided to you)
The FBI will make all three of those categories available to you. The electronic files will be provided on hard drives,
and the FBI will provide you with the hard copy images for review as well.
All electronic images should be viewable as thumbnails, except those seized from Apple devices, which must
be viewed using Cellebrite.
The Cellebrite software will be provided on the drive for your review of images and videos seized from Apple
devices.
The electronic files have the same metadata on the hard drive that was available when the FBI seized each
image. For images that were carved or deleted, no metadata was recovered, so none is viewable. For all
other images, the metadata recovered should be viewable on the hard drive.
The approximately 2,100 electronic images and videos seized from Epstein's devices are separated by folder
to indicate which device each image was seized from.
Because these images are considered obscene material, the FBI is not permitted to make duplicates of them, and
there is a limited number of clean laptops on which these images can be reviewed. As a result, the FBI is only able
to provide a single laptop for review of these images.
Regarding the physical evidence:
Attached are two lists of all physical items in the FBI's custody relating to this case. The first list relates to items
associated with the FBI Florida office's investigation of Epstein. The second list relates to items associated with the
FBI New York office's current investigation.
The vast majority of physical evidence in the FBI's custody is located at the FBI's warehouse in the Bronx. Two
items (1B 77 & 1B 79) are located at 26 Federal Plaza, but the case agents can check those items out from 26
EFTA00030101

=== Page 2 ===
Federal Plaza and bring them to the Bronx warehouse on whatever day you choose to conduct your review so that
you will have all evidence in one place.
The FBI is able to arrange for the defense team to review all physical evidence at the Bronx warehouse under the
following conditions:
The warehouse requires at least two weeks' notice in order to pull all of the items for the entire case and
place them in a location where a large group of people can view them.
The warehouse is open during normal business hours between 9am and 5pm on weekdays.
At least two FBI agents and an AUSA will be present at the Bronx warehouse to assist and answer questions.
The evidence will be placed in a loading dock at the warehouse to provide additional space for the review.
To ensure that there is sufficient space, please let me know how many members of the defense team intend
to be physically present for this review.
Electronic devices such as cellphones and laptops are not permitted in the warehouse. The defense team
may bring a digital camera that is not connected to the Internet or a cellular network into the warehouse. If
the defense team wishes to photograph an item of evidence, the defense will need to inform the agents who
are present, so that they may confirm that the photographed item is not Highly Confidential based on the
presence of nudity.
Electronic media such as VHS tapes, cassette tapes, and CDs will not be playable at the warehouse.
To the extent the defense requests that the FBI bring any physical items to 500 Pearl Street for your client to review,
the FBI is prepared to bring items that are reasonably sized to 500 Pearl Street. With respect to bulky or large
items, the defense team should be able to photograph those for your client to review, unless they are deemed
Highly Confidential, in which case the FBI can make arrangements to transport the item to 500 Pearl Street if
necessary.
The FBI is in the process of confirming that it can provide devices to play all of the electronic media in the case in a
single location at the FBI's offices in downtown Manhattan. We are also double-checking to confirm that all media
that does not contain witness statements have already been produced to you and your client in discovery. The FBI
anticipates that we can arrange for you to review all non-witness statement electronic media at the FBI's office in
downtown Manhattan in approximately three weeks.
To the extent you wish to review all of the discs containing photographs, which were seized from Epstein's
residences in 2019, we note that all of those images have already been produced to you in discovery. For
your awareness, the FBI has informed me that it took their team several weeks to review all of the images on
all of those discs.
Please let me know how you wish to proceed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, March 15, 2021 6:00 PM
To: 'Laura Menninger' <lmenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
EFTA00030102

=== Page 3 ===
Laura,
I expect to be able to answer all of your questions about the evidence review by tomorrow.
We have been looking into the discovery request you made last week, and we hope to have a response ready to provide
to you by next week.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 15, 2021 3:01 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of
when you would have answers, it could help me answer your question.
At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the
attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their
evidence when they seized it from NY and LSJ, so I don't think we need to wait for them to now prepare an inventory
before we start reviewing evidence.
Also, when do you believe you will have a response regarding the discovery I requested last Monday?
Thanks,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
i
(USANYS)
EFTA00030103

=== Page 4 ===
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00030104

=== Page 5 ===
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 3:44 PM
To:
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you. Is that the only index of physical evidence available?
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00030105

=== Page 6 ===
From:
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
Code:
Best,
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
)
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
Thank you,
EFTA00030106

=== Page 7 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
is
V.
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00030107


c1: EFTA00030677
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030677.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Michael Bachner
Cc:
)"
)"
Subject: RE:
Attorney Proffer
Date: Fri, 05 Jun 2020 17:20:23 +0000
Inline-Images: ~WRD358.jpg
Michael,
Thanks for checking in, and we hope you're doing well these days. Given the lack of significant change in terms of health
and safety issues over the past few months since we last were in touch, we are fine to continue to hold in abeyance our
discussion with
We continue to appreciate her willingness to speak with us, and the delay will not prejudice
her at all. Should it still be impracticable to meet in person in another month or two, we may circle back on the possibility
of a videoconference or phone discussion, but in the interim we have no issue with remaining on hold.
Please don't hesitate to be in touch if there are any questions or issues, or if another substantial period of time has gone
by and we haven't connected, and thanks again for being in touch.
From: Michael Bachner <mb@bhlawfirm.com>
Sent: Thursday, June 04, 2020 12:27
To:
)
Subject: Re
Attorney Proffer
Hey
hope all is well. Checking in to see the status of matters.
Stay well
Michael Bachner
Bachner & Weiner, PC
Please excuse typographical errors. Messages sent through dictation.
https://www.actl.com/
EFTA00030677

=== Page 2 ===
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is not
the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited.
If you have received this communication by error, please immediately notify the sender by e-mail and delete this
email from your system. Nothing in this email should be construed as a legal opinion or tax advice.
On Mar 16, 2020, at 11:50 AM,
wrote:
Michael,
The world has obviously changed substantially even since late last week - I know we had conveyed that we wanted to
meet with
sooner rather than later, but if you and/or she has any preference at all to postpone tomorrow's
meeting, that would be fine. If she has a strong inclination to do the meeting and would *prefer* to do it tomorrow,
please let us know and we should be able to make that work at your office, but otherwise we're happy to touch base in
the coming weeks and see what makes sense. The last thing we want to do is endanger anyone's health or safety.
Please let us know what you prefer, and we'll go from there.
thanks,
From: Michael Bachner
Sent: Sunday, March 15, 2020 11:25
To:
Cc:
is
Subject: Re:
Attorney Proffer
let's do the meeting at my office on Tuesday.
Michael Bachner
Bachner & Weiner, PC
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is not
the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-mail
and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax
advice.
EFTA00030678

=== Page 3 ===
On Mar 11, 2020, at 9:53 PM,
)
wrote:
Michael,
We'll put it in the calendar for then, certainly with the understanding that it's a fluid situation. We'll keep in touch and
hope for the best. Stay safe and we'll talk soon.
thanks,
From: Michael Bachner
Sent: Wednesday, March 11, 2020 21:48
To:
Cc:
is
Subject: Re:
Attorney Proffer
, confirming March 17 at 1030. However please I understand that these dates and times have to
remember fluid given the coronavirus situation. A resident of the The Connecticut town where
lives
just tested positive
Michael
Michael Bachner
Bachner & Weiner, PC
Please excuse typographical errors. Messages sent through dictation.
<~WRD057.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is
not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you
are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-mail
and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax
advice.
On Mar 11, 2020, at 5:06 PM,
)
wrote:
EFTA00030679

=== Page 4 ===
Michael,
We appreciate that, thank you. Shall we plan to do a first meeting on Tuesday the 17th at 10:30 a.m.? But again,
please let us know if you prefer a different time, we should be flexible that day.
thank you,
From: Michael Bachner
Sent: Wednesday, March 11, 2020 16:32
To:
Cc:
is
)
Subject: RE:
Attorney Proffer
will meet earlier. How does next week look. 17 18 or 19
From:
)
<
Sent: Wednesday, March 11, 2020 1:04 PM
To: Michael Bachner <mb@bhlawfirm.com>
Cc:
is
Subject: RE:
Attorney Proffer
Sure, and given that timing I actually think it would be helpful to schedule two meetings, so we can be on track to get
all the information we need efficiently, unless you have any objection to that. Can we put meetings on the calendar
for Tuesday the 31st and Thursday the 2nd, say at 10:30 a.m. each day? Or let us know if she or you prefer different
timing.
And I would just add that because we do think she may have useful information for the ongoing investigation, which
continues to proceed, if her personal issues resolve - or allow for a meeting - sooner than those dates three weeks
out, we would prefer to meet earlier if that becomes possible. Understand if not, but wanted to note it.
thanks,
From: Michael Bachner
Sent: Wednesday, March 11, 2020 12:30
To:
)
Cc:
is
Subject: RE:
Attorney Proffer
has some persona issues to deal with. Can we sometime between March 31 and April 3?
From:
)
Sent: Tuesday, March 10, 2020 2:37 PM
To: Michael Bachner
Cc:
is
Subject: RE:
Attorney Proffer
Michael,
EFTA00030680

=== Page 5 ===
Thanks for getting back to us, and we could do anytime this Monday, March 16. What time that day would be good
for you and
thank you,
From: Michael Bachner
Sent: Monday, March 09, 2020 16:09
To:
Subject: RE:
Attorney Proffer
following are dates that are bad for
Please let me know dates that work for oy and I will
confirm on my calendar.
March 12
March 18-20
March 25-30
April 7-15
From: Michael Bachner
Sent: Wednesday, March 04, 2020 17:31
To:
Cc:
is
Subject: Re:
Attorney Proffer
in DC on biz. Get back to u soon
Michael Bachner
Bachner & Weiner, PC
Please excuse typographical errors. Messages sent through dictation.
<image001.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is
not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you
are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-
mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or
tax advice.
On Mar 3, 2020, at 6:15 PM,
)
wrote:
EFTA00030681

=== Page 6 ===
Michael,
Wanted to get back to you, as promised - as we indicated previously, the attorney proffers we've received from you
haven't caused us to change our view of Ms.
status, and I think you've generally addressed the initial and
follow-up questions we've had. I think from our perspective the next step would be to have a conversation with
Ms.
directly, and to cover with her the same topics that we've addressed with you. Ordinarily we would
approach a discussion like that simply by going chronologically, and asking follow-up questions as appropriate along
the way, but as I've mentioned to you previously, if it would be useful to proceed in a different format, or to focus
(or avoid) specific topics in a first meeting, I think we would generally be amenable to that. And of course as we've
also discussed, any discussion would be completely voluntary-not just the interview overall, but any specific topic
or question that she wanted to pass on, or discuss with you in the moment, etc., would be totally up to her. Please
let us know what you think? We're also happy to chat via phone if that would be helpful as well.
thanks,
From:
Sent: Saturday, February 22, 2020 21:59
To: Michael Bachner
Cc:
is
Subject: RE:
Attorney Proffer
Michael,
Received, thank you. This information is helpful, and as with the prior attorney proffer, does not cause us to
change our view of Ms.
status.
We will be traveling most of this upcoming week, but I hope that we will be able to follow up with you the
following week to discuss possible next steps.
thank you,
From: Michael Bachner
Sent: Friday, February 21, 2020 10:45
To:
>
Subject: RE:
Attorney Proffer
Alex, pls see attached replies to your questions.
From: Michael Bachner <mb@bhlawfirm.com>
Sent: Tuesday, February 18, 2020 12:01
To:
>
Cc:
is
Subject: RE:
Attorney Proffer
Good morning.
was away over the weekend. I expect to have a reply to your questions by
tomorrow.
EFTA00030682

=== Page 7 ===
From:
Sent: Saturday, February 15, 2020 3:44 PM
To: Michael Bachner
Cc:
is
Subject: RE:
Attorney Proffer
Got it -- I had that down as London, rather than Paris, so that's helpful. And I should say, these questions aren't
immediately time-sensitive, I just didn't want to forget to ask, since I'm reviewing the notes now.
thanks,
From: Michael Bachner
Sent: Saturday, February 15, 2020 15:41
To:
Cc:
is
Subject: Re:
Attorney Proffer
Hi
is away for the weekend. In our meeting I indicated that she stayed in the Paris apartment
with her husband on one occasion. I will get back to you on Monday or Tuesday regarding the other
questions you've asked today as well as at the meeting. Have a nice weekend
Michael Bachner
Bachner & Weiner, PC
Please excuse typographical errors. Messages sent through dictation.
<image001.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is
not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient),
you are hereby notified that any dissemination, distribution, or reproduction of this communication is
strictly prohibited. If you have received this communication by error, please immediately notify the sender
by e-mail and delete this email from your system. Nothing in this email should be construed as a legal
opinion or tax advice.
On Feb 15, 2020, at 3:05 PM,
)
wrote:
Michael,
Following up on our meeting, one additional question / clarification we have from reviewing our notes is about
whether Ms.
ever visited certain Epstein properties other than his New York mansion and the brief visit to
the Palm Beach residence. I apologize if you addressed that and I missed it, but we wanted to add it to the list of
EFTA00030683

=== Page 8 ===
additional questions - in particular, whether she ever visited the New Mexico ranch, the Little St. James Island,
the Great St. James island, and/or the Paris residence. Also, is it correct that she just visited the Palm Beach
residence the one time you referenced? It's not a problem or issue if she visited any of those other locations, we
just wanted to clarify one way or the other. And happy to discuss via phone if that's useful.
thank you,
From:
Sent: Thursday, February 13, 2020 13:40
To: Michael Bachner
Cc:
is
Subject: RE:
Attorney Proffer
Michael,
We do understand that your attorney proffer today will be preliminary, and to the best of your client's current
recollection and to the best of your current understanding, and without, e.g., having been provided documents or
other materials by the Government.
We also confirm that your statements will be considered to be made pursuant to Fed. R. Evid. 410 and Fed. R.
Crim. P. 11(f), and therefore under those protections. Regarding Rule 408, we'll just note what we have for other
counsel in this case and others who have made similar statements or submissions, which is that we don't take any
position on the effect or application of Rule 408 in a prospective or hypothetical dispute in civil litigation, because
it doesn't implicate any rights the Government would or would not have, but you can consider us advised that
your position is that your statements are also covered under 408. (While our Office itself can't guarantee the
protections of Rule 408 because any dispute on that issue would be beyond our purview, we are also not taking
the position that we believe it does not apply.)
thank you,
From: Michael Bachner
Sent: Thursday, February 13, 2020 10:08
To:
Subject:
Attorney Proffer
Hi
Prior to our meeting today, I am writing to confirm that statements I make to you today
are preliminary and subject to further refinement once Ms.
and I have the benefit of additional
document review and refreshed recollection if necessary based upon input we may receive from your
office. My statements to you are intended in hypothetical form only and in any event, we understand that
the provisions of FRE 408 and 410 apply.
Please advise if my understanding is correct.
Thanks.
Michael Bachner
Bachner & Associates, PC
EFTA00030684

=== Page 9 ===
<image001.jpg>
https://www.actl.com/
EFTA00030685


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c0:
=== Page 1 ===
From: Robert T Curran <robert.t.curran@aexp.com>
To:
)"
Subject: FW: Jeffrey Epstein
Date: Fri, 12 Jul 2019 13:09:23 +0000
Attachments: message_zdm.html
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c0:
=== Page 1 ===
From:
"
=
To:
)"
Subject: Accepted: FBI / SDNY Epstein update mtg
Date: Tue, 07 Jan 2020 01:14:33 +0000
Importance: Normal
Attachments: unnamed
EFTA00031824


c1: EFTA00031113
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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 24, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
New York, NY 10007
Re:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today the Government is producing additional materials, including Jencks Act and
Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced
case. Enclosed please find an index detailing the materials included in today's production.
The Government is also producing today certain materials relating to individuals the
Government does not currently intend to call as witnesses at trial in the above-referenced case.
These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the
Government does not expect to call these individuals to testify at trial. Instead, these materials
contain, among other things, certain witness statements. Enclosed please find an index detailing
these materials. This production should not be taken to indicate that the Government believes it
has any obligation to provide all of these materials; rather, we make this production as a courtesy.
Moreover, although the Government presently does not intend to call the individuals listed in the
enclosed index, we reserve the right to do so and will notify you should the Government determine
that it intends to call any of these individuals at trial.
EFTA00031113

=== Page 2 ===
Page 2
Please note that this letter, the enclosed index, and the enclosed materials are governed
by the July 31, 2020 Protective Order in this case. In particular, the materials are designated
as "confidential" under the Protective Order. The index is itself designated as "confidential,"
because it includes information regarding records designated as "confidential" under the
Protective Order. The Department of Justice directed this office to cease the dissemination of
materials marked with the word "confidential" in order to avoid potential confusion with markings
reserved for classified documents. Accordingly, in order to note the appropriate designation of
this production under the operative Protective Order in this case, the materials being produced
today are marked with the following label: "SUBJECT TO PROTECTIVE ORDER
PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs
of the Protective Order that govern today's production.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
s/
Assistant United States Attorneys
EFTA00031114


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030753.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Subject: Accepted: FBI / SDNY Epstein update mtg
Date: Tue, 07 Jan 2020 23:22:37 +0000
Importance: Normal
Attachments: unnamed
EFTA00030753


c1: EFTA00030782
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c3: VOL00008
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c0:
=== Page 1 ===
From:
)"
To:
)"
Subject: FYI
Date: Sat, 09 May 2020 14:37:21 +0000
Paragraph 67 of the complaint alleges Epstein "physically restrained"
during the cuddling incident.
Sent from my iPhone
EFTA00030782


c1: EFTA00029777
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029777.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "
(USANYS)"
To:
)"
Bcc:
"
Subject: RE: Epstein investigation, prosecution memo
Date: Thu, 18 Feb 2021 22:25:57 +0000
Embedded: RE:_Epstein_investigation,_prosecution_memo.msg
Sender:
Subject: RE: Epstein investigation, prosecution memo
Message-Id:
<BN3P110MB038641169AC554BB10AF143C89859@BN3P110MB0386.NAMP110.PROD.OUTLOOK.COM
>
To:
EFTA00029777


c1: EFTA00031889
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031889.pdf
c6: pdf
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c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: RE: Epstein search warrant documents
Date: Mon, 29 Jun 2020 15:20:21 +0000
I defer to you, but are you sure we don't want rolling productions so we can at least start getting stuff in house?
From:
Sent: Monday, June 29, 2020 11:02 AM
To:
(NY) (FBI)
in
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
>;
)
>;
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Following up on this, I understand from
that she was able to provide you with a 12 TB drive last week - could you
please let us know when we will be able to get the materials? I expect a judge will ask us about discovery as early as this
week.
Also, the related critical question that I don't think we have clarity on is whether you're giving us a copy of everything that
was collected (including reproducing the materials that you previously gave us, but which are not searchable), or have you
and
figured out a way to categorize the prior productions so they're useful for us? We would strongly prefer to just
get everything at once in a usable format, but please let us know if you expect to produce materials differently than that.
thanks,
From:
(NY) (FBI)
Sent: Friday, June 19, 2020 13:14
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
i
(NY) (FBI)
>;
)
is
>;
(NY) (FBI)
i
(USANYS)
Subject: RE: Epstein search warrant documents
,
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK when I can
expect the drives. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
EFTA00031889

=== Page 2 ===
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
)
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(NY) (FBI)
is
is
is
(NY) (FBI)
is
(USANYS)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July and
September searches before moving forward with possible additional charges in the case. I know you had mentioned you
needed to push back your prior estimate of complete production by early June, by a couple weeks, so wanted to see what
the current estimate is? I don't think we've started to get anything yet but please correct me if I'm wrong.
thanks,
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
To:
(USANYS) [Contractor]
in
Cc:
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go from
there.
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
EFTA00031890

=== Page 3 ===
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If we
can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our staffing
levels will be steadily increasing over the next few weeks, but I'm going to have to push back my estimate by a
week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can easily identify
what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
Thanks for this update - we'll take a look and circle back if any questions.
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in searchable
format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to specific devices -
so if we're able to match them up by Bates number now, that might work, but otherwise I think it makes sense for us to
get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think we've
gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
>;
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial numbers.
Any questions, let me know.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
EFTA00031891

=== Page 4 ===
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of information
we need is the serial number, or some other specific identifier, ideally for each device but at least for any device that there
is more than one of the same thing. So for example, we need to be able to somehow differentiate the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the USVI
spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the USVI
list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to reproduce
all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we aren't able to
match any of the prior productions to specific devices - so if we're able to match them up by Bates number now, that
might work, but otherwise I think it makes sense for us to get everything. But let us know if any issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I could to
convey the information. If you are confused by anything, please let me know. In the column for approximate
size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I put what load
file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If there is no entry
in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't have as well as an
EFTA00031892

=== Page 5 ===
iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to beef them up. I will
get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any FBI
tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which both
we and the agents can access. We're required to have the files in a format that we can produce them to defense counsel.
I've done that in many other cases and it hasn't previously been an issue. My understanding from
is that the best
way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will process-by which
I just mean converting into file formats that are loadable onto Relativity. It doesn't really have anything to do with the
taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents earlier
this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9. Again, I
understand from
that the best way forward is to just get copies of the materials in their original formats, which I
understand will be segregated and designated by device. That should work for us! I was just trying to understand the
approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
EFTA00031893

=== Page 6 ===
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was
already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece
by piece as things are processed, I was unaware that you didn't want to review as things were processed, that
you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a differentiation of
methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
in
(USANYS) [Contractor]
Cc:
is
)
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just basically
sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago, but
regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that
means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
is
Cc:
is
Subject: RE: Epstein search warrant documents
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
EFTA00031894

=== Page 7 ===
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
in
Cc:
is
)
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it on
our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data and
where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and send
it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
EFTA00031895

=== Page 8 ===
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review the
returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
is
)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
)
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you.
If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks- it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
i
)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
)
is
i
)
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems to
do so.
Also,
, please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
EFTA00031896

=== Page 9 ===
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're waiting
on that list to be able to do an updated search warrant on all of those devices. Please let us know the current timeline -
and also the current timeline on producing the results from those August and September searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months from our call, which
would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
)
is
(USANYS)
>;
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
is
)
>;
is
)
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
>;
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
Rozier can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
EFTA00031897

=== Page 10 ===
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
(NY) (FBI)
is
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
V.
is
(NY)
(FBI)
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:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
is
V.
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
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
EFTA00031898

=== Page 11 ===
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers
and no way to match up anything-that is, even if we were to try to go hunt down every individual large file in the
native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get
a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million
documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
)
y.
(USANYS)
is
(NY) (FBI)
y.
(USANYS)
Cc:
(USANYS) [Contractor]
is
is
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From:
) [mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
in
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
i
i
is
EFTA00031899

=== Page 12 ===
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
i
)
is
(NY) (FBI)
in
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
)
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
V.
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(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.)
EFTA00031900

=== Page 13 ===
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
)
in
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
in
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
)
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
EFTA00031901

=== Page 14 ===
Cc:
(USANYS) [Contractor]
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
EFTA00031902


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS) [Contractor]"
Subject: GM
Date: Tue, 30 Jun 2020 15:28:21 +0000
Attachments: Jeffrey_Epstein_indictment_PR_FINAL.docx
Just checking, is a draft release in the works? Let us know if you need any help. Attaching the final JE release if that's
helpful.
Thanks.
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
EFTA00029812


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=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 - 1B3
Evidence
31E-MM-108062 -- 1B3
Item:
Evidence
General
Type:
(U//FOUO) Box containing 1) TAPED CONVERSATION PBPD 05-237(1) 2) AUDIO TAPE #1 PBPD 05-243(1) 3)
AUDIO TAPE #2 (2) 4) COPY OF TAPE #1 (3) 5) MICRO TAPE PBPD 05-256(1) 6) PHOTO LINE-UP PBPD 05-
257(1) 7) AUDIO TAPE PBPD 05-294(1) 8) MICRO TAPE (2) 9) CD PBPD 05-295(2) 10) C-90 CASSETTE PBPD
05-313(1) 11) A/X MAIL N.M. PBPD 05-378(1) 12) WHITE PAPER G.M.
(2) 13) MESSAGE
Description: P.S. (3) 14) WHITE PAPER J.
(4) 15) MONTGOMERY COUNTY, MD J.B. (5) 16) WHITE
PAPER V. PBPD 05-379(1) 17) WHITE PAPER FLIGHT INFO (2) 18) THREE WHITE PAPERS PREMIO
COMPUTER INC (3) 19) WHITE PAPER PHONE # PBPD 05-380(1) 20) YELLOW RECEIPT 04/04/05 (2) 21)
WHITE PAPER C.W. (3) 22) WHITE PAPER J. (4) 23) WHITE PAPER FLIGHT 04/05/05 (5) 24) WHITE PAPER G.
(6)
Location: E03707388 ECR8
Barcode: E4229230
Details
Collected On: 08/28/2006 8:00 AM
Receipt Item #: None
CATS ID #: None
CATS Abandonment #: None
FBI Seizure #: None
Abandonment #: None
Storage Location
Discovery
Location
Holding Office: NY - NEW YORK
Finalized By:
Area:
Unavailable in data migrated from
Last Inventory: 07/20/2021 12:00 AM
ACS
Seizing
Individual:
Specific:
Unavailable in data migrated from
ACS
Collected By:
Retention
Retention: No
Legal Caveats
None
Chain of Custody
Shipping Log
History
Acquisition Event
Acquisition Event: (U//FOUO) Items migrated on 2006-08-28
Collected From: (U//FOUO) DET
345 SOUTH COUNTY ROAD
PALM BEACH, FL, 33480
https://sentinel.fbinet.fbi/lavender/#/Evidence/4788340
1/2
SDNY_GM_02753560
EFTA00029903

=== Page 2 ===
7/20/2021
FD-1087
Receipt Given:
No
Holding Office:
MM - MIAMI
Evidence Log:
Missing
Missing
https://sentinel.fbinet.fbi/lavender/#/Evidence/4788340
2/2
SDNY_GM_02753561
EFTA00029904

=== Page 3 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B3
Barcode : Eurnes
Accepted By:
Printed Name:
Reason: Collected
Date/Time: 08/28/2006 11.00am
Accepted By:
Printed Name:
Reason: STORAGE
Date/Time: 02-8-08
330PM.
Accepted By:
Printed Name
Reason:
WS 01 asymay
Date/Time 4-10-08
1100 AM.
Accepted By:
Printed Name
Reason: Review
Date/Time: 04/10/2008 1101am
Accepted By:
Printed Name
Reason: Retarn ofall I.B.S.
Date/Time: 01/13/2009 3:11pm
Accepted By:
Printed Name
Reason:
S10 RAGE.
Date/Time: 01/13/09
315 PM
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
SDNY_GM_02753562
EFTA00029905

=== Page 4 ===
EVIDENCE CHAIN OF CUSTODY
Relinquished Custody
Date and
Accepted Cu
Date and
08
Time
Time
Signature
6/17/19
Signature:
6/18/19
Printed Na
Printed Name
Reason: Transferred to NY
9:30pm
Reason: Receive
2:3EPS
Relinquished
Date and
Accepted Custody
Date and
6/18/19
Time
Time
Signature:
Signatu
6/18/19
Printed Name/
Printed
Reason:
40
3:45A
must 2240242 Reason
3:45pm
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
3/15/21
Signature
3/15/21
Printed Na
4:30p
Printed N
Reason:
Reason:
charged in
4:30pm
Relinqui
Date and
Accepted Custody
Date and
Time
Time
Signature
3/3/121
Signature
3/31/21
Printed N
Printed N
Reason:
CLO
335.
Reason:
Review
335p
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature
4/8/21
Signature:
4/3/21
Printed N
Printed Nar
Reason:
2:33
Reason:
2:33pm
Relinquished Custody Je Custody
changed in
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Case ID: 31E-MM-108062
1B: 3
Barcode: E4229230
This form is incomplete without reference to the FD-1087.
SDNY_GM_02753563
EFTA00029906


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
(USANYS)"
,
Cc:
(USANYS)"
Subject: FW: Maxwell
Date: Fri, 09 Oct 2020 15:16:35 +0000
Team- both
and
followed up on the review of images from the Epstein devices and FBI assured us that they will
get it done. Please keep us posted and let us know if there is anything else we can do to assist. Thanks!
From:
(USANYS)
Sent: Friday, October 9, 2020 11:10 AM
To:
(USANYS)
Cc:
(USANYS)
Subject: Maxwell
says she'll get right on the CART issue and make sure it gets done. Let me know what happens.
Chief, Criminal Division
United States Attorn
EFTA00030584


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=== Page 1 ===
From:
)"
To: "moses_nysdchambers@nysd.uscourts.gov" <moses_nysdchambers@nysd.uscourts.gov>
Subject: Search Warrant Application
Date: Fri, 05 Jul 2019 16:41:05 +0000
Importance: Normal
Attachments: 2019.07.05_New_York_Residence_SW.pdf
Dear Judge Moses:
With apologies for the inconvenience during the Court holiday, attached is a search warrant application. My cell phone
number is
if there are any questions.
Respectfully,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00030223


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=== Page 1 ===
Event: Accepted: Meeting with FBI on Epstein
Start Date: 2019-08-16 14:00:00 +0000
End Date: 2019-08-16 14:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-08-15 22:07:57 +0000
Date Modified: 2019-08-15 22:07:57 +0000
Priority: 5
DTSTAMP: 2019-08-15 18:14:54 +0000
Attendee:
EFTA00031002


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=== Page 1 ===
From:
)"
To:
(OPR)"
Cc:
(OPR)"
(OPR)"
Subject: RE: RE: SDNY investigation
Date: Wed, 13 Feb 2019 20:02:43 +0000
Importance: Normal
That sounds fine, thanks - I'm available at your convenience. Looking forward to speaking.
thanks,
Assistant U.S. Attorney
Southern District of New York
From:
OPR)
Sent: Wednesday, February 13, 2019 07:45
To:
)
Cc:
(OPR)
(OPR)
Subject: RE: RE: SDNY investigation
Thank you for reaching out to contact us.
S OPR's lead attorney assigned to this matter;
is also working on the investigation.
S out of the country for the remainder of the week, but when she returns
next week, she can set up a convenient time for the three of you (and anyone else on your end, if needed) to discuss
things.
We look forward to speaking with you.
Acting Deputy Director
Office of Professional Responsibility
From:
Sent: Tuesday, February 12, 2019 5:28 PM
To:
(OPR)
(OPR)
Subject: RE: SDNY investigation
and
I am one of the AUSAs working on the current investigation of Jeffrey Epstein in the Southern District of New York, and I
was given your contact information by
and so wanted to be in touch for any deconfliction or discussion that
might be useful with respect to our respective matters. Is there a good time to be in touch sometime this week? I should
EFTA00031315

=== Page 2 ===
generally be able to make myself available at your convenience, and please let me know if any information would be
helpful in advance.
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00031316


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=== Page 1 ===
From:
To:
Subject: RE: Mystery Jeffrey Epstein statue found in Downtown Albuquerque
Date: Mon, 06 Jul 2020 16:59:18 +0000
Yeah that was extremely weird
Original Message
From:
Sent: Thursday, July 02. 2020 06:37
To
Subject: Mystery Jeffrey Epstein statue found in Downtown Albuquerque
You probably already saw this but just in case. So bizarre.
https://www.koat.com/article/mystery-jeffrey-epstein-statue-found-in-downtown-albuquerque/33025531
EFTA00031231


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Cc:
(USANYS)"
Subject:
Date: Tue, 07 Apr 2020 18:06:34 +0000
Attachments:
with_attachments.pdf
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
EFTA00030803


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=== Page 1 ===
From:
To:
Cc:
Subject: Detention memo
Date: Mon, 08 Jul 2019 14:13:31 +0000
Importance: Normal
Attachments: : 2019-07-08,_JE,_detention_memo,_draft.docx; detention_memo_redline.pdf
The substantively new stuff is on pp. 10-11 of the redline.
Let me know if we are good to submit to court
From:
Sent: Monday, July 08, 2019 10:05 AM
To:
Subject: clean and redline
Assistant U.S. Attorney
Southern District of New York
EFTA00031681


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=== Page 1 ===
From:
To:
Cc:
Subject: GM in Paris?
Date: Mon, 22 Jun 2020 12:01:27 +0000
https://www.the-sun.com/news/1014441/jeffrey-epstein-ghislaine-maxwell-hiding-paris-flat/
Sent from my iPhone
EFTA00029793


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=== Page 1 ===
From:
)"
To: Andrew Patel
Cc: Jill Shellow
Don Yannella
,
)"
)"
Subject: Re:
/Epstein
Date: Thu, 26 Dec 2019 13:37:54 +0000
Andy,
Three issues:
1. We plan to produce the redacted notes to the defense pursuant to the protective order, and the name on an AEO
basis to defense counsel. Your letter states that both will be provided on an AEO, which misstates our intention.
2. When we discussed this, we understood that this would not be submitted to defense counsel prior to Judge
Torres ruling on your request. There is no language in the letter to that effect, and it seems appropriate to add it.
3. Please add "to the defense" in the first letter to make clear to the Court that you are intervening in our
production of discovery to defense counsel in this matter (and not, for instance, in a disclosure to the public or
any other entity).
Thanks.
On Dec 25, 2019, at 10:25 AM, Andrew Patel
wrote:
,
We have attached a copy (draft) of our letter to Judge Torres. Please let me know your thoughts. We would
like to get this to Judge Torres or if she is not available, the Part I Judge, tomorrow.
Sorry to bother you during a holiday,
Andy
Andrew G. Patel
Attorney at Law
From:
Sent: Friday, December 20, 2019 6:36 PM
To: Andrew Patel
Cc: Jill Shellow
>; Don Yannella
is
is
Subject: RE:
/Epstein
EFTA00030148

=== Page 2 ===
Andy,
We cannot agree to these redactions, and think it would be appropriate for you to file a motion before Judge Torres, under
seal and copying the Government (but ex parte as to the defense). Could you please send us a copy of the letter before
you file it, so that we can ensure that our position is accurately represented? Thanks very much.
Original Message
From: Andrew Patel
Sent: Friday, December 20, 2019 5:14 PM
To:
)
Cc: Jill Shellow
>; Don Yannella
)
)
>; Andrew Patel
Subject: RE:
Epstein
We have attached a proposed disclosure cover letter that is modeled on a letter sent by the Government in United States V.
Madonna, 17 Cr. 89 (CS). We have also attached proposed redacted disclosures. As you and I discussed, we offer this as
a means to ensure our client's safety while permitting the Government to comply with what you believe are your
disclosure obligations.
As an alternative, we are willing to apply under seal to Judge Torres for a Protective Order to preclude the disclosure.
Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material. We do not believe that this is in
fact Brady material, but rather is an error made by our client that we understand is contradicted by the surveillance video
evidence. While we applaud your efforts, we have an obligation to make sure that our client is not harmed by the
possible release of the fact that he met with your Office.
We understand that you have time constraints. Please let us know how you want to proceed so that we can file a motion
before Judge Torres promptly if that is necessary.
Andy
Andrew G. Patel
Attorney at Law
CONFIDENTIALITY NOTICE: This e-mail message is covered by the Electronic Communications Privacy Act, 18
U.S.C. 2510-2521. It is legally privileged. The information it contains is confidential information and is intended only for
the use of the individual or entity named above. If the reader of this message is not the intended recipient, or the
employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination,
distribution or copying of the communication is strictly prohibited. If you have received this e-mail in error, please notify
me immediately by telephone at (212) 349-0230 and by return e-mail, and delete all copies of the message from your
computer. Thank you.
Original Message
From:
) [mailto:
Sent: Friday, December 20, 2019 10:01 AM
To: Andrew Patel
Cc: Jill Shellow; Don Yannella;
);
Subject: RE:
/Epstein
EFTA00030149

=== Page 3 ===
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, Justina 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
<Judge Torres Brady preclusion letter Draft.pdf>
EFTA00030150


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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Order
Date: Mon, 28 Dec 2020 21:56:47 +0000
From:
)
Sent: Monday, December 28, 2020 4:33 PM
To:
)
Subject: Fwd: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Order
Really great work on this, congrats. Hope you're enjoying some relaxing holiday time with your family.
Sent from my iPhone
Begin forwarded message:
From:
Date: December 28, 2020 at 3:04:40 PM EST
To:
Subject: Activity in Case 1:20-cr-00330-AJN USA V. Maxwell Order
This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to
this e-mail because the mail box is unattended.
***NOTE TO PUBLIC ACCESS USERS*** There is no charge for viewing opinions.
U.S. District Court
Southern District of New York
Notice of Electronic Filing
The following transaction was entered on 12/28/2020 at 3:04 PM EST and filed on 12/28/2020
Case Name:
USA V. Maxwell
Case Number:
1:20-cr-00330-AJN
Filer:
Document Number: 104
Docket Text:
ORDER as to Ghislaine Maxwell. On December 8, 2020, Defendant Ghislaine Maxwell filed a renewed
motion for releaseon bail. Dkt No. 97. In an Opinion and Order concurrently filed under temporary seal,
the Court DENIES the Defendant's motion. In light of the fact that the Opinion includes potentially
confidential information that should not be filed on the public docket, the Court will permit the parties
48 hours to propose any redactions to the Courts Opinion and Order and to justify those redactions by
reference tothe Second Circuits decision in Lugosch V. Pyramid Co. of Onondaga, 435 F.3d 110(2d Cir.
2006). After determining which, if any, portions of the Opinion and Order should be redacted, the Court
will file the Opinion and Order on the public docket. As a result, the Court concludes that the
Government has met its burden of persuasion that the Defendant poses a flight risk and that pretrial
detention continues to be warranted. On or before December 30, 2020, the parties are ORDERED to
submit a joint letter indicating whether they propose any redactions and the justification for any such
proposal. This resolves Dkt No. 97. (Signed by Judge
J. Nathan on 12/28/20)(jw)
EFTA00031708

=== Page 2 ===
1:20-cr-00330-AJN-1 Notice has been electronically mailed to:
Jeffrey S. Pagliuca
,
Laura A. Menninger
,
,
Bobbi C Sternheim
Christian R. Everdell
,
Mark Stewart Cohen
,
1:20-cr-00330-AJN-1 Notice has been delivered by other means to:
The following document(s) are associated with this transaction:
Document description:Main Document
Original filename:n/a
Electronic document Stamp:
[STAMP dcecfStamp_ID=1008691343 [Date=12/28/2020] [FileNumber=25148655
-0] [8fc2e0a5746be1ab6fd02215cf022b6d8d835ae393b79c6e1fcbcca10bd1f5065
0aab817a07c4c66df5756e694753a25fc7701976f5ea178e37c41484675dcb8]
EFTA00031709


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=== Page 1 ===
From:
"
)"
To:
)"
Cc:
)"
)"
Subject: Re: MCC New York (Procedural Review)
Date: Tue, 14 Jan 2020 15:27:08 +0000
Me too
Sent from my iPhone
On Jan 14, 2020, at 10:22 AM,
wrote:
I think 2:30 works for
nd I.
From:
(
Sent: Tuesday, January 14, 2020 10:22 AM
To:
>;
>;
i
Subject: RE: MCC New York (Procedural Review)
Both work for me.
From:
Sent: Tuesday, January 14, 2020 10:16 AM
To:
>;
>;
(
V.
;
Subject: RE: MCC New York (Procedural Review)
I just realized that I may have pick-up responsibilities tonight. Could we do 2:30 instead?
From:
Sent: Tuesday, January 14, 2020 10:15 AM
To:
(
is
)
>;
(
is
Subject: RE: MCC New York (Procedural Review)
How about 4:30?
EFTA00029742

=== Page 2 ===
From:
(
Sent: Tuesday, January 14, 2020 9:49 AM
To:
is
)
>;
(
i
Subject: RE: MCC New York (Procedural Review)
Thanks. Rough 24 hours, but good to be back. What works for you guys today? Aside from something at 2, I think
and I are pretty flexible.
From:
Sent: Monday, January 13, 2020 1:36 PM
To:
is
>;
is
(
)
Subject: RE: MCC New York (Procedural Review)
Let's discuss both issues tomorrow when
is back. (feel better soon!)
From:
Sent: Monday, January 13, 2020 1:22 PM
To:
(
)
is
>;
is
(
)
Subject: RE: MCC New York (Procedural Review)
Yes, just start drafting. I think the lawyer will then review what they have. If any holes are identified that require
further interviews or other fact-finding, they will be in touch with us before doing so. But it may make sense to have a
conversation with
to get his understanding as well.
From:
(
Sent: Monday, January 13, 2020 1:19 PM
To:
is
is
>;
(
)
Subject: RE: MCC New York (Procedural Review)
On the report, we can chat when
is back tomorrow - but when you say start the report, do you just mean start
drafting? Is it contemplated that they will do further interviews beyond what have been done for the criminal case?
Any sense of timing?
and I discussed the BOP Board of Inquiry with
nd are going to follow up with
- happy to discuss.
EFTA00029743

=== Page 3 ===
From:
Sent: Monday, January 13, 2020 1:17 PM
To:
is
is
is
(
Subject: RE: MCC New York (Procedural Review)
By way of further update, I spoke with
from OIG today. They had a conference call with Inspector
General
this morning, who dictated that they start the report on the case. The report will include
everything from the time of Epstein's admission to the MCC up to the time of his death.
in DC is the
attorney assigned to the report. The first issue under examination is why Epstein was not given a new cellmate
following Reyes's departure- a draft of this section of the report is expected to be completed by the end of this week.
They will be starting with the materials from the criminal investigation. If they need to do additional fact finding, they
will be in touch with us before doing so. There is no deadline yet for the completion of the report, which will likely
become public.
It likely makes sense to have a brief discussion. In the email below, OIG requested our position on the investigation, but
I
know if we have provided one yet. We may also want to have a call with
From:
Sent: Thursday, January 09, 2020 6:54 PM
To:
Cc:
Subject: FW: MCC New York (Procedural Review)
FYI
From:
Sent: Thursday, January 9, 2020 4:55 PM
To:
i
(
is
is
>; D
Cc:
Subject: FW: MCC New York (Procedural Review)
Hello Everyone,
Our HQ staff was contacted by the Federal Bureau of Prisons (BOP) in association with the matters concerning the
Epstein/MCC case, and informed that they would like to convene a Board of Inquiry that would review the operations at
the MCC NY. I have been asked to share this with the investigative and prosecution team for opinion and
consideration. I requested that the BOP provide us with some specific information and details about what this would
include and we were provided with the below information and attached Program Statement. Can you all please review
EFTA00029744

=== Page 4 ===
this information and then can one representative from the FBI and one representative from the U.S. Attorney's Office,
SDNY, let us know your office's position regarding this matter? I have included SA
and ASAC
of
our Operations Branch I (OPS I) in this email as they deal directly with the BOP HQ. Thank you all.
Special Agent in Charge
U.S. Department of Justice
Office of the Inspector General
New York Field Office
One Battery Park Plaza, 29th Floor
New York, NY 10004
From:
Sent: Wednesday, January 8, 2020 11:44 AM
To:
Subject: MCC New York
Hi
-
The BOP would like to convene a Board of Inquiry (relevant Program Statement attached) that would review operations
generally at MCC New York. Among other issues, it will look at local policy and procedures related to special housing,
review camera operations, and review training and staffing issues. This will not, of course, be a misconduct investigation.
Should the Board come across anything that appears to be new misconduct allegations, they will be reported consistent
with normal misconduct reporting requirements.
We are mindful of the on-going criminal investigation, and are aware that administrative charges may also arise
connected to the criminal case. We will studiously avoid creating any sort of conflict with that case. Please let me know if
you have additional questions or would like to discuss. Thanks in advance.
U.S. Department of Justice
Federal Bureau of Prisons
Office of Internal Affairs
320 First Street, N.W., Room 600
Washington, D.C. 20534
EFTA00029745


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=== Page 1 ===
From:
To: Dawn Hughes
Cc:
Subject: RE: Expert Testimony
Date: Wed, 04 Nov 2020 22:55:57 +0000
Hi Dr. Hughes,
Thanks very much - we appreciated speaking with you this afternoon.
Best,
From: Dawn Hughes
Sent: Wednesday, November 4, 2020 4:34 PM
To:
Cc:
Subject: Re: Expert Testimony
You can contact Roberta Kaplan, Esq.
Roberta Kaplan I Kaplan Hecker & Fink LLP
On Mon, Nov 2, 2020 at 1:42 PM Dawn Hughes
wrote:
Great. We will speak then. I have attached my CV and standard engagement agreement for your
review.
On Mon, Nov 2, 2020 at 1:37 PM
wrote:
Dr. Hughes,
Thanks very much. We are free at 2 p.m. on Wednesday, and if that works for you we can use this
conference line
Thanks,
EFTA00030529

=== Page 2 ===
Sent from my iPhone
On Nov 2, 2020, at 10:54 AM, Dawn Hughes
vrote:
Yes. I would be happy to speak with you all. I have some open time on Wednesday after 2:00.
Let me know what works for you.
Best,
Dr. Hughes
DAWN M HUGHES, PHD ABPP
CLINICAL AND FORENSIC PSYCHOLOGIST
On Thu, Oct 29, 2020 at 3:48 PM
wrote:
Dr. Hughes,
Together with colleagues
I'm one of the federal prosecutors
handling the case of United States V. Ghislaine Maxwell, which is scheduled to go to trial on July 12,
2021 in the Southern District of New York. We would be interested in speaking with you about your
availability to testify as an expert witness at trial. Are you available for a call tomorrow or next week to
discuss?
Thanks very much,
EFTA00030530


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=== Page 1 ===
DESTRICT
1183034
U.S. Department of Justice
Federal Bureau of Prisons
Central Office
320 First St., NW
Washington, DC 20534
June 22, 2020
Danielle Ivory
The New York Times
620 Eighth Avenue
New York, NY 10018
Re: NY Times, Inc. V. U.S. Department of Justice, et al.
Civil No. 20-cv-833
FOIA Request No. 2019-05665
Dear Ms. Ivory:
Attached, please find the Bureau of Prisons' (BOP) release of the first set of records
responsive to the above captioned case and corresponding FOIA Request No. 2019-
05665. After careful review of the first set of records, we have determined 10 pages are
available for release in full; 9 pages are available for release in part; 1 page is
duplicative and 434 pages must be withheld in their entirety. Copies of the releasable
records are attached hereto.
Pursuant to the Freedom of Information Act, 5 U.S.C. § 552, the records are redacted
and/or withheld under the following exemptions:
(b)(5) - concerns certain inter- and intra-agency communications protected by the
deliberative process privilege, the attorney work-product privilege, and/or the
attorney-client privilege;
(b)(6) - concerns material the release of which would constitute a clearly
unwarranted invasion of the personal privacy of third parties;
(b)(7)(A) - concerns records or information compiled for law enforcement
purposes the release of which could reasonably be expected to interfere with
enforcement proceedings;
(b)(7)(B) - concerns records or information compiled for law enforcement purposes the
release of which would deprive a person of a right to a fair trial or an impartial
adjudication
(b)(7)(C) - concerns records or information compiled for law enforcement
purposes the release of which could reasonably be expected to constitute an
unwarranted invasion of the personal privacy of third parties;
(b)(7)(E) - concerns records or information compiled for law enforcement
purposes the release of which would disclose techniques and procedures for law
enforcement investigations or prosecutions;
(b)(7)(F) - concerns records or information compiled for law enforcement
purposes the release of which could reasonably be expected to endanger the life
or personal safety of an individual.
EFTA00030476

=== Page 2 ===
Sincerely,
Eugene E. Baime
Supervisory Attorney
EFTA00030477


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=== Page 1 ===
From:
To:
Subject: FW: Epstein NM re Zorro Trust 1993-1994 Records (FOIA) (Maxwell appears on 1994 doc)
Date: Fri, 13 Mar 2020 16:43:09 +0000
Attachments: GM2791_(Expired_and_Archived)_-Complete_Electronic_File_Contentspdf
Inline-Images: image001.jpg; image003.jpg; image004.jpg; image005.jpg; image007.jpg; image009.jpg;
image010.jpg
Hi
I am not sure if this would be helpful to you but we just got in a FOIA response request this week and it shows Maxwell on
a notarized 1994 documents swearing she is a "disinterested" party and issuing an appraisal for certain of Epstein's New
Mexico land. Just wanted to pass it along because it is the earliest document I believe I have seen her name on.
Best,
Partner
BOIES SCHILLER FLEXNER LLP
Suite 1200
Fort Lauderdale, FL, 33301
(
From:
Sent: Thursday, March 12, 2020 2:33 PM
To:
V.
Cc:
Subject: Epstein NM re Zorro Trust 1993-1994 Records (FOIA) (Maxwell appears on 1994 doc)
EFTA00030804

=== Page 2 ===
#8795
LIMITED POWER OF ATTORNEY
903409
Done at New York City, New York, on the 3rd day of March, 1993.
I, Jeffrey E. Epstein, trustee of the Zorro Trust, a New York trust, hereby appoint John J.
Kelly as attorney-in-fact and agent to act on my behalf, to do and perform all acts and things
necessary to be done, including to execute and deliver on my behalf all statements,
memoranda, instruments of conveyance, and other documents of every sort that, in his
judgment, are or may be required to be executed by me as trustee, with the same force and
effect as I might or could do if personally present, with full power of substitution and
revocation, pursuant to that certain one Purchase Agreement dated February 25, 1993,
between Zorro Trust, as purchaser, and King Brothers Ranch, a New Mexico general
partnership. King Land & Cattle Company, a New Mexico general partnership, and Pine
Canyon Ranch, Inc., a New Mexico corporation, as seller, in connection with the closing of
the purchase by Zorro Trust of certain real property and appurtenant fixtures and personal
property located in Santa Fe County, New Mexico, on or about March 4-8, 1993.
This Power of Attorney is limited to matters pertaining to the transaction. described herein
and shall terminate 30 days following the execution, delivery, and filing of record of the
deeds from seller to purchaser in the real property records of Senta Fe County, New
OF SANTA
STATE OF NEW MEXICO
ISS 806171
I hereby certify that this instrument was filed
for record on the
19 43 3:37 day o'clock Marchal
8
of
AD.
m.
and was duly recorded in book 9031
pageto9 of the records of Santa Fe County.
Witness my Hand and Seal of Office
Jeffrey Epstein, trustee of the
Jona G. Armijo
a New York trust
COUNTY
TER
County Clerk, Santa Fe County, N.M.
theremen Clarter
*
*
Deputy
STATE OF NEW YORK
)
)
COUNTY OF KINGS
)
SANTA FE JONA COUNTY G. ARMIJO NEW MEXICO
The foregoing instrument was acknowledged before me this 3rd day of March, 1993, by
Jeffrey E. Epstein, trustee of Zorro Trust, a New York trust.
Notary Public
My commission expires:
HARRY 1. BELLER
Netary Public, State of NEW York
Qualified
No. 1944
Epstein\closndoc.poa
Considerion
THE
EFTA00030805

=== Page 3 ===
NEW MEXICO STATE LAND OFFICE
PARTIAL ASSIGNMENT OF AGRICULTURAL LEASE
(I/We), the undersigned lessee(s), hereby assign to Jeffrey E. Epstein (Trustee) ml
457 MADISON Ave, New York, NY 10022 me
of Zorro Trust, a New York Trust
Telephone ( 212 )- 750 * 9895
as it relates to the lands described below
all (my/our) right, title and interest/in State Agricultural Lease No. GM 2583
,
and all rights to compensation for the improvements located on the leased land, for which
improvements (I/We) hereby either waive payment or acknowledge receipt of payment of
full improvement value. (I/we) understand and agree that any outstanding sublease of all or a
portion of the leased lands is hereby terminated. The lands covered by said lease are described
as follows:
Township 12 North Range 9 East section 2: Lots 1,2,3,4,7, SWENE%, Signa, SW% for
518.97 acre
Township 12 North Range 9 East section 16: All - 640.00 acres
Total - 1,158.97 acres
Final bulling sent to same
address but in name of
Q.E. Epstein Company
and
10/26/93
EFTA00030806

=== Page 4 ===
PAID
NEW MEXICO STATE LAND OFFICE
APPLICATION FOR PERMISSION TO MAKE IMPROVEMENTS
JEFFREY E. EPSTEIN
ZORRO RANCH
1.
of
(address) P.O. BOX 567, STANLEY, NM 87056
herewith make application for the written consent of the Commissioner of Public Lands to make improvements on
the lands in Lease No. SM 2583 . described as follows:
Gm.2791
SUBDIVISION
SEC. 16 TWP. 12N MCE. 9E ACRES 640
Cancelled
If any or all proposed improvements are to be built under a federal cost-share program, please check which pro-
gram or programs are involved and give actual CODE of each item.
Great Plains Program (SCS) ( ) - ASCS ( ) - OTHER ( ) - NONE ( )
Barns, stables and corrals
Value $ N/A
Well (give depth and description)
Value $ N/A
Fences (give length, 1.e., miles or footage and kind)
Value $ N/A
Windmill
Value $ N/A
Other improvements Grass strip runway for private plane.
TOTAL VALUE OF IMPROVEMENTS
$6,000.00
Amount to be defrayed by federal cost-share program. if any
Value $
0.00
Total economic cost expended by LESSEE
Value :6,000.00
Estimated time of completion: JULY 1, 1994
S LESSEE Jeffrey E. Epstein
LESSEE
ACTION TAKEN BY REQUESTING DIVISION: Cancelled as per May 12,1994
letter from Jeffrey E Epstein 5/23/94 DM)
DATE RETURNED TO LAND USE SPECIALIST:
MAXWELL APPRAISING NM LAND FOR EPSTEIN IN 1994 SWEARING SHE IS A DISINTERESTED PARTY TO THE
TRANSACTION.
EFTA00030807

=== Page 5 ===
APPRAISEMENT OF GRAZING AND AGRICULTURAL LANDS
COMMISSIONER OF PUBLIC LANDS
NEW MEXICO STATE LAND OFFICE BUILDING
PO BOX 1148, SANTA FE, NEW MEXICO 87504-1148
LESSEE: SECTION 10 OF THE NEW MEXICO ENABLING ACT SPECIFICALLY REQUIRES THAT ALL
STATE LAND TO BE LEASED DE APPRAISED AT ITS TRUE VALUE. STATE LAW, UNDER SECTION 19-7-1
NMSA 1978, FURTHER PRESCRIBES THAT SUCH APPRAISEMENT BE SECURED BY THE LESSEE WHEN
ACQUIRING A LEASE AND THAT SUCH APPRAISEMENT BE COMPLETED BY A DISINTERESTED PERSON. THE
INSTRUCTIONS FOR THE COMPLETION OF THIS FORM ARE SET OUT BELOW.
APPRAISEMENT
INSTRUCTIONS: THIS INFORMATION MUST BE COMPLETED BY A DISINTERESTED PERSON AND BASED ON
THAT INDIVIDUAL'S INFORMATION AND BELIEF. THE LAND MUST BE APPRAISED AS VACANT, I.E.
WITHOUT IMPROVEMENTS, FOR BOTH SALE AND LEASE PURPOSES. IT MUST ALSO BE SIGNED BEFORE A
NOTARY PUBLIC.
I,
GHISLAINE MAXNELL
F
DO SOLEMNLY SWEAR (OR AFFIRM), UNDER
THE PENALTIES OF PERJURY, THAT AFTER HAVING PERSONALLY INSPECTED THE TRACT OF LAND(S)
OPINION OF THE APPRAISED CASH VALUE OF SAME (WITHOUT IMPROVEMENTS) IS $ 300.00 PER
CONTAINED IN LEASE NO. GAY 2791 AND DESCRIBED IN EXHIBIT A OF SAID LEASE, THAT MY
ACRE, IF SOLD, AND $ 4.00.00 PER ACRE, FOR LEASE PURPOSES, AND CERTIFY THAT I AM NOT
INTERESTED IN SAID LAND FOR LEASING OR SALE THEREOF.
SIGNED
ADDRESS 457 MADISON AVE, NY 10022
CITY/STATE NEWYORK NY
SUBSCRIBED AND SWORN TO BEFORE ME THIS 20 DAY OF July
1994.
MY COMMISSION EXPIRES:
NOTARY Herry PUBLIC Ifilla
EFTA00030808

=== Page 6 ===
is a name that appears on many corporate documents.
HARRY I. BELLER
Motary Public, State of New York
No. 24-4853924
Qualified In Kings County
Commission Expires Feb. 17,
SIATE
Mel
Post-it* Fax Note
7671
Date
18JULY
# of
pages
To
From
Co/Dept.
Co.
J.EPSTEIN CO
9
Phone #
Phone
#
Fax #
Fax #
Case Manager
BOIES SCHILLER FLEXNER LLP
Suite 1200
Fort Lauderdale, FL, 33301
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
EFTA00030809


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=== Page 1 ===
From:
"
)"
To:
)"
Subject: Maxwell draft elements, order of proof
Date: Sat, 07 Mar 2020 21:56:30 +0000
Attachments: 2020-02-11,_Maxwell_draft_elements_and_order_of_proof.docx
Assistant U.S. Attorney
Southern District of New York
EFTA00030300


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=== Page 1 ===
From:
)"
To:
Cc:
(USANYS)"
)"
Subject: Maxwell discovery productions & laptop
Date: Wed, 18 Nov 2020 14:25:39 +0000
Attachments:2020-11-18_GM_letter_to_MDC_re_laptop.pdf,ATT00001.htm;2020.11.18_MDC_ -
Maxwell_MAIN.pdf; ATT00002.htm; 2020.11.18_MDC__Maxwell_PASSWORD.pdf;
ATT00003.htm; 2020.11.09_MDC - Maxwell_MAIN.pdf;,ATT00004.htm;
2020.11.09_MDC_-_Maxwel_PASSWORD.pdf;ATT00005.htm
Hi
This morning, I dropped off the laptop with a power cord and cover memo for Maxwell to use when reviewing her
discovery. Attached please find a copy of the cover memo.
I also dropped off a hard drive and CD containing a new discovery production for Maxwell. Attached please find the two
cover letters.
Last week, we sent out via FedEx a hard drive containing a separate production, which included replacements of
numerous files that Maxwell has been unable to review from prior productions. The accompanying cover letters are
attached. Would you please confirm that the drive has been provided to Maxwell?
Thanks very much, as always, for your help.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00029978


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: FW: Draft Epstein Devices SW
Date: Thu, 25 Jun 2020 13:22:26 +0000
Attachments: SW_for_all_JE_electronic_devices_v4.docx
I can look at this unless you've already started.
Any more from Audrey? Her call is at 11?
From:
Sent: Wednesday, June 24, 2020 5:06 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: Draft Epstein Devices SW
Chiefs,
Attached for review is a draft search warrant seeking a warrant that expands the scope of our review of the data from the
devices we seized from Epstein. Happy to discuss.
Thanks,
EFTA00029794


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=== Page 1 ===
From:
Subject: FYI
Date: Thu, 13 Jun 2019 23:53:24 +0000
Importance: Normal
Attachments: Agg_Harrass_1996.pdf
I noticed this in the file. Something to remember for later.
EFTA00030289


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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: RE: Epstein search materials for upload and privilege review
Date: Wed, 12 Feb 2020 18:22:00 +0000
Attachments: Epstein_Priv_terms.docx
When it's loaded, can you have PAE run the attached privilege terms and move the hits to PP folders and the nonhits to
NP folders and send me the STR?
Please keep all the folders locked until I can do the spot check.
Thanks,
From:
Sent: Wednesday, February 12, 2020 1:17 PM
To:
Cc:
is
)
is
)
Subject: RE: Epstein search materials for upload and privilege review
The data is almost done. I should have it to you by the end of the week.
Thank you.
From:
Sent: Wednesday, February 12, 2020 1:04 PM
To:
Cc:
is
)
is
Subject: RE: Epstein search materials for upload and privilege review
wanted to follow up on this - is the data fully uploaded, or did it get delayed? Thanks.
From:
Sent: Friday, February 07, 2020 11:25
To:
Cc:
is
)
is
)
Subject: RE: Epstein search materials for upload and privilege review
Great, thank you!
EFTA00029661

=== Page 2 ===
From:
Sent: Friday, February 07, 2020 09:34
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
The data should be ready by Monday morning.
From:
Sent: Tuesday, February 4, 2020 6:58 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
Wanted to quickly check the status of the below - it's only been a couple weeks, so totally understand it may not be
complete, but hopefully we're getting close? If you could please check with the vendor and let us know, we'd be grateful
- and we'll plan to get it to
asap once we have access.
thanks,
From:
)
Sent: Tuesday, January 21, 2020 18:50
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
We've received a hard drive from FBI CART, which they've processed from devices seized and searched in connection with
the Epstein case. Can we please get those materials uploaded to Relativity, for privilege review by
(copied here)? I've
left the hard drive with the materials on your chair. (And if we could please get that hard drive back once the materials
are uploaded, the FBI has another batch they want to transmit to us for the same process, so that will also be coming
shortly.)
And then
these will be subject to just the exact same privilege review you previously ran in connection with Epstein
search warrant returns.
Please let us know if any questions or issues at all? And thanks very much as always.
EFTA00029662


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c6: pdf
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=== Page 1 ===
From:
To:
Subject: RE: [EXTERNAL EMAIL] - Favor -
Date: Mon, 11 Jan 2021 16:54:00 +0000
Sounds good! Let me know if you ever need anything else.
-
On Jan 11, 2021 11:33 AM,
wrote:
Ah, ok. Yeah I think they are the intake squad for MCC matters (I worked with them on the Epstein death investigation) but
l'll reach out to
to confirm.
From:
Sent: Monday, January 11, 2021 11:31 AM
To:
Subject: RE: [EXTERNAL EMAIL] - Favor
#
On Jan 11, 2021 11:26 AM,
(USANYS)"
wrote:
Got it. Do you know who the SSA is of C19 now?
From:
Sent: Monday, January 11, 2021 11:25 AM
To:
Subject: RE: [EXTERNAL EMAIL] - Favor
He was assigned to C-19, and I was assigned to C-30/New York Metro Safe Streets. C-19 is the initial intake
squad for Criminal complaints. I am not sure whether they are responsible for assaults within a federal prison.
-
On Jan 11, 2021 11:21 AM,
(USANYS)"
wrote:
Thanks
Which squad was that? And which squad were you on at the time? I'm trying to figure out why MCC would
have referred that to
From:
Sent: Monday, January 11, 2021 11:20 AM
To
(USANYS)
Subject: [EXTERNAL EMAIL] - Favor
Hi
I have an answer. SA
was assigned to the NYO Bank Robbery Task force at the time of the
assault. He has since retired from the FBI, and therefore he would not be able to answer my work emails.
Respectfully,
=
On Jan 10, 2021 1:29 PM,
(USANYS)"
wrote:
Hey
- hope all is well! We're working on a motion filed by Robert Gist related to the prison assault. Can you tell me
what squad
was on at the time he got this referral and forwarded it to you (Feb 2017)? My memory is that he
was on the squad responsible for dealing with MCC stuff - is that right? And is
still with the FBI?
Thanks!
U.S. Attorney's Office
Southern District of New York
EFTA00030878

=== Page 2 ===


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: Jeffrey Epstein
Date: Mon, 08 Jul 2019 01:33:35 +0000
Importance: Normal
Thanks! I'm still at my desk, but hoping to get home before midnight. Thanks again for covering! You're the greatest.
From:
(USANYS)
Sent: Sunday, July 7, 2019 9:28 PM
To:
Subject: FW: Jeffrey Epstein
Congratulations again!!! So much press coverage. So little time. I hope you're able to get some sleep before the big day
tomorrow. PS I moved my meeting so l'll be handling the sentencing myself. Let me know if you need anything else.
From:
(USANYS)
Sent: Sunday, July 7, 2019 1:08 PM
To:
Cc:
is
V.
is
(USANYS)
Subject: Jeffrey Epstein
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.
&
EFTA00030224


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=== Page 1 ===
From:
)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
)"
Subject: FW: US V. Maxwell Case No. 20-3061, [Unredacted Reply Brief]
Date: Thu, 08 Oct 2020 21:22:43 +0000
Attachments: 2020.10.08_Unredacted_Reply_Brief.pdf;
2020.10.08_Motion_for_Leave_to_File_RB_Under_Seal.pdf
Inline-Images: image001.jpg
FYI
From: Nicole Simmons
Sent: Thursday, October 8, 2020 4:55 PM
Cc: Adam Mueller
>; Ty Gee
>; Laura Menninger
>;
Shin, Won (USANYS)
is
>;
is
(USANYS)
>; Metzner, Karl (USANYS)
Subject: US V. Maxwell Case No. 20-3061, [Unredacted Reply Brief]
To Whom It May Concern:
At the request of Adam Mueller, please see attached the Unredacted version of Ms. Maxwell's Reply Brief in the above
referenced matter. Please let me know if you have any questions or concerns.
Regards,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
www.hmflaw.com
EFTA00030583


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=== Page 1 ===
From:
To:
Subject: RE: Found her!
Date: Fri, 16 Aug 2019 04:20:54 +0000
I mean
it's a good burger!
From:
Sent: Thursday, August 15, 2019 16:40
To:
Subject: Found her!
All you had to do was go to the local In-N-Out burger. just sayin'
https://nypost.com/2019/08/15/jeffrey-epsteins-gal-pal-ghislaine-maxwellspotted-at-in-n-out-burger-in-first-photos-
since-his-death/
Public Affairs
U.S. Attorney's Office for the Southern District of New York
Website: www.justice.gov/usao-sdny.
Facebook: https://www.facebook.com/usaosdny
Follow us on Twitter: @SDNYnews
EFTA00031005


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=== Page 1 ===
From: Bruce Barket
To:
)"
Cc:
(USANYS)"
Aida Leisenring
>, Tony Ricco
>, "BRUCE KOFFSKY"
>, John Diaz
, "Kenneth J. Montgomery Esq"
Subject: Re: Statements by Mr. Tartaglione
Date: Mon, 25 Nov 2019 20:08:45 +0000
Thanks. Talk to you then
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country road
Garden City, NY 11530
Barket Epstein.com
On Nov 25, 2019, at 2:40 PM,
)
wrote:
Yes, we can use the below dial-in for 10am on Wednesday 11/27:
877-989-1320
Passcode: 8616359
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Bruce Barket
Sent: Monday, November 25, 2019 1:25 PM
To:
)
>
Cc:
(USANYS)
>; Aida Leisenring
>; ; Tony Ricco
>; ; BRUCE KOFFSKY
is
; John Diaz
>; ; Kenneth J. Montgomery Esq
Subject: RE: Statements by Mr. Tartaglione
EFTA00030552

=== Page 2 ===
10:00 works for us. Do you have a call in number we can use? I think several of us will join the call
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
From:
) [mailto:
Sent: Saturday, November 23, 2019 6:12 PM
To: Bruce Barket
Cc:
(USANYS); Aida Leisenring; Tony Ricco; BRUCE KOFFSKY;
; John Diaz;
Kenneth J. Montgomery Esq
Subject: Re: Statements by Mr. Tartaglione
and I are both available all day Wednesday, so we can make any time work. That said, I have a slight preference for
morning. How about 10am?
On Nov 23, 2019, at 5:22 PM, Bruce Barket
wrote:
I think Wednesday works better. Give us some times.
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country road
Garden City, NY 11530
Barket Epstein.com
On Nov 23, 2019, at 1:55 PM,
(USANYS)
wrote:
We are available Monday at 4 pm or any time on Wednesday. Let us know what works for the defense team.
Assistant United States Attorney
From: Bruce Barket
Sent: Friday, November 22, 2019 3:06 PM
To:
(USANYS)
>; Aida Leisenring
>; Tony
Ricco
>; BRUCE KOFFSKY
>;
;
John Diaz
>; Kenneth J. Montgomery Esq
EFTA00030553

=== Page 3 ===
Cc:
Subject: RE: Statements by Mr. Tartaglione
Let's set up a call as I believe that the material I requested is relevant and we are entitled to it.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not
clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
From:
(USANYS) [mailto:
Sent: Friday, November 22, 2019 11:51 AM
To: Bruce Barket; Aida Leisenring; Tony Ricco; BRUCE KOFFSKY;
; John Diaz; Kenneth J.
Montgomery Esq
Cc:
)
Subject: RE: Statements by Mr. Tartaglione
All,
In response to your request for any statements made by Mr. Tartaglione during interviews at the MCC related to the
investigation into an event involving Jeffrey Epstein on or about July 23, 2019, we are producing to you a zip folder
with reports of those statements. The zip folder also contains reports of statements attributed to Mr. Tartaglione
that were conveyed to MCC staff by Mr. Epstein. These materials have been marked "sensitive" pursuant to the
protective order in this case and should be treated accordingly.
In response to your additional request for "all the reports and video regarding Mr. Epstein's attempted suicide on July
22-23rd, we do not believe these materials are relevant to this case or covered under Rule 16, and therefore will not
be producing them. If you would like to discuss further, please give us a call.
Assistant United States Attorney
From: Bruce Barket
Sent: Wednesday, November 20, 2019 8:50 AM
To:
(USANYS)
Cc:
is
>; Aida Leisenring
Subject: Re: Statements by Mr. Tartaglione
Thank you.
In addition to the statements attributed to Mr. Tartaglione we are asking did for all the reports and Video regarding
Epstein's attempted suicide on July 22-23rd.
I believe we sent a letter to the MCC shortly after the event asking that the video be preserved.
EFTA00030554

=== Page 4 ===
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country road
Garden City, NY 11530
Barket Epstein.com
On Nov 19, 2019, at 12:23 AM,
(USANYS)
wrote:
Bruce - To the extent your request is to the MCC/BOP, the request is governed by the procedures set forth below
in
email. To the extent the request is to our office pursuant to Rule 16, as a courtesy, we will look to see
what statements are in our possession and gather and produce them to you by the end of the week. The
production will be pursuant to the protective order in this case.
Assistant United States Attorney
From:
Sent: Monday, November 18, 2019 8:50 AM
To: Bruce Barket
is
(USANYS)
is
Cc: Aida Leisenring
Subject: Re: Statements by Mr. Tartaglione
Hi Bruce,
Pursuant to FOIA/Privacy Act and Touhy regulations, we need a release from the inmate, Touhy letter, and subpoena
for the request to be considered locally. Please also be advised that we would have to seek authority under Touhy
through the USAO.
Thank you,
>>> Bruce Barket
11/17/2019 5:03 PM >>>
It is my understanding that Mr. Tartaglione was interviewed by members of Bureau of Prisons in the late hours of
July 22nd or the early hours of July 23, 2019 concerning Jeffrey Epstein's reported attempted suicide attempt.
Pease provide the record of any statements made by Mr. Tartaglione, any written statements made by Mr.
Tartaglione and any recording of any such statements.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not
clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
EFTA00030555

=== Page 5 ===
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
EFTA00030556


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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: Epstein
Date: Mon, 01 Jun 2020 18:53:49 +0000
Indeed.
Original Message
From:
)
Sent: Friday, May 29, 2020 18:26
To:
)
Subject: Re: Epstein
That blows, must be so frustrating. Sorry to hear that.
I won't bother you with every inane observation, but I sure felt like Graydon Carter could have written a better
statement than the one they show at the end of episode 1; "We thought we'd lose a lawsuit if we published it,"
not exactly a profile in courage.
Sent from my iPhone
> On May 29, 2020, at 4:08 PM,
)
wrote:
>
> Yeah I totally agree with your initial thoughts, and you'll have to let me know what you think if you keep
watching.
>
> And yeah, it's unfortunate especially because if COVID wasn't an issue, I think we'd be really close to making
decisions on the other folks! But no way we can move forward even in the next month or two with all this going
on (and our subjects not being ongoing threats to public safety, obviously).
V
>
>
Original Message
> From:
V
Sent: Friday, May 29, 2020 13:55
> To:
> Subject: Re: Epstein
V
> Thanks so much! I'm really interested in your insights. I'm almost through the episode and find the pacing to
be a little tedious, possibly foreshadowing that they made what should be a short series into a long one. (And
I've seen a couple of reviews suggesting something similar.)
V
> I would imagine you guys aren't super excited about the renewed energy (and pressure) the anniversary will
bring. There's definitely a buzz in the air. Thanks again for sending notes!
V
> Sent from my iPhone
V
On May 29, 2020, at 1:49 PM,
)
wrote:
>> Ha I literally just sent the team my notes on it, I watched the whole thing over the past couple days. Have you
watched it yet? I'll forward you my email to them.
EFTA00031312

=== Page 2 ===
Original Message
>> From:
>> Sent: Friday, May 29, 2020 13:35
>> To:
>>
Subject: Epstein
>>
>> Started watching the new Netflix doc yet?
>>
>>
Sent from my iPhone
EFTA00031313


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Automatic reply: Epstein update
Date: Sat, 10 Aug 2019 14:43:02 +0000
As you might imagine, we are getting increasingly frantic calls from defense counsel who continue to be seeing
information in the press that we-the U.S. Attorney's Office-haven't yet received. We need to know as soon as
possible the very basic facts, such as time and cause of death at the absolute minimum. It has now been hours
since this was reported publicly. Please advise when we can expect to receive either a written report on those
basic facts or when we can have a call to get that information to relay to his counsel. It is extraordinarily
frustrating to have to tell them that we have less information than the press. Please advise.
Thank you,
On Aug 10, 2019, at 08:46,
wrote:
Passed away. We are completing a significant incident report for HQ for Death of a Federal Inmatehowever, I do not
have any specifics from the BOP yet.
From:
Sent: Saturday, August 10, 2019 8:44 AM
To:
Cc
Subject: Re: Automatic reply: Epstein update
Thank you for telling us. What do you mean by "passed"?
Thanks,
Sent from my iPhone
On Aug 10, 2019, at 8:18 AM,
wrote:
BOP just provided another update- Epstein has passed. I have no additional info. I will push out updates as we
receive.
From:
Sent: Saturday, August 10, 2019 7:52 AM
EFTA00029739

=== Page 2 ===
To:
Subject: Re: Automatic reply: Epstein update
FYI:
The BOP just informed us that Epstein is being taken by ambulance to the hospital from another apparent suicide
attempt- no other information was provided.
They will update us as more info becomes available.
On Aug 10, 2019, at 7:26 AM,
rote:
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses
may be delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
at
or
EFTA00029740


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
Subject: RE: Travel Records
Date: Wed, 07 Apr 2021 04:57:02 +0000
Thanks! I'm waiting on a few more items from
that I asked her to copy for me during the physical evidence
review. Once I've gotten those into the discovery folder, then l'll ask the paralegals to finalize and send out this next
production.
From:
(USANYS)
Sent: Tuesday, April 6, 2021 10:05 PM
To:
Cc:
Subject: RE: Travel Records
Thanks for checking. I saved the files in a folder called CBP - CONFIDENTIAL located within the folder that has our next
production:
11
From:
Sent: Tuesday, April 06, 2021 10:01 PM
To:
(USANYS)
Cc:
Subject: RE: Travel Records
I do not see them with the other CBP records we previously produced in August 2020, so my view is we should go ahead
and produce these now.
From:
(USANYS)
Sent: Tuesday, April 6, 2021 8:23 PM
To:
Cc:
Subject: FW: Travel Records
- I'm nowhere near as familiar with the discovery, so not sure if this has been produced. If not, let me know and
I can forward to
to produce. l'll also save in her 3500.
From:
N. (NY) (FBI)
Sent: Tuesday, April 06, 2021 11:46 AM
To:
(USANYS)
i
Cc:
is
Subject: RE: Travel Records
We sent the FDR to the UK and are waiting for results. Yes there are records for
Attached are the records for
from 1/1/1990-4/5/2021. There are two sets due to her last name being both
and
on the travel records.
Feel free to give me a call if you have questions.
EFTA00030019

=== Page 2 ===
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
From:
(USANYS)
Sent: Monday, April 5, 2021 10:51 AM
To:
(NY) (FBI)
is
(NYPD)
Cc:
is
)
Subject: [EXTERNAL EMAIL] - Travel Records
and
I wanted to check in to see whether there is any update from the ALAT about travel records on the UK side for Maxwell,
Epstein, and
Also, when we got the CBP records for Epstein and Maxwell for the 1990s, did we also request
those records for
?
Please feel free to give me a call on this.
Thanks!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00030020


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=== Page 1 ===
From: Jordan Merson <jmerson@mersonlaw.com>
To:
Cc: Jesse Mautner <jmautner@mersonlaw.com>
Subject: This Epstein accuser is 'ecstatic' over Ghislaine Maxwell's arrest
Date: Fri, 03 Jul 2020 01:00:39 +0000
Dear Mr.
:
You previously reached out to me but my client is ready to help. Let me know the next steps.
https://nypost.com/2020/07/02/this-epstein-accuser-is-ecstatic-over-ghislaine-maxwells-arrest/
Sent from my iPhone
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=== Page 1 ===
From:
)"
To:
)"
)"
Cc:
)"
Subject: RE: Fwd: Epstein packet
Date: Tue, 23 Jun 2020 13:19:07 +0000
Thank you. Please stay on top of them and keep us posted.
From:
)
Sent: Tuesday, June 23, 2020 9:17 AM
To:
is
)
is
Subject: FW: Fwd: Epstein packet
fyi
From:
Sent: Tuesday, June 23, 2020 9:11 AM
To:
)
Subject: Re: Fwd: Epstein packet
The documents that
sent me are not what you're looking for. I'm working to compile the things that were requested
and I'll email them to you as soon as I get them together. Please give me another day to track some of this stuff down.
I
was hoping
had everything but he didn't have anything you needed.
)"
> 06/23/20 7:42 AM >>>
GM
Can you please advise. If you are able to email docs, that would be great.
Sent from my iPhone
Begin forwarded message:
From:
)"
Date: June 23, 2020 at 7:39:53 AM EDT
To:
Subject: Re: Epstein packet
Great, thx much!
Sent from my iPhone
On Jun 23, 2020, at 7:22 AM,
wrote:
Good morning,
I have sent all documents pertaining to Epstein to
for his review. Once documents have been reviewed he
will be in contact with you if he hasn't already done so. If you should need anything else please feel free to contact me
EFTA00030478

=== Page 2 ===
Thank you.
Sent from my Verizon, Samsung Galaxy smartphone
Original message
From:
)"
Date: 6/22/20 1:53 PM (GMT-05:00)
To:
Subject: Epstein packet
>>>
)" 06/22/2020 13:53 >>>
Hi Exec (XO):
Hope all is well.
It is my understanding that you might have mailed requested docs regarding the Epstein investigation to our office. If so
, it may have been misplaced since we're not readily at our office due to pandemic. Is there any way the docs can be e
mailed? Thx and stay well.
Sent from my iPhone
EFTA00030479


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=== Page 1 ===
STATE
STATES
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
May 3, 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)
Enclosed is discovery pertinent to the following inmate:
Ghislaine Maxwell: 02879-509
Please allow her access to the materials enclosed.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
Assistant United States Attorneys
Enclosure
EFTA00031688


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=== Page 1 ===
From:
)"
To:
Subject: Transcript
Date: Thu, 29 Oct 2020 21:23:38 +0000
Attachments: 2020.07.14,_Maxwell_arraignment,_initial_conference_bail_hearing.pdf
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York. NY 10007
EFTA00030983


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=== Page 1 ===
From: Sigrid McCawley <smccawley@bsfllp.com>
To:
Subject: Ca Police Report from 1997 Epstein recruiting girl by claiming it was a "modeling
interview"
Date: Thu, 11 Jul 2019 14:10:26 +0000
Attachments: Exhibit_030_Dershowitz.pdf
Hello
- I am sure you are getting inundated with information but I ran across this document
this morning and I thought I should provide it to you. It is similar to what
says she
was told when she witnessed young girls coming to the NY mansion - - that they were there for
"modeling interviews" with Victoria Secret. It is redacted so you can't tell who recruited her but
it appears to be a female.
Good luck with everything,
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
smccawley@bsfllp.com
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
EFTA00030256


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=== Page 1 ===
From: Gloria Allred
To:
Cc: Mariann Wang <mwang@chwllp.com>
Subject: New potential victims of Epstein and some of Maxwell who are willing to speak to you and
the FBI.
Date: Mon, 10 Aug 2020 23:31:19 +0000
Inline-Images: image001.png; image002.png
My co- counsel, Mariann Wang, and I would like to schedule a call with one of you to discuss some questions we have
prior to scheduling our clients' interview with you. Would you be available for a call with us on Wednesday at 2 P.M.
e.s.t.?
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
323-653-6530
www.amglaw.com
www.gloriaallred.com
GLORIAALLRED
2020
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
Inducted into National Women's Hall of Fame - 2019
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 323-653-6530. Thank you.
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=== Page 1 ===
From:
(USANYS)"
To:
(CRM)"
Subject: RE: U.S. Department of Justice investigation
Date: Tue, 16 Jun 2020 15:33:14 +0000
Thanks,
although given that Bloxsome has clearly been sharing his own communications with the Home Office, I think
we would be comfortable sharing his.
In any event, I have conferred on this end, and we are prepared to accept your advice and allow you to communicate on our
behalf with the Home Office in lieu of writing our own letter at this time. I'll await your draft.
Thanks very much,
From:
CRM)
Sent: Tuesday, June 16, 2020 11:11 AM
To:
(USANYS)
Subject: RE: U.S. Department of Justice investigation
This is very helpful. It does not look like we can share the Feb email with the Home Office without
checking with Bloxsome first. If we share it, he will cite it as just one more reason the US cannot be
trusted.
Also, I think this process started before Jan 2020. I have my notes at the Embassy, but I think I started
working with
in the late fall, and the DCM put in one or more calls on this in either Nov or Dec. I'll
dig out my notes when I am back in the office later this week.
Let me draft an email to
and her team and then send it for your consideration. I think it would
be better in the first instance to deal with this diplomatically and then escalate if unsuccessful.
From:
(USANYS)
Sent: Tuesday, June 16, 2020 3:40 PM
To:
(CRM)
Subject: FW: U.S. Department of Justice investigation
- You should also be aware of the correspondence below which is what precedes the Valentine's Day email (the
highlighting is mine). Obviously, as with the other one, please keep just to yourself for now, pending further discussions about
next steps, but this gives you some of the context I was referring to. Many thanks,
Begin forwarded message:
From: Gary Bloxsome
Date: February 5, 2020 at 12:39:15 EST
To:
(USANYS)"
Cc:
(USANYS)"
i
(USANYS)"
>, Daniel
EFTA00030190

=== Page 2 ===
Cundy
, Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Dear
Thank you for your email.
We will reflect on the position of DOJ and provide you with a considered response shortly.
Best.
Gary
Gary Bloxsome
Partner
Blackfords LLP
London EC4M 7EF
|
I
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at Hill House, 1 Mint Walk, Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 4 Feb 2020, at 18:23,
(USANYS)
wrote:
External email: is it safe to open attachments and links?
Gary,
You are aware of our position, and we do not believe any further rehashing of our prior conversations is productive at this
point. That said, we can confirm that it is our standard practice to refrain from publicly commenting on the substance of
any witness interview, and we intend to abide by that practice in this case. Beyond that, we can make no commitments.
Please advise as to whether Prince Andrew will agree to be interviewed and, if so, when such interview will take place.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Monday, February 03, 2020 10:46
To:
(USANYS)
>
Cc:
(USANYS)
is
(USANYS)
>; Daniel Cundy
; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
EFTA00030191

=== Page 3 ===
Dear
Thank you for your email of 30 January 2020.
On 10 January 2020 you personally assured me that any contact between the Duke of York and the DOJ was
confidential and would remain confidential within the investigation team in the DOJ and FBI. You said: "We don't
intend to share either the contents or the existence of the conversation beyond our chain of command in the DOJ.
As well as our partners at the FBI. It is confidential within the investigation team and our supervisors." The note I
made of what you said about the confidentiality of the interview process is as follows: "We do not publicise the
content or existence of any of our interviews. We can't guarantee that anyone might not share it with some other
person or it might be shared with other individuals who might come to have knowledge of its existence, but our
office does not advise the press of the interview and doesn't advise other interviewees of the fact the interview has
taken place or the contents of those discussions. For example, it was reported widely that our office was
attempting to interview your client months ago which was inaccurate. We have been working on this request for
several weeks now and it has not hit the press. That is consistent with our processes. We take confidentiality very
seriously."
At no point did you suggest that, because of a press statement made on behalf of the Duke in November 2019, you
or your colleagues in the investigation team would feel able to provide a public commentary on the DOJ's views on
the degree of cooperation provided by the Duke. DOJ's first contact of any kind with the Duke was in early January
2020, and the first mention of any request for consideration of an interview came solely from you.
I object to your wholly inaccurate statement that the Duke has created a public misimpression. The Duke has made
it clear that he has a strong desire to cooperate fully with the ongoing investigation by the DOJ. The
communications between us were intended to enable him to provide that co-operation. In order for this process
to continue, I need to emphasise that we regard the confidential treatment of all contacts between the DOJ and
the Duke as essential. We do not wish to have any public pronouncements on what we regard as a voluntary and
confidential process. Please confirm that any further communications in connection with the requested voluntary
interview will be treated as wholly confidential and the DOJ will offer no further commentary on the Duke's co-
operation.
Best
Gary Bloxsome
Gary Bloxsome
Partner
<image001.jpg> <image002.jpg>
Blackfords LLP
London
EC4M 7EF
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
EFTA00030192

=== Page 4 ===
On 30 Jan 2020, at 23:51,
(USANYS)
wrote:
External email: is it safe to open attachments and links?
Gary,
On November 20, 2019, Prince Andrew publicly offered to cooperate with our investigation into Jeffrey Epstein's crimes,
stating in a press release: "Of course, I am willing to help any appropriate law enforcement agency with their
investigations, if required." In early January 2020, our Office responded to the Prince's public offer by contacting you to
set up the interview that the Prince claimed to be willing give us. More than three weeks after our initial contact with
you, we still had no date for an interview, nor did we even have a commitment from you that the Prince in fact would
agree to an interview.
On January 27, 2020, at a press event held by Safe Horizon to which Mr. Berman was invited, Mr. Berman was asked: "As
part of [the Epstein] investigation have you reached out to interview Prince Andrew, and has he been cooperative?"
Mr. Berman responded: "Ordinarily, our office doesn't comment on whether an individual cooperates or doesn't
cooperate with our investigation. However, in Prince Andrew's case, he publicly offered, indeed in a press release,
offered to cooperate with law enforcement investigating the crimes committed by Jeffrey Epstein and his coconspirators.
So I think in that context, it's fair for people to know whether Prince Andrew has followed through with that public
commitment. So let me say that the Southern District of New York and the FBI have contacted Prince Andrew's attorneys
and requested to interview Prince Andrew and to date, Prince Andrew has provided zero cooperation."
Mr. Berman's statement corrected a public misimpression - created by the Prince himself - that the Prince is cooperating
with our investigation.
As soon as the Prince commits to a date for the interview that he so publicly offered to us more than two months ago, we
would be prepared to announce that he has agreed to be interviewed.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Tuesday, January 28, 2020 11:59
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>; Daniel Cundy
; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Dear
Thank you for your email response claiming that US Attorney Berman's statements were factually accurate and
did not create a misleading impression.
We only have access to edited video and newspaper reporting of what the US Attorney said. Those reports
suggest the US Attorney described the position of the Duke of York and his advisors in misleading,
condemnatory and prejudicial terms. US Attorney Berman is quoted as having stated there has been "zero co-
operation". This is not an accurate statement of the position. The following are also false statements ascribed to
Mr Berman and to the DOJ/FBI: "F.B.I. agents and federal prosecutors in New York reached out to his lawyers
EFTA00030193

=== Page 5 ===
and asked to interview him. There was no response at all, according to three people familiar with the
investigation." (New York Times 27.01.20) and "Geoffrey Berman, a US attorney, said federal prosecutors and
the FBI had asked to interview Prince Andrew about the late paedophile billionaire, but had been met with a
wall of silence "(The Telegraph 28.01.20).
Please provide us with an accurate record of the statements made by The US Attorney and/or the DOJ/FBI
including a transcript of any relevant questions and answers.
We note from your email that you have not provided any response to our request that you confirm that the DOJ
will not be making any further public statements about the Duke of York. We had understood from our
conversations with you and from the rules governing media relations that DOJ personnel and the US Attorney
would not comment on the nature or progress of any grand jury investigation and in particular would not
comment on the willingness of any Subject to make a voluntary statement to the DOJ. We ask you to confirm
that there will be no further public comment on any contact between the Duke of York and the DOJ.
Kind regards
Gary
Gary Bloxsome
Partner
<image001.jpg> <image002.jpg>
Blackfords LLP
London EC4M 7EF
|
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 27 Jan 2020, at 22:59,
(USANYS)
wrote:
External email: is it safe to open attachments and links?
Gary,
Our understanding is that U.S. Attorney Berman made a factual statement in response to a specific question that
suggested the Duke of York either would or was cooperating, and he responded that to date he has not in fact provided
cooperation with our investigation. That is, he corrected the record generally in a factually accurate statement; I don't
believe this would create a misleading impression. I appreciate that you have advised us that your client has a desire to
cooperate, and we look forward to hearing from you when he has made a determination as to whether he is in fact
willing to speak with us.
Regards,
From: Gary Bloxsome
Sent: Monday, January 27, 2020 13:44
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>; Daniel Cundy
EFTA00030194

=== Page 6 ===
; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
The press are reporting that Geoffrey S. Berman, the United States Attorney for the Southern District of New York has
disclosed what we understood were confidential communications between us and
and
It has also been suggested that Geoffrey S. Berman has stated that the Duke of York has not co-operated with the
Southern District. As you know we have made it very clear that the Duke of York has a strong desire to cooperate with
the ongoing investigation by the DOJ and we are trying to reach a position where we are able to advise him to do so.
We are concerned about the misleading impression that has been created and the effect this has on our ability to
advise the Duke to proceed with any voluntary co-operation. Please confirm that the DOJ will not be making any further
public statements on this topic.
Thank you.
Gary Bloxsome
Gary Bloxsome
Partner
Blackfords LLP
London
EC4M 7EF
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at
Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 22 Jan 2020, at 17:34,
(USANYS)
wrote:
External email: is it safe to open attachments and links?
Gary,
We've received your response. We look forward to hearing whether the Duke of York is willing to speak with us.
thank you,
From: Gary Bloxsome
Sent: Wednesday, January 22, 2020 11:35
To:
(USANYS)
Cc:
(USANYS)
i
(USANYS)
>; Daniel Cundy
>; ; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
We are very grateful for your offer of assistance. At present we do not believe you can help us but we would welcome
a real-time conversation once we have achieved some of the more immediate preliminary tasks, including the need to
EFTA00030195

=== Page 7 ===
gather information from the Royal Household and others.
Best
Gary Bloxsome
Partner
Blackfords LLP
London
EC4M 7EF
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at
Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 20 Jan 2020, at 18:52,
(USANYS)
wrote:
External email: is it safe to open attachments and links?
Gary,
Thank you for your response. It would be useful for us if you were able to help us understand the nature of the
issues and procedures with which you are dealing, particularly as it sounds like it will take at least a couple
additional weeks to address even minor preliminary issues, which suggests likely additional subsequent time to
handle further processes-and without a response to the question of whether he is willing to speak with us,
separate from a general desire to cooperate. Our investigation is moving forward expeditiously and so we would be
grateful for some understanding of the relevant issues (especially, though not exclusively, to the extent we may be
able to assist in their resolution) and would be happy to speak via phone if a real-time conversation would be more
conducive to that discussion.
thank you,
From: Gary Bloxsome <gary.bloxsome@blackfords.com>
Sent: Monday, January 20, 2020 11:23
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>; Daniel
Cundy
>; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email. The Duke of York has made it clear to us that he has a strong desire to cooperate fully
with the ongoing investigation by the DOJ.
It is our responsibility to deal with the various issues and procedures that arise here that will need to be addressed
to enable him to do so. We should be able to deal with at least some of the minor preliminary issues in the next two
weeks and we will update you on our progress once we have done so.
Regards,
Gary
EFTA00030196

=== Page 8 ===
Gary Bloxsome
Partner
<image001.jpg> <image002.jpg>
Blackfords LLP
London EC4M 7EF
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at
Croydon, CRO 1EA. A list of members' names is available at this address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 18 Jan 2020, at 01:06,
(USANYS)
wrote:
External email: is it safe to open attachments and links?
Gary,
We write to follow up on our phone conversation of a week ago. Could you please advise regarding status, in
particular the initial question, separate from any logistics, of whether you expect your client will be willing to
speak with us? And of course please let us know if any additional information would be useful to you.
thank you,
From: Gary Bloxsome
Sent: Wednesday, January 08, 2020 07:38
To:
(USANYS)
-
Cc:
(USANYS)
>;
(USANYS)
>; ; Daniel
Cundy
; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email.
Friday 10th January at 1400(LDN) time is fine.
Please forward dial in details.
Kind regards
Gary
EFTA00030197

=== Page 9 ===
Gary Bloxsome
Partner
Blackfords LLP
|
London
EC4M 7EF
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at
Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 7 Jan 2020, at 18:56,
(USANYS)
wrote:
External email: is it safe to open attachments and links?
Gary,
We are available for a preliminary call this Friday, January 10. If it would be convenient for you, we are available
at 9:00 local time for us (which I believe would be 14:00 your time). If that works, we can plan to call you at your
office line unless you'd prefer we use another number or a conference line.
thank you,
From: Gary Bloxsome
Sent: Tuesday, January 07, 2020 11:20
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>; Daniel
Cundy
>; ; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Thank you for your email.
Please confirm whether you would be available for a preliminary telephone call on Friday 10th January 2020.
Kind regards.
Gary
Gary Bloxsome
Partner
Blackfords LLP
London EC4M 7EF
EFTA00030198

=== Page 10 ===
|
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at
Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 4 Jan 2020, at 01:38,
wrote:
External email: is it safe to open attachments and links?
Mr. Bloxsome,
Thank you for your response and for confirming your representation. To respond to your question generally, in
connection with our investigation of conduct relating to Jeffrey Epstein and certain of his associates, we wish to
request a consensual, voluntary law enforcement interview with your client. Generally, we would expect to
inquire about his relationship and communications with Jeffrey Epstein and his associates, as well as certain
allegations that have arisen publicly and in our investigation to date.
Although we recognize we separately have the ability to convey such a request through diplomatic and law
enforcement channels, we understand we may also alternatively inquire directly with counsel, when an
individual has legal representation. Given your representation, we are inquiring directly with counsel in the
first instance.
Certainly we can discuss our request in more detail, but we hope this will provide the information you were
seeking as a threshold matter, and we look forward to being in touch.
Regards,
Assistant U.S. Attorney
Southern District of New York
From: Gary Bloxsome
Sent: Friday, January 03, 2020 10:30
To:
(USANYS)
Cc:
(USANYS)
is
(USANYS)
>; Daniel
Cundy
>; ; Jennifer Richardson
Subject: Re: U.S. Department of Justice investigation
Dear Sirs,
Thank you for your email dated 2 January 2020.
I confirm that we do represent HRH the Duke of York.
I would be grateful if you could please clarify what specifically you invite us to contact you about.
Kind regards
Gary Bloxsome
EFTA00030199

=== Page 11 ===
Gary Bloxsome
Partner
Blackfords LLP
London EC4M 7EF
www.blackfords.com
Blackfords LLP is a limited liability partnership registered in England & Wales with registered number
OC325398 at
Croydon, CRO 1EA. A list of members' names is available at this
address.
GDPR: details of how we handle personal data can be found in our Privacy Statement
Authorised and regulated by the Solicitors Regulation Authority under number 462078.
On 2 Jan 2020, at 18:54,
(USANYS)
wrote:
External email: is it safe to open attachments and links?
Mr. Bloxsome,
We are the federal prosecutors investigating conduct relating to Jeffrey Epstein, under the U.S. Department of
Justice, Southern District of New York. We have been advised that you currently represent HRH The Duke of
York. Could you please advise whether that is correct? We - my colleagues
and I - can be reached anytime at these email addresses, or please let us know if you would prefer to set up a
time to discuss via phone.
Regards,
Assistant U.S. Attorney
Southern District of New York
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From:
To:
Subject: RE: Epstein-related docs released by Second Circuit
Date: Fri, 09 Aug 2019 15:59:01 +0000
Perfect, thanks. I've already been asked and said that we're not a party to this litigation and cannot comment.
From:
Sent: Friday, August 9, 2019 11:43 AM
Subject: Epstein-related docs released by Second Circuit
Just FYI for everybody, today the Second Circuit has unsealed (and posted) a ton of documents from the
V.
Ghislaine Maxwell libel lawsuit, so there likely will be a ton of reporting on that. Any reference to those newly-unsealed
documents are separate from-and do not include-any filings we've made, and are independent of our case.
(We have been aware of the litigation and generally aware of the filings, though it also won't hurt to have a bunch of
journalists combing through them and reporting out interesting elements.)
Anyway just wanted to note that there's likely to be a flood of attention to this development but that it's not anything new
specifically from our investigation.
Assistant U.S. Attorney
Southern District of New York
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From:
)"
To:
)"
(USANYS)"
Subject: FW: Epstein
Date: Mon, 10 Dec 2018 17:47:38 +0000
Importance: Normal
You guys available? This should be quick.
From:
Sent: Monday, December 10, 2018 12:46 PM
To:
Cc:
N. (NY) (FBI)
is
>;
(USANYS)
Subject: Re: Epstein
We are available now if you would like to call but I am on the road so you will have to conference us in separately.
On Dec 10, 2018, at 12:12,
wrote:
and
Any chance you're free for a brief call this afternoon? We wanted to touch base about a few items. I'm sure you're both
very busy in preparation for Wednesday, so we promise to keep it short.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 21:31:54 +0000
Attachments: U.S._v._Ghislaine_Maxwell_Indictment.pdf Ghislaine_Maxwell_Indictment_PR.pdf
Inline-Images: image001.png
Nice work team!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA JUSTITIA OF STREET 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,
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
EFTA00030952

=== Page 2 ===
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 [1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
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.
EFTA00030953

=== Page 3 ===
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.
EFTA00030954


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=== Page 1 ===
From:
)"
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Date: Thu, 29 Oct 2020 22:20:26 +0000
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,
Maurene
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
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00030520

=== Page 2 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
H
-
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:
)"
"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would you
please confirm that your production included all records of any tuition payments that Epstein (or his entities) made for
any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow and
will have limited availability this week, but my colleagues
and
(both cc'd) should be able to
coordinate with you as needed.
Best,
Maurene
Assistant United States Attorney
EFTA00030521

=== Page 3 ===
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
Cc:
is
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Maurene -
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
"
i
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey Epstein and
Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request confidential.
Please let me know if you have any questions or would like to discuss further.
Best,
Maurene
Assistant United States Attorney
EFTA00030522

=== Page 4 ===
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00030523


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=== Page 1 ===
UNITED STATES
DEPARTMENT OF TREASURY
U.S. CUSTOMS
THE DEPARTMENT OF THE
TREASURY
TREASURY THE
SPECIAL AGENT
WAYS
CUSTOMS SERVICE


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=== Page 1 ===
Event: Accepted: Epstein FOIA call
Start Date: 2021-05-07 19:00:00 +0000
End Date: 2021-05-07 19:30:00 +0000
Location: call in
Class: X-PERSONAL
Comment:
Date Created: 2021-05-06 17:04:28 +0000
Date Modified: 2021-05-06 17:04:28 +0000
Priority: 5
DTSTAMP: 2021-05-06 16:04:54 +0000
Attendee:
EFTA00031625


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Maxwell drive delivery Monday 1/11
Date: Mon, 11 Jan 2021 16:12:38 +0000
Hi
Yes, I will meet you outside ISA at 11:30 today. If anything comes up, please feel free to give me a call at
Thank you!
Original Message
From:
Sent: Monday, January 11, 2021 10:47 AM
To:
Cc:
Subject: Re: Maxwell drive delivery Monday 1/11
I will be picking up the drives today. Are you available to run out to me around 11:30?
or
ideally I'd be bringing the drives directly to you after pick up. Are you available around 12-1230?
Feel free to call me at
> On Jan 11, 2021, at 09:48,
wrote:
>
> It will be myself or
V
> Best,
-
>
V
1/8/2021 2:20
> PM
> Good afternoon,
V
> The FBI has very kindly agreed to deliver two new drives from my
> office to the MDC for Ghislaine Maxwell on Monday, January 11th. I've
> cc'd Special Agent
who will be coordinating the delivery.
> Would you please let us know what time the FBI should plan to make the
> delivery and who will be available to receive the drives on Monday?
>
> Thank you all very much for your help.
V
> Best,
V
EFTA00030876

=== Page 2 ===
V V V V V V V V VVVVVVVV
Assistant United States Attorney
> Southern District of New York
EFTA00030877


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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 21:08:43 +0000
Inline-Images: image001.png
Thanks!
From
Sent: Thursday, July 2, 2020 2:04 PM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Awesome work - congrats!
From:
Sent: Thursday, July 02, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
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,
EFTA00031532

=== 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.
EFTA00031533

=== 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.
EFTA00031534


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=== Page 1 ===
From:
To:
Subject: Travel Authorization 10586462 approved by
, now awaiting further
approval
Date: Fri, 30 Aug 2019 17:35:35 +0000
Importance: Normal
Dear
Travel authorization 10586462 has been approved by
, now awaiting further approval.
Trip ID: 10586462
Traveler name:
Purpose: R19NYS13781 - U.S. V. Epstein - Witness Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-09-03 - 2019-09-04
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
E2 Manual Login (User ID and Password):
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# T0007
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.
EFTA00030713


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Subject: Extradition
Date: Sun, 13 Dec 2020 20:15:37 +0000
Attachments: Bail_Section_(Extradition).docx
Here you go - please feel free to edit
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
EFTA00031818


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Automatic reply: Epstein update
Date: Sat, 10 Aug 2019 14:48:55 +0000
Sent from my iPhone
On Aug 10, 2019, at 10:48,
wrote:
What's a good number to call you.
On Aug 10, 2019, at 10:43 AM,
wrote:
As you might imagine, we are getting increasingly frantic calls from defense counsel who continue to be
seeing information in the press that we-the U.S. Attorney's Office-haven't yet received. We need to know
as soon as possible the very basic facts, such as time and cause of death at the absolute minimum. It has now
been hours since this was reported publicly. Please advise when we can expect to receive either a written
report on those basic facts or when we can have a call to get that information to relay to his counsel. It is
extraordinarily frustrating to have to tell them that we have less information than the press. Please advise.
Thank you,
On Aug 10, 2019, at 08:46,
wrote:
Passed away. We are completing a significant incident report for HQ for Death of a Federal Inmatehowever, I do not
have any specifics from the BOP yet.
From:
Sent: Saturday, August 10, 2019 8:44 AM
To:
Subject: Re: Automatic reply: Epstein update
Thank you for telling us. What do you mean by "passed"?
Thanks,
EFTA00029737

=== Page 2 ===
Sent from my iPhone
On Aug 10, 2019, at 8:18 AM,
> wrote:
BOP just provided another update- Epstein has passed. I have no additional info. I will push out updates as we
receive.
From:
Sent: Saturday, August 10, 2019 7:52 AM
To:
Subject: Re: Automatic reply: Epstein update
FYI:
The BOP just informed us that Epstein is being taken by ambulance to the hospital from another apparent suicide
attempt- no other information was provided.
They will update us as more info becomes available.
On Aug 10, 2019, at 7:26 AM,
wrote:
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses
may be delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA
at
or
EFTA00029738


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=== Page 1 ===
From:
Subject: Accepted: Epstein FOIA call
Date: Thu, 06 May 2021 15:53:53 +0000
Importance: Normal
Attachments: unnamed
EFTA00031622


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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: Tue, 07 Jul 2020 18:31:16 +0000
Inline-Images: image001.png
Now my response is a few days late, but thank you!! Really appreciate it - and glad your mom approves ) And hope
you're doing alright these days.
From:
Sent: Saturday, July 04, 2020 16:55
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
A few days late to the party, but huge congrats guys. Such a worthy case. (Or, as my mom texted, "yay SDNY! Ghislaine
Maxwell wasn't allowed to 'slither away'!")
From:
Sent: Thursday, July 02, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
OF JUSTICE QUI PRO TOTAL UNITED VILLING
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
OF
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
EFTA00031243

=== Page 2 ===
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
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 [1] 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
EFTA00031244

=== Page 3 ===
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
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
EFTA00031245

=== Page 4 ===
[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.
EFTA00031246


c1: EFTA00029668
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029668.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Booking Confirmation
-- Beverly Hills, Feb 25
Date: Thu, 13 Feb 2020 05:34:43 +0000
Booking Confirmation
Thank you for making your reservation through our site.
This is a no reply mail box. If you need assistance please contact your CWTSatoTravel customer support site.
This is a copy of your itinerary only. Please review for accuracy. When your reservation is ticketed, your invoice will
be sent in a separate message. The invoice will show your trip details, ticket number, and ticket cost. Please be
prepared to present your invoice (not this itinerary copy) upon airport check-in as proof your ticket has been issued.
CONFIRMATION NUMBERS
SABRE Record Locator #: CCXAXQ
Hotel Confirmation #1:
HH-3185860597 (Hilton Hotels)
NAME(S) OF PEOPLE TRAVELING
Name:
HOTEL
Name:
The Beverly Hilton
Location:
Beverly Hills, CA
Address:
9876 WILSHIRE BLVD, Beverly Hills, CA 90210 USA
Check-in:
Tuesday, Feb 25 16:00
Check-out:
Saturday, Feb 29 12:00
Hotel Confirmation #:
3185860597
Number of Rooms:
1
Phone:
1-310-274-7777
Fax:
1-310-285-1313
Average Rate before taxes and fees:
181.00 USD (per night/room)
Average Rate including taxes and fees: 210.24 USD (per night/room)
Special Requests:
king bed, high floor
AGENCY INFORMATION
Agency: CWTSato Travel
Washington, DC, US
DELIVERY INFORMATION
Deliver To:
Name:
Address:
EFTA00029668

=== Page 2 ===
Phone:
Email:
TRAVEL ARRANGEMENTS
Travel Arranged By:
Travel Arranged For:
HAVE A GREAT TRIP
EFTA00029669


c1: EFTA00031535
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031535.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
(USANYS)"
)"
Subject: RE: Epstein search warrant documents
Date: Thu, 02 Jul 2020 21:34:28 +0000
Thanks. I'm going to talk with Laura about this in detail tomorrow.
From:
Sent: Thursday, July 2, 2020 5:11 PM
To:
(USANYS)
Cc:
(USANYS)
is
is
)
Subject: RE: Epstein search warrant documents
Following up on the below, I think we've given this our absolute best efforts with FBI - they are now well over a month
later than their estimate from April on when we would get the New York materials, they're also past their estimate of
getting us the New York materials from just this Monday, and we don't have anything close to an estimate on the USVI
materials, which constitute the overwhelming majority of the data and are vastly more voluminous than the New York
devices. We have kept pushing the timeline back for this option, hoping that CART will finalize, but I think at this point we
should have a vendor do it.
Attached is an estimate we got from BRG, which would get everything to us in under a month, and in Relativity-friendly
format, in a range of $85-135K. BRG has done this for our office multiple times in the past and are very effective and
efficient, and they get the materials we need. And most importantly, they estimate they can do it all in less than a
month. May we have approval to seek funding for this? The estimate is attached. Thanks very much.
From:
Sent: Tuesday, June 30, 2020 16:23
To:
(NY) (FBI)'
is
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
V.
)
is
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Checking in for the estimate of when we can expect to get all the USVI materials?
thanks,
From:
Sent: Monday, June 29, 2020 13:00
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS)
is
(NY) (FBI)
i
)
is
)
is
(NY) (FBI)
EFTA00031535

=== Page 2 ===
is
(USANYS)
Subject: RE: Epstein search warrant documents
Okay thanks - good luck with the cardiologist! And if you can let us know tomorrow that would be great. Thanks again.
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:59
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
in
(NY) (FBI)
i
)
is
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
When I'm in the office tomorrow, I will be better able to estimate. I'm at my cardiologist right now.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:56 PM,
)"
wrote:
Great, thanks. Is there even a rough estimate of when we will get the USVI materials? Or an estimate of when you'll be
able to see how many items to export, so we'll have a better sense of when we'll get those?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:55
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
is
(NY) (FBI)
V.
)
is
)
is
(NY) (FBI)
^
is
(USANYS)
Subject: RE: Epstein search warrant documents
Yep
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:52 PM,
)"
wrote:
Okay, and I'm sorry to ask again, but to make sure, in this production, you're sending us new versions of what you
previously sent?
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:50
To:
(USANYS) [Contractor]
is
EFTA00031536

=== Page 3 ===
Cc:
(USANYS)
is
(NY) (FBI)
is
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
You are getting both NY and USVI. The biggest stumbling block are the newer Mac items that are in APFS
(there are a bunch from the Island,) so it is difficult to estimate how long those will take until I see how many
items I have to export.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 12:40 PM,
)"
wrote:
Okay thanks, and just to clarify, a few days to finalize the New York materials, and then what about the USVI materials? I
think that is quite a bit more. Just looking for an estimated completion date for everything.
And on my other question - does this mean you're giving us a new, complete copy of everything from both NY and USVI?
thanks,
From:
(NY) (FBI)
Sent: Monday, June 29, 2020 12:34
To:
(USANYS) [Contractor]
is
)
Cc:
(USANYS)
is
(NY) (FBI)
in
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
I am in the process of exporting the materials (documents, spreadsheets, emails, etc) for your review as per my
discussions with
Most of the NY stuff is done, just Mac items left. This might take a few days as 1 item in
particular has over 500,000 emails. We will be able to provide discovery once Defense Council has provided
drives for us to copy items over to. This goes quicker as there is no processing involved. I'll let you know when
everything is complete.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 29, 2020 11:03 AM,
)"
wrote:
Following up on this, I understand from
that she was able to provide you with a 12 TB drive last week - could you
please let us know when we will be able to get the materials? I expect a judge will ask us about discovery as early as this
week.
EFTA00031537

=== Page 4 ===
Also, the related critical question that I don't think we have clarity on is whether you're giving us a copy of everything that
was collected (including reproducing the materials that you previously gave us, but which are not searchable), or have you
and
figured out a way to categorize the prior productions so they're useful for us? We would strongly prefer to just
get everything at once in a usable format, but please let us know if you expect to produce materials differently than that.
thanks,
From:
(NY) (FBI)
Sent: Friday, June 19, 2020 13:14
To:
(USANYS) [Contractor]
is
Cc:
(USANYS)
i
(NY) (FBI)
in
)
is
)
is
(NY) (FBI)
is
(USANYS)
Subject: RE: Epstein search warrant documents
,
We are going every other day now, ramping up to 75% week after next. I need drives to put things on like
and I discussed earlier. Once I have those drives, it will take me a couple days to copy stuff. LMK when I can
expect the drives. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 19, 2020 1:09 PM,
)"
wrote:
following up on the below - please let us know? Given case developments in recent days, this has become
urgent. Thanks.
From:
)
Sent: Wednesday, June 17, 2020 14:28
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(NY) (FBI)
is
is
)
is
(NY) (FBI)
is
(USANYS)
is
(USANYS)
Subject: RE: Epstein search warrant documents
Wanted to circle back on this and check in, particularly because we desperately need to get the results from the July and
September searches before moving forward with possible additional charges in the case. I know you had mentioned you
needed to push back your prior estimate of complete production by early June, by a couple weeks, so wanted to see what
the current estimate is? I don't think we've started to get anything yet but please correct me if I'm wrong.
thanks,
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:28
EFTA00031538

=== Page 5 ===
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
i
)
is
)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Will do.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:26 PM,
)"
wrote:
Understood, and thanks for letting us know. Let's keep in touch both on timing and also on whether there's a way to
identify and categorize what's already been produced, or if we'll need to just get all the raw data at this stage and go from
there.
From:
(NY) (FBI)
Sent: Monday, June 01, 2020 16:23
To:
(USANYS) [Contractor]
is
Cc:
(NY) (FBI)
is
)
is
y
(NY) (FBI)
Subject: RE: Epstein search warrant documents
,
Unfortunately, recent events and our staffing levels have conspired to put a kink in just about everything. If we
can't make heads or tails of the stuff I've already produced, we'll do it again. They have told us that our staffing
levels will be steadily increasing over the next few weeks, but I'm going to have to push back my estimate by a
week or 2. Sorry about that. My next day in the office is Thursday, so I'll be able to see if I can easily identify
what I already gave you and marry it to a reliable identifier.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Jun 1, 2020 4:13 PM,
)"
wrote:
Thanks for this update - we'll take a look and circle back if any questions.
Separately, to follow up on a question from the May 15 email below, the list has just five devices as still pending to be
transferred to us, and I think it's right that the plan is to reproduce all the materials so that we can get them in searchable
format, but just wanted to confirm? Currently, we aren't able to match any of the prior productions to specific devices -
so if we're able to match them up by Bates number now, that might work, but otherwise I think it makes sense for us to
get everything. But let us know if any issue with that.
And related to that question, are we still on track to get the full range of data in the next week or so? I don't think we've
gotten any updates on that status in the past few weeks, and we're eager to be able to start reviewing.
EFTA00031539

=== Page 6 ===
thanks again,
From:
(NY) (FBI)
Sent: Friday, May 29, 2020 12:53
To:
is
(USANYS) [Contractor]
Cc:
is
>;
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Updated item descriptions. Just a side note, many thumb drives and SD cards will not have a serial number
visible externally, but will report one through our tools. I included those electronically reported serial numbers.
Any questions, let me know.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Friday, May 15, 2020 4:11 PM
To:
(NY) (FBI)
in
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of information
we need is the serial number, or some other specific identifier, ideally for each device but at least for any device that there
is more than one of the same thing. So for example, we need to be able to somehow differentiate the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the USVI
spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
EFTA00031540

=== Page 7 ===
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the USVI
list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to reproduce
all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we aren't able to
match any of the prior productions to specific devices - so if we're able to match them up by Bates number now, that
might work, but otherwise I think it makes sense for us to get everything. But let us know if any issue with that.
thanks very much,
From:
(NY) (FBI)
Sent: Thursday, May 14, 2020 15:54
To:
is
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I could to
convey the information. If you are confused by anything, please let me know. In the column for approximate
size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I put what load
file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If there is no entry
in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't have as well as an
iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to beef them up. I will
get you the Island stuff tomorrow.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
(NY) (FBI)
in
(USANYS) [Contractor]
Cc:
is
is
(NY) (FBI)
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any FBI
tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which both
we and the agents can access. We're required to have the files in a format that we can produce them to defense counsel.
I've done that in many other cases and it hasn't previously been an issue. My understanding from
is that the best
way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will process-by which
EFTA00031541

=== Page 8 ===
I just mean converting into file formats that are loadable onto Relativity. It doesn't really have anything to do with the
taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents earlier
this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9. Again, I
understand from
that the best way forward is to just get copies of the materials in their original formats, which I
understand will be segregated and designated by device. That should work for us! I was just trying to understand the
approach, as well as the timeline.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 13:03
To:
)
is
(USANYS) [Contractor]
Cc:
is
>;
(NY) (FBI)
is
(NY) (FBI)
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was
already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece
by piece as things are processed, I was unaware that you didn't want to review as things were processed, that
you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a differentiation of
methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
back was lacking.
FBI NY CART Coordinator
Senior Examiner
From:
)
Sent: Tuesday, May 12, 2020 11:33 AM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
EFTA00031542

=== Page 9 ===
Cc:
is
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just basically
sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago, but
regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that
means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:30
To:
(USANYS) [Contractor]
is
Cc:
is
Subject: RE: Epstein search warrant documents
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
(NY) (FBI)
Sent: Tuesday, May 12, 2020 11:11
To:
(USANYS) [Contractor]
is
Cc:
is
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it on
our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
EFTA00031543

=== Page 10 ===
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
(USANYS) [Contractor]
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data and
where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and send
it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
(NY) (FBI)
>;
(USANYS)
i
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
in
>;
y.
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review the
returns in early June. Thanks again.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
is
-
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you.
If it does, I'll let you know.
NY CART Coordinator
Senior Forensic Examiner
EFTA00031544

=== Page 11 ===
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks-it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
(NY) (FBI)
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
is
>;
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
>;
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems to
do so.
Also,
, please reach out to me at one of the numbers below so we can brain storm. Thanks.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're waiting
on that list to be able to do an updated search warrant on all of those devices. Please let us know the current timeline -
and also the current timeline on producing the results from those August and September searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months from our call, which
would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 15:27
To:
is
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
)
i
is
is
(NY)
EFTA00031545

=== Page 12 ===
(FBI)
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
)
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
(NY) (FBI)
>;
(USANYS)
>;
(NY) (FBI)
i
(USANYS)
Cc:
(USANYS) [Contractor]
>;
>;
>;
>;
(NY) (FBI)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
Rozier can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
1)
2)
3)
4)
5)
/
6)
/
if either of you wants to join (and if not, one of
/
From:
(NY) (FBI)
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
i
(NY) (FBI)
V.
)
>;
(USANYS)
Cc:
(USANYS) [Contractor]
>;
)
>;
is
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
SSA
FBI New York
On Apr 7, 2020 1:55 PM,
)"
wrote:
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
EFTA00031546

=== Page 13 ===
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
)
Sent: Monday, March 09, 2020 12:00
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
in
>;
i
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
-
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
-
Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers
and no way to match up anything-that is, even if we were to try to go hunt down every individual large file in the
native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get
a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million
documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
(NY) (FBI)
Sent: Wednesday, March 04, 2020 16:36
To:
)
is
(USANYS)
EFTA00031547

=== Page 14 ===
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
in
>;
V.
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
NYO CART Coordinator
Senior Forensic Examiner
(office)
(cell)
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
(NY) (FBI)
is
(USANYS)
>;
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
>;
i
>;
is
(NY) (FBI)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
(NY) (FBI)
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
)
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
i
)
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
NY CART Coordinator
Senior Forensic Examiner
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
EFTA00031548

=== Page 15 ===
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
Sent: Monday, February 24, 2020 17:38
To:
(NY) (FBI)
is
(USANYS)
is
(NY) (FBI)
is
(USANYS)
Cc:
(USANYS) [Contractor]
is
>;
>;
i
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think FBI
was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to be
able to review them as well.)
many thanks,
From:
(NY) (FBI)
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
is
)
(NY) (FBI)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
is
V.
i
-
is
(NY)
(FBI)
Subject: RE: Epstein search warrant documents
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
NY CART Coordinator
Senior Forensic Examiner
EFTA00031549

=== Page 16 ===
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
is
is
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
EFTA00031550

=== Page 17 ===
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
EFTA00031551


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=== Page 1 ===
From:
To:
Subject: Travel Authorization 10586462 approved by
, now awaiting further
approval
Date: Fri, 30 Aug 2019 17:30:29 +0000
Importance: Normal
Dear
Travel authorization 10586462 has been approved by
, now awaiting further approval.
Trip ID: 10586462
Traveler name:
Purpose: R19NYS13781 - U.S. V. Epstein - Witness Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-09-03 - 2019-09-04
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
E2 Manual Login (User ID and Password):
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
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Reference ID# T0007
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.
EFTA00030714


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c0:
=== Page 1 ===
From:
"
)"
To:
"
(USANYS)"
Subject: Accepted: Epstein/Maxwell FOIA
Date: Wed, 10 Mar 2021 20:16:15 +0000
Importance: Normal
Attachments: unnamed
EFTA00029855


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From:
)"
To:
)"
Subject: FW: Forfeiture question
Date: Tue, 15 Oct 2019 18:05:42 +0000
On the phone with him now-you're welcome to swing by, but it seems like this will be super short, so no worries.
From: Matthew L. Schwartz
Sent: Tuesday, October 15, 2019 1:56 PM
To:
Cc:
is
Subject: RE: Forfeiture question
I just freed up and can call you in a few minutes if that works.
Matthew L. Schwartz
On October 15, 2019 at 1:39:21 PM EDT,
)
wrote:
Matt,
With apologies: I now need to meet with a witness starting at 4 today, so unfortunately 4:30 no longer works.
Happy to talk between now and 4, or later this evening, if either works. Alternatively, I'm free at 9:30
tomorrow morning, or between 11 a.m. and 1 p.m. tomorrow.
Thanks,
From: Matthew L. Schwartz
Sent: Monday, October 14, 2019 9:10 PM
To:
Cc:
i
Subject: Re: Forfeiture question
4:30 is perfect. Where should I call?
Matthew L. Schwartz
On October 14, 2019 at 6:40:46 PM EDT,
)
wrote:
Hi Matt,
EFTA00029730

=== Page 2 ===
I'm available for a call tomorrow either at 1 p.m. or anytime from 4:30 onwards, if either of those windows
works for you.
Best,
Sent from my iPhone
On Oct 13, 2019, at 8:23 PM, Matthew L. Schwartz
wrote:
Thanks
If any of you have a moment for a forfeiture-related question in the next few days, please let
me know. FYI, this has nothing to do with my firm's representation of certain victims. Thanks.
-mls
Matthew L. Schwartz
On October 13, 2019 at 7:44:17 PM EDT,
wrote:
Hi Matt,
The Epstein case team are AUSAs
and
all cc'd on this
email. They're the right people to talk to about anything Epstein-related.
Sent from my iPhone
On Oct 13, 2019, at 2:59 PM, Matthew L. Schwartz
wrote:
Do either of you guys or the appropriate other person have 2 minutes to discuss a somewhat time-
sensitive, but by no means urgent, Epstein-related forfeiture question in the next few days?
Matthew L. Schwartz
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]
EFTA00029731


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 168 Filed 03/18/21 Page 1 of 5
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 3/18/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
On February 26, 2021, the Government filed its omnibus memorandum of law opposing
Defendants' twelve pre-trial motions. It filed the brief, along with the corresponding exhibits,
under temporary seal pending the Court's resolution of its request to redact sensitive or
confidential information. See Dkt. No. 162. On March 9, 2021, the Defendant objected to
certain of the redactions that the Government had proposed, and she proposed additional
redactions. Having considered the parties' respective positions, the Court will grant the
Government's requests for redactions and sealing, as well as the Defendant's additional
redaction requests, with the exceptions discussed below.
To begin with, the Court's reasoning 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, 1050 (2d Cir. 1995) ("Amodeo II")).
1
EFTA00031598

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 168 Filed 03/18/21 Page 2 of 5
The proposed redactions mostly satisfy this test. First, the Government's brief in
opposition to the Defendant's pre-trial motions is 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). The Court thus concludes that there is a common law and a First Amendment
presumption of access. Id. at 146; see also Nixon V. Warner Commc'ns, Inc., 435 U.S. 589, 602
(1978). The question, then, is whether the redaction and sealing requests are narrowly tailored to
serve substantial interests that overcome that presumption of access.
Like the Government's previous redaction and sealing requests in this case, the
Government bases its requests on its contention that redactions and/or sealing are necessary to
protect the integrity of an ongoing criminal investigation and to protect third parties' personal
privacy interests. As a general matter, these interests are legitimate and provide a basis for
overcoming the presumption of access. See, e.g., Under Seal V. Under Seal, 273 F. Supp. 3d
460, 467 (S.D.N.Y. 2017); United States V. Madoff, 626 F. Supp. 2d 420, 427-28 (S.D.N.Y.
2009). As applied to this case, the Court concludes that the proposed redactions in the
Government's brief generally serve these interests. Exhibit 1 contains a single redaction-the
name of a third party-and the Court concludes that that individual's personal privacy interests
outweigh the presumption of access that exists as to that limited portion of the exhibit. The
proposed redactions to Exhibit 7 are similar in that they seek to protect from public access only
the names and contact information of third parties. Here, too, the interest in protecting the safety
and privacy of those individuals outweighs the presumption of access that attaches to those
documents.
The Court overrules the Defendant's objections to the redactions contained in Exhibit 5
of the Government's brief and adopts the Government's proposed redactions. The core of the
2
EFTA00031599

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 168 Filed 03/18/21 Page 3 of 5
Defendant's objections relate to her contention that some of the information contained in the
redactions has been made public by other means. Notwithstanding this, the redactions to which
the Defendant objects relate to the privacy interests of third parties, which the Second Circuit has
admonished "should weigh heavily in a court's balancing equation." United States V. Amodeo
("Amodeo II"), 71 F.3d 1044, 1050 (2d Cir. 1995). At least some of the redactions to which the
Defendant objects relate to private "family affairs" of a third party, a factor that "weigh[s] more
heavily against access than conduct affecting a substantial portion of the public." Id. at 1051.
And though the Defendant contends that some of the information contained in the redactions is
public, she furnishes no evidence to that effect. As a result, the Court concludes that the
significant privacy interests at stake justify the limited and narrowly tailored redactions
contained in Exhibit 5.
In addition, the Court adopts the Defendant's proposed additional redactions to pages
129-134 of the Government's brief. Those portions of the transcript, which were redacted in the
civil matter, concern privacy interests and their disclosure would merely serve to cater to a
"craving for that which is sensational and impure." Amodeo II, 71 F.3d at 1051 (citation
omitted). The Court thus concludes that such redactions are justified.
On the other hand, the Court agrees with the Defendant's objections to the redactions
contained in pages 1-128 of the Government's brief. To provide some context, the redacted
portions of the brief relate to sealed proceedings that took place before different judges relating
to the issuance of grand jury subpoenas in connection with the present case. See Dkt. No. 51.
Because the Government's brief is a judicial document and because the presumption of access
attaches, the Government's redaction requests must be "necessary to preserve higher values and
only if the sealing order is narrowly tailored to achieve that aim." Lugosch V. Pyramid Co. of
3
EFTA00031600

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 168 Filed 03/18/21 Page 4 of 5
Onondaga, 435 F.3d 110, 124 (2d Cir. 2006). Courts have noted that "disclosing the details of
the Government's efforts to obtain evidence will undoubtedly hamper the investigation, as the
individuals and entities under investigation would be put on notice." United States V. Madoff,
626 F. Supp. 2d 420, 427-28 (S.D.N.Y. 2009). And the Government's interest in protecting an
ongoing investigation from the "danger of impairing law enforcement" may be a countervailing
factor that outweighs the presumption of access. See Lugosch, 435 F.3d at 120. But the
Government advances no non-conclusory basis as to why its investigation at this stage of the
matter would be imperiled by the disclosure of the information regarding how it obtained the
information in question, and the requested redactions are far from narrowly tailored. As a result,
the Court denies the Government's redaction requests in pages 1-128 and denies its request to
file Exhibits 8 and 9 under seal, since those documents relate to this very issue and the same
reasoning applies to them. The Court will give the Government an opportunity to seek more
tailored redactions if it wishes and to specifically justify the ongoing need to redact the requested
information and documents. By March 22, 2021, the Government may file a letter with the
Court-under seal, if necessary-justifying the specific redaction and sealing requests.
Alternatively, by that date the Government can indicate that it will not seek to renew the request.
Furthermore, the Court agrees with the Defendant's objections to the redactions
contained in pages 187-188 of the Government's brief. While the Court previously had granted
the request to redact the same information, see Dkt. No. 99, the Court no longer sees a basis for
keeping this information under seal in light of the strong presumption of access. The information
does not in itself contain any personally identifying information, and the Court concludes that
any minimal threat of interference with the Government's investigation through the disclosure of
this information is outweighed by the presumption of access that attaches to those portions. As
4
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=== Page 5 ===
Case 1:20-cr-00330-AJN Document 168 Filed 03/18/21 Page 5 of 5
above, however, the Court will give the Government an opportunity to justify the ongoing need
to redact this information and these documents; by March 22, 2021, the Government may file a
letter with the Court-under seal, if necessary-justifying the redaction and sealing requests.
Finally, the Court denies the Government's request to file Exhibit 11 entirely under seal.
While portions of that transcript have been redacted, other portions are part of the public record.
See Giuffre V. Maxwell, Case No. 15-cv-7433, Dkt. No. 1212-1. In light of this, the Court sees
no basis to file the transcript entirely under seal rather than by redacting the relevant portions.
In light of the above, the Government is hereby ORDERED to either docket on ECF their
brief and the corresponding exhibits, consistent with this Order, or to file a letter with the Court
justifying more tailored redaction and sealing requests regarding pages 1-128 and 187-188 and
Exhibits 8 and 9 by no later than March 22, 2021. The parties are further ORDERED to meet,
confer, and jointly propose redactions to the Defendant's cover letter objecting to the
Government's proposed redactions by March 22, 2021. Finally, the parties are ORDERED to
meet, confer, and propose redactions to Exhibit 11 of the Government's submission by March
22, 2021.
so ORDERED.
Alim D.Netto
Dated: March 18, 2021
New York, New York
ALISON J. NATHAN
United States District Judge
5
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=== Page 1 ===
From:
)"
To:
Subject: RE: Epstein search warrant documents
Date: Sat, 04 Apr 2020 17:37:03 +0000
Definitely (and sorry for the delay - we were crashing on a bunch of other stuff the past few days). But I do think it would
make sense to have a call, since we haven't gotten any response at all to my email from about a month ago. Whatever
time works for you and him this coming week, we'll make work on our end. Thanks.
From:
Sent: Tuesday, March 31, 2020 14:02
To:
Subject: RE: Epstein search warrant documents
Glad to hear you are both well. I have no experience with Relativity but we could maybe get a conference call going with
and see what we can do? Let me know if you are up for it and when you're available.
Thanks,
From:
[mailto:
Sent: Tuesday, March 31, 2020 1:02 PM
To:
Subject: RE: Epstein search warrant documents
Hey
So far so good here, thanks - just trying to deal with the tech issues of working from home (not to mention the inability to
interview witnesses!) but really can't complain at all, the girlfriend and I are both healthy and distancing. Hope that's true
for you and yours too.
In terms of the issues below, unfortunately there isn't any progress - it's not a delay on our end, we've run the taint
screen and so the AUSAs and agents all have access on Relativity to the materials that
sent over in December. We
also sent the privilege taint terms to the agents a couple weeks ago so they could run the screen on whatever programs
they may be using - that's attached. We hadn't realized that they were impeded on their review due to any taint issue,
we just thought they were using Relativity, same as us.
More generally though, the issue we continue to have is the same one since February. We have absolutely no sense of
what
sent to us - it's not organized or identified by device or even by location, the documents aren't joined with
their attachments (their "families" in the terms of doc review), we can't look at native files, etc. It's all the issues from my
March 9 email, below, which
never responded to. And it's only 1.4 million documents out of what are presumably
tens of millions total - we haven't gotten any version of the rest (and don't know exactly what we're missing, because
again, we have no way to track what we've been given so far).
If
(and/or others at CART) are teleworking, it would be great to get help on this, because obviously weeks are going
by that we could be using to review. I had been trying to push my chiefs for a meeting in early March but then obviously
the world imploded! So not sure what can be done currently, but happy to discuss with anybody that would be useful.
thanks as always,
EFTA00030309

=== Page 2 ===
From:
Sent: Monday, March 30, 2020 13:23
To:
Subject: RE: Epstein search warrant documents
hope you are doing well and more importantly feeling well! Just checking and on the status of everything, is that
issue with the taint review is still on going? I'm assuming you're doing a fair amount of tele working
On Mar 11, 2020 2:05 PM,
wrote:
Let's get together and hash it out, let me know what works for you this week and next and I'll get
and my team
there as well.
From:
) [mailto:
Sent: Wednesday, March 11, 2020 12:03 PM
To:
Subject: RE: Epstein search warrant documents
totally happy to chat, and it's exactly the same issues as we talked about on the phone a couple weeks ago when
we first raised this -- I wonder if it makes sense to get in a room together? Otherwise it's a lot of games of telephone.
But basically the way to think about it is, imagine if we had seized papers from approximately 100,000 filings cabinets in
a dozen different office buildings. And then instead of keeping them organized or labeled by room, or even by office
building, all 1.3 million documents (so far) just got dumped into one big pile - except before that, any documents that
had multiple parts stapled together got separated. And then if any of those documents that was larger than about 100
pages couldn't be opened. That's what we've got, just electronically.
From:
Sent: Wednesday, March 11, 2020 11:15
To:
)
Subject: RE: Epstein search warrant documents
I was out yesterday, let's touch base so we can get this resolved. I'm confused as to what is going on here, sounds like
there are issues that you haven't been able to resolve by going direct with
Thanks,
From:
) [mailto:
Sent: Monday, March 09, 2020 12:00 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
>;
is
is
>;
)
Subject: RE: Epstein search warrant documents
EFTA00030310

=== Page 3 ===
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:
is
(USANYS)
is
is
(USANYS)
Cc:
is
>;
in
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.
EFTA00030311

=== 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
>;
(USANYS)
Cc:
is
is
is
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
is
(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:
V.
(USANYS)
is
is
(USANYS)
Cc:
is
i
is
is
EFTA00030312

=== 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)
in
>;
is
(USANYS)
Cc:
is
V.
in
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.,
EFTA00030313

=== Page 6 ===
which devices the materials came from, whether it's full or partial results, how many more devices we have coming,
etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are
approximately 40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even
counting at least 60+ CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices,
including multiple servers / server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of
time to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
is
Cc:
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
EFTA00030314

=== Page 7 ===
Southern District of New York
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 49 Filed 08/25/20 Page 1 of 4
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT
DATE FILED: 8/25/20
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 10, 2020, the Defendant filed a letter motion related to two issues. Dkt. No.
38. First, the Defendant seeks an order directing the Government to disclose to defense counsel
immediately the identities of the three alleged victims referenced in the indictment. Second, the
Defendant seeks an order directing the Bureau of Prisons ("BOP") to release the Defendant into
the general population and to provide her with increased access to the discovery materials. For
the reasons that follow, Defendant's requests are DENIED without prejudice.
I.
The Disclosure of Alleged Victims' Identities
The Defendant first seeks an order directing the Government to disclose to defense
counsel immediately the identities of the three alleged victims referenced in the indictment. Dkt.
No. 38 at 1. Her request is premature. Production of discovery, which may itself identify
alleged victims and relevant witnesses to the defense, has just begun. Moreover, the parties have
not yet engaged in discussions regarding an appropriate schedule for pretrial disclosures,
including witness lists and $ 3500 material. The Court is mindful of the factors pointed to by the
Defendant-in particular the fact that charges in this matter relate to conduct that allegedly took
place many years ago-and anticipates that such a schedule would require the disclosure of
1
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=== Page 2 ===
Case 1:20-cr-00330-AJN Document 49 Filed 08/25/20 Page 2 of 4
alleged victims and witnesses substantially in advance of trial. But that alone does not justify
such relief at this very early stage. Following the close of discovery, the parties should meet and
confer on an appropriate schedule in light of all relevant factors. If the parties are unable to
reach agreement as to a pretrial disclosure schedule, the Defendant may renew her request. The
denial is therefore without prejudice.
II.
The Defendant's Conditions of Confinement
In her August 10, 2020 letter motion, the Defendant also sought "an order directing
[BOP] to release Ms. Maxwell into the general population and provide Ms. Maxwell with
increased access to the discovery materials while she is detained so that she can meaningfully
participate in the preparation of her defense." Dkt. No. 38 at 1. The Government responded that
the BOP has modified the conditions of Ms. Maxwell's confinement so that she has access to
discovery materials thirteen hours a day, seven days a week. Dkt. No. 41 at 5. The Defendant's
reply credited the BOP's change in policy but nonetheless asked the Court to "confirm these
changes in an order to the BOP" and "that the Court order the BOP to grant Ms. Maxwell the
same privileges given to other detainees." Dkt. No. 42 at 4-5.
The Court denies this request. The BOP is providing the Defendant with conditions that
allow her access to discovery materials so that she can meaningfully participate in the
preparation of her defense. Further action by the Court as this juncture is therefore unnecessary.
Should facts on the ground change such that the Defendant is not being provided sufficient
access to her legal materials, defense counsel may seek intervention by the Court.
The Defendant also requests that the Court order BOP that Ms. Maxwell "be monitored
in the same manner as other pretrial detainees and that the Court order the BOP to grant Ms.
2
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=== Page 3 ===
Case 1:20-cr-00330-AJN Document 49 Filed 08/25/20 Page 3 of 4
Maxwell the same privileges given to other detainees." Dkt. No. 42 at 5. In a footnote, the
defense clarifies that "[a]s long as Ms. Maxwell is monitored in the same manner, and receives
the same privileges as other pretrial detainees, it is not necessary to move her to the general
population." Dkt. No. 42 at 5 n.4.
The Court sees no basis for granting the Defendant's request for an order directed to
BOP. First, the Government has assured the Court that "[a]s with all inmates, the defendant is
able to speak to her counsel behind a closed door, in an area that is visible-but not audible-to
MDC staff," thereby ensuring that Ms. Maxwell's ability to communicate with her counsel is in
no way interfered. Dkt. No. 41 at 4 n.5. And as to the more general implementation of
surveillance procedures, the Court credits BOP's duty to ensure the safety and security of the
Defendant as justifying the measures BOP has adopted. See Bell V. Wolfish, 441 U.S. 520, 547
(1979) ("Prison administrators
should be accorded wide-ranging deference in the adoption
and execution of policies and practices that in their judgment are needed to preserve internal
order and discipline and to maintain institutional security."). Nor does the Defendant provide
any basis for the Court to conclude that the level of surveillance is punitive. Dkt. No. 42 at 5.
Though pretrial detainees "may not be punished prior to an adjudication of guilt in accordance
with due process of law," Wolfish, 441 U.S. at 535, it does not follow that surveillance measures
are punitive just because the Defendant deems them "onerous." Dkt. No. 42 at 4. The
Defendant has provided the Court with no evidence, and no reason to believe, that the
surveillance measures are motivated by improper purposes.
As a result, Defendant's request is denied. To ensure that Ms. Maxwell is able to
continue to adequately participate in her defense, however, the Court hereby ORDERS the
Government to provide written status updates every 90 days detailing any material changes to the
3
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=== Page 4 ===
Case 1:20-cr-00330-AJN Document 49 Filed 08/25/20 Page 4 of 4
conditions of Ms. Maxwell's confinement, with particular emphasis on her access to legal
materials and ability to communicate with defense counsel.
III. Conclusion
For the reasons stated above, Defendant's requests contained in Dkt. No. 38 are DENIED
without prejudice. Following the close of discovery, the parties shall meet and confer on an
appropriate schedule for pre-trial disclosures, including the disclosure of $ 3500 material, exhibit
lists, and witness lists, taking into account all relevant factors. The Government is hereby
ORDERED to submit written status updates every 90 days detailing any material changes to the
conditions of Ms. Maxwell's confinement, with particular emphasis on her access to legal
materials and ability to communicate with defense counsel.
SO ORDERED.
Alim D. Netto
Dated: August 25, 2020
New York, New York
ALISON J. NATHAN
United States District Judge
4
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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
)"
Cc:
)"
Subject: RE: FW:
Date: Wed, 05 Aug 2020 21:55:21 +0000
Attachments: 2020.08.05_MDC_ - Maxwell.docx
This is a draft letter.
Unfortunately, I do not think the DVDs will work. McAfee is problematic and skips ~300 PDFs when I try to
burn it.
Original Message
From:
)
Sent: Wednesday, August 5, 2020 4:00 PM
To:
Cc:
)
(USANYS) [Contractor]
Subject: Re: FW:
Thanks
would you mind sending me a zipped version please? I'll get this out to defense counsel after
emails about the other issue. Thanks all.
Sent from my iPhone
> On Aug 5, 2020, at 3:55 PM,
)
wrote:
V
>
,
thanks very much for jumping on this.
V
V
,
per my email a moment ago. It may be easiest to zip these and send that way, or otherwise to send in
two emails since the total file size is large.
>
V
Please anyone let me know if any issues? And thanks again to all for the quick fix.
V
>
> From:
(USANYS) [Contractor]
> Sent: Wednesday, August 05, 2020 15:50
> To:
)
> Subject:
V
V
V
>
>
Special Assistant to the U.S. Attorney United States Attorney's
>
Office, SDNY
V
>
> SDNY_GM_00000834-SDNY_GM_00000846.pdf>
> SDNY_GM_00000847-SDNY_GM_00000852.pdf>
> SDNY_GM_00000853-SDNY_GM_00000874.pdf>
EFTA00031411

=== Page 2 ===
>
SDNY_GM_00000875-SDNY_GM_00000900.pdf>
>
SDNY_GM_00000901-SDNY_GM_00000903.pdf>
> SDNY_GM_00000904-SDNY_GM_00000905.pdf>
>
SDNY_GM_00000906-SDNY_GM_00000918.pdf
>
SDNY_GM_00000919-SDNY_GM_00000924.pdf>
> SDNY_GM_00000925-SDNY_GM_00000955.pdf>
> <SDNY_GM_00000956-SDNY_GM_00000962.pdf>
EFTA00031412


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=== Page 1 ===
From:
(USANYN)"
To:
)"
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Fri, 03 Jul 2020 10:58:37 +0000
Awesome!
Assistant United States Attorney
Public Information Officer for the Albany/Plattsburgh Offices
Northern District of New York
James T. Foley U.S. Courthouse
Albany, NY 12207
Phone:
518-431-0249
From: USDOJ-Office of Public Affairs
Sent: Thursday, July 2, 2020 3:53 PM
To:
(USANYN)
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
seal - centered header for gov delivery
The United States Department of Justice
Audrey Strauss
Acting United States Attorney
Southern District of New York
FOR IMMEDIATE RELEASE
THURSDAY, JULY 2, 2020
WWW.JUSTICE.GOV/USAO-SDNY
CONTACT: JIM MARGOLIN
PHONE:
EFTA00031863

=== Page 2 ===
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
NEW YORK CITY - Audrey Strauss, the Acting U.S. Attorney for the Southern
District of New York, William F. Sweeney Jr., the Assistant Director in Charge of
the New York Field Office of the Federal Bureau of Investigation (FBI), and
Dermot Shea, Commissioner of the New York City Police Department (NYPD),
announced that Ghislane Maxwell was arrested this morning and charged with
enticing a minor to travel to engage in criminal sexual activity, transporting a
minor with the intent to engage in criminal sexual activity, conspiracy to commit
both of those offenses, and perjury in connection with a sworn deposition.
The indictment unsealed today alleges that between at least in or about 1994
through 1997, Maxwell and co-conspirator Jeffrey Epstein exploited girls as young
as 14, including by enticing them to travel and transporting them for the purpose
of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference
for young girls, Maxwell played a critical role in the grooming and abuse of minor
victims that took place in locations including New York, Florida, and New
Mexico. In addition, as alleged, Maxwell made several false statements in sworn
depositions in 2016. Maxwell is expected to be presented this afternoon in 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."
EFTA00031864

=== Page 3 ===
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[1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, Ghislane Maxwell assisted, facilitated,
and participated in Jeffrey Epstein's abuse of minor girls by, among other things,
helping Jeffrey Epstein to recruit, groom, and ultimately abuse victims known to
Maxwell and Epstein to be under the age of 18. The victims were as young as 14
years old when they were groomed and abused by Maxwell and Epstein, both of
whom knew that their victims were in fact minors. As a part and in furtherance of
their scheme to abuse minor victims, Maxwell and Epstein enticed and caused
minor victims to travel to Epstein's residences in different states, which Maxwell
knew and intended would result in their grooming for and subjection to sexual
abuse.
As alleged, Maxwell enticed and groomed minor girls to be abused in multiple
ways. For example, Maxwell attempted to befriend certain victims by asking them
about their lives, taking them to the movies or taking them on shopping trips, and
encouraging their interactions with Epstein. Maxwell also acclimated victims to
Epstein's conduct simply by being present for victim interactions with Epstein,
which put victims at ease by providing the assurance and comfort of an adult
woman who seemingly approved of Epstein's behavior. Additionally, to make
victims feel indebted to Epstein, Maxwell would encourage victims to accept offers
of financial assistance from Epstein, including offers to pay for travel or
educational expenses. Maxwell also normalized and facilitated sexual abuse by
discussing sexual topics with victims, encouraging them to massage Epstein, and
undressing in front of a victim.
As Maxwell and Epstein intended, these grooming behaviors left minor victims
vulnerable and susceptible to sexual abuse by Epstein. Maxwell was then present
for certain sexual encounters between minor victims and Epstein, such as
interactions where a minor victim was undressed, and ultimately Maxwell was
present for sex acts perpetrated by Epstein on minor victims. That abuse included
sexualized massages during which a minor victim was fully or partially nude, as
well as group sexualized massages of Epstein involving a minor victim where
Maxwell was present.
As alleged, minor victims were subjected to sexual abuse that included, among
other things, the touching of a victim's breasts or genitals, placing a sex toy such a
vibrator on a victim's genitals, directing a victim to touch Epstein while he
masturbated, and directing a victim to touch Epstein's genitals. Maxwell and
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.
EFTA00031865

=== Page 4 ===
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.
[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.
###
Do not reply to this message. If you have questions, please use the contacts in the
message or call the Office of Public Affairs at
.
Follow us:
T Fa Yo In
This email was sent to
using GovDelivery, on behalf of U.S. Department of Justice Office of Public Affairs 950 Pennsylvania
Ave., NW Washington, DC 20530
TTY
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Department of Justice Privacy Policy I GovDelivery Privacy Policy
EFTA00031866


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=== Page 1 ===
From:
"
)"
To:
Subject: Automatic reply: Fwd: Ghislaine Maxwell 02879-509
Date: Thu, 02 Sep 2021 19:26:20 +0000
I am out of the office through September 3, 2021. During that time I will have limited access to email and voicemail. For urgent matters, please
contact another AUSA on the matter or AUSA
at
EFTA00030984


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=== Page 1 ===
From:
)"
To: "Kathleen E. Cassidy"
)"
Cc:
"
>, , Susan Necheles
"
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: following up
Date: Mon, 21 Dec 2020 19:51:34 +0000
Embedded: RE:_following_up.msg
Sender:
Subject: RE: following up
Message-Id:
<DM3P110MB05407EF315B4443DC1FE756092C00@DM3P110MB0540.NAMP110.PROD.OUTLOOK.CO
M>
To:
Cc:
EFTA00031706


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=== Page 1 ===
From:
)"
To: Aimee Hector
Subject: RE: Hello and potentially helpful info
Date: Sat, 13 Jul 2019 21:10:34 +0000
Importance: Normal
Aimee - great to hear from you, and I didn't know about that case so I appreciate the heads up. It's an avalanche of info
these days so we're just triaging at all times. Will add this to our list for Monday - thanks again. And yes, would be great
to catch up sometime soon!
From: Aimee Hector
Sent: Friday, July 12, 2019 11:55
To:
Subject: Hello and potentially helpful info
Hope all is well at the Office. Would love to get together for lunch or something sometime soon. Just reaching
out because I believe you are handling the Epstein case and that Berman is assigned. I assume you all know this,
but Judge Berman had the Cameron Douglas case, which I handed with Jeff Brown at the time, and Cameron
Douglas was granted bail with various requirements that he reside in his NY apartment with 24 hr surveillance
paid for by him etc. He ultimately violated those conditions by smuggling drugs via an electric toothbrush.
Berman is obviously well aware of the situation and it could be a helpful data point for you all if you don't
already know about it (not sure anyone is left with the institutional knowledge of that case).
Best,
Aimee
EFTA00030280


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=== Page 1 ===
From:
To:
Subject: RE: Maxwell
Date: Mon, 06 Jul 2020 17:03:40 +0000
This is now belated, but thank you - much appreciated!
From:
Sent: Thursday, July 02, 2020 10:52
To:
Subject: FW: Maxwell
Congrats! I know it's been challenging, in so many ways. And it's a huge accomplishment.
From:
Sent: Thursday, July 02, 2020 10:43 AM
To:
Subject: Maxwell
PCU - Please join me in congratulating
on the arrest this morning of Ghislaine Maxwell.
spoke a bit about the case on our call on Tuesday and the truly remarkable job the team has done in bringing it. I won't
repeat all of that, buy you should know, as you read press coverage today that already is making it seem like these charges
were inevitable, that they were anything but, and that they are instead the result of an extraordinary amount of work and
perseverance and creativity by
in building a case based on conduct that I'm pretty sure is older
than all of our paralegals.
will be holding a press conference at 12, and while it is sadly not possible for all of us to be there to join her given
current conditions, I hope we can all take a moment to remotely congratulate the team on a terrific accomplishment in
bringing an extremely important case against a woman very worthy of criminal prosecution.
EFTA00030955


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=== Page 1 ===
3/16/2021
FD-1087
31E-MM-108062 1B1
Package copy
Split To
50D-NY-3027571
Item 1B132
(U) One (1) beige massage table.
50D-NY-3027571
Item 1B131
(U) One (1) brown massage table.
50D-NY-3027571
Item 1B130
(U) One flat box containing one (1) large framed photo.
50D-NY-3027571
Item 1B129
(U) One box containing four (4) framed photos.
50D-NY-3027571
Item 1B128
(U) One box containing twelve (12) framed photos.
50D-NY-3027571
Item 1B127
(U) One box containing five (5) framed photos and one (1) un-
framed photo.
Evidence
31E-MM-108062 1B1
Item:
Evidence
General
Type:
(U) Box containing 1) ONE PHONE MESSAGE BOOK PBPD05-1024 (1) 2) THREE PHONE MESSAGE
BOOKS
(2) 3) ONE FILE FOLDER WITH TWO FILES
(3) 4) SHREDDED
PAPER
(4) 5) ONE FILE FOLDER - ORANGE
(7) 8) BLACK FRAMED
PHOTO OF NUDE GIRL
(8) 9) NINE PICTURES IN FRAMES (9) 10) EIGHT PHOTOS FROM
OFFICE (10) 11) TWO PHOTOS - SITTING ROOM (11) 12) TWO PHOTOS - TABLE
(12) 13)
Description: TWO VHS TAPES POOL AREA (13) 14) TWO CDS - MARKED "HAPPY BIRTHDAY" (15) 16) ONE MESSAGE
PAD - 1ST FLOOR (16) 17) ONE MESSAGE PAD - DESK (17) 18) THREE CDS - DESK (18) 19) ONE 8MM -
DESK (19) 20) UNFRAMED PHOTOS - DESK (20) 21) TWO FRAMED PHOTOS - DESK (21) 22) TWO FRAMED
PHOTOS - TABLE (22) 23) THREE SOAPS ON A ROPE (23) 24) TWO VIBRATORS - "TWIN TORPEDO" (24) 25)
TWO SOAPS ON A ROPE (26) 27) ONE HIGH SCHOOL TRANSCRIPT - AH (27) 28) ONE BOTTLE OF JOY
JELLY - MASTER BEDROOM (28) 29) THREE VIDEO TAPES - MASTER BEDROOM
Location:
E03707388 - ECR8
Barcode:
E4229228
Details
Collected On: 08/28/2006 11:50 AM
Receipt Item #: None
CATS ID #: None
CATS Abandonment #: None
FBI Seizure #: None
Abandonment #: None
Storage Location
Discovery Location
Holding Office: NY - NEW YORK
Area:
N/A
Finalized By:
Seizing Individual:
Last Inventory: 08/04/2020 12:00 AM
Specific:
N/A
Collected By:
Retention
Retention: No
Legal Caveats
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/10
SDNY_GM_02753552
EFTA00029895

=== Page 2 ===
3/16/2021
FD-1087
None
Chain of Custody
Shipping Log
History
Acquisition Event
Acquisition Event: (U//FOUO) Items migrated on 2006-08-28
Collected From: (U//FOUO)
345 SOUTH COUNTY ROAD
PALM BEACH, FL, 33480
Receipt Given:
No
Holding Office:
MM - MIAMI
Evidence Log:
Missing
Missing
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
2/10
SDNY_GM_02753553
EFTA00029896

=== Page 3 ===
Chain of Custody FD-192
Case ID : 31E-MM-108062
1B1
Barcode : 24779778
Accepted By:
Printed Name
Reason: Collected
Date/Time: 08/28/2006 11:50am
no
Accepted By:
Printed Name:
Reason: STORAGE EXCLUDING ITEMS# ,2,16,17.
Date/Time: 2-8-08
330 PM.
Accepted By:
Printed Name:
Reason: Review of Item#s 1,2,16,17
Date/Time: 02-08-08 3:31pm
Accepted By:
Printed Name:
Reason:
RELEASED TO SA.
Date/Time: 04-10-08 1100AM.
Accepted By:
Printed Name:
Reason: Review of 181 excluding 6+7
Date/Time: 04/10/2008 110/Am
Accepted By:
Printed Name:
Reason: Return dall IBs
Date/Time: 01/13/2009 3:14pm
Accepted By:
Printed Name:
Reason:
STORAGE
Date/Time 01/13/2009 3:15PM
Accepted By:
Printed Name:
Signature:
Reason:
Date Time:
Accepted By:
Printed Name:
Signature:
Reason:
Printed Name:
6/14/19 Signature:
Date/Time:
Accepted By:
Reason:
Date/Time:
WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
SDNY_GM_02753554
EFTA00029897

=== Page 4 ===
EVIDENCE CHAIN OF CUSTODY
Relinquished Custody Fed-Ex# 47834467632 Date and
Accepted 0
Date and
Time
Time
Signature
6/17/19
Signature:
Printed N
Printed Nan
6/20/19
Reason: Transferred to NY
9:35am
Reason: RECEIVED HERMIAM
3:00m
Relinquished Cut
Date and
Accepted Custody
Date and
Time
Signature:
6/24/19
Time
Signature:
61/HC/2
Printed Name/A
Printed Na
Reason: do
2:10Pm
Reason: Evidence Review
2:10p
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signatu
7/8/19
Signatur
Printed
Printed
Reason 865/6021
Relinquished Custody
4.00mg Date and
Reason:
Accepted Custody
Date and
Time
Time
Signatu
3/15/21
Signature
3/15/21
Printed
Printed N
4:30p
Reason: storage
Reason:
Changed in
4:39m
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature
3131121
Signature:
Printed N
3/31/21
Printed Nar
Reason:
TCTO
3:35pm
Reason:
Keview
335p
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
4/8/21
Signature:
Printed Na
r/s/h
Printed Nam
Reason: storage
2:33p
Reason:
Charged 17
2:33pm
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
6/2/21
Signature:
6/2/21
Printed Na
Reason: Charged alt
3:40PM
Printed Na
3:40
Reason:
Charged ant
pm
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Case ID: 31E-MM-108062
1B:
1
Barcode: E4229228
This form is incomplete without reference to the FD-1087.
SDNY_GM_02753555
EFTA00029898


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=== Page 1 ===
From:
)"
To:
)"
Cc:
,
)"
(USANYS)"
Subject: Re: Epstein case
Date: Tue, 05 Jan 2021 18:33:26 +0000
Inline-Images: image001.gif
I'll handle. Thanks.
Sent from my iPhone
On Jan 5, 2021, at 1:17 PM,
) wrote:
Apologies, I forgot to pass this along earlier, but this Norwegian reporter got my email address from the law
school where I teach a workshop, and sent me this request.
Sent from my iPhone
Forwarded message
From: Tore Gjerstad
Date: Tue, Jan 5, 2021 at 5:58 AM
Subject: VS: Epstein case
To:
Dear
,
Have you had time to consider this request?
Best regards,
Tore
Fra: Tore Gjerstad
Sendt: onsdag 16. desember 2020 11:28
Til:
Emne: Epstein case
Dear
,
I'm an investigative reporter at The Norwegian Business Daily in Oslo, (Dagens Næringsliv). We have been
writing about Jeffrey Epstein's political connections for a year, among them revealing how he managed to get
Bill Gates through the doors of the Nobel Peace Prize committee's leader in 2013. But our main target has
EFTA00030938

=== Page 2 ===
been the former UN assistant Secretary General, Mr. Terje Rød-Larsen, who resigned as president of the
International Peace Institute in New York, after we revealed his financial dealings with Epstein. I'm attaching
our translated articles.
The reason why I'm writing to You is that I see You were on the team at SDNY prosecuting him. And I've
heard that You reached out to some of the people who were on Epstein's flight log in recent years. I would be
grateful if we could exchange background information that might help us in our further investigation. We
have reason to believe that both Mr. Rød-Larsen and his wife Mona Juul were on his plane one time during
Christmas to Epstein's island in the years 2010-2015.
I'm sorry for reaching out to You on this email, but I couldn't find one at the SDNY website.
Here are some of our 40 articles:
https://www.dn.no/politikk/international-peace-institute/terje-rod-larsen/jeffrey-epstein/norwegian-
newspaper-dn-reveals-diplomat-terje-rod-larsen-owed-jeffrey-epstein-130000/2-1-891702
https://www.dn.no/politikk/terje-rod-larsen/bill-gates/jeffrey-epstein/behind-the-scenes-how-jeffrey-epstein-
helped-billionaire-bill-gates-fund-un-affiliated-think-tank-projects/2-1-885697
https://www.dn.no/magasinet/dokumentar/jeffrey-epstein/thorbjorn-jagland/terje-rod-larsen/bil-gates-and-
jeffrey-epstein-met-with-nobel-committee-chair/2-1-885834
https://www.dn.no/politikk/jeffrey-epstein/terje-rod-larsen/mona-juul/jeffrey-epstein-funded-special-
performance-of-tony-award-winning-play-for-the-un-community/2-1-918850
Best regards,
Tore Gjerstad
Political reporter
The Norwegian Business Daily
Mobil:
DagensNæringsliv
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=== Page 1 ===
From:
To: J
Cc:
>,
Subject: Re: Letter from
counsel
Date: Wed, 21 Aug 2019 19:43:13 +0000
I believe it was yesterday, but I'll confirm.
>>>
> 8/21/2019 8:57 AM >>>
Thanks,
What day did the facilities manager talk to him / test run the shower?
Assistant U.S. Attorney
212-637-1023
On Aug 21, 2019, at 08:56,
> wrote:
Hi
Just a couple updates:
I caught one of the officers who normally does SHU rec. He confirmed that
can go to the roof for recreation.
SHU rec is normally from about 6:00/6:30 to 10:30/11:00. The officer said
is usually sleeping, and once he
eventually wakes up, he never asks them to go. The officer said when
and Epstein were housed together,
Epstein asked about rec. The officer told Epstein he would take him at 6:00 AM before his attorneys showed up.
was in the cell during this conversation, and the officer told me made a comment like "I can take you up
together" to both of them.
The Facilities Manager told me they talked to
He had no complaints about his cell. He only complained that
water leaked in his cell when people "took long showers." Facilities ran the shower for awhile and didn't see the water
leaking down to
cell, but if I give
the benefit of the doubt, he may be correct that the water makes
its way down there eventually after it's been running for a long, long time.
Evening watch SHU staff confirmed they gave
the three newspapers that arrived in the mail yesterday morning.
I think that's it for now. Let me know if you need anything else.
Thanks!
Staff Attorney
CLC New York
Metropolitan Correctional Center
EFTA00029721

=== Page 2 ===
?
> 8/20/2019 2:47 PM >>>
an
Bruce Barket just filed the attached letter on ECF. Are you available for another call this afternoon, please?
Thanks,
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
Haddon, Morgan and Foreman, P.C
Laura A. Menninger
HADDON
150 East 10th Avenue
MORGAN
Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
FOREMAN
www.hmflaw.com
LMenninger@hmflaw.com
March 9, 2021
The Hon. Alison J. Nathan
United States District Court Judge
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Objection to Proposed Redactions of Government's Omnibus Response &
Exhibit 5
Dear Judge Nathan:
On behalf of defendant Ghislaine Maxwell, we respectfully oppose certain of the redactions
proposed by the government to their Omnibus Memorandum in Opposition to the Defendant's
Pre-Trial Motions ("Response"), submitted to the Court on February 26, 2021.
Specifically, we oppose the redactions proposed by the government contained on pages 1-128
and 187-88 of the Response as well as certain of the redactions in Exhibit 5. We believe
additional redactions are appropriate to pages 129-134 of the Response. We hereby attach our
proposed redactions to pages 129-134, 187-88 and Exhibit 5.
The Response and its Exhibits are clearly "judicial documents" presumptively subject to the
public access rights under both the common law and First Amendment. Lugosch V. Pyramid
Co. of Onondaga, 435 F.3d 110, 119 (2d Cir. 2006); Brown V. Maxwell, 929 F.3d 41, 49 (2d
Cir. 2019). Ms. Maxwell also specifically asserts her right to an open and public trial
pursuant to the Sixth Amendment. Press-Enterprise Co. V. Superior Court (Press-Enterprise
II), 478 U.S. 1, 7 (1986).
Objections to Redactions Proposed on Pages 1-128
The government's proposed redactions on pages 1-128 all relate to materially inaccurate
statements made by a prosecutor for the government to Chief Judge McMahon. They also
relate to a sealed proceeding in which the government circumvented decades-old precedent in
this Circuit which held that civil litigation materials subject to a protective order cannot be
obtained absent notice to, and an opportunity to object by, individuals with a privacy interest
in those documents. Numerous civil litigants in the Second Circuit are negotiating protective
orders every day in reliance on Martindell and have the right to know that the protective
orders may be of little to no utility when their civil opponent seeks to have them used as a tool
EFTA00029844

=== Page 2 ===
The Hon. Alison J. Nathan
March 9, 2021
Page 2
for a criminal prosecution against them.
In circumstances such as these, "it is most important 'to have a measure of accountability and
for the public to have confidence in the administration of justice.' Lugosch, 435 F.3d at 119
(quoting United States V. Amodeo (Amodeo II), 71 F.3d 1044, 1048 (2d Cir. 1995)).
Although the government claims that the items must remain sealed due to an "ongoing
investigation," they have failed to explain why. Beyond their ipse dixit pronouncement, the
same materials they obtained via their ex parte and in camera procedure are being released to
the public under the
unsealing process, without objection from the government. The
name of the subpoena recipient (Boies Schiller) and the names of Chief Judge McMahon and
Magistrate Judge Netburn (who issued their rulings nearly two years ago) certainly cannot
alone compromise any such purported investigation. The government submission thus fails to
demonstrate that denial of public access is "essential to preserve higher values and is narrowly
tailored to serve that interest." United States V. Aref, 533 F.3d 72, 82 (2d Cir. 2008) (quoting
Press-Enterprise II, 478 U.S. at 13-14).
Ms. Maxwell believes that this Court has the jurisdiction in connection with this criminal case
to determine whether to keep under seal testimony that occurred before Chief Judge
McMahon that gave rise to this prosecution, especially as those documents have now become
"judicial documents" by virtue of the pretrial motions in this case. If the Court prefers,
however, Ms. Maxwell will first make application to Chief Judge McMahon to unseal those
materials.
Objections to Redactions Proposed on Pages 187-188
Ms. Maxwell also objects to the government's proposed redactions on pages 187-188. The
language at issue there concerns a diary that Accuser-2 has publicly and repeatedly claimed
supports her allegations. Importantly, Accuser-2 read from this allegedly corroborating diary
on a NY Times podcast. Yet now the government seeks to redact her explanation for why Ms.
Maxwell is not mentioned once in this diary: Accuser-2 "stopped writing in her journal about
a month after that first meeting with Epstein" and the rest of her diary is "personal in nature
and ha[s] nothing to do with the defendant or Epstein."
How that document, or its origin, incompleteness, or lack of corroborating content could now
be "confidential" is unexplained by the government in its request. Certainly, Accuser-2 has
not acted as though the contents are "confidential."
Objections to Government's Proposed Redactions to Exhibit 5
For similar reasons, Ms. Maxwell objects to certain of the redactions proposed by the
government to Exhibit 5 to their Response. The materials highlighted in our attached Exhibit
5 are all very public pieces of information, at the instigation of
The
government has offered no explanation for their need to protect her "privacy" interests when
she has profited with her numerous podcasts, Netflix appearances and other media
participation, wherein she shares the same information. With the support 01
and
EFTA00029845

=== Page 3 ===
The Hon. Alison J. Nathan
March 9, 2021
Page 3
her counsel, her entire
Because
has already publicly proclaimed the same allegations as are
represented in the Kramer notes at 4-5, attached as Exhibit 5 to the government's Response,
the government cannot show any privacy interest in keeping those portions redacted or sealed.
Objections to Government's Failure to Redact Materials Under Seal in
Litigation at
Pages 129-134
The government proposes, at pages 129-134, to redact only certain portions of Ms. Maxwell's
sealed deposition testimony. Judge Preska has ruled that certain questions and answers are
still under seal and subject to the Protective Order in the
case. In Ms. Maxwell's
Motions, we limited our proposed redactions to the portions of deposition testimony that
Judge Preska has ruled should remain sealed, yet the government intends to publicize those
sealed portions. See, e.g.,
V. Maxwell, Case No. 15-cv-7433-LAP, Dkt. 1212-1. The
appropriate redactions which reflect Judge Preska's rulings are contained in the attached
exhibit.
For the foregoing reasons, Ms. Maxwell respectfully requests the Court publicly docket the
Response, with the following exceptions:
Accept Ms. Maxwell's proposed redactions to pages 129-134;¹
Accept the government's proposed redactions to pages 158-186;
Accept Ms. Maxwell's proposed redactions to pages 187-188;2
Accept Ms. Maxwell's proposed redactions to Exhibit 5.³
Respectfully submitted,
Jan Laura A. Menninger a.
CC: Counsel of Record
1 Ms. Maxwell has indicated additional lines that ought to be redacted with yellow
highlighting.
2 Ms. Maxwell disagrees with all of the government's redactions on these pages, as
indicated by the red boxes.
3 The blue boxes on the attached Exhibit 5 indicate the government redactions
opposed by Ms. Maxwell. Ms. Maxwell does not oppose the other red boxes proposed by the
government to protect the privacy interests of other non-parties.
EFTA00029846


