# docs_fts_content

c1: EFTA00029760
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029760.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject:
Date: Wed, 19 Feb 2020 00:11:24 +0000
Attachments: 2003-10-05,
PBPD_Police_Reports.pdf
FYI, in case you haven't seen this in the files before. He's been deposed about this before, but wanted to flag.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00029760


c1: EFTA00030979
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030979.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)
1"
Cc:
(USANYS)"
Subject: RE: Catch up tomorrow? 10:30?
Date: Tue, 27 Aug 2019 02:38:46 +0000
Okay, I can let you know when we rap up my guess is early to mid afternoon.
Original Message
From:
) 1
Sent: Monday, August 26, 2019 9:17 PM
To:
(USANYS)
Cc:
(USANYS)
Subject: Re: Catch up tomorrow? 10:30?
Who is Epstein? Oh, right.
I'm not sure re the message but want to talk forfeiture and rico
Sent from my iPhone
> On Aug 26, 2019, at 9:14 PM,
(USANYS)
wrote:
V
>
is our this week, and I have Epstein conference before Berman at that time.
>
> Do you know when the message for
was left? My understanding is that our team connected with someone
in that office late last week, and they agreed to stand down pending the end of our investigation.
>
> Sent from my iPhone
V
>> On Aug 26, 2019, at 9:05 PM,
) 1
wrote:
>>
Sent from my iPhone
EFTA00030979


c1: EFTA00030821
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030821.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To
Subject: Accepted
counsel call
Date: Mon, 08 Jul 2019 02:27:08 +0000
Importance: Normal
Attachments: unnamed
EFTA00030821


c1: EFTA00030453
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030453.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Final Voucher 10894369(1) prepared by a travel arranger is pending your review
Date: Fri, 20 Dec 2019 15:29:45 +0000
Importance: Normal
Dear
Final voucher 10894369(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 10894369
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13261 - U.S. V. Epstein - Witness Interviews
Destination: Santa Monica (City), CA, United States
Dates: 2019-12-15 - 2019-12-17
Current status: Pending Voucher Approval
Voucher total expenses: 1256.87
Estimated trip cost: 1662.95
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0012
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00030453


c1: EFTA00030482
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030482.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Bruce Barket
To:
Cc:
(USANYS"
>, Aida Leisenring
>, Michael Bachrach
Subject: Re: Ex parte order
Date: Thu, 25 Jun 2020 14:25:51 +0000
Received. Thank you.
Bruce A. Barket
Barket, Epstein, Kearon, Aldea & LoTurco
On Jun 25, 2020, at 10:23 AM,
wrote:
Good morning,
We will not be going forward on June 30. Hopefully, we will see you on July 13.
-Chambers of Judge Karas
From: BOBBI C STERNHEIM
Sent: Wednesday, June 24, 2020 2:46 PM
To:
Cc:
i
(USANYS
>; Bruce Barket
>; ; Aida Leisenring
is
is
is
>; Michael Bachrach
is
is
;
Subject: Re: Ex parte order
Good morning, all-
Just inquiring whether the Court is firm on NOT going forward with the Curcio Hearing
on June 30th. (Mr. Bachrach and I need to cancel flights and reschedule for the July 13th hearing.)
Thank you-
Bobbi
EFTA00030482

=== Page 2 ===
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
On Jun 12, 2020, at 1:44 PM,
wrote:
Dear Defense Counsel and Firewall Counsel.
Attached, please find a brief ex parte order from Judge Karas. The same will be filed under seal.
--Chambers of Judge Karas
<16cr832_ex parte order.pdf>
EFTA00030483


c1: EFTA00029879
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029879.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Cc:
)"
Subject: RE: [EXTERNAL EMAIL] - RE: Epstein Evidence status
Date: Mon, 03 Aug 2020 19:38:30 +0000
is checking email intermittently so he'll get back you. Unfortunately I can't answer your questions directly
right now but in the event that
needs assistance locally to satisfy your needs, I'll take care of it.
Thanks,
On Aug 3, 2020 3:33 PM,
)"
wrote:
I know you may still be traveling, but I wanted to check in on a handful of outstanding issues. If you're not available,
perhaps Francesco can assist?
-
On this past Sunday and Monday, you had said you had you had additional materials you planned to get to us on
Monday. I don't believe we ever received anything additional this past week. Are those still pending, and if so,
when can we get those materials?
-
There were three folders that were included in the first disc you provided to us, but then also provided again on
the most recent disc. Those folders are: NYC024328, NYC024366, and NYC024392. Can you please let us know
why those were provided twice? In particular, we need to know whether any supplemental information is in the
new folders with those NYC numbers, or whether we can ignore them on the recent disc because we already
received them.
-
One item is listed on your spreadsheet as having been provided on 7/23, but it was not on the most recent disc
you sent. That item is: NYC027913 (row 40 in your spreadsheet).
In case it's useful, I'm attaching a version of the spreadsheet you put on the disc, but with all the items we received
folders for on the most recent hard drive highlighted in yellow.
Separately, we're still waiting on answers to the questions from Thursday and Friday, July 23 and 24. To refresh, those
questions are:
-
Comparing your most recent spreadsheet to the prior one, and leaving aside the "Nothing for Southern"
designations as well as the NYC numbers that look like they're for the desktops that held the actual drives we're
EFTA00029879

=== Page 2 ===
looking at (such as NYC024385, 387, 389, 391, and 393, and NYC027909), I think there are just three additional
devices listed here that weren't on the spreadsheet you previously sent. I have those as: NYC024328 (row 10),
NYC024367 (row 62), and NYC027910 (row 96). Please confirm that these were added, and also that we're not
missing any? I believe those were all provided on the first disc.
-
As previously mentioned, the vendor has advised that in the initial seven devices provided, there were
approximately 71,000 documents that are zero bytes (i.e., empty files). They are listed in the second attached
spreadsheet. Is that accurate? Or does that reflect some issue with the extraction process?
thanks,
From:
Sent: Friday, July 24, 2020 15:09
To:
Cc:
is
is
is
is
is
is
Subject: [EXTERNAL EMAIL] - RE: Epstein Evidence status
I don't have the evidence in front of me, but it is probably accurate. It is not unusual for the software to find such
files. I will review Monday to make sure. As to your questions from last night, the sheet should be
comprehensive. I only recall 1 addition, but I am sure that what I have is reflected in the sheet. As for the items
in dark grey, there are 2 servers with multiple drives. Some of those drives have physically failed. We have to get
them to one of our HQ specialists for recovery. Since they are physically broken, data recovery may or may not
be possible. It can be a very long process. We will get that moving ASAP. Need anything else, let me know.
On Jul 24, 2020 2:20 PM,
)"
wrote:
In addition to the pending questions below, we've been advised by the vendor that is reviewing the initial seven devices
(that were provided on a per-device extraction basis, as previously discussed) that those materials include approximately
71,000 documents that are zero bytes (i.e., empty files). They are listed in the attached spreadsheet.
Is that accurate? Or does that reflect some issue with the extraction process?
thanks,
From:
)
Sent: Thursday, July 23, 2020 18:08
EFTA00029880

=== Page 3 ===
To:
Cc:
V.
Subject: RE: Epstein Evidence status
This is very helpful, thank you. Comparing this to the prior spreadsheet, and leaving aside the "Nothing for Southern"
designations as well as the NYC numbers that look like they're for the desktops that held the actual drives we're looking at
(such as NYC024385, 387, 389, 391, and 393, and NYC027909), I think there are just three additional devices listed here
that weren't on the spreadsheet you previously sent. I have those as:
1. NYC024328 (row 10)
2. NYC024367 (row 62)
3. NYC027910 (row 96)
Could you please confirm that I have those additions correct, and that I'm not missing any? And it looks like all of those
were included in the drive you provided today.
I also see there are some drives that are still being processed, including NYC024376 through 380 and several drives in
NYC024395 - could you please let us know what that means?
Thanks very much, and we'll circle back if any issues with anything we received today, which should get to Chris in the
next day or two.
thanks again,
Original Message
From:
Sent: Thursday, July 23, 2020 14:44
To:
-
Cc:
is
Subject: Epstein Evidence status
Here is the up to date spreadsheet. I color coded things to hopefully make it easier. There are 5 items I have to
get you (as we discussed this morning) Those should take another day or 2, so looking at Monday/Tuesday for that. Any
questions, let me know.
EFTA00029881


c1: EFTA00030660
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030660.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
(USANYS)"
)"
)"
Subject: RE: updates
Date: Tue, 03 Sep 2019 16:00:21 +0000
Importance: Normal
Thanks. Makes sense. As part of that, can you just remind the Brass in a sentence or less who she is?
From:
Sent: Tuesday, September 3, 2019 11:56 AM
To:
(USANYS)
Cc:
(USANYS)
>;
)
>;
Subject: RE: updates
Thanks, sending now-I'm adding one bullet point, which is that we are scheduled to meet with
on
9/11 for a reverse proffer. I'm not sure whether we had discussed that, so wanted to make sure you were aware.
From:
(USANYS)
Sent: Tuesday, September 3, 2019 11:06 AM
To:
Cc:
(USANYS)
is
Subject: RE: updates
Got it, thanks. Please make those changes and pass up.
From:
Sent: Tuesday, September 3, 2019 11:05 AM
To:
(USANYS)
Cc:
(USANYS)
is
is
Subject: RE: updates
Thanks,
Only small changes:
Because of Hurricane Dorian, it looks like this week's Florida trip will have to be rescheduled. I'll make that
change.
still appears to be open to a videoconference interview. What she backed out of was meeting us last
week.
The
interview will be in person, not by videoconference (that's my error,
pointed that out and
l'll fix it).
Regarding the
attorney proffer, I would say she has denied knowing the victims were minors and that the
massages would be sexual in nature.
From:
(USANYS)
Sent: Tuesday, September 3, 2019 10:58 AM
EFTA00030660

=== Page 2 ===
To:
Cc:
(USANYS)
is
Subject: RE: updates
Hope you all had a good long weekend and got to take a bit of a break. Assuming no big developments since Friday
afternoon, I've proposed some modest additions/changes to your bullets, below. Can you take a quick look, note my
question below on
and let me know if there is anything worth discussing further? If not, you can send on to the
Brass noting this is per Geoff's request for an update. Thanks
Oh, and we'll do something more official soon, but a formal welcome to the unit,
On August 27th, the team met separately with
and
and
are Victim-2 and
Victim-3 in the Indictment and have previously described
as the individual through whom they
scheduled all of their encounters with Epstein. Critically, both have also said
was present when they
arrived to perform the massages (and thus would have seen how old they were) and on some occasions paid
them after the "massages" were complete. During our meetings on August 27,
and
both conveyed that
they are willing to continue to cooperate in an ongoing investigation into Epstein's co-conspirators.
On August 27th, the team met with
who reported being sexually assaulted at several of
Epstein's properties while she was an adult.
described being recruited to perform massages for Epstein by
Ghislaine Maxwell.
indicated that she would cooperate with our ongoing investigation.
On August 27th, the team interviewed
who described being recruited by Ghislaine Maxwell
and caused to engage in sexualized massage sessions with Epstein, during which she was sexually assaulted.
These assaults occurred in London, Florida, the USVI, and New York, beginning when
was 17 and
continuing into her early twenties. These incidents occurred in the 1990s, before the sex trafficking statutes were
enacted.
indicated that she would cooperate with our ongoing investigation.
On August 27th, the team met with
who has previously been interviewed and has described being
sexually assaulted by Epstein at several of his properties when she was 17.
has reported that
was present during at least one of these encounters.
has indicated that she will cooperate with our
ongoing investigation.
On August 29th, the team met with
and
who have each
reported being sexually abused by Epstein while they were adults. We are in the process of scheduling an
interview with
who, as noted, was an adult at the time she was abused, and has accused Ghislaine
Maxwell of being involved in her abuse. We anticipate that the interview will occur by videoconference, likely
during the next two weeks. [Is this still happening, I thought she had backed out?]
Weather permitting, the team hopes to travel to Florida the week of September 3 for two meetings. First, we
hope to meet with
)
for a second proffer.
worked as an assistant to Epstein in 2004,
reporting to
Her duties included scheduling two to three "massages" for Epstein each day he was in
Florida. Second, we hope to meet with
for a reverse proffer. When
was 16, Epstein
proposed that she recruit girls for him, and
brought her young friends to Epstein for "massages" for
several years.
was granted immunity by SDFL and provided grand jury testimony as part of the prior
investigatoin, and we hope to pursue
as a witness in this case. Our understanding is that
coordinated appointments for the victims through
On September 6th, we are scheduled to meet with
defense counsel for an second attorney proffer.
At the initial attorney proffer,
attorney's substantially minimized her knowledge of the criminal elements
of her conduct, namely the age of the girls she was scheduling to "massage" Epstein.
EFTA00030661

=== Page 3 ===
On September 9th, we are scheduled to interview
by videoconference.
has
accused Ghislaine Maxwell of recruiting her when she was 16.
On September 16th, we are scheduled to interview
,
who worked as Epstein's "house man" at the
New York Residence for many years. To our knowledge,
has never been interviewed before.
During the week of September 16th, the team plans to travel to California for several meetings. We hope to
meet with
a victim who is described in our previous memorandum regarding co-conspirators.
We have previously interviewed
who has told us that
was not only involved in scheduling her
"massages," but met/observed
in person and was present for conversations about the sexual natures of
the encounters with Epstein, and we hope to discuss whether
is willing to cooperate with our ongoing
investigation. While we are in California, we also hope to schedule follow-up interviews with
and
described above.
EFTA00030662


c1: EFTA00031833
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031833.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: FW: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Date: Thu, 31 Dec 2020 00:38:28 +0000
Embedded: FW_Disparities_in_Counsel_and_Discovery_Access_for_Ghislaine_Maxwell_and_Justin_Riv
era.msg
Sender:
Subject: FW: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Message-Id:
<BN3P110MB033997374A05F403AFF6027192D60@BN3P110MB0339.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
EFTA00031833


c1: EFTA00030201
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030201.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject:
Date: Mon, 15 Jul 2019 05:19:59 +0000
https://www.thedailybeast.com/jeffrey-epstein-has-a-secret-charity-heres-who-it-gave-money-to
EFTA00030201


c1: EFTA00029644
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029644.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: NY Times: Jeffrey Epstein's Charity: An Image Boost Built on Deception
Date: Tue, 26 Nov 2019 19:08:50 +0000
https://www.nytimes.com/2019/11/26/business/jeffrey-epstein-charity.html?
action=click&module=Top%20Stories&pgtype=Homepage
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00029644


c1: EFTA00029921
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029921.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 1B8
Evidence
31E-MM-108062 - 1B8
Item:
Evidence
General
Type:
(U//FOUO) Box containing 1) VHS TAPE OF SURVEILLANCE PBPD 05-1205(1) 2) VHS TAPE OF
SURVEILLANCE (2) 3) VHS TAPE (3) 4) VHS TAPE (4) 5) VHS TAPE (5) 6) VHS TAPE (6) 7) VHS TAPE (7) 8)
SIXTEEN DVD-R DISCS PBSO PBPD 05-1219(1) 9) CINGULAR ENVELOPE WITH SUBPOENA INFO PBPD 05-
Description: 1245(1) 10) CINGULAR WIRELESS CD (2) 11) SONY MICRO CASSETTE PBPD 06-21(1) 12) GREEN FOLDER
A. PBPD 06-24(1) 13) SONY MICRO CASSETTE PBPD 06-39(1) 14) SONY MICRO CASSETTE PBPD 06-59(1)
15) SONY MICRO CASSETTE PBPD 06-95(1) 16) T-160 VIDEO CASSETTE PBPD 06-120(1) 17) SONY MICRO
CASSETTE PBPD 06-182(1) 18) SONY MICRO CASSETTE PBPD 06-348(1) 19) CD PBPD 06-397(1)
Location:
E03707388 ECR8
Barcode: E4229235
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
Receipt Given:
No
Holding Office: MM - MIAMI
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/2
SDNY_GM_02753578
EFTA00029921

=== Page 2 ===
7/20/2021
FD-1087
Evidence Log:
Missing
Missing
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
2/2
SDNY_GM_02753579
EFTA00029922

=== Page 3 ===
Chain of Custody FD-192
Case ID . : 31E-MM-108062
1B8
Barcode 5409735
Accepted By
Printed Na
Reason:
Accepted By
Printed Na
Reason:
Accepted By
Printed Na
Reason:
Accepted By:
Printed Na
Reason:
Accepted By:
Printed Na
Reason:
Accepted By:
Printed Na
Reason:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Reason:
6/14/19
Signature:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
SDNY_GM_02753580
EFTA00029923

=== Page 4 ===
EVIDENCE CHAIN OF CUSTODY
Relinqui
Date and
Signature
ime
Printed No.:
1/20/19
Reason: TO
Relinquism
3:00
Date and
Signature
Time
Printed NO.
/24/19
Reason:
:10p
Relinquiser
Date and
ime
Signature
Printed NAME
/15/21
Reason:
1:30pm
Relinquis
Date and
Signature
ime
Printed Name
31/21
Reason:
35p
Relinquis
ate and
Signature:
ime
Printed Name
1/6/21
Reason:
3,8
Relinquish
the and
me
Signature:
Printed Name
7/21
Reason:
oss
Relinquish
ate and
me
Signature:
Printed Name
8/21
Reason:
:33pm
Relinquish
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
IB: 8
Barcode: E4229235
This form is incomplete without reference to the FD-1087.
SDNY_GM_02753581
EFTA00029924


c1: EFTA00031519
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00031519.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Draft SW
Date: Thu, 02 Jul 2020 00:38:04 +0000
Attachments: New_Hampshire_Premises_SW_Affidavit.ebd.docx
Call me if you want to discuss.
From:
Sent: Wednesday, July 1, 2020 8:19 PM
To:
Subject: RE: Draft SW
Not that we know of.
From:
Sent: Wednesday, July 1, 2020 8:19 PM
To:
Subject: RE: Draft SW
It looks like the Boston address is an office building with a bunch of law firms, including
any idea if they or
any other firm in the building has represented her historically?
From:
Sent: Wednesday, July 1, 2020 7:49 PM
To:
Cc
Subject: Draft SW
Attached
EFTA00031519


c1: EFTA00030359
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00030359.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Subject: detention memo
Date: Thu, 02 Jul 2020 16:09:26 +0000
Attachments: 2020-07-02,_United_States_v_Maxwell_20_Cr_330_(AJN),_detention_memorandum.pdf
Here's what we filed, FYI. We'll address the circumstances of the arrest orally during the argument.
Assistant United States Attorney
Southern District of New York
EFTA00030359


c1: EFTA00029695
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0007/EFTA00029695.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Fwd: 2nd Circuit
Date: Mon, 17 May 2021 17:14:21 +0000
Attachments: 2021.05.14,_GM,_order_regarding_sleeping_conditions.pdf
One of Maxwell's attorneys sent the below email. I've attached the Friday ruling that he is referring to which is not a bail
order and instead relates to the conditions of confinement. As you know, he already appealed Judge Nathan's prior bail
orders. (After he filed the bail appeal in the Circuit, Judge Nathan subsequently denied the defense's request for a
renewed bail hearing). Does he need to file a new appeal? It's not clear to us what he is doing here. Happy to give you a
call to discuss.
Thanks!
Begin forwarded message:
From: David Oscar Markus <dmarkus@markuslaw.com>
Date: May 17, 2021 at 10:47:46 AM EDT
To:
Subject: 2nd Circuit
Hi
I hope this note finds you well.
Based on the court's ruling on Friday, I will be filing a renewed motion for bond in the Second Circuit. I
will note the government's opposition unless you inform me that I am mistaken.
Thanks,
David
--David Oscar Markus
Markus/Moss
markuslaw.com
305-379-6667
EFTA00029695


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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein call
Date: Wed, 09 Jan 2019 15:29:07 +0000
Importance: Normal
Attachments: unnamed
EFTA00031834


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=== Page 1 ===
EFTA00031446
Archdiavese of Notwark
Issex Catholic High School
Congregation of Christian Brothers
East Orange, New Jersey
This Certifies that
Michael Albert Thomas
has completed the requirements for graduation and
is hereby awarded this
Diploma
Issued by authority of the Archdiocese of Newark,
June 9, 1996
+
Therefore Marrich
Archbishop of Newark
A James DePriss Principal
Sr. Dominica Rocebio SC
Secretary for Education/Lapevintendent uperintendent


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=== Page 1 ===
From: "inquiry@claimfox.com" <inquiry@claimfox.com>
To:
Subject: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell
Date: Tue, 07 Jul 2020 17:05:18 +0000
Your Request is Being Prepared
The request for records has been received and is being prepared. You will be notified
when the requested records and invoice are available for pick-up via the ClaimFox
Portal.
Date Of Loss:
Claimant Name: Ghislaine Maxwell
Invoice #: 42561447
Requested From: USAA - Criminal Banking
Claim #: 40897182
Reference #:
You can check the status of this and other requests by going to the ClaimFox Portal.
Powered by ClaimFox, Inc. © 2019 ClaimFox, Inc. - All Rights Reserved
SBP 1A
Disclaimer
The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and
others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking
action in relation of the contents of this information is strictly prohibited and may be unlawful.
This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast Ltd, an innovator in
Software as a Service (SaaS) for business. Providing a safer and more useful place for your human generated data. Specializing in;
Security, archiving and compliance. To find out more Click Here.
EFTA00031497


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Accepted: Epstein Oral Argument-- Second Circuit
Date: Wed, 09 Jan 2019 19:22:06 +0000
Importance: Normal
Attachments: unnamed
EFTA00031330


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: Letter regarding discovery attached.
Date: Wed, 12 Aug 2020 15:59:18 +0000
Attachments: 2020-08-12,_GM,_letter_to_defense_counsel_re_discovery.docx
Inline-Images: image001.jpg
Draft letter response attached. Let me know if you have any revisions before I send to the chiefs.
From:
Sent: Monday, August 10, 2020 2:02 PM
To:
is
Subject: RE: Letter regarding discovery attached.
Thanks for sending,
I agree with this approach, though defer to
if she's handling, and thanks in advance. On
the last point: I do think we have a firm view that they should not be filing our discovery materials in civil cases. I don't
care about the substance of these particular documents, but I think we agree that is an important aspect of the protective
order to assert, both in this instance and in general, so this issue doesn't continue to crop up.
From:
Sent: Monday, August 10, 2020 11:37 AM
To:
Cc:
Subject: FW: Letter regarding discovery attached.
I think
is particularly swamped this week - can you please take the lead on whatever we're going to do with this
(i.e., presumably whatever the chiefs decide)? My personal vote would be to tell them that the protective order explicitly
precludes the use of criminal grand jury materials in Maxwell's civil cases, and the materials are sealed because they
relate to an ongoing grand jury investigation and they should feel free to raise the issue with Nathan and we'll respond.
(And I would think our response could basically be a copy-paste of the letter I wrote to Netburn.) We could also note in
our response to Jeff and Laura, if we wanted to, that given their awareness of the materials, we assume they will retract
the obviously false claims about government malfeasance.
All that said, I also wouldn't object if they just want to allow them to file these materials under seal; I don't think it
matters hugely. If we could have resolved
(et al) by now, none of this would be an issue.
thanks,
From: Jeff Pagliuca <jpagliuca@hmflaw.com>
Sent: Sunday, August 09, 2020 18:56
To:
is
)
V.
Cc: Laura Menninger <Imenninger@hmflaw.com>; Christian Everdell <CEverdell@CohenGresser.com>; Mark S. Cohen
<mcohen@CohenGresser.com>; Nicole Simmons <nsimmons@hmflaw.com>
Subject: Letter regarding discovery attached.
EFTA00030902

=== Page 2 ===
Dear Counsel,
Please see attached conferral letter.
Jeff
Jeffrey S. Pagliuca
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
jpagliuca@hmflaw.com
www.hmflaw.com
mation 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
EFTA00030903


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=== Page 1 ===
From:
To:
Subject: FW: Pending FOIA # 1424728 - JEFFREY EPSTEIN UNCLASSIFIED
Date: Fri, 25 Jan 2019 18:53:15 +0000
Attachments: 1424728.pdf
Classification: UNCLASSIFIED
As discussed. Sorry for the delay, but were busy with the arrest this morning.
Let me know your thoughts.
Have a great weekend.
From:
Sent: Thursday, January 24, 2019 12:36 PM
To:
Subject: FW: Pending FOIA # 1424728 - JEFFREY EPSTEIN UNCLASSIFIED
Classification: UNCLASSIFIED
TRANSITORY RECORD
From:
Sent: Thursday, January 24, 2019 11:32 AM
To:
-
Cc:
Subject: Pending FOIA # 1424728 - JEFFREY EPSTEIN UNCLASSIFIED
Classification: UNCLASSIFIED
TRANSITORY RECORD
**Your response to this communication is required within 7 days and is accounted for in the "Percentage of Timely FOIA
Requests" element of your Field Office Health Measure.
Good afternoon, CDC
and SA
I am processing a FOIA request and the subject is Jeffrey Epstein.
The requester's name is Bill Stevens. In searching the Bureau's indices, the following file was located and determined
responsive to the subject of this FOIPA request. It is RIDS policy to notify the CDC and Case Agent to ensure all pending
investigations are handled appropriately.
FILE NUMBER (including sub-files): 31E-MM-108062
Investigator/SA:
RIDS is required to collect and review the potentially responsive information to determine how to properly respond to this
FOIPA request. Below you will find RIDS standard questions for handling pending cases. We request your office address
each question and provide the specific details associated with this pending matter. Your responses to the questions below
will determine the exemptions or whether exclusion is appropriate for this request.
If you have any questions please feel free to contact me at
Thank you for your assistance.
1. What is the current status of the pending investigation (e.g., investigation is ongoing, awaiting U.S. Attorney decision to
prosecute, trial is pending, an appeal from the trial is pending, etc.)?
EFTA00030111

=== Page 2 ===
2. Can we advise the subject/requester that the investigation is pending or would this jeopardize the investigation?
3. If pending, does the investigative file contain any releasable material pertaining specifically to the subject of the request
that will not harm or interfere with this or any other pending investigation?
[Please note releasable material could include, but is not limited to public source material (i.e., newspaper articles, internet
downloads, items in the public domain such as video clips and press releases, court transcripts, criminal affidavits, and other
court filings)].
4. Has the subject of this investigation been interviewed?
File number 31E-MM-108062 serials 1-250 is located on the FBI Vault. It was released from Civil Action 17-CV-03956. I
consulted with my expert regarding this and he advised me to see if it would be ok for us to process and release serials
251-257? I have attached the request letter below for your reference.
Thank you,
Classification: UNCLASSIFIED
Classification: UNCLASSIFIED
Classification: UNCLASSIFIED
EFTA00030112


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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
April 30, 2021
BY ELECTRONIC MAIL
Mark Manley
Re:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Mr. Manley:
The Government writes in response to your letter to the Honorable Alison J. Nathan regarding
your client
and your request for assurances regarding ensuring your client's anonymity
in upcoming criminal proceedings, including in documents or information that identifies your client.
As an initial matter, the Government notes that to date, there have been no filings on the public
docket in the above-captioned criminal case that name your client. Second, to the extent the
Government has produced documents with your client's name to the defense pursuant to its disclosure
obligations in this criminal case, those materials have been designated as confidential and are
governed by the Protective Order in this case (Dkt. No. 36). Pursuant to the Protective Order, the
defense is prohibited from filing publicly any confidential information referenced in the discovery
materials, unless authorized by the Government in writing or by order of the Court. The defense has
complied with this requirement of the Protective Order and has indicated that it will continue to do
so.
As to the upcoming criminal trial in this matter, the Government notes that it does not intend
to call your client as a witness at trial. As a courtesy,¹ we note that your client's name may arise
1 As a general matter, the Government is not obligated to provide a detailed preview to the defense,
or third parties, about how it expects to prove its case at trial.
EFTA00031609

=== Page 2 ===
Page 2
during the public testimony of witnesses and may be listed on public exhibits introduced at trial. See
United States V. Akhavan, 20 Cr. 188 (JSR), 2021 WL 1216909, at *3 (S.D.N.Y. Apr. 1, 2021) ("[T]he
public has a similar right to access documents presented to the jury, and in criminal cases, this right
stems from not only the common law, but also the Sixth Amendment guarantee of a 'public trial.'
Indeed, the Second Circuit has explained that 'the public has an especially strong right of access to
evidence introduced in trials." (quoting United States V. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995)
(internal quotation marks and citation omitted)).
Finally, although the Government is mindful of privacy interests of third parties,² we are not
aware of any procedure under United States criminal law that allows third parties to exercise input
regarding whether or not their names or information about them will be mentioned at a criminal trial,
nor would it be legally permissible to conduct a trial under seal or preclude public access to a criminal
trial.
Respectfully submitted,
AUDREY STRAUSS
United States Attorney
By:
s/
Assistant United States Attorneys
Cc: The Honorable Alison J. Nathan (By email)
Defense counsel (By email)
2 The Government is not presently aware of any authority under which the privacy laws of the United
Kingdom would have any force in this jurisdiction, and your letter cites none. In addition, the
Government respectfully notes that your client is not a victim of child sexual exploitation in
connection with this case, and thus the Crime Victims' Rights Act, 18 U.S.C. $ 3771, does not apply.
EFTA00031610


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=== Page 1 ===
From:
Bcc:
Subject: Re: FW: URGENT REQUEST FOR VTCs-GHISLAINE MAXWELL 02879-509
Date: Mon, 21 Dec 2020 15:18:23 +0000
Embedded: Re:_FW:_URGENT_REQUEST_FOR_VTCs-GHISLAINE_MAXWELL_02879-509.msg
Sender:
Subject: Re: FW: URGENT REQUEST FOR VTCs-GHISLAINE MAXWELL 02879-509
Message-Id: <5FE0BCB7020000DE000E0DAE@SMTP1.BOP.GOV>
Recipient:
EFTA00030098


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=== Page 1 ===
PRISM Scanned Document
Page 1 of 1
U.S. Department of State
APPLICATION FOR
U.S. PASSPORT
REGISTRATION
(Type or print all capital letters in blue of black ink in white areas only)
1. NAME (First and Middle)
GHISCAINE MOELLE
LAST
MAXWELL
400956
046842429
2. MAIL PASSPORT TO: BOX
APT
-
5 Yr
X
10
Issue
Date
STATE
X
D
0
DP
CITY
ST THOMAS
u
usrI
End. #
Exp.
ZIP CODE
COUNTRY IN CARE OF (If applicable)
00802
c/o AMERICAN YACHT, HARBOR
5. DATE OF BIRTH
6. SOCIAL SECURITY NUMBER
4. PLACE OF BIRTH (City & State or City & Country)
Month
Year
(SEE PAGE
3. SEX
2
/
MAISON LAFFITT PRANCE
7. HEIGHT
8. HAIR COLOR
9. EYE COLOR
HOME TELEPHONE
11. BUSINESS TELEPHONE
12. OCCUPATION
Feet
inches
S
P
BROUN
BROWN
Business WOMAN
ADDRESS
IDO
NOT
IST
BOX)
STREET/R.F.D.
CITY
STATE
ZIP CODE
STATEMAS USUI
00802
FOLD
MOTHER'S FULL MAIDEN NAME
BIRTHPLACE
BIRTHDATE
U.S. CITIZEN
14. FATHER'S FULL
Chk
Yes
Yes
MAXELL Last
MANAD E12 AGETH
FRANCE
name
No
16 HAVE YOU EVER OR ORMER SPOUSE'S FULL
WRTH
BIRTHDATE
CITIZEN
Yes
BEEN MARRIED
No
DATE OF MOST RECENT CED?
17. THER NAMES YOU HAVE USED
Month
Day
Give Date
(1)
18. HAVE YOU EVER BEEN ISSUED A U.S. PASSPORT?
Yes
F YES, COMPLETE NEXT LINE AND SUBMIT PASSPORT IF AVAILABLE.
DISPOSITION
No
APPROXIMATE ISSUE DATE
Submitted
NAME IN WHICH ISSUED
MOST RECENT PASSPORT NUMBER
Month
Day
Year:
Lost
Other
Is in necessary to submit a statement with as application for a - passport when a previous valid or potentially valid passport cannot be presented. The
statement must set forth in detail why the previous passport cannot be presented. Use Form DG-04.
19. EMERGENCY CONTACT. If you wish, you may supply the name, address and telephone number of *
20. TRAVEL PLANS not mandatory)
person not traveling with you to be contacted in case of amergency.
Month
Day
Year
Date
of Trip
12052002
NAME
Langth
of Trip
work
STREET
united Kingdom
CITY
STATE
ZIP CODE
TELEPHONE
00000065-001
0
COUNTRIES Tp BE VISITED:
21. STOP DD NOT SIGN APPLICATION UNTIL REQUESTED TO DO so BY PERSON ADMINISTERING OATH.
0
I have not, since acquiring United States performed any of the listed "Acts or Conditions
on the iverse of applicati form (unles: explemence stat $ uttached m emnly swear (or affirm
that the statements made on this application are true and the gh true likeness of me.
X
X
Goe Annlicant Signature age 14 or older
Father's/Legal Guardian's Signature (if identifying minor)
FOLD
X
Mother's/Legal Guardian's Signature (If identifying minor)
Clerk of Court: Location
Mgrth
Day
Yes
PASSPORT Agent
11272002
(SEAL)
Postal Employee
(Signature of person authorized to accept application)
(Vice) Consul USA
23a. Applicant's or Father's Identifying Documents
23b. Mother's Identifying Documents
Driver's License
Passport
Other (Specify)
Nat.
Cert.
Driver's License
Passport
Other (Specify)
Expiration
<<<<<<<<
Issue
Expiration
THENT STATE
Issue
of Plece
Date:
1272002
Date
Issue
Date:
Date:
Name Chislaine N.Marwell ID No. 27544548
Name
24. FOR ISSUING OFFICE US ONLY (Applicant's evidence of citizenship
27574548
Birth Certificate
SR
CR
E
Passport Bearer's Name:
SAME
Report of Birth:
9
X
Naturalization/Citizenahp Cent
Other:
11.27.4
Seen & Returned:
Attached:
25.
BL1 12/3/02 14:11 657 IA CK $0.00
FEE
NABI 1406 046842429
OTHER
DS-11
OMB No. 1405-0004 Expires: 12/31/2001 Estimated Burden 20 Minutes
Page 3 of 4
https://cdi.state.osis.gov/pls/PPT/rpt_passport_images.display_doc?p_hash=9722EF4329. 2/24/2020
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=== Page 1 ===
From:
To:
Subject: RE: Epstein -- travel approval form
Date: Tue, 04 Feb 2020 19:10:53 +0000
I'm going to make some calls so if I don't pick up when you call, that's why, but I'm here and will get off the phone
and come down whenever you're available.
thanks,
From:
Sent: Tuesday, February 04, 2020 13:02
To:
Subject: Re: Epstein -- travel approval form
No problem, I'm around whenever you're back.
On Feb 4, 2020, at 12:44,
wrote:
I may run late. Don't come till I call!
Sent from my iPhone
On Feb 3, 2020, at 5:45 PM,
wrote:
That works, thanks - just let me know if your schedule changes, otherwise l'll come by at 1:00 tomorrow. Thanks again
and looking forward to it.
From:
Sent: Monday, February 03, 2020 16:07
To:
Subject: RE: Epstein -- travel approval form
Right now 1 p.m. looks open.
From:
Sent: Monday, February 3, 2020 1:33 PM
To:
Subject: RE: Epstein -- travel approval form
No problem at all, and I'm very flexible tomorrow afternoon - whatever time is good for you I can make work, so just
let me know and l'll put it in the calendar.
EFTA00029802

=== Page 2 ===
From:
Sent: Monday, February 03, 2020 13:31
To:
Subject: RE: Epstein -- travel approval form
So sorry for the delay. Maybe tomorrow? I have time in the afternoon.
From:
Sent: Friday, January 31, 2020 1:09 PM
To:
Subject: RE: Epstein -- travel approval form
Totally understand, and next week would be fine - let me know if it's helpful to set a time, and otherwise l'll touch
base midweek if we haven't connected by then.
And thanks very much re: the memo.
From:
Sent: Friday, January 31, 2020 12:53
To:
Cc:
Subject: RE: Epstein -- travel approval form
Already signed and sent upstairs
I will do my best to ensure signature immediately.
Re: this afternoon: it may be best to kick it to next week. If some time develops before 3, I'll let you know, but right
now it is iffy.
From:
Sent: Friday, January 31, 2020 12:21 PM
To:
Cc:
Subject: Epstein -- traver approval form
We dropped off the Sweden travel memo for you - we were unexpectedly significantly delayed in getting OIA approval,
but it finally came this morning, so with apologies for the short turnaround, hoping to get Office and final DOJ
approval this afternoon. Thank you!
And separately, if you still wanted to meet up today, I'll be around until about 3:00, but I'm also flexible next week if
that's easier.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00029803


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=== Page 1 ===
From: Robert Glassman <glassman@psblaw.com>
To:
Subject: Another alleged victim cannot find Jeffrey Epstein confidant Ghislaine Maxwell to serve complaint
- ABC News
Date: Fri, 29 May 2020 03:34:51 +0000
https://abcnews.go.com/US/alleged-victim-find-jeffrey-epstein-confidant-ghislaine-maxwell/story?id=70941695
Robert S. Glassman
Panish Shea & Boyle
psblaw.com
EFTA00030454


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=== Page 1 ===
From:
)"
To: Christian Everdell <CEverdell@CohenGresser.com>, 'Laura Menninger'
<Imenninger@hmflaw.com>,
)"
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Thu, 08 Apr 2021 21:19:26 +0000
Inline-Images: image001.jpg
Chris,
I am going to be tied up for a bit the morning on the 12th. Would it work on your end to meet at the warehouse at 11am,
please? The warehouse will be open until 4:30pm, though I'm told I can request additional time in advance if you think
the review will take more than 5 1/2 hours.
Also, I am working on gathering information in response to Laura's email and expect to be able to respond to it later this
evening.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Christian Everdell <CEverdell@CohenGresser.com>
Sent: Thursday, April 8, 2021 5:06 PM
To: 'Laura Menninger' <lmenninger@hmflaw.com>;
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
I plan to arrive at the warehouse on April 12 with an investigator and a paralegal at around 9:30am. Does that work?
Thanks,
Chris
EFTA00030035

=== Page 2 ===
From: Laura Menninger [mailto:Imenninger@hmflaw.com]
Sent: Wednesday, April 07, 2021 4:23 PM
To:
)';
);
(USANYS)
Cc: Jeff Pagliuca; Christian Everdell; 'BOBBI C STERNHEIM'
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
My apologies, I meant to include in my previous email that we could have the Bronx view on Monday, April 12. Thank you
for the logistics.
Regarding the spreadsheets you provided, I have several issues.
First, there are a couple of items that you have noted for the Bronx Warehouse but will in fact need to be brought to 500
Pearl for review because you labeled them as "Highly Confidential" and not "bulky." These appear to include:
NY Evidence List
Items 1B127-130 (4 boxes).
Item 1B13 (1 box)
Florida Evidence List
Item 1, Subitem 26 - one large framed photo from Master Bedroom.
Second, with regard to the "Bulky" photos (Florida Items 1, Subitems 8, 15a, 15b and 15c), are we permitted to
photograph those or not? If not, we will need them transported to 500 Pearl.
Third, Florida Item 8, Subitem 8, says it is Sixteen DVD-R Discs from PBSO but you do not indicate that we can review
those. Why? We need to address with the Court promptly any issues related to our request to view all evidence.
Fourth, Electronic surveillance - Your email yesterday stated that these were all "electronic files" with no corresponding
physical item. However, for several, the chart indicates "Blu-Ray Disks;" is there a reason we cannot inspect these?
Another Florida item is listed as "one original recording of an interview dated 4/24/07"; I am suspicious that "one original
recording of an interview" is not truly only an "electronic" file? I was practicing law in 2007 and do not recall "electronic
files" being the standard then. Can you please confirm? I know that Chris has written separately about the many files for
which the metadata has apparently been stripped, so we will have to address purely electronic information at another
date.
Shredded Paper - Yes, we need to review that as well.
"Missing from Assigned Box" items - can you please provide more of an explanation for all "missing items"?
I will let you know any other issues as I see them. However, now that we have made travel plans in reliance on your
agreement to produce all evidence items, I am hoping that you can promptly answer these questions so that we can
resolve any of them as needed this week.
Thank you,
-Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
EFTA00030036

=== Page 3 ===
From:
Sent: Wednesday, April 7, 2021 1:44 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Hi Laura,
The Bronx warehouse is located at 2350 Lafayette Ave, Bronx, NY. There is plenty of street parking outside of the
building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the
attorney, investigator, and paralegal at the warehouse to escort them into the building to the evidence review room. The
AUSA will remain present at the warehouse to answer any questions that may arise.
The FBI has informed me that they can make the evidence available for review at the warehouse any day next week or the
week of April 19th. Please just let me know what day you prefer, and we will coordinate with the FBI to arrange for the
review.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Wednesday, April 7, 2021 3:30 PM
To:
is
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for the updated spreadsheets and the information regarding the timing of the review at 500 Pearl.
I believe we will be able to have an attorney, investigator and paralegal present at the Bronx warehouse to take photos of
the "excluded from transportation" items. Please let us know the particulars for that visit when you have a moment.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
EFTA00030037

=== Page 4 ===
From:
Sent: Wednesday, April 7, 2021 10:06 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
Attached please find the revised spreadsheets, which reflect designations under the Protective Order for the three mini-
VHS tapes that I referenced below.
I learned this morning that the Marshals intend to bring Ms. Maxwell back to the MDC each review day at 4:30pm. So we
can plan for the review to take place at 500 Pearl Street from 9:30am to 4:30pm each day beginning on April 13th.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Wednesday, April 7, 2021 12:09 AM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
-
is
(USANYS)
Cc: 'Jeff Pagliuca' <jpagliuca@hmflaw.com>; 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)"
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good evening,
Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day
thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street
at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer rooms on the 5th floor of
the 500 Pearl Street courthouse beginning at 9:30am on April 13th. I will plan to be present and to continue assisting with
logistics. If any questions or concerns arise, please feel free to call my cellphone at
To assist in preparing for this review, attached please find annotated versions of the three evidence spreadsheets I
previously emailed to you: (1) a spreadsheet of New York evidence; (2) a spreadsheet of Florida evidence; and (3) a more
detailed spreadsheet of the sub-items contained in the Florida evidence spreadsheet. A couple things to note:
These spreadsheets now indicate the Protective Order designation, if any, for each item to be reviewed. As you will
see, there are three mini-VHS tapes that I need to double check before assigning a final designation. I expect to be
able to access a mini-VHS cassette player later this week, at which point I will be able to provide an updated
EFTA00030038

=== Page 5 ===
spreadsheet with a confirmed designation for those three items. Additionally, please note that there is one item
about which we plan to provide you with a letter later this week.
These spreadsheets also indicate where each item will be made available for the defense to review. As you will see,
we have now learned that one item (consisting of shredded paper) is currently at FBI headquarters and will not be
available for review next week. Please let me know if you believe you need to review that item, and I will inquire as
to whether and how it can be relocated to New York. Additionally, all 1D items consist of electronic data (as
opposed to 1B items, which are physical items). As is noted in the spreadsheets, the electronic data that constitute
the 1D items in this case have either already been produced to you in discovery (e.g., pen register data, GPS data,
and aerial footage), or are digital recordings of interviews that will be produced as non-testifying witness
statements. Because these 1D items are data files stored in the FBI system, there is no corresponding physical item
to produce for you to review.
Please let me know when you would like to schedule a time for a smaller group from the defense team to review evidence
at the Bronx warehouse.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, April 5, 2021 10:48 PM
To: Laura Menninger <lmenninger@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
Laura,
Thank you for your email and for your understanding as we work through the logistics of arranging this review. Your
modifications and clarifications are acceptable to us. Below I address each specifically:
The FBI can arrange for a lawyer, investigator, and paralegal to inspect and photograph the precluded items at the
Bronx warehouse either next week or the week after. Please let us know what day you would like to arrange for
that inspection, and I will coordinate with the FBI accordingly. I would suggest trying to schedule this visit early
next week if possible so that if there are items that you believe need to be produced to 500 Pearl Street, we will
have time to do so during a subsequent day of review at 500 Pearl if the FBI agrees to transport the item(s).
Tomorrow, I will send you evidence spreadsheets with annotations of which items the FBI will not be producing to
500 Pearl Street, and which items we are designating under the Protective Order. Please note that certain items
will be designated "Confidential," in which case they may be photographed, but the photographs should be treated
as Confidential under the Protective Order. Other items will be designated "Highly Confidential," in which case they
may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to
photograph this latter category because some Highly Confidential evidence items include both nude and non-nude
portions, in which case we would permit photography of the non-nude portions.
EFTA00030039

=== Page 6 ===
In light of our decision to produce non-testifying witness statements beginning on April 12, 2021, we are no longer
segregating any electronic media that contain witness statements during this review. This is because all of the
witness statements on the electronic media in the FBI's possession are from witnesses whom the Government does
not expect to call at trial in this case. Please note that we intend to produce digital audio files to you containing the
contents of the electronic media with these non-testifying witness statements, but you are of course welcome to
review the original recordings themselves.
In terms of space, I have been informed that we will not be permitted to conduct this review in a courtroom and
will instead be required to do so in the proffer rooms. I have reserved the two largest proffer rooms available at
500 Pearl. We can use the largest proffer room for evidence review, and the slightly smaller proffer room as a
private meeting space for the defense team.
Confirmed, I will ask the FBI to bring all electronic highly confidential images to 500 Pearl Street, including the
2,100 that were not previously reviewed and the electronic images that were previously provided for review at the
MDC.
Confirmed, I will ask the FBI to bring the 7 hard-copy highly confidential materials to 500 Pearl Street.
As I mentioned earlier today in a separate email, the FBI and AUSAs are prepared to facilitate this review beginning April
13th and continuing every day thereafter until your review is complete. I have also formally requested that the Marshals
produce Ms. Maxwell to 500 Pearl Street on April 13th and every day thereafter until the review is complete. The
Marshals previously confirmed their willingness to produce Ms. Maxwell for such a review in general, but they have not
yet confirmed their ability to do so on any particular dates. I will let you know as soon as the Marshals inform me
whether they can accommodate these specific dates.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Friday, April 2, 2021 5:36 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for your email. Your proposal is largely acceptable to us, with the following modifications and clarifications.
For the items that you propose below to exclude from the evidence transported to 500 Pearl Street (with the
exception of the cash held at 26 Federal Plaza), we will need to have access for a lawyer, investigator and paralegal
to inspect and photograph those items at the Bronx warehouse. This seems to include the bulky items, electronic
devices and "fragile" items.
Once they are photographed and shared with the team and our client, we can decide whether a separate
inspection by our client and/or any expert is necessary at a later time. To be clear, the government's photos
of these same items are insufficient.
EFTA00030040

=== Page 7 ===
If there are any items we are not permitted to photograph (and perhaps you will be able to tell us by April 5
which those are), we likely will need to have those transported because there is no way for our client to
inspect the evidence. We can wait to finalize this issue until you have finished deciding what items you
consider non-photographable, and if we can't agree, then discuss next steps.
Please let us know when these "non-transportable" items can be inspected and photographed at the Bronx
warehouse. It makes sense that it would be done soon so that we can raise any issues as necessary with the
Court.
For playing any of the electronic media, we will obtain the necessary equipment to play at 500 Pearl Street and
seek permission to bring those devices into the Courthouse. You can segregate out the section of recordings that
contain "witness statements" and advise us then which ones cannot be played, but we still need to inspect the
outside of those recordings.
As far as space, can you please advise whether the largest proffer room will be available for review of evidence? It
is my understanding that it can accommodate a large number of the team members at one time. If not, is a locked
courtroom available for us to review the evidence? The agents could bring out a limited number of boxes at a time
for inspection.
We understand that the evidence will not be taken outside of the monitoring of the agents or your staff and
appreciate that you will have a separate room for us to consult with our client privately (without the evidence).
We understand that all of the highly confidential materials, including not only the 2,100 images not previously
disclosed as well as the electronic images that were only shown to NY counsel and the client at the MDC, will be
available for review on a singular laptop at 500 Pearl Street.
We also understand the 7 hard-copy highly confidential materials will also be available for inspection at 500 Pearl
Street.
Please let me know if you have any questions or disagree with my understanding. If you agree, we can then proceed as
scheduled on April 12 and continue day to day until we are finished, with a break if necessary for the arraignment.
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Saturday, March 27, 2021 4:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with
arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will
also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12th.
Physical Evidence
It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are
certainly willing to work with you to ensure that your client can review any physical items that are material to the
preparation of her defense.
We would propose excluding the below items from production to 500 Pearl:
EFTA00030041

=== Page 8 ===
We appreciate your note that the massage tables are not needed, which will certainly help with the logistics
of transport.
We also appreciate your indication that the cash items from 26 Federal Plaza do not need to be produced.
Those are the only items not located in the Bronx warehouse.
The FBI has seized dozens of electronic devices, including desktop computers, servers, and laptops, from
Jeffrey Epstein's residences in 2019. Photographs of those devices were produced in our August 2020
productions as part of the search warrant photographs, and you have received copies of the data that was
seized from those devices pursuant to a warrant. The production of these devices would be very
cumbersome, and we do not see any value in looking at an electronic device that cannot be turned on.
The framed pictures are bulky and cumbersome to transport. These are also very delicate and are difficult
to transport. Photographs of those seized images were already provided to you as part of the photographs
from the searches of Epstein's residences.
Certain items seized from the New York residence are bulky, fragile, and/or difficult to transport. These
include plaster busts of female torsos and a stuffed dog. Photographs of these items were already provided
to you from the search of the New York residence.
The remaining physical items of evidence would fit into approximately 15 to 20 boxes. The FBI has indicated that it
would be feasible to transport those boxes to 500 Pearl Street.
Regarding your request for equipment that can play the recordings, we believe they would require a VCR, a cassette
player, a CD player, an adapter for a micro VHS tape, and a microcassette player. If you wish to play these
recordings at 500 Pearl, you will need to provide that equipment. We have asked the FBI whether any other
equipment would be necessary and will let you know if that is the case prior to the date of your review. It is our
understanding that any recordings that are not witness statements and that are not highly confidential have been
produced to you in discovery. We are not aware of any discoverable, non-highly confidential, recordings that were
not produced to you as part of the Government's discovery productions in the fall. To confirm that understanding,
we are working with the FBI to physically doublecheck each recording. If we identify any discoverable recordings
that have not already been produced, we will promptly provide them to you.
The segregation of highly confidential material will require the FBI and an AUSA to physically review each item to
confirm the item's status. We will endeavor to do so by your requested date of April 5, 2021.
We can confirm that neither the AUSA(s) nor the agent(s) will record or attempt to record any part of the evidence
review or conversations among the defense team or with the defendant during this review. Although the evidence
cannot be left outside of the presence of an agent, we will ensure that a room is available for the defense team and
the defendant to confer privately away from the agent(s) and the AUSA(s) without monitoring.
As for your request for a space large enough to fit 8 members of the defense team, the defendant, an agent, an
AUSA, and the evidence, my office cannot control the space that the Marshals allow us to use at 500 Pearl outside
of the proffer rooms. We will certainly request as large a space as possible, but if we are required to use the
proffer rooms, then members of the defense team may need to rotate in and out of the room. I know members of
the defense team have been in those proffer rooms before, and they can hopefully provide some thoughts on how
we might use the proffer room space effectively for your purposes. If the Court grants authorization for the
defense to bring electronic devices into 500 Pearl, that is certainly fine with the Government, and you may note our
consent in your request to Judge Nathan for such authorization.
Highly Confidential Electronic Images
The 2,100 electronic images were recovered during the responsiveness review of images and videos seized from
Jeffrey Epstein's devices, which review was not complete until early November 2020. We indicated on page 4 the
cover letter to our November 9, 2020 production, which included all other images and videos from those devices,
that "the Federal Bureau of Investigation ('FBI') seized multiple nude and partially nude images from several for the
above-listed electronic devices. All such images have been designated Highly Confidential. The FBI will make these
images available for review by the defense upon request." We did not receive a request from the defense to review
these images until your March 8, 2021 letter, which requested to "view and inspect all materials designated by your
office as 'Highly Confidential' under the terms of the Protective Order".
EFTA00030042

=== Page 9 ===
We did not ask the FBI to bring the 7 hard copy images to the MDC in the fall because we did not understand you to
be requesting a review of physical, non-electronic evidence during those meetings. Our understanding of the
defense request at that time was to review the electronic highly confidential images that were recovered from CDs
from Epstein's residence. We will ensure that the 7 hard copy images are available to you for review at 500 Pearl.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 22, 2021 5:19 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
We have considered your proposal. Unfortunately, it does not permit us an adequate ability to review the evidence in the
case and does not permit our client to meaningfully participate in her own defense.
First, we are unable to meaningfully review the evidence without the benefit of our laptops and other electronic devices
which are needed to take notes of our review. We also need access to our devices during the review to compare the
physical evidence with the electronic discovery and with our work product.
Second, we need to provide our client the ability to review all discovery, including any recordings, in order to assist in her
own defense. Presuming that she will not be taken to the FBI downtown office, then your proposal offers no means by
which she can both inspect a recording in its physical form and listen to the recording at the same time.
In order to address the deficiencies in your proposal, we believe the following are necessary:
Physical Evidence
All of the physical evidence currently located in the FBI Bronx warehouse will be transported to 500 Pearl Street
and made available during the week of April 12, with our client present, in a room sufficiently large to
accommodate 8 attorneys and investigators.
We do not need the "bulky" massage tables transported; if there are any other extremely large evidence
pieces, let us know what they are and we can consider whether we can have someone review and
photograph those at the Bronx warehouse at an earlier time.
From your email, it appears that only two items are not located at the Bronx warehouse - both envelopes
with cash. Please confirm this. We do not need the two "cash" evidence items transported to 500 Pearl.
If there are other evidence items housed somewhere other than the Bronx, please let us know what they are
and where they are.
We will be permitted to bring our laptops, and a camera, into 500 Pearl Street; we are happy to seek permission
from Judge Nathan to do so.
EFTA00030043

=== Page 10 ===
Either the FBI can provide the equipment necessary to listen to any of the recordings at 500 Pearl Street or we can
bring the necessary equipment. If we are to provide the equipment, we will need to know in advance the formats
of each recording so that we can be prepared. You can note that on your Excel spreadsheet by the item number by
March 29 to give us adequate time to secure the necessary equipment.
The FBI can segregate any physical evidence that you deem "highly confidential." You can identify any "highly
confidential" physical evidence items on your Excel spreadsheets by April 5 (one week before the evidence view). If
we need to photograph or reproduce any such item for expert evaluation, we will seek leave of court. Otherwise,
we will not photograph any such items during the review during the week of April 12. This will ensure the evidence
review proceeds smoothly and there will not be any need to ask permission to photograph on an item by item
basis.
The FBI also can segregate any recordings which we will be able to inspect, but not listen to, during the evidence
view the week of April 12. You can note such designation on your Excel spreadsheet. If we disagree, we can seek
leave of the Court in advance.
We understand that an FBI Agent and/or AUSA may be present during our physical evidence review at 500 Pearl
Street but of course must ensure that no recordings are made of our conversations and also ensure that there is a
separate, secure room in which we can confer with our client during the evidence view without monitoring by the
government.
Please confirm whether all electronic recordings (other than the highly-confidential images and videos described
below) have previously been produced to us, and if not, please explain which ones were not produced by the
discovery deadlines last fall and why.
Highly Confidential Electronic Evidence
Can you please explain why 2,100 + 7 "highly confidential" images have not been shared with us yet? It was our
understanding that you previously provided all "highly confidential" images to our client - and to defense counsel -
for review at the MDC in November. We are confused about where these previously undisclosed items were
located and why they have not yet been made available for inspection and review.
During the week of April 19, Ms. Maxwell should be produced to 500 Pearl Street to review (with counsel and a
defense staff member, on the 1 laptop provided) all of the 5,507 electronic images and video marked "highly
confidential". These should be segregated into the three categories you describe (never-before produced,
previously produced, and the 7 hard-copy images).
Please let us know if you will not agree to any of these steps so that we can address the issues with the Court.
Thank you.
Laura A. Menninger 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 16, 2021 4:40 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
i
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding
discovery cover letter. We are sending a copy of these files to the MDC for your client as well.
In response to your questions, the FBI has informed me of the following:
EFTA00030044

=== Page 11 ===
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
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
EFTA00030045

=== Page 12 ===
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
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
EFTA00030046

=== Page 13 ===
(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 I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
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
EFTA00030047

=== Page 14 ===
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger <lmenninger@hmflaw.com>;
)
i
(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
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
EFTA00030048

=== Page 15 ===
From:
)
Sent: Tuesday, March 9, 2021 1:38 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
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
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
EFTA00030049

=== Page 16 ===
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@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,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
EFTA00030050

=== Page 17 ===
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.
EFTA00030051


c1: EFTA00030792
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c0:
=== Page 1 ===
From:
To:
,
Subject: RE: New documents:
V. Maxwell (Doc# 1078, S.D.N.Y. 1:15-cv-07433-LAP)
Date: Wed, 29 Jul 2020 19:20:57 +0000
Inline-Images: image001.jpg
This is what happens when defense counsel refuses to communicate effectively with the prosecution. If they had just
ASKED us how we got the transcript, they wouldn't have made this ridiculous filing.
From:
Sent: Wednesday, July 29, 2020 3:16 PM
To:
>;
Subject: FW: New documents:
V. Maxwell (Doc# 1078, S.D.N.Y. 1:15-cv-07433-LAP)
Those fucking idiots.
From: Sigrid McCawley
Sent: Wednesday, July 29, 2020 14:35
To:
>;
>;
Subject: FW: New documents:
V. Maxwell (Doc# 1078, S.D.N.Y. 1:15-cv-07433-LAP)
I wanted to alert you that Maxwell's counsel just filed the attached public filing in the
V. Maxwell case.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
From: ECFdocuments@pacerpro.com [mailto:ECFdocuments@pacerpro.com]
Sent: Wednesday, July 29, 2020 2:07 PM
To:
Subject: New documents:
V. Maxwell (Doc# 1078, S.D.N.Y. 1:15-cv-07433-LAP)
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
EFTA00030792

=== Page 2 ===
V. Maxwell
Docket entry number: 1078
LETTER addressed to Judge Loretta A. Preska from Ty Gee dated July 29, 2020 re:
Reconsideration of the Courts July 23 Ruling. Document filed by Ghislaine Maxwell.
(Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D, # (5)
Exhibit E). (Gee, Ty) (Entered: 07/29/2020)
Date entered: 2020-07-29
VIEW CASE
https://app.pacerpro.com/cases/1833757
Sent from PacerPro, the fastest and most insightful way to access federal court records.
Questions? sales@pacerpro.com or (415) 890-4958
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
EFTA00030793


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: U.S. V. Maxwell, S2 20 Cr. 330 (AJN)
Date: Fri, 07 May 2021 20:54:56 +0000
Attachments: Reply_to_Dkt_270.pdf
Hi
and
Please see attached from Maxwell's attorneys.
Thanks,
From: BOBBI C STERNHEIM
Sent: Friday, May 7, 2021 3:39 PM
To:
(US
Cc: Christian Everdell
Laura Menninger
Jeff Pagliuca
Subject: U.S. V. Maxwell, S2 20 Cr. 330 (AJN)
Good afternoon-
Attached is a courtesy copy of today's ECF filing.
Enjoy the weekend,
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
EFTA00031675

=== Page 2 ===
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
EFTA00031676


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=== Page 1 ===
From:
)"
To:
)"
Subject: RE: Epstein search warrant documents
Date: Tue, 07 Apr 2020 22:09:25 +0000
Will do and thanks
From:
)
Sent: Tuesday, April 07, 2020 18:09
To:
Subject: FW: Epstein search warrant documents
I'm around tomorrow at 11, so just ping me if you end up wanting me to dial in, depending on how the numbers/phone
technology works out. Thanks.
From:
(USANYS)
Sent: Tuesday, April 7, 2020 6:05 PM
To:
is
(USANYS)
Cc:
is
Subject: RE: Epstein search warrant documents
Yes, I should be able to do this.
From:
Sent: Tuesday, April 7, 2020 5:52 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: FW: Epstein search warrant documents
- is one (or both) of you able to join this tomorrow? As we've discussed a number of times, we are not
getting any support on this from FBI at our level so I think it would be very helpful to have support up the chain.
thanks,
From:
Sent: Tuesday, April 07, 2020 15:27
To:
>;
(USANYS)
is
is
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
EFTA00030322

=== Page 2 ===
From:
)
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
>;
is
in
)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
From:
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
is
is
is
(USANYS)
Cc:
is
V.
is
is
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
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
EFTA00030323

=== Page 3 ===
To:
is
(USANYS)
is
(USANYS)
Cc:
is
>;
is
is
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers
and no way to match up anything-that is, even if we were to try to go hunt down every individual large file in the
native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get
a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million
documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
From:
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
>;
is
(USANYS)
Cc:
is
V.
is
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
EFTA00030324

=== Page 4 ===
(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.
(office)
(cell)
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
i
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
V.
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
)
Sent: Monday, February 24, 2020 17:38
EFTA00030325

=== Page 5 ===
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
>;
>;
is
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)
is
)
>;
V.
(USANYS)
Cc:
is
>;
i
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,
EFTA00030326

=== Page 6 ===
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:
in
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.
EFTA00030327

=== Page 7 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00030328


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From:
To:
Subject: Accepted: Epstein Meeting
Date: Mon, 06 Jan 2020 16:16:53 +0000
Importance: Normal
Attachments: unnamed
EFTA00031910


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=== Page 1 ===
From:
To:
)"
Cc:
Subject: RE: RE: documents for Relativity
Date: Tue, 02 Apr 2019 13:03:23 +0000
Importance: Normal
Good morning,
The documents have been loaded to Relativity and are available for review. Please let me know if there are any questions.
Thank you.
From:
Sent: Monday, March 25, 2019 7:00 PM
To:
Subject: RE: documents for Relativity
Could we please load the documents in the following folder into Relativity for US V. Epstein (USAO # 2018R01618):
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNYinvestigation\Subpoena
Returns\Bo Schiller\2019-03-04, Boies Schiller first subpoena response
In terms of structure, we'd like to create a folder identified as "Subpoena Returns" (at the same level as "FBI Case File" is
currently), and in a subfolder within Subpoena Returns, a folder titled "BSF returns," and within that a subfolder identified
as "BSF first production" that the docs in the above link can be deposited into (including any additional subfolders). Does
that work?
Please let me know if any questions or if any other information would be helpful, and if you could please let us know
when it's all uploaded?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00030124


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=== Page 1 ===
Event: Accepted: Epstein NY property
Start Date: 2020-07-16 17:30:00 +0000
End Date: 2020-07-16 18:00:00 +0000
Location: Skype Meeting; Conference ID: 612 758 867;
Class: X-PERSONAL
Comment:
Date Created: 2020-07-16 16:14:11 +0000
Date Modified: 2020-07-16 16:14:11 +0000
Priority: 5
DTSTAMP: 2020-07-16 15:43:20 +0000
Attendee: Weinstein, Marc A. <marc.weinstein@hugheshubbard.com>
EFTA00031305


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=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:25:05 +0000
Inline-Images: image001.png
Thank you!!
From
Sent: Thursday, July 02, 2020 13:24
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Amazing work. Congrats!
From:
Sent: Thursday, July 02, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA JUSTITIA OF SOFFICE SESTION
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,
EFTA00031473

=== 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
EFTA00031474

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things,
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.
EFTA00031475


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 19-2221 United States of America V. Epstein "FRAP 42 with Prejudice FILED"
Date: Wed, 21 Aug 2019 14:07:33 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 08/21/2019
Case Name:
United States of America V. Epstein
Case Number: 19-2221
Document(s): Document(s)
Docket Text:
FRAP 42 STIPULATION, with prejudice, FILED.[2637827] [19-2221]
Notice will be electronically mailed to:
Ms.
-:
Assistant U.S. Attorney:
Assistant U.S. Attorney:
Martin G. Weinberg, -:
Reid Weingarten, -:
,
,
The following document(s) are associated with this transaction:
Document Description: Order_stipulation
Original Filename:/opt/ACECF/live/forms/MargaretLain_192221_2637827_Order_stipulation_293.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=08/21/2019] [FileNumber=2637827-0]
[18bed1551fae4b1760126e33d4cea61fdf7f7412298ae77040d85cca9fbfaa7d77b25eb42acbf03aee51d4cc9e11a5
e79a1005016ac49d3b218d6caa20f5e4a]]
Recipients:
Ms.
Assistant U.S. Attorney
Assistant U.S. Attorney
Martin G. Weinberg, -
Reid Weingarten, -
EFTA00031718


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=== Page 1 ===
From:
To:
(USANYS)"
Cc:
Subject: Epstein VI lawsuit
Date: Fri, 17 Jan 2020 02:48:22 +0000
Hi
- I assume, given the news coverage, that your team and the executives have seen the lawsuit filed by the
Virgin Islands government against Epstein's estate, the 1953 Trust, and various entities (which seeks, among
other relief, to void the fraudulent transfer of assets to the trust)? If not, let me know and I can circulate the
complaint and more detail to the broader group.
EFTA00029752


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: draft response to preservation / production request
Date: Tue, 06 Aug 2019 05:14:27 +0000
Attachments: 2019-08-05,_JE,_letter_to_defense_re_preservation_requests.docx;
Epstein.Letter.Request.Discovery_7-26-19_.pdf;
8.1.19_Supplemental_Discovery_Letter_Epstein_(1).pdf
Revised to include a response to the supplemental letter, and also attaching both defense letters for reference. (It does
not, I should note, respond to the separate 16-page letter.)
From:
Sent: Tuesday, August 06, 2019 00:33
To:
is
Subject: RE: draft response to preservation / production request
I know this is like literally the worst night to circulate this, but if either of you happens to have an opportunity to take a
glance tomorrow, I'm very happy to incorporate any thoughts / suggestions / corrections before sending up the chain -
and if not, no worries at all, l'll send it up and I'm sure there will be time to weigh in after, too.
thanks,
EFTA00030539


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=== Page 1 ===
From: "postmaster@usdoi.gov" <postmaster@usdoj.gov>
To:
Subject: SecureMail Encryption Response
Date: Fri, 12 Jul 2019 01:19:55 +0000
Your message was successfully encrypted.
Message Details:
From:
To:
Subject: RE: Epstein
EFTA00030189


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: Re: GM indictment
Date: Fri, 26 Jun 2020 15:18:34 +0000
Talk to
,
who was checking JM policy on this. In the horse case, we did put photos in the indictment in order
to use them in the press conference.
On Jun 26, 2020, at 11:01 AM,
(USANYS)
wrote:
I suppose we could, but is it really necessary? Didn't we use a photo of Epstein at his press conference without having it
in the indictment? The photo of them is, as you note, widely publicly available, so I don't think we could be accused of
publicizing something not already out there (or any more sensational than the indictment itself).
From:
(USANYS)
Sent: Friday, June 26, 2020 10:50 AM
To:
(USANYS)
is
(USANYS)
<
Subject: GM indictment
We are thinking that photos of GM/JE (the iconic one of them together) and the locations where the abuse happened
would be a good visual. To that end, can we put the photos into the indictment so there is no issue with using them at
the press conference?
Chief, Criminal Division
United States Attorney's Office, SDNY
EFTA00030776


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: FW: GM Letter Due Today
Date: Thu, 28 Jan 2021 22:56:50 +0000
Attachments: 2021-01-
28_GM_letter_to_Judge_Nathan_re_defense_proposed_redactions_in_pretrial_motions_v1.r
d.docx
My edits
From:
(USANYS)
Sent: Thursday, January 28, 2021 5:45 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
is
)
Subject: GM Letter Due Today
Apologies for getting this to you at this hour, but we owe the Court a letter today regarding the defendant's proposed
redactions to the pre-trial motions. Attached is a draft letter and the exhibit for your review.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
43
EFTA00030000


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=== Page 1 ===
From:
(USANYS) [Contractor]"
@usa.doj.gov>
To:
)"
Subject: Automatic reply: Question re Epstein Relativity
Date: Fri, 12 Mar 2021 22:56:17 +0000
I will be out of the office on March 12, 2021. I will be back in the office on March 15, 2021
If there are any questions please contact either
or
Thank you.
EFTA00031586


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=== Page 1 ===
From:
(USANYS)"
To:
)"
,
(USANYS)"
Cc:
)"
)"
Subject: RE: draft press release
Date: Tue, 30 Jun 2020 13:33:44 +0000
Attachments: 2020-06-27_GM_press_release_draft.rc+ebd.docx
Combined edits to this.
What number did we put in the release for Epstein?
Happy to discuss any. If these look okay, next version should go to
From:
Sent: Saturday, June 27, 2020 7:32 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: draft press release
I imagine this will go through many rounds of edits, but just to put something down on paper with plenty of time in
advance - see attached. I'll be out of pocket tonight (unless there's anything time-sensitive), but can turn edits tomorrow
no problem if that's useful.
thanks,
EFTA00030814


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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: Re: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Date: Thu, 31 Dec 2020 04:38:03 +0000
Embedded:Re_Disparities_in_Counsel_and_Discovery_Access_for_Ghislaine_Maxwell_and_Justin_Riv
era.msg
Sender:
Subject: Re: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
Message Id: 1C662AF5-342B-4623-8808-74684A308441@usa.doj.gov>
To:
Cc:
Cc:
Cc:
Cc:
Cc:
Cc:
Cc:
Cc:
Cc:
EFTA00031581


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=== Page 1 ===
From:
"
)"
To: "Weinstein, Marc A." <marc.weinstein@hugheshubbard.com>
Subject: Accepted: Epstein NY property
Date: Thu, 16 Jul 2020 14:51:48 +0000
Importance: Normal
Attachments: unnamed
EFTA00031302


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=== Page 1 ===
Event: Accepted: Epstein records W SDNY
Start Date: 2019-08-27 17:30:00 +0000
End Date: 2019-08-27 18:30:00 +0000
Location: OCME, 421 E. 26th St
Class: X-PERSONAL
Comment:
Date Created: 2019-08-27 16:47:46 +0000
Date Modified: 2019-08-27 16:47:46 +0000
Priority: 5
DTSTAMP: 2019-08-27 14:13:09 +0000
Attendee:
(OCME)
EFTA00029729


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=== Page 1 ===
From:
)"
To: Christian Everdell
>, , Laura Menninger
N
"Mark S. Cohen"
>, "Jeff
Pagliuca"
>, BOBBI C STERNHEIM
,
'BOBBI C STERNHEIM'
Cc:
)"
N
(USANYS)"
i
,
)"
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Date: Mon, 03 May 2021 22:53:53 +0000
Attachments: 2021.05.03_Discovery_Production.zip; 2021.05.03_Maxwell_Discovery_Letter.pdf
Counsel,
Attached please find a supplemental discovery production in the above-referenced case, as well as a corresponding cover
letter.
Our paralegals have included a copy of this production on the replacement drive you provided last week to be loaded for
your client. The drive was sent to the MDC by FedEx today.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00031015


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=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 - 1B6
Evidence
31E-MM-108062 1B6
Item:
Evidence
General
Type:
(U//FOUO) Box containing 1) MEDICAL SUPPLIES PBPD 05-386(1) 2) 727 LETTERHEAD (2) 3) INVOICE
#42700 (3) 4) AMAZON.COM A.M. (4) 5) WHITE PAPER J.L. (5) 6) MESSAGE FROM J. (6) 7) MESSAGE FROM
J.L. (7) 8) WHITE PAPER 2#S (8) 9) WHITE PAPER (917) (9) 10) MISC. DOCUMENTS - TRASH PULL PBPD 05-
874(1) 11) MISC. PAPERWORK- TRASH PULL PBPD 05-878(1) 12) TWO MAGAZINES - TRASH PULL PBPD
05-901(1) 13) PAPER WITH A.S.- TRASH PULL PBPD 05-915(1) 14) VHS T-160 CASSETTE PBPD 05-929(1)
Description: 15) SONY MICRO CASSETTE (2) 16) SONY MICRO CASSETTE (3) 17) SONY MICRO CASSETTE (4) 18)
SONY MICRO CASSETTE PBPD 05-937(1) 19) SONY MICRO CASSETTE (2) 20) SONY MICRO CASSETTE (3)
21) SONY MICRO CASSETTE (4) 22) MISC PAPERWORK- TRASH PULL PBPD 05-941(1) 23) SONY MICRO
CASSETTE PBPD 05-942(1) 24) SONY MICRO CASSETTE (2) 25) MISC PAPERS - TRASH PULL PBPD 05-
943(1) 26) CLEAR PIECE OF PLASTIC PBPD 05-944(1) 27) MISC PIECES OF PAPER - TRASH PULL (2) 28)
SONY MICRO CASSETTE PBPD 05-945(1) 29) SONY MICRO CASSETTE (2)
Location:
E03707388 ECR8
Barcode: E4229233
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
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/2
SDNY_GM_02753571
EFTA00029914

=== Page 2 ===
7/20/2021
FD-1087
Collected From: (U//FOUO) DET
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
2/2
SDNY_GM_02753572
EFTA00029915

=== Page 3 ===
Chain of Custody FD-192
Case ID
Accepted
Print
Reason
Accepted
Print
Reason
Accepted
Print
Reason
Accepted
Print
Reason
Accepted
Print
Reason
Accepted
Printe
Reason
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Signature:
Reason:
Date/Time:
Accepted By:
Printed Name:
Accepted By:
Printed Name:
6/14/19
Signature:
Reason:
Date/Time:
Signature:
Reason:
Date/Time:
WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR
Printed Name:
Signature:
Date:
SDNY_GM_02753573
EFTA00029916

=== Page 4 ===
EVIDENCE CHAIN OF CUSTODY
Relinquish
Date and
cla/cs
Time
Signature:
Printed Name:
Reason: Tree
2:3am
Relinquiship
Date and
Time
Signature:
18/19
Printed Name:
Reason:
3:45p
Relinquiship
Date and
Time
Signature
/15/21
Printed Name:
Reason:
1:30pm
Relinquish
Date and
Time
Signature:
3/31/21
Printed Name:
Reason:
335p
Relinquiship
Date and
Time
Signature:
Printed Name:
1/8/21
Reason:
2:33pm
Relinquish
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: 6
Barcode: E4229233
This form is incomplete without reference to the FD-1087.
SDNY_GM_02753574
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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Subject: RE: Maxwell drive delivery Monday 1/11
Date: Mon, 11 Jan 2021 19:36:57 +0000
Amazing, thank you!
From:
(USANYS) [Contractor]
Sent: Monday, January 11, 2021 11:38 AM
To:
Subject: RE: Maxwell drive delivery Monday 1/11
Hi
- I just handed off the drives (and password envelopes) to
The padlock drive without the cord was
ready this morning, so the correct drive is being delivered to MDC. Thanks so much!
From:
Sent: Friday, January 8, 2021 4:18 PM
To:
(USANYS) [Contractor]
Subject: RE: Maxwell drive delivery Monday 1/11
Thank you!
From:
(USANYS) [Contractor]
Sent: Friday, January 8, 2021 4:00 PM
To:
Cc:
Subject: RE: Maxwell drive delivery Monday 1/11
Absolutely!
I plan to be in the Office all day on Monday, and am happy to meet you or whomever at any time that
is convenient. I can be reached via mobile
or email. Once you, or whoever is delivering the items, lets me
know when would work to hand off the materials, I'll have all the items ready for you.
Thanks very much, all!
From:
Sent: Friday, January 8, 2021 2:22 PM
To:
(USANYS) [Contractor]
Cc:
Subject: FW: Maxwell drive delivery Monday 1/11
Hey
Would you please coordinate with
to get her (or whoever from the FBI is delivering the drives to the MDC) the two
drives for Maxwell, along with the password cover letter on Monday?
This delivery should include both the smaller drive you loaded today, and the bigger drive containing a full copy of all
discovery to date. (If the drive without a cord isn't ready by the time the FBI is picking it up, please just give them the one
with the cord).
Thanks so much,
EFTA00030868

=== Page 2 ===
From:
Sent: Friday, January 8, 2021 2:20 PM
To:
Cc:
Subject: Maxwell drive delivery Monday 1/11
Good afternoon,
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.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00030869


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=== Page 1 ===
From:
)"
To: Alex Conlon
Cc: Alexandra Elenowitz-Hess
Subject: RE: Scheduling a proffer
Date: Wed, 03 Apr 2019 23:14:25 +0000
Importance: Normal
Attachments: Standard_Proffer_Agreement.docx
Alex,
That makes sense, thanks. Our team is available to do Friday at 11:00, and we can host here at our offices,
,
if that still works for you both (and Jenna if she's able to join). On our end I expect it will be prosecutors
and me, and FBI Special Agent
Separately, as promised, attached is our form proffer agreement-when we meet with your client we'll add her name and
counsel information (and also change all the he / him to she/ her, obviously). Please let me know if any questions on that.
Thanks again, and looking forward to meeting in person on Friday.
Original Message
From: Alex Conlon
Sent: Wednesday, April 03, 2019 15:15
To:
Cc: Alexandra Elenowitz-Hess
Subject: RE: Scheduling a proffer
Hi,
Thanks so much for your email. Fully agree -- Jenna is the best. This is for an attorney proffer and if possible, Jenna will
probably join us.
I'm not sure whether
legally changed her name, or if I was just given her husband's last name
(
). I'll ask
her about it tonight. Also happy to ask her about phone numbers for anyone associated with Epstein.
Thanks,
Alex
Alex Conlon I Kaplan Hecker & Fink LLP
Original Message
From:
Sent: Wednesday, April 3, 2019 3:07 PM
EFTA00030151

=== Page 2 ===
To: Alex Conlon
Cc: Alexandra Elenowitz-Hess
Subject: Re: Scheduling a proffer
That's great, thanks - and
is fantastic, happy to have her involved. Just to clarify, and to help with our scheduling, I
take it we'll start with an attorney proffer? Or let me know if I misinterpreted and we're talking about a meeting with the
client. Either one totally fine but wanted to confirm- - let me know and I'll circle back in timing, and will also send you a
copy of our standard proffer agreement so you have it for your meeting with her this afternoon.
Two other quick things - first, we know your client as
but I think you mentioned her name has changed?
Could you please let me know her current last name?
And second, one very helpful thing for us would be to have any phone numbers she utilized with Epstein or anyone
associated with him at that time, and/or numbers for him or others she communicated with in connection with him.
Primarily, that could help to corroborate and confirm her recollections, and it's something we don't need to talk to her
directly about to get started working on. If you think it would concern her to provide that at this stage, no problem at all,
we can circle back to it later, but wanted to mention it.
thanks,
On Apr 3, 2019, at 14:30, Alex Conlon
<mailto:
wrote:
Hi there,
Sorry for the delay on our end. Robbie is going to be out of town, but Alex Hess (cc'd here) and I, and our colleague Jenna
Dabbs (former member of your office), would love to do a proffer with you tomorrow or Friday. We can do it by phone or
in person, but would prefer to do it in person.
On Thursday, we are available from 9 to 11AM or after 4PM. On Friday, we are available any time after 11AM.
What works best for you?
Thanks!
Alex
Alex Conlon Kaplan Hecker & Fink LLP
EFTA00030152

=== Page 3 ===
<mailto:
This email and its attachments may contain information that is confidential and/or protected from disclosure by the
attorney-client, work product or other applicable legal privilege. If you are not the intended recipient of the email, please
be aware that any unauthorized review, use, disclosure, dissemination, distribution, or copying of this communication, or
any of its contents, is strictly prohibited. If you have received this communication in error, please notify the sender
immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the
attorney-client, work product or other applicable legal privilege. If you are not the intended recipient of the email, please
be aware that any unauthorized review, use, disclosure, dissemination, distribution, or copying of this communication, or
any of its contents, is strictly prohibited. If you have received this communication in error, please notify the sender
immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00030153


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=== Page 1 ===
From:
To:
Subject: Final Voucher 10982122(1) has received final approval
Date: Mon, 24 Feb 2020 11:35:25 +0000
Importance: Normal
Dear
Final voucher 10982122(1) has received final approval.
Trip ID: 10982122
Voucher ID: 1
Voucher type: Final
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R20NYS13340 - Epstein investigation (2018R01618) - Witness Interviews
Destination: Stockholm, Sweden
Dates: 2020-02-03 - 2020-02-06
Current status: Voucher Awaiting Payment
Voucher total expenses: 2143.49
Estimated trip cost: 2954.54
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# V0008
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.
EFTA00031711


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=== Page 1 ===
From:
)"
To: Sigrid McCawley
Subject: RE: Victims' Concerns re: Epstein's release
Date: Sun, 14 Jul 2019 16:36:05 +0000
Importance: Normal
No apology necessary - I appreciate the notification.
thanks,
From: Sigrid McCawley
Sent: Sunday, July 14, 2019 10:49
To:
Subject: Victims' Concerns re: Epstein's release
- I know you are crazy busy so my apologies for the interruption and I realize that you noted this in your filing -
but the victims I represent asked that I communicate to you their significant concern for their own safety if Epstein is
released. Thank you for all you are doing.
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
(t)
(m)
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
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=== Page 1 ===
From:
"
)"
To:
)"
Subject: 2019-07-12, JE, response to bail release request, draft.docx
Date: Fri, 12 Jul 2019 07:04:54 +0000
Importance: Normal
Attachments: 2019-07-12,_JE_response_to_bail_release_request_draft.docx
just in case
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein
Date: Mon, 04 Nov 2019 15:19:33 +0000
8
From:
Sent: Monday, November 4, 2019 10:19 AM
To:
Cc:
Subject: RE: Epstein
Thanks, that would be great. Are you meeting at
office, or is he coming to 8?
From:
Sent: Monday, November 4, 2019 10:17 AM
To:
Cc:
Subject: Epstein
Hey
-- we're meeting with
at 4 pm if you are around.
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=== Page 1 ===
From:
To:
USANYS)"
Subject: Re: Epstein
Date: Sat, 13 Jul 2019 01:23:17 +0000
Importance: Normal
All very interesting - and true re the breadth of the statute. Maybe it's worth going to Odeon more often.
Have a nice weekend
Sent from my iPhone
> On Jul 12, 2019, at 9:10 PM,
(USANYS)
wrote:
>
> I just ran into Reid Weingarten at Odeon, who told me that he had just met with his client and he may reach out
to the team early next week to have an "interesting conversation". He added that he spoke to his son, who is an
in
who told him that the sex trafficking statute is quite broad. (That he could have figured out for
himself).
EFTA00031698


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 1 of 5
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 13, 2020
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in opposition to the defendant's letter of
August 10, 2020 (the "Defense Letter" or "Def. Ltr."), requesting that the Court order the
Government to disclose the names of certain Government witnesses 11 months prior to trial, and
requesting that the Court intervene in the protocols and individualized inmate determinations of
the Bureau of Prisons. Both applications should be denied.
A. The Defendant's Demand That the Government Name Certain Trial Witnesses
For the third time in as many weeks, the defendant and her counsel have applied to the
Court for relief that is premature, meritless, or both. See Order dated July 23, 2020 (Dkt. 28)
(denying the defendant's request that the Court enter an order prohibiting the Government and
attorneys for non-parties from making extrajudicial statements "concerning this case"); Order
dated July 30, 2020 (Dkt. 37) (denying the defendant's application for a protective order that would
allow the defense to publicly name and identify victims). In the defendant's most recent
application, she asks the Court to order that the Government disclose a partial witness list, in the
form of identifying certain victims referenced in the Superseding Indictment (the "Indictment"),
fully 11 months prior to trial. This request is at best premature given that the production of
discovery, on the schedule agreed to by the defendant, has just begun. Moreover, the parties have
had no discussions about-let alone asked the Court to set-a schedule for pretrial disclosures,
including for witness lists and 3500 material.
In the first instance, the defendant complains about the status of discovery production,
arguing that "almost six weeks since" the arrest of the defendant, the Government is "just now
beginning to produce Rule 16 discovery, despite confirming to the Court that discovery would
begin as soon as the Court entered a protective order." Def. Ltr. at 2. The suggestion that the
Government somehow delayed that initial production is nonsense. As the Court is aware, the
EFTA00029966

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 2 of 5
Honorable Alison J. Nathan
August 13, 2020
Page 2
protective order was docketed on Friday, July 31, 2020¹-the timing of which was principally the
result of the defendant's own refusal to agree to the terms of the proposed protective order. The
Government then promptly produced an initial discovery production totaling more than 12,000
pages the following Wednesday, August 5, 2020. Additionally, the Government continues to
produce discovery and earlier today made a second production, as the Government advised defense
counsel last week it intended to do, totaling more than 150,000 pages, principally consisting of
financial records.² Although the Government expects to continue to produce a large amount of
electronic discovery, the two productions already made constitute the vast majority of initial
discovery, including search warrant applications and subpoena returns, which the Government has
now produced more than a week in advance of its deadline of August 21, 2020, and
approximately 11 months prior to trial.
In sum, the Government has acted expeditiously in meeting its initial discovery obligations,
providing more than 165,000 pages of discovery materials in less than two weeks following the
entry of the protective order-all of which was accompanied by detailed indices describing the
general topics and sources of the materials.
Against this backdrop, the Defense Letter claims that over the course of just five days,
defense counsel determined, having "expeditiously reviewed [the discovery] for high level
content," Def. Ltr. at 2, that they cannot possibly investigate the charges against their client based
on the materials provided thus far, and asking the Court to order the Government to provide the
defendant with a partial witness list. That request should be denied.
Tellingly, the defendant cites no authority that requires the relief requested at this stage in
the litigation-i.e., prior to the completion of discovery and approximately 11 months before
trial-nor is the Government aware of any. For example, in the lead case cited by defense counsel,
United States V. Cannone, 528 F.2d 296, 301 (2d Cir. 1975), although the opinion acknowledged
the ability of district courts to compel disclosure of the identity of government witnesses, the
Second Circuit reversed for abuse of discretion the district court's decision to do so in that case
because the defendant there, as here, had made "only an abstract, conclusory claim that such
disclosure was necessary to its proper preparation for trial." Id. at 301-02. In United States V.
Rueb, 00 Cr. 091 (RWS), 2001 WL 96177, at *8 (S.D.N.Y. Feb. 5, 2001), while the Court ordered
the Government to provide the defendant with its witness list, it did so one month before trial,
following the completion of discovery production and in the context of pretrial motions. Those
circumstances plainly are not present here. Finally, in United States V. Warme, a Western District
of New York opinion from 2009 that has never been cited by another court, although the Court
1 The Defense Letter states that the protective order was "entered" by the Court on July 30, 2020.
While that is the date the protective order was signed by the Court, it was posted to the docket on
July 31, 2020.
2 The Government's most recent discovery transmittal letter also included the months and years of
birth of the three victims identified in the Indictment, to enable the defendant to evaluate whether
she will make any motions or legal arguments-more than four months in advance of the deadline
for any such motion-relating to the ages of the victims.
EFTA00029967

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 3 of 5
Honorable Alison J. Nathan
August 13, 2020
Page 3
ordered disclosure of a certain victim identity shortly after the indictment, the Court noted that the
Government had already confirmed to the defendant the identities of three of the four relevant
victims, and that a fourth victim, whose identity was at issue, was the subject of a charge that failed
to identify the date of her alleged rape or any prior encounters between the victim and the
defendant. 2009 WL 427111, at *2. None of those facts are present here-by contrast, here, the
Indictment particularly describes relevant time periods and events, including referring to the
defendant's conversations with victims, interactions with victims, and specific relevant locations.
To the extent the defendant is arguing that she cannot identify the nature of the charges
against her, the proper vehicle for such an argument is a motion for a bill of particulars. Any such
motion can be made in December with all other motions and following the completion of
discovery. While the Government anticipates opposing such a motion as baseless on the facts of
this case, the Government respectfully submits that in any event such a motion could not be
meaningfully evaluated at this stage, prior to the completion of discovery. See United States V.
Mahabub, 13 Cr. 908 (AJN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug. 26, 2014) (denying a
motion for a bill of particulars that sought, among other things, the "alleged victim and noting that
"[a] bill of particulars is not required unless the charges of the indictment are so general that they
do not advise the defendant of the specific acts of which he is accused. The government can also
discharge its obligation to disclose this information by other means, such as by presenting evidence
in discovery.
A bill of particulars is not meant to provide the details of the government's
evidence, or to be used as an investigative tool.") (emphasis added, quotations and citations
omitted); see also United States V. Thompson, 13 Cr. 378 (AJN), 2013 WL 6246489, at *7
(S.D.N.Y. Dec. 3, 2013) (denying a motion for a bill of particulars and noting that such motions
are not "a general investigative tool, a discovery device or a means to compel the government to
disclose evidence or witnesses to be offered prior to trial") (emphasis added) (quotations and
citation omitted); cf. United States V. Sindone, 01 Cr. 517 (MBM), 2002 WL 48604, at *2
(S.D.N.Y. Jan. 14, 2002) (denying a motion for a bill of particulars to identify "the unnamed
alleged victim(s)" but instructing the government to disclose the name of any victim it did not
intend to call as a witness at trial by 14 days prior to the start of trial).
Alternatively, to the extent defense counsel is unable to assess or comprehend the discovery
produced by the Government, the Government is more than willing to discuss with the defense
3 Defense counsel's invocation of the protective order in support of its argument, Def. Ltr. at 1, 3,
should be of little comfort. The Government is deeply concerned by the recent actions of the
defendant's counsel who represent her in both this criminal matter as well as in certain civil
matters, and who in a recent public filing in a civil case referred to their receipt of sealed materials
in discovery in this case. In particular, the defendant's counsel publicly claimed in a civil filing
that they purportedly had received "critical new information" from the criminal case that it could
not disclose "because it is subject to a protective order in the Criminal Action," and further noting
publicly a desire to seek modification of the protective order in this case to use such materials in
the civil case, which the protective order expressly precludes. See Giuffre V. Ghislaine Maxwell,
No. 15 Civ. 7433 (LAP) (Dkt. 1100). Moreover, even assuming the defendant intends to
scrupulously adhere to the terms of the protective order, that would not change the relevant legal
standards, which weigh heavily against granting the requested relief.
EFTA00029968

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 4 of 5
Honorable Alison J. Nathan
August 13, 2020
Page 4
any such issues as the discovery process continues. To date, the defendant has yet to ask the
Government a single substantive question about the discovery. The Government is also prepared
to engage in good faith discussions with the defense about an appropriate schedule for disclosure
of 3500 material, exhibit lists, and witness lists, all of which the Government expects to produce
reasonably in advance of the trial date in July 2021 to permit the defense to investigate witnesses.
But particularly given the nature of the charges, the Government's strong desire to protect the
privacy of the alleged victims, and the lack of any legal precedent for the defendant's request, the
Government respectfully submits that at the present time-eleven months prior to trial, nearly
three months prior to the discovery deadline, and more than four months prior to the pretrial
motions deadline-there is no basis for the defendant to demand the Government disclose the
identity of its witnesses.
B. The Defendant's Request that the Court Dictate the Conditions of Her Confinement
The defendant's requests with respect to the conditions of her confinement at the
Metropolitan Detention Center ("MDC") are similarly premature and unavailing, and her request
that the Court dictate the terms of her confinement to the Bureau of Prisons ("BOP") should also
be denied.4
As an initial matter, the defendant's argument that she is being treated "worse" than other
inmates is incorrect. There is no merit to her complaints about being monitored by staff, as it is
entirely appropriate for BOP to carefully monitor any inmate, particularly a new inmate who has
never before been incarcerated and who faces the strong likelihood of serving many years in prison.
Additionally, like all inmates, the defendant may be subject to observation or searches of her
person or space as appropriate.⁵ It is otherwise entirely unclear what specific "privileges given to
other pretrial detainees" the defendant believes she is being denied.
More generally, the defendant, like all pretrial inmates, is subject to an individualized
assessment by the BOP with respect to his or her placement in a facility. Here, for reasons
including safety, security, and the orderly functioning of the facility, BOP has made the
determination that, at present, the defendant should not be fully integrated into the dorm-style
accommodations of the general population. The Government understands from BOP that it will
4 Once again, defense counsel has rushed to seek Court intervention on issues they have made little
or no meaningful effort to address with the Government or, in this case, the BOP. The Government
learned of the defendant's specific objections to her conditions of incarceration for the first time
from the Defense Letter, and has since conferred with BOP to understand and to address the issues
as appropriate. Moreover, as noted below, the defendant filed the instant challenge to the BOP's
plan to permit her time to review discovery before the BOP had a chance to implement (and
ultimately modify) that plan.
5 Defense counsel claims that prison staff "constantly observe" the defendant "including her phone
conversations with defense counsel." This is misleading. As 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. Among other reasons, this is so MDC staff can ensure that inmates do not complete
calls with their counsel and then call other individuals on a non-recorded line.
EFTA00029969

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 5 of 5
Honorable Alison J. Nathan
August 13, 2020
Page 5
continue to evaluate where the defendant should be housed within the facility and that the
defendant will be placed into the general population if and when BOP is assured that such
placement would not pose a threat to the orderly operation of the institution. The defendant
identifies no basis for the Court to disturb that determination by the BOP, particularly given that,
as detailed below, her housing assignment will not negatively affect her ability to review discovery
in this case.
Regarding the defendant's request in connection with access to discovery, the Government
understands from BOP that the defendant had not even yet received her copy of the Government's
first discovery production at the time the Defense Letter was filed-she received the materials on
Tuesday, August 11. While it is correct that BOP's initial plan was to provide three hours per day
of access to the discovery-the same access that is granted to every other pretrial inmate, including
those with trial dates scheduled for far earlier than July 2021-as of earlier this week, and given
the volume of expected discovery, BOP informed the defendant that she will have the opportunity
to access to her discovery from 7:00 a.m. to 8:00 p.m. every day of the week. Although this
arrangement will be subject to continued evaluation on an ongoing and individualized basis, and
is subject to ordinary considerations of prison operations, BOP intends to provide that access on
an ongoing basis to the extent it remains reasonably practicable to do so. Accordingly, this
application should be denied as moot.
C. Conclusion
For the reasons set forth above, the defendants' requests, as set forth in the Defense Letter,
should be denied.
Respectfully submitted,
AUDREY STRAUSS
A Acting United States Attorney
By:
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2415
Cc:
All counsel of record, via ECF
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=== Page 1 ===
U.S. V. Ghislaine Maxwell
MAXWELL HAS BEEN CHARGED WITH FACILITATING
THE SEXUAL ABUSE OF UNDERAGED GIRLS FOR
JEFFREY EPSTEIN.
THE CHARGED CONDUCT OCCURRED IN NEW YORK CITY,
PALM BEACH, FLORIDA, SANTA FE, NEW MEXICO, AND
LONDON, ENGLAND.
IF YOU RECOGNIZE EITHER OF THESE PERSONS AND
FEEL YOU MAY BE A VICTIM, PLEASE CALL THE
FOLLOWING NUMBER:
1-800-CALL FBI
DEPARTMENT SISTETIA OF
EFTA00030009

=== Page 2 ===
U.S. V. Ghislaine Maxwell
Properties Owned by Epstein Where Alleged
Grooming and/or Abuse of Minor Victims Occurred:
New York, New York
Palm Beach, Florida
Santa Fe, New Mexico
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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: prosecution teams
Date: Wed, 03 Feb 2021 21:50:20 +0000
Attachments: 2020.10.07,_Maxwell,_Prosecution_Teams_Letter.pdf
Hi
I've attached a copy of the letter you were looking for. Hope this helps.
Best,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00029893


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=== Page 1 ===
Citrix Attachments
Expires February 17, 2020
DB-SDNY-PROD007.zip
2.3 GB
Download Attachments
Thomas Moyer uses Citrix Files to share documents securely.
EFTA00029727


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=== Page 1 ===
From:
To:
Cc:
Subject: Draft Opposition to Maxwell Third Bail Motion
Date: Tue, 09 Mar 2021 01:15:28 +0000
Attachments: 2021-03-09_GM_Government_Third_Bail_Opposition_v7.docx
Attached for review please find a draf
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
EFTA00029842


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=== Page 1 ===
Event: Accepted: Epstein/Maxwell FOIA
Start Date: 2021-03-10 22:00:00 +0000
End Date: 2021-03-10 22:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2021-03-10 20:51:52 +0000
Date Modified: 2021-03-10 20:51:52 +0000
Priority: 5
DTSTAMP: 2021-03-10 20:20:27 +0000
Attendee:
EFTA00030075


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=== Page 1 ===
Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
IN THE MATTER OF AN APPLICATION
TO BRING PERSONAL ELECTRONIC DEVICE(S) OR
GENERAL PURPOSE COMPUTING DEVICE(S) INTO
THE COURTHOUSES OF THE
SOUTHERN DISTRICT OF NEW YORK FOR
USE IN A PROCEEDING OR TRIAL
x
The following Order is subject to the definitions, obligations and restrictions imposed pursuant to
Standing Order M10-468, as Revised. Upon submission of written application to this Court, it is hereby
ORDERED that the following attorney(s) are authorized to bring the Personal Electronic Device(s) and/
or the General Purpose Computing Device(s) (collectively, "Devices") listed below into the Courthouse for use in
a proceeding or trial in the action captioned:
United States VS. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
.
ORDERED that for the device(s) checked below SDNY Courtroom WI-FI access shall be provided.
November 29, 2021-January 15, 2022
The date(s) for which such authorization is provided is (are)
Attorney(s)
E-mail
Device(s)
Courtroom
WiFi
Granted
HP laptop
318
X
HP laptop
318
X
HP laptop
318
X
(Attach Extra Sheet If Needed)
The attorney(s) identified in this Order must present a copy of this Order when entering the
Courthouse. Bringing any authorized Device(s) into the Courthouse or its Environs constitutes a certification by
the attorney that he or she will comply in all respects with the restrictions and obligations set forth in Standing
Order M10-468, as Revised.
so ORDERED:
November 28, 2021
Dated:
Alim D.Nitto
United States Judge
EFTA00031254

=== Page 2 ===
Page 2 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
IN THE MATTER OF AN APPLICATION
TO BRING PERSONAL ELECTRONIC DEVICE(S) OR
GENERAL PURPOSE COMPUTING DEVICE(S) INTO
THE COURTHOUSES OF THE
SOUTHERN DISTRICT OF NEW YORK FOR
USE IN A PROCEEDING OR TRIAL
x
The following Order is subject to the definitions, obligations and restrictions imposed pursuant to
Standing Order M10-468, as Revised. Upon submission of written application to this Court, it is hereby
ORDERED that the following attorney(s) are authorized to bring the Personal Electronic Device(s) and/
or the General Purpose Computing Device(s) (collectively, "Devices") listed below into the Courthouse for use in
a proceeding or trial in the action captioned:
United States VS. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
-
ORDERED that for the device(s) checked below SDNY Courtroom WI-FI access shall be provided.
November 29, 2021-January 15, 2022
The date(s) for which such authorization is provided is (are)
Attorney(s)
E-mail
Device(s)
Courtroom
WiFi
Granted
HP laptop
318
X
HP laptop
318
X
(Attach Extra Sheet If Needed)
The attorney(s) identified in this Order must present a copy of this Order when entering the
Courthouse. Bringing any authorized Device(s) into the Courthouse or its Environs constitutes a certification by
the attorney that he or she will comply in all respects with the restrictions and obligations set forth in Standing
Order M10-468, as Revised.
so ORDERED:
Dated:
November 28, 2021
Alim D.Nitto
United States Judge
EFTA00031255


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=== Page 1 ===
United States District Court
SOUTHERN DISTRICT OF FLORIDA
TO:
SUBPOENA TO TESTIFY
BEFORE GRAND JURY
FGJ 07-103(WPB)-Tues./No. OLY-35
SUBPOENA FOR:
PERSON
X
X
DOCUMENTS OR OBJECT[S]
YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
Court at the place, date and time specified below.
PLACE:
ROOM:
United States District Courthouse
Grand Jury Room
701 Clematis Street
West Palm Beach, Florida 33401
DATE AND TIME:
March 13, 2007
1:00 pm*
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
All documents referring or relating to Jeffrey Epstein, including but not limited to billing statements,
record of payments, appointment books, treatment notes, and correspondence.
*Please coordinate your compliance with this subpoena and confirm the date and time, and location of
your appearance with Special Agent
I, Federal Bureau of Investigation, Telephone:
This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
on behalf of the court.
CLERK
DISTRICT STATES COURT
DATE:
March 2, 2007
(BY) DEPUTY CLERK
DISTRICT OF FROM
This subpoena is issued upon application
Name, Address and Phone Number of Assistant U.S. Attorney
of the United States of America
Assistant U.S. Attorney
500 So. Australian Avenue, Suite 400
West Palm Beach, FL 33401-6235
Tel:
Fax:
*If not applicable, enter "none."
To be used in lieu of AOI 10
FORM ORD-227
JAN.86
MM15-GRAND JURY SUBPOENAS-000033
EFTA00030866

=== Page 2 ===
RETURN OF SERVICE
RECEIVED
DATE
PLACE
BY SERVER
SERVED
DATE
PLACE
SERVED ON (NAME)
SERVED BY
TITLE
STATEMENT OF SERVICE FEES
TRAVEL
SERVICES
TOTAL
DECLARATION OF SERVICE2
I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Return of Service and
Statement of Service Fees is true and correct.
Executed on
DATE
Signature of Server
Address of Server
ADDITIONAL INFORMATION
1.As to who may serve a subpoena and the manner of its service see Rule 17(d). Federal Rules of Criminal Procedure, or
Rule 45(c), Federal Rules of Civil Procedure.
2. "Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United
States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal
Procedure) or on behalf of certain indigent parties and criminal defendants who are unable to pay such costs (28 USC
1825, Rule 17(b) Federal Rules of Criminal Procedure)"
MM15-GRAND JURY SUBPOENAS-000034
EFTA00030867


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=== Page 1 ===
From:
To:
Cc:
Subject: Documents for tomorrow
Date: Wed, 28 Jul 2021 20:56:59 +0000
Attachments: SDNY_GM_02753552-02753555.pdf; SDNY_GM_02753556-02753559.pdf;
SDNY_GM_02753560-02753563.pdf; SDNY_GM_02753564-02753567.pdf;
SDNY_GM_02753568-02753570.pdf; SDNY_GM_02753571-02753574.pdf;
SDNY_GM_02753575-02753577.pdf; SDNY_GM_02753578-02753581.pdf;
SDNY_GM_02753582-02753584.pdf; SDNY_GM_02753585-02753588.pdf; 2006-09-
06_DESCRIPTION_OF_PROPERTY_LOG_REGARDING_EPSTEIN_JEFFREY
2007-08-
10_INVESTIGATIVE_CASE MANAGEMENT_COLLECTED_ITEMS_FOR_A_CASE_0
8_10_2007.pdf; 2006-11-15,
,_interview_302.pdf; 2006-11-
15,
interview_notes.pdf
Mandy,
As discussed, here are the documents to be printed for our meeting with
tomorrow. Give me a call if you have any
questions.
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:
EFTA00029894


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=== Page 1 ===
From:
"
)"
To: "Miller, Michael"
)"
,
)"
Cc:
"Weingarten, Reid"
"Lucas, Morgan"
,
"Scavelli, Michael"
Subject: RE: Epstein
Date: Wed, 21 Aug 2019 00:30:35 +0000
Received, thank you.
From: Miller, Michael
>
Sent: Tuesday, August 20, 2019 16:38
To:
)
is
)
>;
Cc:
;
Weingarten, Reid
>; ; Lucas, Morgan
>; Scavelli,
Michael
Subject: Epstein
Dear
Please see the attached that we filed a few minutes ago.
Mike
Michael C. Miller
Partner
www.steptoe.com/mmiller
Steptoe
direct
Steptoe & Johnson LLP
fax
1114 Avenue of the Americas
cell
New York, NY 10036
www.steptoe.com
This message and any attached documents contain information from the law firm Steptoe & Johnson LLP that may be confidential and/or privileged. If you
are not the intended recipient, please do not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the
sender immediately by reply e-mail and then delete this message.
EFTA00029720


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=== Page 1 ===
Event: Accepted: Meet on Epstein
Start Date: 2019-09-17 19:30:00 +0000
End Date: 2019-09-17 20:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-09-17 21:38:39 +0000
Date Modified: 2019-09-17 21:38:39 +0000
Priority: 5
DTSTAMP: 2019-09-17 14:01:48 +0000
Attendee:
(USANYS)
EFTA00031632


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Subject: RE: GM - Letter re Warden
Date: Tue, 01 Dec 2020 22:41:13 +0000
Attachments: 2020-12-01_GM_letter_regarding_defense_request_re_MDC_warden_vfinal.docx
From:
)
Sent: Tuesday, December 01, 2020 1:38 PM
To:
>;
(USANYS)
Subject: RE: GM - Letter re Warden
Agree with your proposal,
Otherwise nothing from me. Thanks very much.
From:
Sent: Tuesday, December 1, 2020 1:27 PM
To:
(USANYS)
Cc:
Subject: Re: GM - Letter re Warden
Sure, no problem.
,
any comments?
Sent from my iPhone
On Dec 1, 2020, at 1:20 PM,
(USANYS)
wrote:
If you guys want to make any edits you like and then send to the chiefs, that's fine with me. I'm not sure when I'll be
done here
On Dec 1, 2020, at 12:48 PM,
wrote:
Hi
Thanks so much for drafting - I think my only suggestion would be to tweak the language a little bit to make it more
obvious that the language from Bobbi is a direct quote from them/ that they wrote it (and that we aren't just
characterizing their view).
Thanks!
From:
(USANYS)
Sent: Tuesday, December 1, 2020 12:45 PM
To:
is
Subject: GM - Letter re Warden
Hi - I didn't have as much time to work on this as I had hoped before I have to leave the office, but wanted to get the
draft circulating. Sorry about that. Please feel free to edit as much as you like. Saved in the correspondence folder,
and attached.
EFTA00030413

=== Page 2 ===
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:
EFTA00030414


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
(USANYS)
[Contractor]"
Cc:
)"
(USANYS)"
Subject: RE: Discovery Requests
Date: Wed, 27 Jan 2021 14:36:57 +0000
Inline-Images: image001.jpg; image002.jpg
We have all of the materials just about prepared to go out.
is doing a last check of the PROD011 that
exported
to the shared and then everything will be all set.
From:
Sent: Thursday, January 21, 2021 9:40 PM
To:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: Discovery Requests
Thanks so much,
and my apologies for the delayed response. I've been traveling for work and fell behind on emails
as a result. I will email defense counsel to ask them to send a link where they'd like the materials uploaded.
From:
(USANYS) [Contractor]
Sent: Wednesday, January 20, 2021 10:29 AM
To:
is
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: Discovery Requests
I can upload these files for defense counsel today and will be able to load a disc for Maxwell when I'm back at the office
tomorrow. I recall that the last time we produced to defense in this manner they preferred to use their FTP site. Would
you mind asking them to send over a link to where they'd like the materials uploaded? Thanks!
From:
Sent: Tuesday, January 19, 2021 8:27 PM
To:
(USANYS) [Contractor]
i
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: Discovery Requests
Thanks so much! Once you have the renumbered files, would you please prepare them for production to the defense?
Ideally, they could go on a disc for Maxwell and USAfx for defense counsel, but let me know if it's too large.
From:
(USANYS) [Contractor]
Sent: Tuesday, January 19, 2021 1:45 PM
To:
is
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: Discovery Requests
EFTA00030861

=== Page 2 ===
The materials from 6a have been re-stamped with the range: SDNY_GM_00327069.001 - SDNY_GM_00327069.794. They
are currently being loaded here: \Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Discovery\GM\13
Re-Bates
Once we have 6b and 6c sorted out we will let you know.
From:
(USANYS) [Contractor]
Sent: Tuesday, January 19, 2021 10:21 AM
To:
is
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: RE: Discovery Requests
Hey
We will take care of 6a today.
6b and 6c will require us to check the drives that we have at the office. Neither
nor I will be at the office today or
tomorrow. I plan on going in on Thursday and will be able to check on those issues that defense points out. Not to jump to
conclusions but I believe that PAE's .DAT files typically include only the beginning number in a range which would give the
appearance of gaps in the production. As such there is a decent chance that defense is incorrect about the gaps as they
list them although we will not know until we actually check the productions.
Thanks,
From:
Sent: Friday, January 15, 2021 9:02 PM
To:
(USANYS) [Contractor]
i
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: FW: Discovery Requests
Hi
and
Would you please take a look at request number 6 below and figure out how to address it? I believe you may need to
work with
for some of these issues.
Thanks,
From: Christian Everdell
Sent: Thursday, January 7, 2021 4:13 PM
To:
)
is
)
is
(USANYS)
Cc: Mark S. Cohen
>; Bobbi Sternheim
>; Jeff Pagliuca
'Laura Menninger'
Subject: Discovery Requests
and
-
We write to raise a number of discovery issues. Please let us know your position on these issues at your earliest
convenience.
EFTA00030862

=== Page 3 ===
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.
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
EFTA00030863

=== Page 4 ===
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,
Christian R Everdell
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.
EFTA00030864


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 10892303-1(1) has received final approval
Date: Tue, 31 Dec 2019 15:02:41 +0000
Importance: Normal
Dear
Final voucher 10892303-1(1) has received final approval.
Trip ID: 10892303-1
Voucher ID: 1
Voucher type: Final
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R20NYS13197 - U.S. V. Epstein - Witness Interview (California)
Destination: Santa Monica, CA, United States
Dates: 2019-12-15 - 2019-12-18
Current status: Voucher Awaiting Payment
Voucher total expenses: 2227.40
Estimated trip cost: 2440.58
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
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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.
EFTA00031716


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=== Page 1 ===
From:
)"
To:
(OPR)"
Cc:
DPR)"
Subject: RE: RE: SDNY investigation
Date: Wed, 10 Jul 2019 14:32:24 +0000
Importance: Normal
Just called but missed you - I'm at my desk if you're able to chat,
From:
)
Sent: Wednesday, July 10, 2019 10:29
To
(OPR)
Co
OPR)
Subject: RE: RE: SDNY investigation
With apologies for the belated response, that works for me if it's still okay for you - l'Il try you in a couple minutes
From:
(OPR)
Sent: Wednesday, July 10, 2019 07:53
To:
Cc:
(OPR)
Subject: RE: RE: SDNY investigation
How about 10:30?
From:
)
Sent: Tuesday, July 09, 2019 10:13 PM
To
(OPR)
(OPR)
Subject: RE: RE: SDNY investigation
,
Been a little while since we've been in touch - I hope you're well. I was wondering if it would be possible to speak briefly
tomorrow? I'm available anytime until 4:00 p.m., and would be happy to chat in the morning if that's convenient, though
I understand it's short notice. Please let me know what might work? And thank you very much as always.
From:
I
OPR)
Sent: Tuesday, February 19, 2019 12:10
To:
)
Cc:
(OPR)
Subject: RE: RE: SDNY investigation
9:30 tomorrow morning? We'll call you then at
unless you provide another #.
Many thanks
EFTA00030290

=== Page 2 ===
From:
Sent: Tuesday, February 19, 2019 11:59 AM
To:
(OPR)
Cc:
OPR)
Subject: RE: RE: SDNY investigation
,
Unfortunately I'm in the grand jury and meetings most of the afternoon, but I'll be free (and in the office) anytime this
evening starting at 5:00, or could talk anytime tomorrow before 2:00. What works best for you?
thanks,
Assistant U.S. Attorney
Southern District of New York
From:
(OPR)
Sent: Tuesday, February 19, 2019 11:35
To:
)
Cc:
(OPR)
Subject: RE: RE: SDNY investigation
- My cocounsel Steve Fenn and I would like to speak with you today, if possible. Is there a good time for us to phone
you?
Regards,
From:
Sent: Tuesday, February 12, 2019 5:28 PM
To
(OPR)
(OPR)
Subject: RE: SDNY investigation
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
nd 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
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
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From:
To:
Cc:
Subject: RE: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB)
Date: Tue, 06 Aug 2019 20:43:16 +0000
Inline-Images: image001.jpg
Thanks, that's great-I'll send you calendar invitations when we nail down timing.
From
Sent: Tuesday, August 6, 2019 4:40 PM
To:
Cc:
Subject: Re: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB)
I'm good for both days as well.
On Aug 6, 2019 4:39 PM, "
wrote:
Those dates work for me. The 26th im wide open and the 27th preferable late afternoon would be best for
me.
From:
Sent: Tuesday, August 6, 2019 4:21:29 PM
To:
Cc:
Subject: RE: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB)
Just following up on this-do these dates work for you?
From
Sent: Monday, August 5, 2019 7:03 PM
To:
Cc:
Subject: FW: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB)
Team,
EFTA00030537

=== Page 2 ===
Are you available for interviews on 8/26 and 8/27? Regarding the photos (attached), we can discuss next time we talk.
Thanks.
From: Teri Gibbs
Sent: Monday, August 5, 2019 6:52 PM
To:
Cc:
Subject: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB)
Hi Ms. Moe:
Thank you for taking the time to speak with our firm on Friday, August 2, 2019, regarding our clients,
and
who believe they were assaulted by Epstein in or around June 2004.
We have confirmed our clients' availability for interviews with your office. Ms.
is available for an
in-person interview on August 26, 2019, or August 27, 2019. Ms.
who is located
is available
,
for an interview via video conference, preferably the week of August 26th. Please confirm whether your office
is available to meet with Ms.
on those dates and whether we can arrange a video conference for Ms.
Additionally, as discussed in our call, we have attached two PDF files for your review which contain pictures
of Ms.
and Ms.
from 2004. If possible, please confirm whether our clients are in any of the
photographs seized from Epstein's home.
Thank you. We look forward to hearing from you soon.
Best regards,
Teri Gibbs
Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this e-mail in
error, any review, use, dissemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e-mail and please
delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation.
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communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or
(ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein.
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=== Page 1 ===
From
To
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:47:03 +0000
Attachments: U.S._v._Ghislaine_Maxwell_Indictment.pdf Ghislaine_Maxwell_Indictment_PR.pdf
Inline-Images: image001.png
Great stuff, good luck!!
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 SOFFICE 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
EFTA00031873

=== 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.
EFTA00031874

=== 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.
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From:
To:
Subject: RE: Subpoena Log and Subpoena Records
Date: Thu, 31 Oct 2019 15:54:07 +0000
You have co-owner status now. Congratulations!
From:
Sent: Thursday, October 31, 2019 10:36 AM
To:
Subject: RE: Subpoena Log and Subpoena Records
Can you either change my folder settings from editor to co-owner so that I can add her? Or just add her directly?
Whatever is easiest. I will go ahead and re-upload all the subpoenas and returns since there appear to be no files in the
folder for either.
From:
Sent: Thursday, October 31, 2019 1:47 AM
To:
Subject: RE: Subpoena Log and Subpoena Records
Yes, I think she needs two things:
1. Access to USAFX. I just added you to the folder.
2. All the subpoena returns re-loaded since they've expired since I last uploaded them.
From:
Sent: Tuesday, October 29, 2019 5:23 PM
To:
Subject: FW: Subpoena Log and Subpoena Records
Is there a folder/is what she is talking about on there?
From:
Sent: Tuesday, October 29, 2019 3:04 PM
To:
Subject: FW: Subpoena Log and Subpoena Records
Hi
I was just going through all of my emails for the Epstein investigation to make sure everything was in the case file -
realized that I never asked to get access to USAFX in order to see all the subpoenas and returns Can you give me access
and is everything still posted on that site?
Thanks so much -
Special Agent
FBI New York Field Office
EFTA00031401

=== Page 2 ===
Violent Crimes Task Force
From:
Sent: Saturday, August 17, 2019 4:27 PM
To:
Cc:
Subject: Subpoena Log and Subpoena Records
Hi,
Attached is a log of all the subpoenas we've served and what has come back. I've posted the actual subpoenas and
returns on the USAO's FTP site, called USAFX. Carpenter and Gildea already have access to USAFX. For everyone else,
you'll need an account which is very easy. Will can help you get an account - I think he'll just need your cellphone
number.
Let us know if you have any questions.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
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=== Page 1 ===
From: Sigrid McCawley
To:
)"
Subject: RE: Epstein
Date: Sun, 07 Jul 2019 02:44:18 +0000
Great work - thanks!
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Saturday, July 06, 2019 10:40 PM
To: Sigrid McCawley
Subject: RE: Epstein
Sigrid,
Thanks very much for being in touch, and for the kind words - this hit the news much faster than we anticipated, so
unfortunately we weren't able to directly reach all the folks we wanted to before the reports came out, but we truly and
greatly appreciate your help and the help of your clients throughout our investigation. And we expect that the
investigation will expand significantly in the coming weeks, so I'm sure we'll be in touch.
thanks again,
From: Sigrid McCawley
Sent: Saturday, July 06, 2019 22:30
To:
Subject: Epstein
Thank you for having the courage to see justice. I spoke to
moments ago and she was in tears hearing that
Epstein has finally been arrested for his years of criminal abuse.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
EFTA00030241

=== Page 2 ===
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
EFTA00030242


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
)"
)"
)"
Subject: RE: GM Letter Due Today
Date: Thu, 28 Jan 2021 23:16:56 +0000
Attachments: 2021-01-
28_GM_letter_to_Judge_Nathan_re_defense_proposed_redactions_in_pretrial_motions_v1.r
d.ebd.docx
Some small stuff in track. Thanks
From:
(USANYS)
Sent: Thursday, January 28, 2021 5:45 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
>;
)
Subject: GM Letter Due Today
Apologies for getting this to you at this hour, but we owe the Court a letter today regarding the defendant's proposed
redactions to the pre-trial motions. Attached is a draft letter and the exhibit for your review.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
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=== Page 1 ===
Citrix Attachments
Expires January 15, 2020
DB-SDNY-Prod003.zip
159.5 MB
Download Attachments
Thomas Moyer uses Citrix Files to share documents securely.
EFTA00030620


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From:
)"
To: Raymond L Colon
Subject: RE: Congratulations
Date: Tue, 09 Jul 2019 16:55:19 +0000
Importance: Normal
Thank you -- I appreciate it.
Original Message
From: Raymond L Colon
Sent: Monday, July 08, 2019 21:25
To:
)
Subject: Congratulations
Job well done. Congratulations on the Epstein case.
Sent from my iPhone
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=== Page 1 ===
U.S. Department of Justice
Real Property Net Equity Worksheet
United States Marshals Service
For All Property Types
PART I: ASSET INFORMATION
1. CATS Asset ID:
2. USMS Pre-Seizure No.:
3. Court Case No.:
4. District:
USMS-D54-00000307
NYS
5. Full Address:
6. Year Built:
9 East 71st Street, New York, NY 10021, New York County
1910
7. Vested Owner(s) per Lien Report:
8. Owner(s) as Identified by IA/USAO:
Maple, Inc., a U.S. Virginia Islands Corporation
MAPLE INC.
9. Type of Property:
10. Stage:
11. Forfeiture Date:
Single Family Residence
Pre-Seizure
12. APN or Owner/VIN (if SFD Manufactured Home)
13. GPS Coordinates:
14. Occupancy:
BLOCK: 1386 LOT: 10
40.771573, -73.966461
Unknown
15. Additional Information:
Please see condition report for property details.
a. Sold at/Pending Tax Sale Date:
b. Realtor Name: (if on market)
C. Foreclosure Proceeding Bank & Date:
-
PART II: VALUATION INFORMATION
16. Valuation Type:
Valuation Date:
Valuation Amount:
Broker Price Opinion (Desktop)
2019-08-22
$
81,000,000.00
PART III: MORTGAGE LIENS/JUDGEMENT EXPENSES
17. First Mortgage Lienholder:
Recorded Date:
Lien Amount:
18. Base Year Real Estate Taxes:
Taxes Paid:
Prior Years' Delinquent Taxes
$
345,286.05
$
345,286.05
19. Supplemental Liens/ Judgement Expenses: Please see attached report for full lien detail(s).
Supplemental Lien Amount:
PART IV: NET EQUITY SUMMARY
Valuation Amount $
81,000,000.00
Income $
-
Total Liens $
-
Management & 12-month Maintenance Expenses $
(870,106.00)
Sale - Related Expenses $
(2,576,098.00)
Total $
77,553,796.00
TOTAL NET EQUITY
$77,553,796.00
95.75%
* Management & 12-Month Maintenance Expenses include items such as association dues, grounds work, current & back taxes,
utilities, cleaning, pre-seizure & custody work, as well as maintenance and repairs.
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=== Page 1 ===
From: "Kate L. Doniger"
To:
(USANYS)"
Cc:
)"
N
Alexandra Conlon
, Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Date: Wed, 15 Apr 2020 13:08:36 +0000
Thanks very much,
Kate L. Doniger I Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Wednesday, April 15, 2020 12:10 AM
To: Kate L. Doniger
Cc:
>; Alexandra Conlon
>;
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
Kate,
Thank you for checking in. I hope you are keeping well also. I do not think we need any additional information from you at
this time. I hope to be able to provide an update early next week.
Thanks,
From: Kate L. Doniger
Sent: Tuesday, April 14, 2020 3:01 PM
To:
(USANYS)
Cc:
>; Alexandra Conlon
is
Roberta Kaplan
Subject: RE: Request for Information Relating to Jeffrey Epstein
We hope that you are keeping well in this very challenging time.
We completely understand that all things are in flux these days, but we just wanted to check in with you about our
request and whether there is any other information you need from us. If it would be helpful to set up a call to discuss, we
are available at your convenience.
Best,
Kate
Kate L. Doniger Kaplan Hecker & Fink LLP
EFTA00030319

=== Page 2 ===
From:
(USANYS)
Sent: Thursday, February 27, 2020 7:23 PM
To: Alexandra Conlon
>; Roberta Kaplan
Cc: Kate L. Doniger
Subject: RE: Request for Information Relating to Jeffrey Epstein
Alexandra and Robbie,
Thank you for this. I will contact you regarding the request.
Thanks,
From: Alexandra Conlon
Sent: Tuesday, February 25, 2020 7:54 PM
To:
(USANYS)
>; Roberta Kaplan
Cc: Kate L. Doniger
is
Subject: RE: Request for Information Relating to Jeffrey Epstein
SENT ON BEHALF OF ROBERTA KAPLAN
AUSA
Thank you for contacting us. Attached please find a Touhy letter and supporting exhibit requesting documents from the
Department of Justice in connection with our pending litigation against Jeffrey Epstein's estate.
We are happy to schedule a time to talk if it would be helpful to discuss our request.
Best Regards,
Robbie
Alexandra Conlon Kaplan Hecker & Fink LLP
From:
(USANYS)
Sent: Monday, January 6, 2020 6:59 PM
To: Roberta Kaplan
Cc: Kate L. Doniger
>; Alex Conlon
Subject: Request for Information Relating to Jeffrey Epstein
Dear Ms. Kaplan,
Please find attached a letter regarding the request you discussed with AUSA
for certain information
relating to Jeffrey Epstein. As stated in the letter, please contact me once you have had a chance to review the letter if you
would like to discuss the issues therein further.
EFTA00030320

=== Page 3 ===
Thanks,
Assistant United States Attorney
Southern District of New York
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-770 United States of America V. Maxwell "Motion FILED for bail"
Date: Mon, 17 May 2021 20:50:01 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 05/17/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-770
Document(s): Document(s)
Docket Text:
MOTION, for bail, on behalf of Appellant Ghislaine Maxwell in 21-770, 21-58, FILED. Service date 05/17/2021
by CM/ECF. [3102450] [21-770, 21-58]
Notice will be electronically mailed to:
Notice will be stored in the notice cart for:
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Motion FILED
Original Filename: Motion for Reconsideration4.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=05/17/2021] [FileNumber=3102450-0]
[af9aab28891e80a21dee810d54129a886570637c738ee09dc616ff56110a0f1aef0897141dbcec842505547dc49999
11dd5d8fc8da383fbe04f509071ec0dad8]|
EFTA00018190

=== Page 2 ===
Document Description: Supporting Document
Original Filename: Appendix to the Renewed Motion for Reconsideration4.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=05/17/2021] [FileNumber=3102450-1]
[bfd5d5123fc8fc9fca32aecd0dbde6bcfb337f880c0f0bde611f6521f7e4147a1afa4cae33bb83a940a70a8bc2c59239
2b151424f9d6cadb6b194593aaaa12ee]]
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=== Page 1 ===
From:
To:
Ce:
Subject: SDNY NEWS CLIPS, OCTOBER 28, 2020
Date: Thu, 29 Oct 2020 00:53:11 +0000
Inline-Images: image001.png
SDNY PRESS CLIPPINGS
DEPARTMENT
JUSTITIA
MAXWELL
FOX: https://www.foxnews.com/media/nancy-grace-ghislaine-maxwell-jail-release-movement
POST: https://nypost.com/2020/10/28/epstein-accuser-starts-foundation-for-victins-of-sexual-abuse/
NAJIBULLAH
NYT: https://www.nytimes.com/2020/10/28/world/asig/rohde-ofghanistan-kidnap-arrest.html
REUTERS: https://uk.reuters.com/article/uk-usa-justice-kidnapping-idUKKBN27D2VY
ALJAZEERA: https://www.aljazeera.com/news/2020/10/28/charges-unsealed-in-2008-kidnapping-of-journalists-in-ofghonistan
PARNAS, ETAL
NBC: https://www.cnbc.com/2020/10/28/lev-parnas-partner-david-correia-set-to-plead-guilty.html
ABC: https://gbcnews.go.com/Politics/wireStory/change-plea-scheduled-rudy-giuliani-related-case-7387921
NYT: https://www.nytimes.com/2020/10/28/nyregion/dovid-correia-guilty-rudy-giuliani.html
MATTERS OF INTEREST:
POST: https://nypost.com/2020/10/28/suspect-in-firebombing-of-nypd-patrol-car-faces-federal-charges/
FOX: https://www.foxnews.com/politics/cruz-grills-twitter-ceo-dorsey-restricting-hunter-biden-stories
YAHOO: https://sports.yahoo.com/giuliani-gets-irate-after-fox-news-kennedy-questions-his-hunter-bider-alegations-you-beter-apologize-07019082.html
LAW30: https://www.law360.com/construction/articles/1323464/feds-say-border-woll-grop-can-t-intervene-in-bannon-case
YAHOO!: https://news.yahoo.com/former-york-city-accountant-admitted-035342976.html
LAW.COM: https://www.law.com/newyorklawjournal/2020/10/28/can-you-see-me-now-lessons-learned-from-virtual-proceedings/
LAW.COM: https://www.law.com/nationallowjournal/2020/10/28/in-ted-cruzs-fec-suit-judges-question-whether-compaign-restriction-stop-corruption/
WSJ: https://www.ws.com/articles/puerto-rico-judge-says-no-to-insider-trading-probe-colling-accusations-sensotional-1160392703-
PROPUBLICA: https://www.propublica.org/article/top-fec-officials-undisclosed-ties-to-trump-raise-concerns-over-agency-neutraity
OK: https://okmagazine.com/news/fyre-fest-billy-mcfarland-solitary-confinment-prison-dumpster-fyre-podcast/
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
Subject: Officers watching Epstein were on overtime due to jail staffing shortage, union president says
Date: Mon, 12 Aug 2019 01:37:53 +0000
You may want to ask the Warden about this issue at least generally tomorrow.
https://www.washingtonpost.com/national-security/it-was-inevitable-officers-watching-epstein-were-on-
overtime-due-to-jail-staffing-shortage-union-president-says/2019/08/11/2b611404-bc5e-11e9-a5c6-
1e74f7ec4a93_story.html
Sent from my iPhone
EFTA00018983


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=== Page 1 ===
From:
To:
Cc:
Subject: [EXTERNAL] US V Maxwell 11/17/21 VOIR dire
Date: Thu, 18 Nov 2021 00:32:34 +0000
Attachments: XLBH1MAXVDF.pdf
EFTA00019416


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
)"
Cc:
)"
Subject: phone records
Date: Thu, 25 Apr 2019 15:34:13 +0000
Importance: Normal
Attachments:
number.pdf;
number.pdf;
message_with_number.pdf
Hi
and
If you have a moment for a call today, that would be great- I should be at my desk all of today. Separately, a few things
on phone records:
FYI, according to the 302s, it looks like the number for
on the messages
was
subpoenaed-see attached-along with some other New York based numbers that I don't recognize
and
Could you please check for those records in the file? Thanks!
It also looks like the number fo
on the phone messages we discussed yesterday
is the same number
provided to the agents when she was originally interviewed. According to a 302
(attached), tolls and subscriber records were subpoenaed for that number. Could you please check the FBI file to
see if you can locate those records?
We discussed
last name yesterday. It's
Could you please start doing a workup on her? Attached is
a message from
at a
number, which might be a good place to start.
On the message pads from West Palm, there are six different phone messages from
at
Could you please run that number to see who that is?
In addition, there are multiple phone messages from an
at
Could you please
check to see if you can sort out who that is?
Thanks!
Assistant United States Attorney
Southern District of New York
New York, NY 10007
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=== Page 1 ===
From:
To:
Cc:
Subject: Call tomorrow re Maxwell
Date: Tue, 24 Nov 2020 23:46:29 +0000
Attachments: 2020.11.24_AJN_order_re_meet_&_confer_re_MDC_conditions.pdf
Hi
In response to the letter we filed yesterday, today Maxwell's counsel filed her own letter demanding that Judge Nathan
order the Warden of the MDC to appear for a court proceeding to address the defense's complaints about Maxwell's
conditions of confinement. Judge Nathan endorsed that letter with an order that the parties confer and provide another
update letter by Tuesday 12/1. Attached is the defense letter with Judge Nathan's endorsement.
Would you be available tomorrow (11/25) afternoon to discuss, please? Apologies for the late request, but we are hoping
to address this before the Thanksgiving holiday.
Thanks very much,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00017820


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=== Page 1 ===
From:
To:
Subject: FW: NPA
Date: Tue, 23 Feb 2021 17:53:09 +0000
Attachments: 2021-02-26_GM_Government_Opposition_(NPA)_(MC).docx
Hi
- do you want to look next or should I? I'm pretty flexible this afternoon, so happy to defer to your schedule.
From:
Sent: Tuesday, February 23, 2021 12:46 PM
To:
is
is
Subject: RE: NPA
Thanks very much,
I think this is in great shape and is very compelling. Some small edits and my responses to your
comments attached. Happy to jump on a call if that would be useful.
From:
Sent: Tuesday, February 23, 2021 2:02 AM
To:
is
>;
Subject: NPA
All,
Attached is the most recent draft of the NPA brief. Apologies for the delay, I really struggled with this one. I think our
arguments in the first half are strong, but I'm really not wild about the second half. Would very much appreciate your
comments/edits. I've also flagged a few issues for consideration/discussion. If you're able to review tomorrow morning,
that would be great.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00018287


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=== Page 1 ===
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true
and correct to the best of my knowledge and belief.
Executed this 5 day of August 2020.
Counsel to the Acting United States Attorney
United States Attorney's Office for the
Southern District of New York
1
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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
,
)"
Subject: Re: Epstein calls
Date: Thu, 29 Aug 2019 15:54:56 +0000
Looks like all we have on the calendar today will be the 5 pm interview.
Sent from my iPhone
On Aug 29, 2019, at 11:49 AM,
wrote:
Ok I'll pass this info along. Separately do we have an update on today's interview timing wise?
On Aug 29, 2019, at 10:48,
)
wrote:
The attached are voicemails our office has received regarding Epstein. There are actually a few that I think merit a call
back and might be of investigative value. Would you please handle, or pass along to whoever has been handling the
FBI tip line?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Thursday, August 29, 2019 10:01 AM
To:
Subject: Epstein calls
I just want to be sure that you received all of these previous calls.
EFTA00019701

=== Page 2 ===
<mime-attachment>
<mime-attachment>
<mime-attachment>
<mime-attachment>
<mime-attachment>
<mime-attachment>
<mime-attachment>
<mime-attachment>
<mime-attachment>
<mime-attachment>
<mime-attachment>
<mime-attachment>
<mime-attachment>
EFTA00019702


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein/Maxwell
Date: Wed, 22 Jul 2020 17:36:26 +0000
Yes, thanks
From:
(USANYS)
Sent: Wednesday, July 22, 2020 1:34 PM
To:
(USANYS)
Subject: FW: Epstein/Maxwell
12 tomorrow works for you, right? If so, I can propose that or something Friday morning in the alternative?
From:
(ODAG)
Sent: Wednesday, July 22, 2020 1:03 PM
To:
(ODAG)
is
(USANYS)
Cc:
(USANYS)
Subject: RE: Epstein/Maxwell
Hi
,
I'm happy to assist you. I'm available Thursday or Friday to discuss what documents you are trying to
locate. Please let me know if you have availability on either of those days.
Thanks,
From:
(ODAG)
Sent: Wednesday, July 22, 2020 12:49 PM
To:
(USANYS)
Cc:
(USANYS)
is
(ODAG)
Subject: RE: Epstein/Maxwell
Thanks. OPR and
may have a better sense on document custodians than do I.
From:
(USANYS)
Sent: Wednesday, July 22, 2020 12:41 PM
To:
(ODAG)
Cc:
(USANYS)
is
(ODAG)
Subject: RE: Epstein/Maxwell
Thanks,
Among our questions was who, whether at ODAG, SDFL, or NDGA we should be in touch with at this point
regarding documents. I also know OPR did a significant document collection last year.
We will reach back to OPR, but if there is a particular point of contact at SDFL or NDGA on issues related to document
collection, in particular, please let us know. And if a call on those issues would be helpful, happy to set one up.
EFTA00019238

=== Page 2 ===
Thanks very much,
From:
(ODAG)
Sent: Wednesday, July 22, 2020 10:56 AM
To:
(USANYS)
Cc:
(USANYS)
is
(ODAG)
Subject: RE: Epstein/Maxwell
Happy to talk, but my only real role related to recusal issues and consequences. Now that the CVRA litigation is over, you
probably are best going directly to SDFL, as I don't have any of their documents. Thanks,
Associate Deputy Attorney General
Office:
Cell:
From:
(USANYS)
Sent: Tuesday, July 21, 2020 6:23 PM
To:
(ODAG)
Cc:
(USANYS)
Subject: Epstein/Maxwell
- Hope all is well. We had spoken last summer, after the Epstein case was charged, about some potential
document/discovery requests related to the SDFL investigation and the NPA, in particular. Those conversations were
largely at mooted at the time by Epstein's death, but as I'm sure you know, we've recently charged Ghislaine Maxwell and,
anticipating potentially similar issues, we were hoping to revisit those conversations. Do you have time later this week
for a quick call? If so, please let us know what might work for you.
Thanks very much,
Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
Tel.
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=== Page 1 ===
From:
)"
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Date: Tue, 09 Mar 2021 15:34:15 +0000
Hi Joe-we're - on now, if this time still works for you.
From:
Sent: Monday, March 8, 2021 2:01 PM
To: Joe Nascimento
Cc:
is
Subject: RE:
)
- Epstein
Great, thanks. We can use this conference line:
From: Joe Nascimento
Sent: Monday, March 8, 2021 1:54 PM
To:
Cc:
>;
Subject: Re:
)
- Epstein
Yes, 10:30 works for me. Thank you!
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
From:
)
Date: Monday, March 8, 2021 at 1:32 PM
To: Joe Nascimento
Cc:
)
i
)
Subject: RE:
)
- Epstein
Hi Joe,
Thanks, hope all is well with you. We're free for a call at 10:30 tomorrow morning, would that work for you?
Thanks,
EFTA00017978

=== Page 2 ===
From: Joe Nascimento
Sent: Monday, March 8, 2021 1:24 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
,
I hope you are well. Please let me know if you have 5 min for a quick call.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 2, 2020, at 11:09 AM,
)
wrote:
Hi Joe,
Thanks for reaching out, we were planning to email you. We continue to appreciate your client's cooperation with our
investigation, and her status from our perspective has not changed. We'll be in touch going forward, and
All the best,
From: Joe Nascimento
Sent: Thursday, July 2, 2020 11:07 AM
To:
Cc:
is
)
Subject: Re:
- Epstein
Good morning,
Hope you are all well. Just wanted to check in after seeing the reports of Ghislaine's arrest.
If you need anything from us, let us
know.
-Joe
EFTA00017979

=== Page 3 ===
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Feb 21, 2020, at 3:53 PM,
)
wrote:
Joe,
We very much appreciated that, and we just wanted to let you know that the lack of communication separate from
that discussion shouldn't be interpreted in any way negatively. We'll certainly be in touch again when we're able.
thanks again,
From: Joe Nascimento
Sent: Wednesday, February 19, 2020 15:03
To:
Cc:
is
)
>
Subject: Re:
- Epstein
We really appreciate this email. I was able to speak with
a few weeks ago and gave the green light to share
name and information provided with anyone necessary in your investigation. We will wait to hear from you if
you need anything further.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
EFTA00017980

=== Page 4 ===
From:
)"
Date: Monday, February 17, 2020 at 3:40 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Joe,
We just wanted to check in very briefly-we had been hopeful that we'd be able to circle back with you earlier, but our
investigation is currently still ongoing, so at the very least we wanted to let you know that we continue to appreciate
both your client's prior assistance and her willingness to assist in the future. Nothing in our investigation since we
were last substantively in touch has changed our view of your client, and we hope to be able to be in touch with you in
the coming weeks with an update. In the interim, we do continue to view her status as we've previously conveyed,
and please let us know if any issues arise on your end.
thank you,
From:
Sent: Saturday, November 30, 2019 14:42
To: Joe Nascimento
Cc:
>;
)
Subject: Re:
- Epstein
Hi Joe,
Thanks for checking in
,
so no issues on our end, but we appreciate your
following up.
Thanks,
Sent from my iPhone
On Nov 30, 2019, at 8:54 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check-in as
Please let us know if you need anything from us.
Thanks,
Joe
Sent from my iPhone
EFTA00017981

=== Page 5 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 9, 2019, at 9:47 PM,
)
wrote:
Joe,
We will meet tomorrow at the same place as last time- the Hilton in West Palm Beach, on Okeechobee
Blvd. My cell is
when you arrive. My colleague,
will be joining us, and he
can be reached at
Thanks,
Sent from my iPhone
On Sep 4, 2019, at 10:46 PM, Joe Nascimento
wrote:
Yes, we will be there.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 5:32 PM,
)
wrote:
Hi Joe,
EFTA00017982

=== Page 6 ===
Thanks for letting us know. Let's plan to meet on Tuesday. Would 11:30 work?
Thanks,
From: Joe Nascimento
Sent: Wednesday, September 4, 2019 10:13 AM
To:
Cc:
>;
Subject: Re:
- Epstein
Good morning,
Yes, we had to hunker down for 2 days but were spared. Thanks. For next week, the 10th, 11th or 13th
work best for me. Look forward to hearing from you.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Sep 4, 2019, at 10:04 AM,
)
wrote:
Hi Joe,
Hope the storm missed you this week, and that you and your client are doing okay.
Our team is working out some scheduling issues today, and we should know more by this afternoon.
I'll plan to reach out then to discuss scheduling, if that's okay.
Thanks,
Sent from my iPhone
On Aug 30, 2019, at 9:52 AM, Joe Nascimento
wrote:
Good morning,
EFTA00017983

=== Page 7 ===
Just wanted to check in to see if you still planned to travel south given the storm. Current estimates
show a landing (somewhere) Tuesday with very bad weather on Wednesday. Airports might close
(which will answer my question), but that's a guess.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 21, 2019, at 2:40 PM,
)
wrote:
Hi Joe,
Thanks very much, we'll plan to see you then. We'll most likely meet at a conference space at a hotel in
West Palm Beach, and I'll let you know closer in time which location.
Thanks,
From: Joe Nascimento
Sent: Monday, August 19, 2019 6:37 PM
To:
Cc:
is
Subject: Re:
)
- Epstein
Hi
Both the time and date work for us. Let me know the location when you have it confirmed.
Thanks,
Joe
Sent from my iPhone
EFTA00017984

=== Page 8 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Aug 19, 2019, at 11:11 AM,
)
wrote:
Joe,
Following up on scheduling, we were wondering if your client is available for a proffer on September 4th.
We're flexible on timing that day, but we would propose meeting at 12:30 p.m., if that works.
Thanks,
From: Joe Nascimento
>
Sent: Wednesday, August 7, 2019 4:53 PM
To:
Cc:
is
)
Subject: Re:
-
- Epstein
Hi
I just wanted to follow up re the August 14th meeting. Is it possible to schedule for early afternoon
(anytime after 1)? I have proactive cooperation ongoing in another case involving multiple jurisdictions,
and they are looking to meet the morning of 8/14. I understand if your schedule is already set, and will
work around it.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza | 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Friday, August 2, 2019 at 3:34 PM
EFTA00017985

=== Page 9 ===
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
Joe,
Thanks, much appreciated. If possible, it would be helpful to hold August 14th for a meeting, and we'll
follow up to firm up plans as we get closer. If there are any conflicts with that date, please let us know,
we're happy to be flexible.
Thanks,
From: Joe Nascimento
Sent: Thursday, August 1, 2019 8:10 PM
To:
Cc:
is
)
Subject: Re:
-
- Epstein
Hi
I do not have any travel plans during the month of August, nor does
September is a busy month
with two trials set, and I will be traveling out of the country from Sept 17-30, but I will do everything to
be as flexible as possible.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
EFTA00017986

=== Page 10 ===
From:
)"
Date: Thursday, August 1, 2019 at 6:10 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
) - Epstein
Joe,
As we start thinking about scheduling a next meeting with
we were wondering if you could
please let us know if there are any particular weeks that would not work for you or your client for a
meeting in Florida (in particular, we don't want to interfere with anyone's summer vacation plans).
We will of course be in touch to talk about a next meeting in more detail, but in the first instance it would
be helpful to get a sense of your schedules, for planning purposes.
Thanks,
From: Joe Nascimento
Sent: Wednesday, July 17, 2019 6:25 PM
To:
Cc:
is
)
Subject: Re:
)
- Epstein
Hi
,
That works for me. Please call me on my cell
). Thanks.
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 17, 2019, at 5:58 PM,
)
wrote:
Hi Joe,
EFTA00017987

=== Page 11 ===
Following up, we were wondering if you were available for a call to discuss next steps. We're available
on Friday at 2:30, if that works, but let us know if there are other times that would be more convenient
for you.
Thanks,
From: Joe Nascimento
Sent: Saturday, July 13, 2019 12:39 PM
To:
Cc:
)
is
Subject: Re:
- Epstein
Good afternoon,
It was a pleasure to meet you yesterday. In light of the recent filing and media reports,
As always, feel free to contact me at any time if we can be of further assistance. Look forward to
meeting again.
-Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, July 11, 2019 at 9:07 PM
To: Joe Nascimento
Cc:
)"
,
Subject: RE:
)
- Epstein
Hi Joe,
We will be at the Hilton in West Palm Beach, at 600 Okeechobee Blvd. Please call me when you are
here, and we will meet you in the lobby.
EFTA00017988

=== Page 12 ===
Thanks,
From: Joe Nascimento
Sent: Thursday, July 11, 2019 9:02 PM
To:
Cc:
is
Subject: Re:
-
- Epstein
Good evening,
Have you set a location for our meeting tomorrow?
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 10, 2019, at 12:03 PM,
)
wrote:
Thank you, we will plan to see you then in West Palm Beach. We are still coordinating
logistics, and we will let you know that morning the address where we should meet.
Since we will be traveling, please feel free to call my cell if you need to reach us for any
reason:
Thanks,
Sent from my iPhone
On Jul 10, 2019, at 11:39 AM, Joe Nascimento
EFTA00017989

=== Page 13 ===
<mailto:
wrote:
Of course
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. B<x-apple-data-detectors://2/0>rd<x-apple-data-
detectors:/2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors.//2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com/>
On Jul 10, 2019, at 11:34 AM,
<mailto:
wrote:
Joe,
Would it be possible to meet earlier, perhaps at noon on Friday? Thank you.
Sent from my iPhone
On Jul 9, 2019, at 10:51 PM, Joe Nascimento
<mailto:
mailto:
wrote:
,
Can we meet Friday, early afternoon (around 1-1:30)? Please send me your proffer letter.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors.//2/0>2250 S.W. B<x-apple-data-detectors://2/0>rd<x-apple-data-
detectors://2/0><x-apple-data-detectors:/2/0> Avenue<x-apple-data-detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com><http/www.crimlawfirm.com/
On Jul 9, 2019, at 4:56 PM,
<mailto:
EFTA00017990

=== Page 14 ===
<mailto:
wrote:
Joe,
We ended up slotting in a few things in the interim, but we're still good for 6:30 for sure.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Tuesday, July 09, 2019 16:43
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: Re:
)
- Epstein
Hi
,
I got done a little earlier today - do you want to bump up our call time?
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. <x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0> Avenue<x-apple-
data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com-http://www.crimlawfirm.com-http://www.crimlawfirm.com/
On Jul 9, 2019, at 10:02 AM, Joe Nascimento
<mailto:
<mailto:
wrote:
Hi
,
Are you still free for a call?
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami, FL 33129
p.
f.
e.
<mailto:
EFTA00017991

=== Page 15 ===
<mailto:
www.crimlawfirm.com http://www.crimlawfirm.com http://www.crimlawfirm.com/
From:
)"
<mailto:
<mailto:
Date: Sunday, July 7, 2019 at 10:19 PM
To: Joe Nascimento
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
)"
<mailto:
<mailto:
Subject: RE:
)
- Epstein
Joe,
Sure, thanks - and yes, quite the weekend. If it's alright with you, let's do 10:00 a.m. on
Tuesday - you can reach us at
, or we can also call you then if that's easier,
whatever you prefer.
thanks,
From: Joe Nascimento
<mailto:
<mailto:
Sent: Sunday, July 07, 2019 18:51
To:
<mailto:
<mailto:
Cc:
<mailto:
<mailto:
<mailto:
<mailto:
Subject: Re:
)
- Epstein
Hi
,
No need to take any more time out of what I'm sure was a busy weekend for you. Let's set a
time for Tuesday morning (the earlier the better for me). Let me know what works for you.
Thanks,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
EFTA00017992

=== Page 16 ===
Lawyer's Plaza | 4th Floor
2250 S.W. <x-apple-data-detectors://2/0>rd<x-apple-data-detectors.//2/0> Avenue<x-apple-
data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com-http://www.crimlawfirm.com>http//www.crimlawfirm.com/
On Jul 7, 2019, at 4:04 PM,
<mailto:
<mailto:
wrote:
Joe,
Thank you for reaching out, and we would be happy to schedule a time to speak with you. I
expect our schedules may be somewhat unpredictable tomorrow; would it work to set a time
to talk on Tuesday? We can schedule it for before you meet with
, if that's helpful.
Or if you'd like to talk sooner, we could schedule a time later today, or check in tomorrow
about a possible afternoon discussion. Please let us know what you prefer, and we look
forward to being in touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Joe Nascimento
<mailto:
<mailto:
Sent: Saturday, July 06, 2019 22:55
To:
<mailto:
<mailto:
Subject:
)
- Epstein
Begin forwarded message:
From:
<mailto:
<mailto:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
<mailto:
Cc:
<mailto:
mailto:
Subject:
)
- Epstein
My former partner, Alan Ross, represented
, prior to his
EFTA00017993

=== Page 17 ===
passing in 2018.
served
with a grand jury subpoena earlier today,
and as Alan's former partner and FL Bar appointed inventory attorney, she has contacted me.
Unfortunately, I am unable to meet with her until Tuesday, but I would appreciate a few
minutes of your time at your convenience as I am getting up to speed. Please let me know
what day/time is best for you.
Look forward to speaking with you.
Best,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. <x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0> Avenue<x-apple-
data-detectors://2/0>
Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com-http://www.crimlawfirm.com--http/www.crimlawfirm.com/
EFTA00017994


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Accepted: Call w/ Andy Tomback and Marc Weinstein (Epstein estate)
Date: Wed, 31 Mar 2021 18:17:21 +0000
Importance: Normal
Attachments: unnamed
EFTA00018019


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Cc:
)"
)"
Subject: RE: United States V. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.)
Date: Wed, 21 Aug 2019 02:56:40 +0000
Embedded: Jnited_States_v_Jeffrey_Epstein,_19-CRIM-00490_(S.D.N.Y.).msg
Oh yes, I'm sorry - attached.
From:
(USANYS)
Sent: Tuesday, August 20, 2019 22:35
To:
Cc:
is
)
Subject: FW: United States V. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.)
Thanks,
When you have a moment, could you please forward me the letters Steptoe sent? (Sounds like they are the
actual requests here.) Thanks!
From:
Sent: Tuesday, August 20, 2019 8:45 PM
To: Miller, Michael
Cc:
is
>; Weingarten, Reid
>; ; 'Martin G. Weinberg' <owlmgw@att.net>; Scavelli, Michael <mscavelli@Steptoe.com>;
Meade, Jason <jmeade@Steptoe.com>;
(USANYS)
Subject: RE: United States V. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.)
Mike,
Consistent with the email sent by
of our Civil Division on August 13, 2019, your August 20, 2019, requests for
disclosure made pursuant to the Department of Justice's Touhy regulations will be handled by AUSA
of
our Civil Division, copied here. Please note that in light of the death of the defendant and in anticipation of the entry of
the proposed order of nolle prosequi, no further productions will be made in the context of the criminal case of United
States V. Epstein, 19 Cr. 490.
Separately, we are not able to accept service of any materials on behalf of entities separate from this Office.
thank you,
From: Miller, Michael
Sent: Tuesday, August 20, 2019 11:42
To:
Cc:
is
>; Weingarten, Reid
>; 'Martin G. Weinberg' <owlmgw@att.net>; Scavelli, Michael <mscavelli@Steptoe.com>;
Meade, Jason <jmeade@Steptoe.com>
Subject: United States V. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.)
EFTA00019659

=== Page 2 ===
Please find attached correspondence for your attention. We intend to serve these requests separately on the
MCC and the FBI, but are providing you with copies of all three letters as a courtesy. If you are willing to accept
service for all three, we will not otherwise serve them.
Mike
Michael C. Miller
Partner
+1 212 506 3955 direct I +1 917 349 9129 mobile I +1 212 506 3950 fax
Steptoe
Steptoe & Johnson LLP
1114 Avenue of the Americas I New York, NY 10036
www.steptoe.com
This message and any attached documents contain information from the law firm Steptoe & Johnson LLP that may be confidential and/or privileged. If you
are not the intended recipient, please do not read, copy, distribute, or use this information. If you have received this transmission in error, please notify the
sender immediately by reply e-mail and then delete this message.
EFTA00019660


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=== Page 1 ===
From:
To:
Cc:
)"
Subject: RE: RE:
for mailing
Date: Mon, 29 Jun 2020 14:13:33 +0000
Attachments: 2020-06-29,
pdf; 2020-06-29,
pdf
Adding to this, two more for this morning, please, attached. For the
please mail; for the
if you could please mail it to the address but also fax it to the fax number listed? Thanks again.
From:
Sent: Monday, June 29, 2020 09:36
To:
Cc:
Subject: RE: subpoena for mailing
As discussed, could you please put the attached subpoena in the mail this morning? Let me know if any questions or
issues, otherwise should be all set.
thanks very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00020235


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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Subject: RE: Epstein Pros Memo
Date: Wed, 14 Aug 2019 17:52:27 +0000
Thanks. And last thing, sorry, can you send me the court dates and what happened at them?
From:
Sent: Wednesday, August 14, 2019 1:48 PM
To:
(USANYS)
Subject: RE: Epstein Pros Memo
19-490
From:
(USANYS)
Sent: Wednesday, August 14, 2019 13:48
To:
Subject: RE: Epstein Pros Memo
Thanks! What was the docket?
From:
Sent: Wednesday, August 14, 2019 1:45 PM
To:
(USANYS)
Cc:
is
)
Subject: RE: Epstein Pros Memo
Sure, attached. Depending on what exactly you're looking for, the ODAG memo and UMR from when we were charging,
also attached, may also be useful.
From:
(USANYS)
Sent: Wednesday, August 14, 2019 13:15
To:
)
is
-
is
)
Subject: Epstein Pros Memo
Can you send it to me?
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00019818


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=== Page 1 ===
Event: Accepted: Call re: Epstein FOIA
Start Date: 2021-03-19 13:00:00 +0000
End Date: 2021-03-19 13:30:00 +0000
Location:
133318#
Class: X-PERSONAL
Comment:
Date Created: 2021-03-11 21:11:35 +0000
Date Modified: 2021-03-11 21:11:35 +0000
Priority: 5
DTSTAMP: 2021-03-11 20:29:47 +0000
Attendee:
)
EFTA00017904


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 1 of 9
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 4/27/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
Defendant Ghislaine Maxwell seeks an order authorizing a subpoena pursuant to Rule
17(c)(3) of the Federal Rules of Criminal Procedure. As detailed in the subpoena and Maxwell's
moving papers, she seeks authorization to serve a subpoena to the law firm of Boies, Schiller and
Flexner LLP. BSF has filed a letter in opposition to the subpoena request. Additionally, the
Government submitted a letter requesting that it be given notice of all pending and future
subpoenas applications, an opportunity to challenge them, and copies of any documents
produced. For the reasons that follow, the Court denies Maxwell's motion as to Requests 1
through 8 and Request 12 and reserves judgment on Requests 9 through 11. The Court also
denies the Government's requests, though it will direct the Government to notify the Court of its
views as to Requests 9 through 11.
I.
Legal Standard
Rule 17(c) permits subpoenas ordering the production of "books, papers, documents,
data, or other objects." Fed. R. Crim. P. 17(c)(1). When the subpoena seeks the production of
personal or confidential information about a victim, it may be served on a third party only by
court order. Fed. R. Crim. P. 17(c)(3).
1
EFTA00020298

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 2 of 9
The purpose of Rule 17(c) is to facilitate the trial by designating a time and place prior to
trial to obtain and inspect evidentiary material. See United States V. Nixon, 418 U.S. 683, 698-99
(1974) (citing Bowman Dairy Co. V. United States, 341 U.S. 214, 220 (1951)). It is not intended
to provide an additional means of discovery or to serve as a general "fishing expedition." Id. at
698-700. As a result, courts must be mindful not to allow the Rule 17(c) process to become a
"broad discovery device" that would undermine the discovery procedures set forth in Rule 16.
United States V. Cherry, 876 F. Supp. 547, 552 (S.D.N.Y. 1995). Thus, if an item is not
discoverable under Rule 16, a party cannot make it discoverable simply by subpoenaing it under
Rule 17. United States V. Barnes, No. S9 04-CR-186 (SCR), 2008 WL 9359654, at *2 (S.D.N.Y.
Apr. 2, 2008).
To determine whether issuance of the subpoena is appropriate, the Court considers the
factors articulated in United States V. Nixon, 418 U.S. at 699-700. In Nixon, the Supreme Court
explained that in order to require production prior to trial, the moving party must show: (1) that
the documents are evidentiary and relevant; (2) that they are not otherwise procurable reasonably
in advance of trial by exercise of due diligence; (3) that the party cannot properly prepare for
trial without such production and inspection in advance of trial and that the failure to obtain such
inspection may tend unreasonably to delay the trial; and (4) that the application is made in good
faith and is not intended as a general 'fishing expedition." Id. at 698-700. To clear that hurdle,
the Court considers (1) relevancy, (2) admissibility, and (3) specificity. Id. at 700.
II.
Discussion
A. The BSF Subpoena
The proposed subpoena makes twelve requests. Some of the requests relate to documents
that Maxwell believes will be relevant at trial. For others, the proffered relevance relates to
2
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Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 3 of 9
Maxwell's pending motions to suppress evidence. While ordinarily Rule 17(c) is "trial-focused"
and "may be used only to obtain materials admissible as evidence at trial," at least some courts
have held that Rule 17(c) can be used to compel the production of documents in connection with
a suppression hearing. United States V. Louis, No. 04-CR-203 (LTS), 2005 WL 180885, at *3
(S.D.N.Y. Jan. 27, 2005). Even then, the requests fail for the reasons stated below.
Requests 1 through 5 all fail on the basis that they do not comply with Nixon's specificity
requirement. Requests 1 through 5 all target communications between "any" owner,
shareholder, partner or employee of BSF and government officials or co-counsel in civil
litigation, from 2015 to the date of the subpoena. While the requests focus on a certain subject,
the requests are so overbroad that issuance of the Rule 17(c) subpoena would be improper. As
set forth in the subpoena, the term "communications" encompasses "all forms of correspondence,
including regular mail, email, text message, memorandum, or other written communication of
information of any kind." The use of the terms "all" and "any" "do not evince specificity."
United States V. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16,
2021). Here, the requests do not identify specific lawyers or employees of BSF whose
communications are relevant. See United States V. Wey, 252 F. Supp. 3d 237, 243 (S.D.N.Y.
2017) (discussing that while an originally requested subpoena was insufficiently specific, a new
requested subpoena satisfied the specificity requirement because it identified a specified set of
individuals whose records were sought). The requests also encompass "all" forms of
correspondence without limitation. And while the requested subpoenas are limited to the period
between 2015 and 2021, the timeframe is still overly broad. These requests are precisely the
kind of "fishing expedition" that the specificity requirement is designed to prevent. See Bowman
Dairy Co., 341 U.S. at 221. Indeed, the requests are akin to discovery requests in civil litigation.
3
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=== Page 4 ===
Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 4 of 9
See United States V. Avenatti, No. (S1) 19-CR-373 (PGG), 2020 WL 86768, at *6 (S.D.N.Y.
Jan. 6, 2020). But Rule 17(c) subpoenas are not tools of discovery. Nixon, 418 U.S. at 698;
Wey, 252 F. Supp. 3d at 253. On the specificity prong alone, Requests 1 through 5 fail to satisfy
the Nixon standard.
Requests 1 and 2 fail for the separate reason that, if Maxwell is entitled to the materials
sought at all, they should come from the Government. Requests 1, 2, and 8 all seek documents
that are procurable from the Government. As noted above, Requests 1 and 2 seek
communications between BSF and government officials regarding a certain subject, from 2015
to the date of the subpoena. Request 8, meanwhile, refers to a specific grand jury subpoena that
the Government issued to BSF. As to all of these requests, Maxwell asserts that the Rule 17(c)
subpoena is necessary to fix what she deems to be the Government's failure to comply with its
discovery obligations. Among the principles set forth in Nixon is that the materials must not be
otherwise procurable reasonably in advance of trial by exercise of due diligence. Nixon, 418
U.S. at 699. These three requests target information that reasonably can be expected to be in the
hands of the Government. To the extent that Maxwell has a basis to argue that the Government
has not met its discovery obligations, the Rule 17(c) subpoena process is not the proper
mechanism for pursuing that. Rather, with notice to the Government so that the issue is properly
joined, Maxwell must make some showing of that failure and seek specific and appropriate relief
from this Court.
Requests 6 and 7 seek contingency fee agreements or engagement letters between BSF
and two of its clients who are alleged victims. Maxwell has failed to make the required showing
under Nixon that these records would be relevant or admissible for purposes of her Rule 17(c)
application. The only plausible theory of relevance set forth in Maxwell's papers is that these
4
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Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 5 of 9
documents are necessary for purposes of impeachment. But as a general matter, the need to
impeach witnesses generally "is insufficient to require [materials'] production in advance of
trial." Nixon, 418 U.S. at 701. Many courts have held that impeachment material does not
become relevant until after the witness testifies. United States V. Skelos, No. 15-CR-317
(KMW), 2018 WL 2254538, at *2 (S.D.N.Y. May 17, 2018), ), aff d, 988 F.3d 645 (2d Cir.
2021) (collecting cases); United States V. Scaduto, No. 94-CR-311 (WK), 1995 WL 130511, at
*1 (S.D.N.Y. Mar. 27, 1995) ("Potentially impeaching statements "ripen into evidentiary
material only if and when the witness testifies at trial (citation omitted)). See also
Avenatti, 2020 WL 86768, at *6 (rejecting the argument that the defendant needed the recordings
in question prior to trial in order "to demonstrate witnesses' bias or self-interest."). The
arguments as to relevance are otherwise specious, and the Court cannot discern what relevance
the materials responsive to Requests 6 and 7 may have. In any event, there is little risk that
review of these materials, if they become relevant and admissible, will lead to a delay at trial,
given their limited volume. United States V. Seabrook, No. 16-CR-467, 2017 WL 4838311, at *2
(S.D.N.Y. Oct. 23, 2017). For documents that may ripen into relevance if and when the BSF
clients testify, Maxwell presumably could request that the Court issue a subpoena to require
production of the engagement letters to the Court so that the information can be made available
to Maxwell, if appropriate, at the conclusion of each witness's direct testimony. See United
States V. Giampa, No. S 92-CR-437 (PKL), 1992 WL 296440, at *3-*4 (S.D.N.Y. Oct. 7, 1992);
United States V. Ferguson, No. 3:06-CR-137 (CFD), 2007 WL 4577303, at *3 (D. Conn. Dec.
26, 2007).
Maxwell also argues that compulsion of the materials' production under Rule 17(c) is
justified because the materials appear not to have been produced by BSF in response to the grand
5
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=== Page 6 ===
Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 6 of 9
jury subpoena at issue in Request 8; she thus contends that the absence of the documents in that
production suggests coordination between the Government and BSF. Other than through
conclusory speculation, she fails to explain how the contents of those letters may be relevant to
her theory of preexisting coordination between the Government and BSF. Furthermore, to the
extent Maxwell argues that the Government may have the documents and has refused to produce
them in contravention of Brady or Giglio, the argument is little more than an attempt to
circumvent the discovery processes that are in place. The production of Giglio material has not
yet happened, and so any claim that the Government has failed to produce these documents
consistent with its Giglio obligations is premature. Furthermore, as set forth in the Opinion &
Order resolving some of Maxwell's pre-trial motions, the Government has represented in good
faith that it is cognizant of its Brady obligations and that it has complied and will continue to
comply with them. This Court knows well that the Government has not always lived up to those
obligations in every case. But nothing has transpired that provides any reason to doubt the good
faith representations that have been made to the Court by the AUSAs appearing here. In sum,
none of Maxwell's theories justify production of these documents under the Rule 17(c) process.
Request 12, which seeks "any" submission to the Epstein Victims' Compensation
Program made by BSF, fails under the relevance prong of the Nixon standard. The request seeks
"any" submission made by BSF to the EVCP. In its reply brief, BSF represents that Maxwell
offered to narrow this request to just those materials submitted on behalf of victims who
ultimately testify in this action.
The request's failure to satisfy the Nixon standard is in part due to its relative lack of
specificity, for even if Maxwell had established the relevance of some evidence captured by this
request, she plainly has not demonstrated the relevance of all materials submitted to the EVCP.
6
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Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 7 of 9
See United States V. Aguilar, No. CR 07-00030 (SBA), 2008 WL 3182029, at *6 (N.D. Cal. Aug.
4, 2008). Maxwell argues that the materials are relevant because they may reveal monetary
incentives to testify in a particular way. That argument demonstrates that the documents are
being sought for impeachment. As stated above, the mere fact that certain documents might be
impeachment evidence does not render them "relevant" for purposes of Rule 17(c); if at all, those
documents would become relevant only after a witness testifies. See Skelos, 2018 WL 2254538,
at *2. Maxwell's argument that the documents are relevant because their impeachment value is
exculpatory does not get around this general bar. These materials only become relevant if or
when those witnesses testify. She presents no other nonconclusory basis as to why they are
exculpatory. Indeed, Maxwell concedes that the primary purpose of these documents will be for
purposes of cross-examination, leaving little doubt as to the purported claim of relevance. And
to the extent Maxwell posits that statements made as part of the EVCP process may be
exculpatory in themselves, the argument is speculative because she provides no basis for why
that expectation might be reasonable. The "mere hope" that the documents may contain some
exculpatory evidence is insufficient to justify enforcement of a Rule 17(c) subpoena (or, as here,
issuance of such a subpoena in the face of objections). See United States V. Rich, No. S 83-CR-
579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984). Maxwell's reliance on cases
involving the Government's obligations under Brady and Giglio to produce impeachment
evidence prior to trial are thus inapposite to the current context. Pena, 2016 WL 8735699, at *2-
3. Maxwell thus fails to establish Request 12's compliance with the Nixon standards. Maxwell
may renew her request for these documents once she identifies specific individuals whose
submissions she seeks and spells out with specificity the relevance of all requested materials. At
that time, the Court will determine whether it is proper to require production of these materials to
7
EFTA00020304

=== Page 8 ===
Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 8 of 9
the Court so that the information may be made available to Maxwell, if appropriate, at the
conclusion of each witness's direct testimony. See Giampa, 1992 WL 296440, at *3; Ferguson,
2007 WL 4577303, at *3.
The Court will reserve on Requests 9 through 11 in order to allow the Government to
weigh in on the propriety of the requests. The Court assumes that the Government has enough
information, based on the public filings, to provide its views. If the Government seeks the
specific subpoena requests, it shall confer with defense counsel and raise any dispute with the
Court. The Government shall file its response within one week of this Order.
In sum, for Request 1 through 8 and 12, the Court will not authorize service of the
proposed subpoena on the basis that Maxwell has failed to establish that the requests are
sufficiently specific and that the materials sought are relevant or admissible. Maxwell may
renew more tailored requests in compliance with this Order. The Court sees no basis for doing
so on an ex parte basis. For Requests 9 through 11, the Court will reserve its decision until it
hears from the Government.
B. The Government's Subpoena-Related Request
The Government seeks a preemptive, blanket ruling that it be entitled notice of all future
subpoenas, an opportunity to challenge them, and production of any information obtained
therefrom. This request is denied. Assuming Maxwell seeks the issuance of a future subpoena
for which there is no basis to proceed ex parte, the Government will be provided notice and the
Court would likely consider the Government's briefing regardless of standing as part of its duty
to ensure that the subpoena meets the requirements of Nixon. See United States V. Bergstein, No.
16-CR-746 (PKC), 2017 WL 6887596, at *3 (S.D.N.Y. Dec. 28, 2017). But ex parte Rule 17(c)
subpoenas are possible in some circumstances if justified. See Skelos, 2018 WL 2254538, at *8
8
EFTA00020305

=== Page 9 ===
Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 9 of 9
(collecting cases). As a result, the blanket ruling sought by the Government is improper and
denied.
III. Conclusion
The Defendant's motion for an order authorizing the subpoena pursuant to Rule 17(c)(3)
is DENIED. The Government is ORDERED to respond to Requests 9 through 11 of the
proposed subpoena within one week of this Order.
so ORDERED.
Alim D.Nitto
Dated: April 27, 2021
New York, New York
ALISON J. NATHAN
United States District Judge
9
EFTA00020306


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=== Page 1 ===
From:
(USANYS)
To:
(USANYS)"
Subject: RE: Maxwell investigation, prosecution memo
Date: Mon, 13 Apr 2020 18:47:51 +0000
Will do!
From:
(USANYS)
Sent: Monday, April 13, 2020 2:46 PM
To:
(USANYS)
Subject: Fwd: Maxwell investigation, prosecution memo
Please put on our calendars
Begin forwarded message:
From:
(USANYS)"
Date: April 11, 2020 at 2:07:03 PM EDT
To:
(USANYS)"
Cc:
)"
(USANYS)"
(USANYS)"
(USANYS)"
(USANYS)"
i
(USANYS)"
i
)"
)"
Subject: Re: Maxwell investigation, prosecution memo
That is good for team and chiefs.
Sent from my iPhone
On Apr 11, 2020, at 10:00 AM,
(USANYS)
wrote:
Thanks, team. Let's set up a conference call at 1pm on Wednesday to discuss. Does that time work for everyone?
On Apr 10, 2020, at 11:43 PM,
wrote:
All,
Attached please find the prosecution memo for the Ghislaine Maxwell investigation. The team will be working on a
draft indictment, but we wanted to submit the memo as soon as it was completed.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00019244

=== Page 2 ===
One Saint Andrew's Plaza
New York, NY 10007
2020-04-10 GM prosecution memo..pdf>
EFTA00019245


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c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
)"
)"
)"
Cc:
"
(USANYS)"
Subject: New Maxwell Lawsuit
Date: Wed, 18 Mar 2020 15:53:28 +0000
https://www.nytimes.com/2020/03/18/business/jeffrey-epstein-ghislaine-maxwel-lawsuit.html?
action=click&module=Latest&pgtype=Homepage
EFTA00018876


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=== Page 1 ===
From:
To:
Subject: OPR
Date: Wed, 06 Feb 2019 23:14:03 +0000
Importance: Normal
https://www.reuters.com/article/us-usa-justice-epstein/justice-department-conducting-professional-misconduct-probe-
in-epstein-case-idUSKCN1PV2NJ?il=0
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
EFTA00019182


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=== Page 1 ===
From:
To:
Subject:
Date: Thu, 04 Nov 2021 16:35:41 +0000
Attachments: 2021-11-03_Defense_Motion_for_Juror_Name_Reconsideration.pdf
Sines V. Kessler, 17 Civ. 72 (KNM) (W.D. Va.)
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:
EFTA00018372


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=== Page 1 ===
Event: Accepted: Meet re: Epstein Investigation
Start Date: 2018-12-06 21:30:00 +0000
End Date: 2018-12-06 22:30:00 +0000
Location: Conference Room 646
Class: X-PERSONAL
Comment:
Date Created: 2018-12-05 00:52:30 +0000
Date Modified: 2018-12-05 00:52:30 +0000
Priority: 5
DTSTAMP: 2018-12-05 00:37:27 +0000
Attendee:
EFTA00019532


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=== Page 1 ===
From:
"
)"
To:
)"
Subject: Accepted: Call re: Epstein FOIA
Date: Thu, 11 Mar 2021 20:29:51 +0000
Importance: Normal
Attachments: unnamed
EFTA00017903


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=== Page 1 ===
From:
To:
Bcc:
"
Subject: 2020-12-16 GM renewed bail motion opposition FINAL.docx
Date: Wed, 16 Dec 2020 22:26:41 +0000
Embedded: 2020-12-16_GM_renewed_bail_motion_opposition_FINAL.docx.msg
Sender:
Subject: 2020-12-16 GM renewed bail motion opposition FINAL.docx
Message-Id:
<BN1P110MB017999B3D54972D6E1D5E2D38AC50@BN1P110MB0179.NAMP110.PROD.OUTLOOK.CO
M>
To:
EFTA00019243


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=== Page 1 ===
From:
(USANYS)"
To:
,
(USANYS)"
Cc:
(USANYS)"
Subject: Re: Important question re USA V Ghislaine Maxwell
Date: Sun, 05 Jul 2020 01:23:54 +0000
No worries at all - we just forward all these to you!
Sent from my iPhone
On Jul 4, 2020, at 20:36,
(USANYS)
wrote:
,
I'll respond and also let them know not to contact you anymore.
Sent from my iPhone
On Jul 4, 2020, at 7:15 PM,
(USANYS)
wrote:
FYI
Sent from my iPhone
Begin forwarded message:
From: kathryn milofsky
Date: July 4, 2020 at 19:08:45 EDT
To:
"
"
N
Subject: Important question re USA V Ghislaine Maxwell
Reply-To: kathryn milofsky
Dear Mr Rosmiller, Ms Moe,
I am Kathryn Milofsky a producer for ITV News in the UK, based in NY.We are the largest commercial
broadcaster in the UK, similar in style stature to NBC.
We are trying to establish when the bail hearing is in your case USA V Maxwell.
Could you be so kind as to let me know.
Have a wonderful safe July 4th.
Best
Kathryn Milofsky
Producer
ITV News
EFTA00019535

=== Page 2 ===
EFTA00019536


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=== Page 1 ===
From: Jane Lytvynenko
To: undisclosed-recipients:;
Bec:
)"
Subject:
Date: Sat, 10 Aug 2019 13:25:37 +0000
Hello,
I'm a reporter with BuzzFeed News. We're seeing reports that Jeffrey Epstein has died. Could you please
confirm?
Thank you,
Jane
Jane Lytvynenko I
I
Reporter I BuzzFeed News
PGP I Signal, WhatsApp, Telegram, Cell:
Send anonymous tip:
EFTA00019947


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=== Page 1 ===
From:
To:
Subject:
Date: Wed, 27 Jan 2021 23:13:21 +0000
Attachments: 2016.2.29_Meeting_Notes_and_Business_Cards.pdf;
!Memo_of_Law_ISO_Motion_to_Suppress_Evidence_Obtained_from_BSF_Subpoena_(Un
redacted).pdf
Motion and our notes of the
neeting attached.
U.S. Attorney's Office for the
Southern District of New York
EFTA00019070


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=== Page 1 ===
Event: Accepted: Update Conference Call - Epstein
Start Date: 2019-08-13 13:30:00 +0000
End Date: 2019-08-13 14:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-08-13 13:42:04 +0000
Date Modified: 2019-08-13 13:42:04 +0000
Priority: 5
DTSTAMP: 2019-08-13 00:09:51 +0000
Attendee:
(USANYS)
EFTA00019863


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=== Page 1 ===
Steptoe
STEPTOE & JOHNSON LLP
Michael C. Miller
212 506 3955 direct
212 506 3950 fax
1114 Avenue of the Americas
New York, NY 10036
212 506 3900 main
www.steptoe.com
August 20, 2019
Via Electronic Mail
Federal Bureau of Investigation, New York Field Office
26 Federal Plaza
New York, NY 10278
Re:
United States v. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.)
Dear Ms. Maguire,
We represent Jeffrey Epstein, Reg No. 76318-054, who was previously
incarcerated at the Metropolitan Correction Center in New York, New York (the "MCC")
while awaiting trial on federal charges in the above-captioned case. We have been
authorized by his estate to write pursuant to 28 C.F.R. §§ 16.21-16.26 to request
documents and records from the U.S. Department of Justice related to Mr. Epstein.
Specifically, we are seeking: any (1) protocols relating to the response
to/investigation of inmate deaths within the MCC; (2) video recordings of all entrances
and exits to the MCC; (3) entry and exit logs for the MCC; (4) video recordings of the
hallways of the floor on which Mr. Epstein's cell was located; and (5) logs related to the
guards on duty at the MCC (collectively, the "Requested Evidence"). The applicable
time period for the requests is from 7:00 am on Friday, August 9, 2019 until 8:00 am on
Saturday, August 10, 2019. As required by the regulations, we set forth below a
summary of the relevance of the Requested Evidence.
Mr. Epstein died in federal custody in his cell at the MCC. We are troubled by the
circumstances of his death and by reports of irregularities at the facility. According to a
statement issued by the Federal Bureau of Prisons:
On Saturday, August 10, 2019, at approximately 6:30 a.m., inmate Jeffrey
Edward Epstein was found unresponsive in his cell in the Special Housing Unit
EFTA00019411

=== Page 2 ===
August 20, 2019
Page 2
from an apparent suicide at the Metropolitan Correctional Center (MCC) in New
York, New York. Life-saving measures were initiated immediately by responding
staff. Staff requested emergency medical services (EMS) and life-saving efforts
continued. Mr. Epstein was transported by EMS to a local hospital for treatment
of life-threatening injuries, and subsequently pronounced dead by hospital staff.
The FBI is investigating the incident.
In a separate statement, Attorney General William P. Barr indicated that "Mr. Epstein's
death raises serious questions that must be answered." On August 12, Mr. Barr further
stated, "We are now learning of serious irregularities at this facility that are deeply
concerning and that demand a thorough investigation."
Moreover, there was initial uncertainty about the cause and manner of Mr.
Epstein's death. The New York City Office of Chief Medical Examiner ("OCME")
declined to immediately release a determination, citing the need for "further
information." Days later, the OCME announced that it had reached a conclusion
following a "careful review of all investigative information."
We intend to conduct our own investigation into the circumstances of Mr.
Epstein's death. In order to do so, we ask that the Requested Evidence be made
available to counsel.
Please let us know if you would like to discuss this request.
Sincerely,
include
Michael Miller
Steptoe & Johnson LLP
1114 Avenue of the Americas
New York, NY 10036
Martin G. Weinberg
Martin G. Weinberg, P.C.
20 Park Plaza, Suite 1000
Boston, MA 02116
EFTA00019412


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=== Page 1 ===
From:
To:
Subject: MCC Suicide/Epstein
Date: Sat, 10 Aug 2019 18:31:13 +0000
Not sure who is handling this but just reaching out to touch base.
FBI New York
EFTA00018984


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=== Page 1 ===
From:
To:
Subject: Could Jeffrey Epstein's New York townhouse be turned into an art museum? I Fox Business
Date: Tue, 21 Jan 2020 13:20:38 +0000
https://www.foxbusiness.com/lifestyle/jeffrey-epstein-new-york-mansion-an-art-museum
Sent from my iPhone
EFTA00018251


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=== Page 1 ===
From:
To:
Subject: RE: Efrain Reyes
Date: Mon, 30 Nov 2020 15:26:33 +0000
Yes, I agree.
From:
Sent: Monday, November 30, 2020 10:26 AM
To:
Subject: RE: Efrain Reyes
That's really sad.
EFTA00017827


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=== Page 1 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before
the GRAND JURY of the people of the United States for the Southern District of New York, at the United States
Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the
Southern District of New York, at the following date, time and place:
Appearance Date:
Appearance Time:
to testify and give evidence in regard to an alleged violation of :
18 U.S.C. §§ 371, 1001, 1519
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
Personal appearance is required unless excused by the U.S. Attorney's Office for the Southern
District of New York. Please see the attached riders.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
August 15, 2019
Geoffey S. Bermine
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
rev. 02.01.12
EFTA00018955

=== Page 2 ===
RIDER
(Grand Jury Subpoena to
dated August 15, 2019)
Advice of Rights
1. You may refuse to answer any question if a truthful answer to the question would tend to
incriminate you.
2. Anything that you do say may be used against you by the grand jury or in a subsequent legal
proceeding.
3. If you have a lawyer, the grand jury will permit you a reasonable opportunity to step outside the
grand jury room to consult with your lawyer if you so desire.
4. If you would like a lawyer but do not have funds to retain one, you may make an application to
the United States Magistrate Judge who will decide whether to appoint a lawyer to represent you.
Instructions and Definitions:
1. This subpoena calls for the production of categories of documents, records, correspondence,
other written material (including electronically stored material), and physical items, as specified
below, in your possession, custody or control.
2. This subpoena covers all responsive documents wherever they may be found, including on
computers, email accounts, iCloud accounts, servers, cellphones, and other personal electronic
devices, whether in the United States or any foreign jurisdiction.
3. This subpoena does not call for the production of any documents protected by a valid claim of
privilege, although any responsive document over which privilege is being asserted must be
preserved. Any documents withheld on grounds of privilege must be specifically identified on a
privilege log with descriptions sufficient to identify their dates, authors, recipients, and general
subject matter.
Materials to be Produced:
1. All materials relating to Jeffrey Epstein including, but not limited to, any text messages, emails,
social media messages or posts, documents, or notes.
EFTA00018956


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=== Page 1 ===
Event: Accepted: Meet re Epstein
Start Date: 2019-04-25 14:00:00 +0000
End Date: 2019-04-25 14:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-04-25 13:42:42 +0000
Date Modified: 2019-04-25 13:42:42 +0000
Priority: 5
DTSTAMP: 2019-04-25 13:24:04 +0000
Attendee
EFTA00017793


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=== Page 1 ===
From:
)"
To:
)"
Cc:
)"
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She
is willing to fly to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to
discuss ?
Date: Mon, 21 Oct 2019 13:53:59 +0000
Sounds good, thanks, and sorry not to be available.
From:
Sent: Monday, October 21, 2019 09:37
To:
Cc:
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to
New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
I think we try to make this work. I can stay late on Wednesday.
From:
Sent: Friday, October 18, 2019 10:13 PM
To:
Cc:
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to
New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
I would say yes but we're pretty stacked on Wednesday (and I have a hard cut-off at 6:30 - Hadestown!). We could split
up, or ask if she could do another day
thoughts,
?
From:
Sent: Friday, October 18, 2019 19:17
To:
is
Subject: Fwd: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria just left me a vm- she said the client is a victim form the 90s and is willing to be interviewed on Wednesday. I
think she wants to know soon whether we want to do that, because it affects trial arrangements. l'll be on trial on
Wednesday, so defer to you as to whether that fits your schedules.
Sent from my iPhone
Begin forwarded message:
From: Gloria Allred
Date: October 18, 2019 at 5:02:17 PM EDT
To:
)"
Cc:
)"
EFTA00019706

=== Page 2 ===
Subject: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.jpg>
<image002.png>
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
EFTA00019707


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Cc:
(USANYS)"
)"
Subject: Re: well this is interesting
Date: Sun, 07 Jul 2019 21:52:00 +0000
Importance: Normal
Very interesting
Sent from my iPhone
On Jul 7, 2019, at 5:41 PM,
)
wrote:
Reid Weingarten will be appearing (with Marty Weinberg) on behalf of Epstein tomorrow.
We'll get the download from the Buffalo team!
Assistant U.S. Attorney
Southern District of New York
EFTA00018146


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Epstein
Date: Mon, 26 Aug 2019 17:29:29 +0000
We spoke with her, all set. Thanks.
Sent from my iPhone
On Aug 26, 2019, at 1:22 PM,
wrote:
Sent from my iPhone
Begin forwarded message:
From:
Date: August 26, 2019 at 12:39:45 EDT
To:
Subject: Epstein
Hi, This is
's attorney,
Please give me a call regarding tomorrow
Sent from my iPhone
EFTA00020125


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=== Page 1 ===
From:
)"
To:
Cc:
)"
,
)"
Subject: Epstein Devices SW
Date: Thu, 25 Jun 2020 16:13:20 +0000
Attachments: SW_for_all_JE_electronic_devices_v5.docx
and
Attached is a draft search warrant affidavit seeking authorization to expand the scope of our search of Epstein's devices.
Thank you so much for your help pulling together the information for this. I left
as the affiant because I believe he
swore out the most recent warrant, but let me know if I should switch it to Mandy instead.
Our hope is to get this to Judge Gorenstein this afternoon and swear it out tomorrow. Whichever of you will be the
affiant, would you please call me with any corrections/edits to the affidavit? You'll see there's one question in there from
Ted about whether we've seen any photos of Maxwell on the discs seized from the NY residence that I'm hoping you can
help me answer.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00020232


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=== Page 1 ===
From:
To:
)"
Cc:
Subject: RE: RE: documents for Relativity
Date: Tue, 26 Mar 2019 12:39:42 +0000
Importance: Normal
Will do.
Thank you.
From:
Sent: Monday, March 25, 2019 7:00 PM
To: R
Subject: RE: documents for Relativity
Could we please load the documents in the following folder into Relativity for US V. Epstein (USAO # 2018R01618):
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#2018 SDNYinvestigation\Subpoena
Returns\ Boies Schiller\2019-03-04, Boies Schiller first subpoena response
In terms of structure, we'd like to create a folder identified as "Subpoena Returns" (at the same level as "FBI Case File" is
currently), and in a subfolder within Subpoena Returns, a folder titled "BSF returns," and within that a subfolder identified
as "BSF first production" that the docs in the above link can be deposited into (including any additional subfolders). Does
that work?
Please let me know if any questions or if any other information would be helpful, and if you could please let us know
when it's all uploaded?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00019549


c1: EFTA00018223
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018223.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Call on Epstein
Start Date: 2020-02-04 18:30:00 +0000
End Date: 2020-02-04 19:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-02-04 15:51:23 +0000
Date Modified: 2020-02-04 15:51:23 +0000
Priority: 5
DTSTAMP: 2020-02-04 15:41:09 +0000
Attendee:
EFTA00018223


c1: EFTA00017884
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00017884.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Court Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Palm Beach School District
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend
before the United States District Court for the Southern District of New York, 40 Foley Square, in the
Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the
following date, time and place:
Appearance Date:
November 29, 2021
Appearance Time: 9:00 a.m.
Appearance Place:
40 Foley Square, Courtroom 906
to testify and give evidence in the following matter:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring
with you and produce at the above time and place the following:
PERSONAL APPEARANCE IS REQUIRED
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
September 16, 2021
AUDREY STRAUSS
United States Attorney for the
UNITED COURT
Southern District of New York
FOR
THE
YORK
Assistant United States Attorney
One St. Andrew's Plaza
New York, New York 10007
Email:
Telephone:
rev. 02.01.12
EFTA00017884

=== Page 2 ===
EFTA00017885


c1: EFTA00018134
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00018134.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject:
302
Date: Tue, 03 Sep 2019 13:28:28 +0000
Importance: Normal
Attachments: Fernandez_302.pdf
Please see attached. We have no issues with you producing this to the defense, but do you have a protective order in
your case? Thanks.
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00018134


c1: EFTA00019774
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0003/EFTA00019774.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
mcc new TORK
mcc new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
SPECIME HOUSING WAIT
L-TIER
DATE: 08/09/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1201
202
8:00-8:30 AM
208
803
4:00-4:30 PM
401
402
12:30- 1:00 AM
1233
1234
8:30-9:00 AM
836
83
4:30-5:00 PM
433
434
1:00-1:30 AM
103
hol
9:00-9:30 AM
908
909
5:00-5:30 PM
503
504
1:30-2:00 AM
13'
132
9:30-10:00 AM
960
941
5:30-6:00 PM
531
5321
2:00-2:30 AM
201
202
10:00-10:30 AM
10"
1012
6:00-6:30 PM
Col
602
2:30-3:00 AM
235
236
10:30-11:00 AM
10
10
6:30-7:00 PM
635
634
3:00-3:30 AM
301
302
11:00-11:30 AM
1108
11
7:00-7:30 PM
701
702
3:30-4:00 AM
333
34
11:30-12:00 AM
1138
sell
7:30-8:00 PM
733
734
4:00-4:30 AM
416
407
12:00-12:30 PM
1713
1214
8:00-8:30 PM
806
807
4:30-5:00 AM
430
431
12:30- 1:00 PM
1238
sell
8:30-9:00 PM
830
8
5:00-5:30 AM
500
501
1:00-1:30 PM
08
109
9:00-9:30 PM
900
901
5:30-6:00 AM
533
300
1:30-2:00 PM
180
141
9:30-10:00 PM
938
934
6:00-6:30 AM
60
603
2:00-2:30 PM
you
go?
10:00-10:30 PM
1002
1003
6:30-7:00 AM
632
633
2:30-3:00 PM
10:30-11:00 PM
1932
1038
7:00-7:30 AM
702
703
3:00-3:30 PM
11:00-11:30 PM
1102
1103
7:30-8:00 AM
727
3:30-4:00 PM
11:30-12:00 PM
73
1131
1132
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be
conducted on an irregular schedule and no more than 40 minutes apart. All observations must be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019774

=== Page 2 ===
mcc new YORK
mcc new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
SPECIAL HOUSING VAIT
M-TIER
DATE: 08/09/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1203
1204
8:00-8:30 AM
8"
8R
4:00-4:30 PM
403
404
12:30- 1:00 AM
1235
D36
8:30-9:00 AM
8.8
839
4:30-5:00 PM
435
436
1:00-1:30 AM
105
106
9:00-9:30 AM
910
9"
5:00 -5:30 PM
505
506
1:30-2:00 AM
133
134
9:30-10:00 AM
946
94
5:30-6:00 PM
583
5340
2:00-2:30 AM
500
204
10:00-10:30 AM
10"
10"
6:00-6:30 PM
600
604
2:30-3:00 AM
231
238
10:30-11:00 AM
1037
1038
6:30-7:00 PM
637
638(
3:00-3:30 AM
303
304
11:00-11:30 AM
1108
1109
7:00-7:30 PM
703
Droto
3:30-4:00 AM
335
334
11:30-12:00 AM
50
1,51
7:30-8:00 PM
sets
7360
4:00-4:30 AM
408
yea
12:00-12:30 PM
200
10"
8:00-8:30 PM
808
809
4:30-5:00 AM
437
433
12:30- 1:00 PM
738
1739
8:30-9:00 PM
882
8331
5:00-5:30 AM
5(2
503
1:00-1:30 PM
08
605
9:00-9:30 PM
902
903
5:30-6:00 AM
535
36
1:30-2:00 PM
137
38
9:30-10:00 PM
seb
936
6:00-6:30 AM
600
605
2:00-2:30 PM
"I"
712
10:00-10:30 PM
1004
100
6:30-7:00 AM
634
635
2:30-3:00 PM
10:30-11:00 PM
1034
1035
7:00-7:30 AM
704
75
3:00-3:30 PM
11:00-11:30 PM
1104
1105
7:30-8:00 AM
733
734
3:30-4:00 PM
11:30-12:00 PM
1133
1134
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. — 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be
conducted on an irregular schedule and no more than 40 minutes apart. All observations must be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019775

=== Page 3 ===
acc new YORK
MCC NEW YORK
mcc new YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
ZA
SPECIAL HOUSING UNIT
TIER-J
DATE: 08/09/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1205
1206
8:00-8:30 AM
806
80
4:00-4:30 PM
405
406
12:30- 1:00 AM
1237
1238
8:30-9:00 AM
859
880
4:30-5:00 PM
437
438
1:00-1:30 AM
107
108
9:00-9:30 AM
9"
912
5:00 -5:30 PM
507
5°S
1:30-2:00 AM
135
134
9:30-10:00 AM
941
942
5:30-6:00 PM
535
530
2:00-2:30 AM
205
206
10:00-10:30 AM
10"
1012
6:00-6:30 PM
605
Col
2:30-3:00 AM
239
240
10:30-11:00 AM
031
1000
6:30-7:00 PM
639
64
3:00-3:30 AM
305
3C4
11:00-11:30 AM
1106
107
7:00-7:30 PM
too
706
3:30-4:00 AM
337
338
11:30-12:00 AM
1149
es../
7:30-8:00 PM
0737
73
4:00-4:30 AM
410
4"
12:00-12:30 PM
b"
1212
8:00-8:30 PM
810
8"
4:30-5:00 AM
434
435
12:30- 1:00 PM
750
10st
8:30-9:00 PM
884
835
5:00-5:30 AM
504
555
1:00-1:30 PM
108
109
9:00-9:30 PM
94
g
5:30-6:00 AM
537
538
1:30-2:00 PM
18
6t/1
9:30-10:00 PM
637
938
6:00-6:30 AM
606
607
2:00-2:30 PM
110
"I"
10:00-10:30 PM
1004
100
6:30-7:00 AM
636
637
2:30-3:00 PM
10:30-11:00 PM
1030
00
7:00-7:30 AM
707
706
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
735
736
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be
conducted on an irregular schedule and no more than 40 minutes apart. All observations must be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019776

=== Page 4 ===
mcc new YORK
mpc new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
ZA
SPECIAL HOUSING UNIT
TIER-K
DATE: 08/09/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1707
1208
8:00-8:30 AM
805
806
4:00-4:30 PM
407
408
12:30- 1:00 AM
1239
1240
8:30-9:00 AM
85
838
4:30-5:00 PM
489
440
1:00-1:30 AM
109
110
9:00-9:30 AM
9"
9th
5:00 -5:30 PM
509
5'⁰
1:30-2:00 AM
137
3El
9:30-10:00 AM
938
555
5:30-6:00 PM
537
"
2:00-2:30 AM
207
208
10:00-10:30 AM
10"
1012
6:00-6:30 PM
67
60
2:30-3:00 AM
241
242
10:30-11:00 AM
10th
V4
6:30-7:00 PM
641
(042
3:00-3:30 AM
307
308
11:00-11:30 AM
1115
91/
7:00-7:30 PM
LOLO
you
3:30-4:00 AM
339
340
11:30-12:00 AM
68,11
-90
7:30-8:00 PM
739
C/40
4:00-4:30 AM
42
413
12:00-12:30 PM
D"
1212
8:00-8:30 PM
812
813
4:30-5:00 AM
434
437
12:30- 1:00 PM
198
1749
8:30-9:00 PM
836
839
5:00-5:30 AM
500
507
1:00-1:30 PM
111
12
9:00-9:30 PM
aple
900
5:30-6:00 AM
539
540
1:30-2:00 PM
ag.)
'si
9:30-10:00 PM
989
940
6:00-6:30 AM
CS8
69
2:00-2:30 PM
7%
you
10:00-10:30 PM
1008
10°
6:30-7:00 AM
USE
639
2:30-3:00 PM
10:30-11:00 PM
1035
108
7:00-7:30 AM
708
3:00-3:30 PM
11:00-11:30 PM
707
7:30-8:00 AM
737
738
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m.- 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be
conducted on an irregular schedule and no more than 40 minutes apart. All observations must be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019777

=== Page 5 ===
mcc new TORK
mcc new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING WAIT
SPECIAL HOUSING UNIT
ZA
TIER-G
DATE: 08/09/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
1204
12'0
8:00-8:30 AM
sal
588
4:00-4:30 PM
409
410
12:30- 1:00 AM
1241
1242
8:30-9:00 AM
850
&
4:30-5:00 PM
441
442
1:00-1:30 AM
I"
112
9:00-9:30 AM
9"
912
5:00-5:30 PM
5"
512
1:30-2:00 AM
134
140
9:30-10:00 AM
0146
(A)
5:30-6:00 PM
537
540
2:00-2:30 AM
2ch
210
10:00-10:30 AM
1010
10"
6:00-6:30 PM
609
60
2:30-3:00 AM
243
244
10:30-11:00 AM
1040
104
6:30-7:00 PM
1013
64
3:00-3:30 AM
3c9
310
11:00-11:30 AM
4/18
//19
7:00-7:30 PM
709
710
3:30-4:00 AM
341
342
11:30-12:00 AM
cs ll
11'51
7:30-8:00 PM
741
742
4:00-4:30 AM
414
415
12:00-12:30 PM
nill
Dr
8:00-8:30 PM
814
8'5
4:30-5:00 AM
438
439
12:30- 1:00 PM
10th
1744
8:30-9:00 PM
838
839
5:00-5:30 AM
508
5c9
1:00-1:30 PM
108
109
9:00-9:30 PM
908
909
5:30-6:00 AM
541
5"2
1:30-2:00 PM
38
139
9:30-10:00 PM
Q41
942
6:00-6:30 AM
610
6"
2:00-2:30 PM
7"
12
10:00-10:30 PM
1010
10"
6:30-7:00 AM
6/0
64/
2:30-3:00 PM
10:30-11:00 PM
1040
1041
7:00-7:30 AM
709
710
3:00-3:30 PM
11:00-11:30 PM
7:30-8:00 AM
739
740
3:30-4:00 PM
11:30-12:00 PM
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be
conducted on an irregular schedule and no more than 40 minutes apart. All observations must be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019778

=== Page 6 ===
mcc new YORK
MCC new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
SPECIAL HOUSING UNIT
ZA
TIER-H
DATE: 08/09/2019
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
START
END
START
END
START
END
FRAME
12:00-12:30 AM
12"
1212
8:00-8:30 AM
813
8'4
4:00-4:30 PM
4"
412
12:30- 1:00 AM
1243
1244
8:30-9:00 AM
852
863
4:30-5:00 PM
443
44
1:00-1:30 AM
113
114
9:00-9:30 AM
110
9R
5:00-5:30 PM
513
514
1:30-2:00 AM
141
142
9:30-10:00 AM
946
94)
5:30-6:00 PM
541
54
2:00-2:30 AM
2"
212
10:00-10:30 AM
1012
1013
6:00-6:30 PM
101
612
2:30-3:00 AM
2115
246
10:30-11:00 AM
1038
103r
6:30-7:00 PM
UD
1614
3:00-3:30 AM
3"
312
11:00-11:30 AM
81/1
1/14
7:00-7:30 PM
711
710
3:30-4:00 AM
343
344
11:30-12:00 AM
cell
138
7:30-8:00 PM
Este
944
4:00-4:30 AM
416
417
12:00-12:30 PM
718
719
8:00-8:30 PM
8"6
ErS
4:30-5:00 AM
yuo
441
12:30- 1:00 PM
1044
295
8:30-9:00 PM
840
841
5:00-5:30 AM
5.0
is
1:00-1:30 PM
89/
09
9:00-9:30 PM
Q10
a
5:30-6:00 AM
5.13
544
1:30-2:00 PM
137
38
9:30-10:00 PM
943
944
6:00-6:30 AM
6'2
65
2:00-2:30 PM
208
209
10:00-10:30 PM
102
104
6:30-7:00 AM
602
643
2:30-3:00 PM
10:30-11:00 PM
10th
1043
7:00-7:30 AM
712
3:00-3:30 PM
11:00-11:30 PM
7"
7:30-8:00 AM
7"
3:30-4:00 PM
11:30-12:00 PM
702
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be
conducted on an irregular schedule and no more than 40 minutes apart. All observations must be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019779

=== Page 7 ===
moo new TORK
mcc new YORK
MCC NEW YORK
SPECIAL HOUSING UNIT
SPECIAL HOUSING UNIT
30 MINUTE CHECK SHEET
SPECIAL HOUSING UNIT
ZB
DATE: 8-9-19
TIME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
TIME FRAME
TIME
TIME
SIGNATURE
RAME
START
END
START
END
START
END
12:00-12:30 AM
12:00AM
1203
8:00-8:30 AM
8:13
8:15
4:00-4:30 PM
405
400
12:30- 1:00 AM
12:30
12:33
8:30- 9:00 AM
8:48
8:50
4:30-5:00 PM
432
435
1:00-1:30 AM
1:00
103
9:00-9:30 AM
9:08
9:10
5:00-5:30 PM
501
504
1:30-2:00 AM
130
133
9:30-10:00 AM
9:36
9:38
5:30-6:00 PM
536
538
2:00-2:30 AM
200
203
10:00-10:30 AM
10:12
10:14
6:00-6:30 PM
603
606
2:30-3:00 AM
230
233
10:30-11:00 AM
10:47
10:49
6:30-7:00 PM
631
633
3:00-3:30 AM
300
303
11:00-11:30 AM
11:22
11:24
7:00-7:30 PM
707
709
3:30-4:00 AM
330
333
11:30-12:00 AM
11:57
11:59
7:30-8:00 PM
735
738
4:00-4:30 AM
400
403
12:00-12:30 PM
12:11
12:13
8:00-8:30 PM
802
804
4:30-5:00 AM
430
433
12:30- 1:00 PM
12:36
11:38
8:30-9:00 PM
839
842
5:00-5:30 AM
5 100
5303
1:00-1:30 PM
1:24
1:20
9:00-9:30 PM
910
913
5:30-6:00 AM
530
533
1:30-2:00 PM
1:41
1:43
9:30-10:00 PM
943
946
6:00-6:30 AM
600
603
2:00-2:30 PM
2:03
2:05
10:00-10:30 PM
1014
1017
6:30-7:00 AM
630
633
2:30-3:00 PM
2:23
2:25
10:30-11:00 PM
1046
1040
7:00-7:30 AM
3:00-3:30 PM
700
3:09
11:00-11:30 PM
703
3:11
N19
1121
7:30-8:00 AM
730
733
3:30-4:00 PM
11:30-12:00 PM
3:49
3:51
1778
115
MORNING WATCH
DAY WATCH
EVENING WATCH
OPERATIONS
OPERATIONS
OPERATIONS
LIEUTENANT
LIEUTENANT
LIEUTENANT
A staff member must observe all inmates confined in a continuous locked down status, such as administrative
detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
a.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
12:30 am - 1:00 a.m.), thus ensuring an inmate is observed at least twice per hour. These rounds are to be
conducted on an irregular schedule and no more than 40 minutes apar
ist be
documented.
REVIEWED BY MORNING WATCH LIEUTENANT
CAPTAIN
EFTA00019780

=== Page 8 ===


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=== Page 1 ===
From:
To:
,
Subject: FW: Language to include
Date: Thu, 02 Jul 2020 02:27:04 +0000
Attachments: contact_list_only_31E-NY-3027571_6.26.2020.xlsx
could you please take on this project of making sure the victim info in the database is accurate for the letter that will
go out? I can't tell if this email is just meant to supplement the data we already have, or if they're sending this as the
proposed list (which would be strange, since it has our statutory victims on it). Thanks.
From:
Sent: Wednesday, July 1, 2020 9:37 PM
To:
is
>;
>;
Cc:
Subject: Re: Language to include
Good Evening,
SA
has identified each of these names on the attached spreadsheet as victims in the original case
against Jeffrey Epstein. Included in the attached document is victim contact information as well as attorney
information regarding representation and contact information. This is a comprehensive list.
Lastly, would you be able to send your draft language for the VNS notifications?
Thank you,
Program Manager
FBI Victim Services Division
From:
Sent: Monday, June 29, 2020 9:05 AM
To:
Cc:
^
Subject: Language to include
Good Morning,
I hope each of you had a good weekend. Please find language below that has been approved by FBI NY, VSD
executive management and our OGC rep. I'm more than happy to have a call if you would like to discuss.
EFTA00020240

=== Page 2 ===
The FBI's Victim Services Division (VSD) is committed to providing services and support to victims of crimes
committed by Jeffrey Epstein. Though this particular indictment is focused on specific individuals, you are still
entitled to your rights, resources, and referrals as a federal victim independent of this indictment. An overview
of these services is available at www.fbi.gov/resources/victim-services If you would like to speak with a Victim
Specialist, or if you have any questions regarding your rights to victim services and referrals, please email
victimservices@fbi.gov.
Thank you,
Program Manager
FBI Victim Services Division
EFTA00020241


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=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
Subject: Epstein
Date: Sat, 10 Aug 2019 15:10:41 +0000
All,
Sorry to see the sad news about Epstein. I'm sure you're shaken.
,
and I went through a similar
suicide three years ago with a securities fraud defendant. If you need anything, we're here for you. You were
doing you're job and obviously no one wishes harm to come to anyone.
EFTA00019949


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=== Page 1 ===
From:
(NY) (FBI)"
To:
)"
Cc:
(NY) (FBI)"
)"
Subject: RE: GM bank accounts
Date: Thu, 02 Jul 2020 14:01:50 +0000
Attachments: SUMMARY_OF_MAXWELL_BANK_ACCTS_V1.pdf;
SUMMARY_OF_MAXWELL_CREDIT_CARDS_ACCTS_V1.pdf
I have attached the schedule of bank accounts you requested. Additionally, I have attached a schedule of credit cards.
Please contact me if you have any questions.
Best
From:
) [mailto:
Sent: Wednesday, July 01, 2020 12:46 PM
To:
(NY) (FBI)
Cc:
(NY) (FBI)
is
^
is
)
is
Subject: GM bank accounts
With apologies for the quick turn around on this, could you please send us a list of all known bank accounts held in
Maxwell's name (or otherwise associated with her)? For those accounts, please provide the last year/month we have
account statements for, whether we know if the account is still open, and the account balance as of that statement. On
the list, please include accounts that we are aware of but do not yet have information for. If you could please send this
today, that would be ideal.
Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00020364


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=== Page 1 ===
From:
)"
To: Gloria Allred
Cc:
)"
,
)"
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of
Epstein. She is willing to fly to New York for the victim meeting on Oct. 23. May I call you
at 5:45 P.M. to discuss ?
Date: Tue, 22 Oct 2019 18:59:08 +0000
Inline-Images: image003.jpg; image004.png
Will do. Would you please let us know when would be a good time to reschedule?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gloria Allred
Sent: Tuesday, October 22, 2019 2:56 PM
To:
Subject: RE: Urgent. I have a new alleged victim of EI have a new client who was a victim of Epstein. She is willing to fly to
New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Please cancel for today. Sorry.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
ALLRED. MAROKO & GOLDBERG
2019
Best Lawyers
Martindale-Hubbell
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
From:
)
Sent: Tuesday, October 22, 2019 11:54 AM
EFTA00019708

=== Page 2 ===
To: Gloria Allred
Cc:
is
Subject: Re: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to
New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria,
Is
still available for our 4pm call, or do we need to reschedule?
Thanks,
On Oct 22, 2019, at 12:26 PM,
wrote:
Ok thanks, please keep us posted. We are happy to accommodate
schedule.
And yes, we can speak with
at your office from noon to 1pm tomorrow.
will be the AUSA
handling that meeting.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gloria Allred
Sent: Tuesday, October 22, 2019 12:24 PM
To:
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Just a heads up. I think she is needing to reschedule and is cancelling for today. I will let you know a.s.a.p. or by 2P.M. at
the latest. Sorry. Also, re
for tomorrow.can you speak to her from noon to 1 P.M. at my office at 305
Broadway? I need to leave at 1P.M. to catch the train to D.C.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image003.jpg>
<image004.png>
EFTA00019709

=== Page 3 ===
From:
Sent: Tuesday, October 22, 2019 8:19 AM
To: Gloria Allred
Cc:
in
>; Young, Amanda N. (NY) (FBI)
Subject: Re: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Hi Gloria,
We are find with a conference call this afternoon if that is ok with your client. We can use the below dial-in:
Passcode
And your proposed time for
interview works on our end.
Thanks,
On Oct 21, 2019, at 8:11 PM, Gloria Allred
wrote:
I have 2 questions. First, would it be o.k. with all of you if we did the call with
tomorrow at 4P.M. e.s.t as a
conference call rather than as a Skype call? We will be in at least 4 different locations and I think it will be easier if we
did it that way. If so, please send us the number to dial. Daniel from my CO counsel Marianne Wang's office will also be
joining us on the call. Also ,re
my client who is flying in for victim services will be happy to speak with you, but I
have a very tight schedule on Wednesday, because I need to be on a 1 or at the latest 2 P.M. train to D.C. that day.
Could we have the meeting from noon to 1P.M.? My office is only one block away from the FBI meeting.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.jpg>
<image002.png>
From:
Sent: Monday, October 21, 2019 6:40 AM
To: Gloria Allred
i
Cc:
>; Young, Amanda N. (NY) (FBI)
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to
fly to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria,
We will make ourselves available to meet with your new client on 10/23. Because the victim meeting is being run by
the FBI, their victim services folks are handling travel logistics. I'm cc'ing
who should be able to
hopefully help coordinate travel. Would you please provide
with your new client's name as it appears on her
ID, date of birth, email address, and phone number?
EFTA00019710

=== Page 4 ===
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gloria Allred
Sent: Friday, October 18, 2019 5:02 PM
To:
Cc:
Subject: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to
New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image003.jpg>
<image004.png>
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
EFTA00019711

=== Page 5 ===
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
EFTA00019712


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=== Page 1 ===
From:
To:
Subject: RE:
Date: Thu, 16 Jan 2020 13:40:04 +0000
10-4 that works on our end, if that's alright with all of you
From:
Sent: Wednesday, January 15, 2020 6:07 PM
To:
Subject: RE:
We can move this to Friday 1/24 at 3:30.
From:
Sent: Wednesday, January 15, 2020 10:46 AM
To:
Subject: RE:
Spoke to
- if they want to have the possibility to go longer than an hour the 23rd won't work. But if it's an hour, we
can do it.
From:
Sent: Tuesday, January 14, 2020 12:24 PM
To:
Subject: RE:
We'll take 4 pm on Thursday the 23rd.
From:
Sent: Tuesday, January 14, 2020 9:22 AM
To:
Subject: RE:
We'd be looking at 4-530 then. Sorry,
has meetings with all of the Judges lined up, which take up big chunks of time.
From:
Sent: Tuesday, January 14, 2020 9:20 AM
To:
Subject: RE:
I think so - one more range to check, how about from 2 pm forward on the 23rd?
From:
Sent: Tuesday, January 14, 2020 9:18 AM
To:
Subject: RE:
Looks like 330-5 is the only time that day that works for everyone. Does that work?
EFTA00019231

=== Page 2 ===
From:
Sent: Monday, January 13, 2020 4:20 PM
To:
Subject:
- what is full brass availability on Friday January 24 for a presentation by defense counsel fo
? I would
block off 90 minutes but could be done in 60.
EFTA00019232


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=== Page 1 ===
From:
To:
Cc:
Subject:
trial prep
Date: Mon, 19 Jul 2021 13:09:06 +0000
Attachments: 2021.07.19_Court_Subpoena_
Hi
Good to see you the other day. As I mentioned, our team is planning to call
as a witness at the trial scheduled
to begin on November 29, 2021. For your records, attached please find a trial subpoena. We expect
will
testify relatively early in the trial, and may even get on the stand on
In terms of trial preparation, I'd like to schedule an initial meeting over WebEx, at which point we can pick a time in
August for
to meet with our team in person for further prep at our office. For the WebEx, would you and
be available the morning of 7/26, the afternoon of 7/27, or the morning of 7/30?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00019650


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=== Page 1 ===
From: "Weinstein, Marc A."
To:
)"
Cc: Andrew Tomback
Subject: Epstein Estate update
Date: Mon, 09 Nov 2020 14:49:47 +0000
and
:
Would you have time for a call this afternoon to give you an update on a new development?
Thanks,
Marc
Marc A. Weinstein
Partner
Chair, White Collar Defense
Hughes Hubbard & Reed LLP
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost,
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
EFTA00019126


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=== Page 1 ===
From:
To:
Cc:
Subject: Motion to Quash
Date: Thu, 18 Nov 2021 20:45:14 +0000
Attachments: 2021.11.18_Mot_to_quash_v3.docx; 2021.11.18_Mot_to_quash_v2_to_v3.docx.
Hi all,
Attached is a revised draft and a redline of the motion to quash.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00019418


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=== Page 1 ===
Case 20-2413, Document 140-1, 10/19/2020, 2955244, Page1 of 3
20-2413-cv
v. Maxwell
UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCUIT
SUMMARY ORDER
Rulings by summary order do not have precedential effect. Citation to a summary order filed
on or after January 1, 2007, is permitted and is governed by Federal Rule of Appellate
Procedure 32.1 and this Court's Local Rule 32.1.1. When citing a summary order in a
document filed with this Court, a party must cite either the Federal Appendix or an
electronic database (with the notation "summary order"). A party citing a summary order
must serve a copy of it on any party not represented by counsel.
At a stated term of the United States Court of Appeals for the Second Circuit, held at
the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York,
on the 19th day of October, two thousand twenty.
PRESENT: JOSÉ A. CABRANES,
ROSEMARY S. POOLER,
REENA RAGGI,
Circuit Judges.
,
Plaintiff-Appellee,
20-2413-cv
V.
GHISLAINE MAXWELL,
Defendant-Appellant,
SHARON CHURCHER, JEFFREY EPSTEIN,
Respondents,
JULIE BROWN, MIAMI HERALD MEDIA COMPANY,
MICHAEL CERNOVICH, DBA CERNOVICH MEDIA,
Intervenors.
1
EFTA00018289

=== Page 2 ===
Case 20-2413, Document 140-1, 10/19/2020, 2955244, Page2 of 3
FOR PLAINTIFF-APPELLEE:
DAVID BOIES (Sigrid S. McCawley, on the
brief) Boies Schiller Flexner LLP, Armonk,
NY.
FOR DEFENDANT-APPELLANT:
ADAM MUELLER (Ty Gee, on the brief)
Haddon, Morgan and Foreman, P.C.,
Denver, CO.
FOR INTERVENORS:
CHRISTINE N. WALZ (Sanford L. Bohrer,
on the brief) Holland & Knight LLP, New
York, NY, for Intervenors Julie Brown and
Miami Herald Media Company.
Appeal from an order of the United States District Court for the Southern District of New
York (Loretta A. Preska, Judge).
UPON DUE CONSIDERATION WHEREOF, IT IS HEREBY ORDERED,
ADJUDGED, AND DECREED that the order of the District Court be and hereby is
AFFIRMED.
Defendant-Appellant Ghislaine Maxwell appeals from a July 23, 2020 order unsealing certain
litigation materials, including, and related to, Maxwell's April 2016 deposition transcript. She argues
that the District Court abused its discretion in ordering the unsealing of the deposition materials.
Specifically, she argues that there is a lower presumption of access to the deposition materials at
issue in this case than to the summary judgment materials we ordered unsealed in Brown v. Maxwell,
929 F.3d 41 (2d Cir. 2019), and that her interests outweigh the public's interests. We assume the
parties' familiarity with the underlying facts, the procedural history of the case, and the issues on
appeal.¹
When reviewing a district court's decision to seal a filing or maintain such a seal, "we
examine the court's factual findings for clear error, its legal determinations de novo, and its ultimate
decision to seal or unseal for abuse of discretion." Brown, 929 F.3d at 47 (citing Bernstein v. Bernstein
Litowitz Berger & Grossman LLP, 814 F.3d 132, 139 (2d Cir. 2016)). A district court abuses its
discretion if it "(1) bases its decision on an error of law or uses the wrong legal standard; (2) bases its
decision on a clearly erroneous factual finding; or (3) reaches a conclusion that, though not
necessarily the product of a legal error or a clearly erroneous factual finding, cannot be located
within the range of permissible decisions." Klipsch Grp. Inc. v. Epro E-Commerce Ltd., 880 F.3d 620,
627 (2018) (internal quotation marks omitted).
1 Although Michael Cernovich, DBA Cernovich Media, did not enter an appearance in this
appeal, letters of his dated July 31, 2020 and September 9, 2020 are before the Court.
2
EFTA00018290

=== Page 3 ===
Case 20-2413, Document 140-1, 10/19/2020, 2955244, Page3 of 3
We cannot conclude that the District Court abused its discretion in ordering the unsealing of
the deposition materials. While "the presumption of public access in filings submitted in connection
with discovery disputes or motions in limine is generally somewhat lower than the presumption
applied to material introduced at trial, or in connection with dispositive motions such as motions for
dismissal or summary judgment," the District Court correctly held that the deposition materials are
judicial documents to which the presumption of public access attaches, and did not abuse its
discretion in rejecting Maxwell's meritless arguments that her interests superseded the presumption
of access. Brown, 929 F.3d at 50. The District Court's order articulated and applied the correct legal
framework in its individualized review of the materials to be unsealed.
CONCLUSION
We have reviewed all of the arguments raised by Defendant-Appellant Maxwell on appeal
and find them to be without merit. We DENY the motion to consolidate this appeal with the
pending appeal in United States v. Maxwell, No. 20-3061-cr. For the foregoing reasons, we also
AFFIRM the July 23, 2020 order of the District Court.
In the interest of judicial economy, any further appeal in this civil case shall be referred to
this panel.
The mandate shall issue forthwith.
FOR THE COURT:
Catherine O'Hagan Wolfe, Clerk
UNITED STATES
SECOND
Catherine
CIRCUIT
OF
3
EFTA00018291

=== Page 4 ===
Case 20-2413, Document 140-2, 10/19/2020, 2955244, Page1 of 1
United States Court of Appeals for the Second Circuit
Thurgood Marshall U.S. Courthouse
40 Foley Square
New York, NY 10007
DEBRA ANN LIVINGSTON
CATHERINE O'HAGAN WOLFE
CHIEF JUDGE
CLERK OF COURT
Date: October 19, 2020
DC Docket #: 15-cv-7433
Docket #: 20-2413cv
DC Court: SDNY (NEW YORK
Short Title:
V. Maxwell
CITY)
DC Judge: Preska
BILL OF COSTS INSTRUCTIONS
The requirements for filing a bill of costs are set forth in FRAP 39. A form for filing a bill of
costs is on the Court's website.
The bill of costs must:
*
be filed within 14 days after the entry of judgment;
be verified;
be served on all adversaries;
not include charges for postage, delivery, service, overtime and the filers edits;
identify the number of copies which comprise the printer's unit;
*
include the printer's bills, which must state the minimum charge per printer's unit for a page, a
cover, foot lines by the line, and an index and table of cases by the page;
*
state only the number of necessary copies inserted in enclosed form;
*
state actual costs at rates not higher than those generally charged for printing services in New
York, New York; excessive charges are subject to reduction;
*
be filed via CM/ECF or if counsel is exempted with the original and two copies.
EFTA00018292

=== Page 5 ===
Case 20-2413, Document 140-3, 10/19/2020, 2955244, Page1 of 1
United States Court of Appeals for the Second Circuit
Thurgood Marshall U.S. Courthouse
40 Foley Square
New York, NY 10007
DEBRA ANN LIVINGSTON
CATHERINE O'HAGAN WOLFE
CHIEF JUDGE
CLERK OF COURT
Date: October 19, 2020
DC Docket #: 15-cv-7433
Docket #: 20-2413cv
DC Court: SDNY (NEW YORK
Short Title:
V. Maxwell
CITY)
DC Judge: Preska
VERIFIED ITEMIZED BILL OF COSTS
Counsel for
respectfully submits, pursuant to FRAP 39 (c) the within bill of costs and requests the Clerk to
prepare an itemized statement of costs taxed against the
and in favor of
for insertion in the mandate.
Docketing Fee
Costs of printing appendix (necessary copies
)
Costs of printing brief (necessary copies
)
Costs of printing reply brief (necessary copies
)
(VERIFICATION HERE)
Signature
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=== Page 1 ===
From:
To:
Cc:
Subject: NM USAO
Date: Mon, 20 Jul 2020 22:52:29 +0000
Chiefs,
We received an inquiry from the New Mexico U.S. Attorney's Office about possible forfeiture of Epstein's New Mexico
property. Would you have time for a quick call in the next couple days to discuss, please?
Thanks,
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=== Page 1 ===
From:
To:
Cc:
Subject:
Date: Fri, 01 Nov 2019 15:56:45 +0000
Hi
I wanted to let you know that I just received a call from
,
an attorney in Florida, who reached out to me to
say that he met with
and may be representing them in connection with our investigation and
possible civil litigation. I said that I could not discuss this further, gave him your contact information, and encouraged him
to reach out to you directly to sort this out. I just wanted to let you know because I expect he'll reach out to you.
If you have any questions for us or if a call would be helpful, please let us know.
Best,
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:
(USANYS)"
To:
(USANYS)"
(USANYS)"
(USANYS)"
)"
Cc:
(USANYS)"
)"
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE: Epstein FOIA case, Times V. BOP, 20-cv-833
Date: Fri, 04 Dec 2020 03:54:52 +0000
Embedded: RE:_Epstein_FOIA_case,_Times_v_BOP_20-cv-833.msg
Sender:
Subject: RE: Epstein FOIA case, Times V. BOP, 20-cv-833
Message-Id:
<BN3P110MB0465ADE7E1442B43B2925129FEF10@BN3P110MB0465.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
To:
To:
Cc:
Cc:
Cc:
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=== Page 1 ===
From
To
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:24:13 +0000
Inline-Images: image001.png
Congrats! Well done
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 OF JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
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.
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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.
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GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
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=== Page 1 ===
CURRICULUM VITAE
GAIL S. GOODMAN, PH.D.
I. Personal Information
Office:
Department of Psychology
e-mail:
University of California
phone:
Davis, CA 95616
Place of Birth:
Citizenship:
U.S.A.
II. EDUCATION AND TRAINING
1977
Ph.D. - University of California, Los Angeles
Major: Developmental Psychology
Minors: Perception and Physiological Psychology
1972
M.A. - University of California, Los Angeles
Major: Psychology
1971
B.A. - University of California, Los Angeles
Major: Psychology
Minors: Sociology and Anthropology
III. PROFESSIONAL EXPERIENCE
2006 - present
Distinguished Professor of Psychology
Department of Psychology
University of California, Davis
2004 - present
Director, Center for Public Policy Research
University of California, Davis
2014 - 2017
Visiting Professor, Department of Psychology,
City University London, UK
2000 - 2019, 2021-present
Consultant, Special Assault Forensic Evaluation Center
(formerly Multidisciplinary Interview Center)
Sacramento County Child Protective Services
2001 2006
Professor of Psychology (Adjunct)
University of Oslo, Norway
1992 2005
Professor of Psychology
Department of Psychology
University of California, Davis
3
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1996 2004
Director, Center on Social Sciences and Law
Institute on Governmental Affairs
University of California, Davis
1991 1992
Professor of Psychology
Department of Psychology
State University of New York at Buffalo
1988 1991
Associate Professor of Psychology
Department of Psychology
State University of New York at Buffalo
1987 1988
Associate Professor and Director,
Dual Degree Program in Psychology and Law
Department of Psychology
University of Denver
1982 1987
Assistant Professor and Director,
Dual Degree Program in Psychology and the Law
Department of Psychology
University of Denver
1981 - 1982
Lecturer
Department of Psychology
University of Denver
1980 1981
Research Associate
Department of Psychology
University of Denver
1977 1980
Postdoctoral Fellow
National Institute of Child Health and Human Development
Postdoctoral Fellow in Developmental Psychology
Department of Psychology
University of Denver
1978 1979
Visiting Scholar
Laboratoire de Psychologie Expérimentale
Université Rene Descartes (Paris V)
Paris, France
1976 1977
Lecturer in Developmental Psychology
Department of Psychology
University of California, Riverside
1975 Summer
Predoctoral Trainee at the Summer
Institute on the Genetics of Developmental
Processes for Social Scientists
Institute for Behavioral Genetics
University of Colorado, Boulder
4
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1972 1975
Predoctoral Trainee
National Institute of Mental Health
Predoctoral Trainee in Developmental Psychology
Department of Psychology
University of California, Los Angeles
1973 Summer
Instructor in Child Growth and Human Development
Santa Monica College
1971 - 1972
Research Assistant
Department of Psychology
University of California, Los Angeles
IV.
PROFESSIONAL MEMBERSHIPS
Association for Psychological Science, Fellow
American Psychological Association, Fellow
Divisions: Experimental Psychology, 3 (Fellow); Developmental
Psychology, 7 (Fellow); Society for the Psychological Study of
Social Issues, 9 (Fellow); Society for Child and Family Policy and Practice, 37 (Fellow);
Psychology & Law, 41 (Fellow); Traumatic Stress, 56 (Fellow).
Psychonomics Society, Member
Society for Research in Child Development, Member
Western Psychological Association, Fellow
American Professional Society on the Abuse of Children (APSAC), Founding Member,
Previously on Advisory Committee, Research Committee, etc.
International Society for the Prevention of Child Abuse and Neglect, Member
International Society for Traumatic Stress Studies, Member
Association for Criminal Justice Research (California), Member
V.
HONORS AND AWARDS
Recipient, UC Davis Academic Senate Distinguished Faculty Research Award, 2021
Recipient, the CAPSAC's Karen J. Saywitz Legacy Award, 2021
Member, Norwegian Academy of Science and Letters, 2018-present
Doctor Philosophiae Honoris Causa (Honorary Doctorate), University of Oslo, Norway, 2017
Recipient, American Psychological Association's 2016 Award for Distinguished Contributions to
Research in Public Interest (Senior), 2016
Recipient, Distinguished Contributions to Psychology and Law Award, American Psychology-Law
Society, Division 41, American Psychological Association, 2015
Recipient, James McKeen Cattell Fellow Award for Lifetime Contributions to Applied Research,
Association for Psychological Science, 2012
Recipient, Distinguished Scientific Contribution Award, California Psychological Association, 2010
Recipient, Distinguished Scholarly Public Service Award, University of California, Davis, 2009
Recipient, Urie Brofenbrenner Award for Lifetime Contributions to Developmental Psychology in the
Service of Science and Society, Division 7 (Developmental Psychology), American Psychological
Association, 2008
Recipient, American Psychological Association's 2005 Award for Distinguished Contributions to
Research in Public Policy
Recipient, American Psychological Association's 2005 Award for Distinguished Professional
Contributions to Applied Research
Recipient, Nicholas Hobbs Award, Division 37 (Child, Youth, and Family Services) of the American
Psychological Association, 2003.
5
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Recipient, American Academy of Forensic Psychology's 2002 Award for Distinguished Contributions to
Forensic Psychology
Member, Norwegian Center for Advanced Study/Norwegian National Academy of Sciences, Group on
Eyewitness Memory, 2003-2004
Recipient, Teaching and Mentoring Award from the Consortium on Women and Research, UC Davis,
1998
Recipient, American Psychology and Law (Div. 41) Teaching and Mentoring Award, 1996
Recipient, Robert Chin Award, SPSSI, Division 9 of the American Psychological Association, 1995
(awarded for contribution to the child abuse literature; best paper of the year)
Recipient, American Professional Society on the Abuse of Children Research Career Achievement Award,
1992
Recipient, Steven Schaffer Outstanding Research Contributions Award of the National Organization for
Victim Assistance, 1986
Certificate of Merit, American Bar Association, 1982 Media award for contributing to the public's
knowledge of the American legal system
President, Division 7 (Developmental Psychology) of the American Psychological Association; President-
Elect, 2011-2013; President, 2013-2015; Past-President, 2015-2016.
President, Division 41 (American Psychology-Law Society), American Psychological Association, 1996-
1997; President-Elect, 1995-1996; Past-President, 1997-1998.
President, Section on Child Maltreatment, Division 37 (Children, Youth, and Family Services) of the
American Psychological Association, 1999-2000; President-Elect, 1997-1998; Past President, 2000-
2002.
President, Division 37 (Children, Youth, and Family Services [subsequently renamed Society for Child
and Family Policy and Practice]) of the American Psychological Association, 1992-1993;
President-Elect, 1991-1992; Past- President, 1993-1994
Member-at-Large, Division 7 (Developmental Psychology) of the American Psychological Association,
2004-2006.
Representative to APA Council for Division 41 (Psychology and Law), 2003-2005
USPHS Postdoctoral Fellowship, University of Denver
Two NIMH Predoctoral Fellowships, UCLA
Phi Beta Kappa, Magna Cum Laude, and Departmental Honors in Psychology, UCLA
California State Scholarship, Pitzer College, Claremont, CA
(I have appeared on a number of local and national radio talk shows and television shows to discuss my
research on children's testimony and child abuse. I have also been quoted in numerous newspaper and
magazine articles written on this topic. My research has been cited in State and Federal Supreme Court
decisions. I have contributed to American Psychological Association and American Medical Association
Amicus Briefs to the US Supreme Court.)
VI.
TEACHING AND RESEARCH GRANTS
Teaching Grants:
Faculty Mini-Grant for Undergraduate Instructional
Improvement, University of California, Riverside, 1977
Faculty Teaching Improvement Grant, University of Denver, 1983
Faculty Teaching Improvement Grant, University of California, Davis 1997
Research Grants and Contracts:
Small Awards
Memory for Pictorial Detail
W.T. Grant Foundation Grant
G.S. Goodman, Principal Investigator
1977 - 1980 $5,000
6
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The Development of Visual Scanning and Memory National Institute of Child Health
and Human Development
Individual Postdoctoral Fellowship
1977 - 1980 $14,000/year
Schema Confirmation and Schema Deployment
NIMH Small Grant
G.S. Goodman, Principal Investigator
1982 - 1983
$10,000 plus 55% indirect
The Development of Memory for Scripted Action Events
Biomedical Research Grant
University of Denver
G.S. Goodman, Principal Investigator
1982 - 1983 $2,000
The Child Witness
University of Colorado Medical Center
(Funds made available by the W.T. Grant Foundation.)
G.S. Goodman & M.M. Haith, Co-Investigators
1981 - 1984 $1,500
Children's Eyewitness Testimony
University of Colorado Medical Center
(Funds made available by the W.T. Grant Foundation.)
G.S. Goodman, Principal Investigator
1984 - 1986 $2,000
Children's Use of Props to Recall an Event
Biomedical Research Grant, University of Denver
G.S. Goodman, Principal Investigator
1985 - 1987 $1,800
Children's Memory for Repeated Events
Biomedical Research Grant, University of Denver
M.J. Farrar and G.S. Goodman, Co-Investigators
1986 - 1987 $2,500
Attitudinal Determinants of Empathy toward Child Victim/Witnesses of Sexual Abuse
National Center on Child Abuse and Neglect
G. S. Goodman, Principal Investigator/Faculty Sponsor
Predoctoral Fellowship for Bette L. Bottoms
1991 - 1992 $10,000
Long-term Memory for Invasive Genital Touch
University of California Intercampus Research Grant
G.S. Goodman, Principal Investigator
1992 - 1993 $2,000
7
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Attributions of Self-Blame in Child Victims of Sexual Abuse
National Center on Child Abuse and Neglect
G. S. Goodman, Principal Investigator/Faculty Sponsor
Predoctoral Fellowship for Jodi A. Quas
1994 - 1995 $10,000
Effects of Hearsay on Jurors' Decisions
University of California Intercampus Research Grant
G.S. Goodman, Principal Investigator
1994 - 1995 $10,000
Long-term Effects of Criminal Court Involvement
University of California Intercampus Research Grant
G.S. Goodman, Principal Investigator
1995 - 1997 $8,000
Effects of Repeated Interviews on Children
California Family Court System
G. S. Goodman, Faculty Sponsor
Dissertation Fellowship for Jodi Quas
1996 - 1997 $15,000
Memories of Childhood: True versus False Reports
National Science Foundation Dissertation Grant
G. S. Goodman, Principal Investigator/Faculty Sponsor
Dissertation Grant for Jianjian Qin
1997 - 1999 $10,000
Interviewing Children Repeatedly: Memory and Suggestibility
University of California Intercampus Research Grant
G.S. Goodman, Principal Investigator
1997 - 1998 $8,000
Developmental Differences in False Memory
University of California Intercampus Research Grant
G.S. Goodman, Principal Investigator
1998 - 1999 $3,000
Protective Custody: Children's Memory and Understanding of
A Traumatic Life Event
University of California Faculty Research Grant
G.S. Goodman, Principal Investigator
2000 - 2001 $10,000
Children's Heuristics and Rejection of False Events
National Science Foundation Dissertation Grant
G.S. Goodman, Principal Investigator/Faculty Sponsor
Dissertation Grant for Simona Ghetti
2001 - 2002 $8,500
8
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The Development of Memory for Emotional Pictures: Amygdala Response
University of California Faculty Research Grant
G.S. Goodman, Principal Investigator
2002 - 2003 $4,000
Influencing Children's Eyewitness Memory Through Familiarity and Stereotypes
National Science Foundation Dissertation Grant
G.S. Goodman, Principal Investigator/Faculty Sponsor
Dissertation Grant for Ingrid Cordón
2004 - 2005 $11,307
Amini Foundation Grant
Authenticity as a Mediator of Attachment and Memory/Suggestibility Relations
in Children
G.S. Goodman, Principal Investigator
2006 - 2007 $20,000
Developmental Trajectories of Gist and Monitoring Processes in True and False
Memories
University of California Faculty Research Grant
G.S. Goodman, Principal Investigator
2008 - 2009 $2,000
Child Maltreatment: Eyewitness Memory and Executive Function
National Science Foundation Dissertation Grant
G.S. Goodman, Principal Investigator/Faculty Sponsor
Dissertation Grant for LaTonya Harris
2009 - 2010 $12,000
Amini Foundation
Authenticity and Adults' Discernment of Children's Accurate and Inaccurate Memory
Reports
G.S. Goodman, Principal Investigator
2010-2012 $12,789
Stuart Foundation
Stuart Foundation National Youth in Transition Database Project
G.S. Goodman, Principal Investigator
2010-2011 $10,000
Sierra Foundation
Sierra Foundation National Youth in Transition Database Project
G.S. Goodman, Principal Investigator
2011-2012 $10,000
Child Eyewitness Memories: Effects of Familiarity
University of California Faculty Research Grant
G.S. Goodman, Principal Investigator
2012 - 2014 $2,000
9
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Amini Foundation
The Roles of Attachment and Authenticity in Children's Memory, Suggestibility, and
Honesty
G.S. Goodman, Principal Investigator
2013-2016 $16,000
Interviewing Children and Judging Children's Reports
University of California Faculty Research Grant
G.S. Goodman, Principal Investigator
2013 - 2015 $2,000
Parent-Child Discussion and Children's Eyewitness Memory
National Science Foundation Dissertation Grant
G.S. Goodman, Principal Investigator/Faculty Sponsor
Dissertation Grant for Kelly McWilliams
2013-2015 $18,500
The Scientific and Legal Status of Parental Alienation
University Outreach and International Programs
G.S. Goodman, Principal Investigator
University of California, Davis
2013-2016 $20,000
Predictors of Children's Lying to Conceal Parental Transgression
National Science Foundation Dissertation Grant
G.S. Goodman, Principal Investigator/Faculty Sponsor
Dissertation Grant for Daniel Bederian-Gardner
2014-2016 $9,000
Affecting and Assessing Children's Memory and Suggestibility: Effects of Relationship
Status, Attachment, and Authenticity
Amini Foundation
G.S. Goodman, Principal Investigator
2015 - 2020
$14,000
Empathy and Child Maltreatment
Social Sciences Center
University of California, Davis
G.S. Goodman, Principal Investigator
2015 2017
$10,000
Survey on Psychologists' Views of Spanking Children
American Psychological Association
Cindy Miller-Perrin (Principal Investigator)
G.S. Goodman (Co-PI)
2015-2016
$2,000
10
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University of California Faculty Research Grant
G.S. Goodman, Principal Investigator
2015 - 2017 $2,000
Eyewitness Memory in Children and Adolescents with Autism Spectrum Disorder
National Science Foundation Dissertation Grant
G.S. Goodman, Principal Investigator/Faculty Sponsor
Dissertation Grant for Jonni Johnson
2016-2017, $18,011
Amini Foundation
Authenticity, Attachment, and Empathy: A Longitudinal Study of Child Maltreatment
Victims
G.S. Goodman, Principal Investigator
2016-2019
$11,000
UC Consortium on Social Sciences and Law
Child Victims and Witnesses in the Legal System
Working Group
G.S. Goodman, Lead Investigator
2016-2017
$15,000
University of California Faculty Research Grant
G.S. Goodman, Principal Investigator
2018 - 2022
$2,000
Psychology and Law: A UC Davis and Altai State University Interdisciplinary/
International Collaboration
Global Affairs, University of California, Davis
G.S. Goodman & D. Shestowsky, Principal Investigators
2019-2022
$15,000
Large Awards
Effects of Criminal Court Testimony on Child Sexual Assault Victims
National Institute of Justice
G.S. Goodman, Principal Investigator
1985 - 1988
$175,000 (including 55% indirect costs)
Child Sexual and Physical Abuse: Children's Testimony and
Jurors' Reactions to Child Witnesses
U.S. Department of Health and Human Services
G.S. Goodman, Principal Investigator
1986 1990
$450,000
11
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Impact of Courtroom Practices on Children's Testimony and Jurors' Reactions
U.S. Department of Health and Human Services
G.S. Goodman, Principal Investigator
1989 1993
$450,000
Characteristics and Sources of Allegations of Ritualistic Abuse
U.S. Department of Health and Human Services
G.S. Goodman, Principal Investigator
1989 - 1993
$380,000
Emotional Effects of Courtroom Testimony on Child Victims:
Synthesis of Goodman et al.'s and Runyan et al.'s findings
G.S. Goodman, Co-Investigator; D. Whitcomb, Principal Investigator
National Institute of Justice
1991 - 1993 $45,000
Children's Out-of-Court Statements
National Institute of Justice
G.S. Goodman, Principal Investigator
1993 - 1997
$253,500
Impact of Dissociation, Trauma, and Stress-Arousal on Memory and Suggestibility in the
Assessment of Abused and Neglected Children
National Center on Child Abuse and Neglect
Mitchell Eisen, Principal Investigator, Gail S. Goodman, Co-Principal Investigator
1994 - 1998
$390,000 (main grant); $90,000 subcontract to Goodman
Benchbook on Child Witnesses
State Justice Institute
G.S. Goodman, Principal Investigator
1995 - 1998
$81,000
Emotional Effects of Legal Involvement on Child Victims: A 10-year Follow-up
National Science Foundation
G.S. Goodman, Principal Investigator
1996 2002
$410,000
Child Maltreatment: Transitions from School to the Workforce
National Science Foundation
G.S. Goodman, Principal Investigator; Jodi Quas, Co-PI
1999 2001
$54,000
Child Maltreatment Investigations/Forms of Legal Representation for Children
U.S. Department of Health and Human Services
12
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G.S. Goodman, Principal Investigator
2000 2003
$65,000
False Memory Resistance: The Role of the Metacognitive Strategy.
National Science Foundation
Simona Ghetti, PI: Gail S. Goodman, Co-PI
2003 - 2006, $180,000
Trauma and Memory
University of California, Davis
G.S. Goodman, Principal Investigator
2004 - 2006
$32,000
CDSS-UCD Center for Public Policy Research
California Department of Social Services
G.S. Goodman, Principal Investigator
2005 - 2008
$4.5 million
National Science Foundation Grant
Attachment and Memory
G.S. Goodman, Principal Investigator
2006 - 2011
$350,000
California Department of Corrections and Rehabilitation: Reducing Recidivism and
Prison Overcrowding in California
G.S. Goodman, Principal Investigator
2007 - 2010
$8.5 million
CDSS-UCD Center for Public Policy Research
California Department of Social Services
G.S. Goodman, Principal Investigator
2008 - 2011
$4.1 million
California's National Youth in Transition Database
California Department of Social Services
G.S. Goodman, Principal Investigator
2010 2011
$599,000
CDSS-UCD Center for Public Policy Research
California Department of Social Services
G.S. Goodman, Principal Investigator
2011 - 2014
$4.3 million
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San Pasqual Academy: Ten-year Evaluation
New Alternatives, Inc.
Michael J. Lawler, Principal Investigator, University of South Dakota
$173,710
G.S. Goodman, Principal Investigator for UC Davis Subcontract
2012-2013
$114,112
Long-Term Eyewitness Memory in Children Exposed to Violence
National Institute of Justice
G.S. Goodman, Principal Investigator
2014-2019
$439,989
Child Maltreatment and Long-Term Memory: Person Identification after 20 Years
National Science Foundation
G.S. Goodman, Principal Investigator
2014 - 2020
$300,000
Welfare Facilitation
California Department of Social Services
G.S. Goodman, Principal Investigator
2014 - 2015
$49,000
UC Consortium on Social Sciences and Law
University of California
Steven Clark, Principal Investigator
G.S. Goodman, Co-Principal Investigator
2014 - 2017
$298,341
Children's Eyewitness Memory and Suggestibility: The Role of Familiarity
National Science Foundation
G.S. Goodman, Principal Investigator
2019- 2022
$300,000
San Pasqual Academy: Evaluation
San Diego County and New Alternatives Inc.
G.S. Goodman, Principal Investigator
2019 - 2022
$1,777,496
RAPID: Trust and Legal Socialization During the COVID-19 Pandemic
National Science Foundation
G.S. Goodman, Principal Investigator
2019 2022
$200,000
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VII.
OTHER PROFESSIONAL CONTRIBUTIONS
Member, National Institute of Mental Health Small Grant Review Committee, 1985 - 1989
Steering Committee and Founding Member, American Professional Society on the Abuse of Children
(APSAC), 1986 - 1989
Member, American Psychological Association Advisory Board on Child Abuse 1988 - 1990
Member, American Psychological Association Advisory Committee on Child Abuse 1992 - 1994
American Psychological Association Legal Issues Working Group on Child Maltreatment, 1991 - 1995
American Psychological Association Working Group on Anatomically Detailed Dolls, 1991 - 1995
Society for Research in Child Development, Ethics Committee, 1993 - 1999; Chair, 1995 - 1997
Fellows Committee, American Psychological Society, 1999 - 2002
Executive Committee, Division 41 (Psychology & Law), American Psychological Association, 1992 - 1998,
2003 - 2006
Executive Committee, Division 7 (Developmental Psychology), American Psychological Association, 2005
- 2007
Planning Committee, Child Welfare League of America, Western Division, Training Conference, 2006 -
2007
Advisory Board, Laboratory on Development and Cognitive Neuroscience, University of Oslo, 2006 -
present
Board Member, California Children's Advocacy Centers, 2014 - 2016
International Consultant, British Psychological Society Working Group on Eyewitness Memory, 2007 -
2008
American Psychology-Law Society, Interdisciplinary Grant Program, Chair, 2008
Member, Data Sharing Subcommittee, Child Welfare Council of California, 2008 - present
Board of Directors, Association for Criminal Justice Research (California), 2010 - 2013
National Training Advisory Board, National Children's Advocacy Center, Huntsville, AL, 2010 - 2015
Penn State University Child Abuse Advisory Board, 2014 - present
Advisory Board/Consultant, Eliciting Reliable Reports from Children: A Literature Review of Influential
Factors. Dr. K. Saywitz (PI), Swedish National Board of Health and Welfare, 2014 - 2016
Editorial Board, Journal of Experimental Psychology: Applied, 2014-2018
Editorial Board, Psychology, Public Policy, and Law, 2008 - present; Action editor for selected child witness
articles, 2012-present
Editorial Board, Child Abuse & Neglect: The International Journal, 2012-present
Editorial Board, Kempe-Haruv International Journal on Child Maltreatment, 2016- present
Editorial Board, Law and Human Behavior (APA Div. 41 journal), 1994 - 2011
Publication Board, American Psychology-Law Society Book Series, 2004 - 2011
Editorial Board, Perspectives on Psychological Science, 2007 - 2008
Editorial Board, Child Maltreatment (American Professional Society on the Abuse of Children journal),
1995 - 1998
Editorial Board, Child Development (Society for Research in Child Development journal), 1989 - 1996
Editorial Board, Applied Cognitive Psychology (Society for Applied Research in Memory and Cognition
journal), 1995 - 2002
Editorial Board, Applied Developmental Sciences, 2000 - 2008
Advisory Editorial Panel, Contemporary Psychology (American Psychological Association book review
journal), 1992 - 1998 (Ad Hoc Advisory Editorial Board Member, Contemporary Psychology, 1990 -
1991)
Editorial Board, Trauma, Violence, and Abuse, 1999 - present
Editorial Board, Narrative and Life History (Erlbaum Publishers), 1990 - 1992
Editorial Board, Child, Youth and Family Services Quarterly (Newsletter of APA's Division 37), 1991 - 1993
Editorial Board, Journal of Social Issues (APA Division 9, SPSSI journal), 1987 - 1991
Editorial Panel, Journal of Interpersonal Violence, 1986 - 1990
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Research Board, Seneca Center, 2009
Research Advisory Board, National Quality Improvement Center of the Representation of Children in the
Child Welfare System, University of Michigan/US Dept of Health and Human Services, 2010-
2011
Conference Program Committee Member, International Association for Relationship Research, 2011
Co-Chair, Division 7 and Division 37 Task Force on Effects of Physical Punishment of Children, 2014-
2019
Member, White Paper Committee on Child Witness Interviewing, Division 41 (APLS), 2016, 2020-2021
American Psychological Association, Planning Committee, Roundtable on Physical Punishment of
Children, 2014-2105
National Institute on Child Health and Human Development (NICHD), Capstone Grant Panel, 2016, 2018
Co-Director, UC Consortium for Social Sciences & the Law, 2016 - 2017
Ad Hoc Reviewer for Psychological Review, Cognitive Psychology; Child Development; Developmental
Psychology; Memory and Cognition; Child Abuse & Neglect; Law and Human Behavior; Journal of
Interpersonal Violence; Journal of Experimental Psychology: Learning, Memory and Cognition; Infant
Behavior and Development; Journal of Applied Psychology; Journal of Personality and Social Psychology;
Psychological Bulletin; Journal of Child Clinical Psychology, Journal of Experimental Child Psychology,
Applied Developmental Psychology, Perspectives in Psychological Sciences, etc.
Ad Hoc Grant Reviewer for the Government of Australia; the National Science Foundation; National
Institute of Health; the Canadian Government; the City University of New York; W.T. Grant Foundation;
Economic and Social Research Council, UK; etc. Ad Hoc Convention Program Reviewer for the American
Psychology-Law Society; Society for Research in Child Development; American Psychological
Association, etc. Consultant, Aspen Systems Corporation and Koba Associates, Rockville, Maryland and
Washington, D. C., respectively, 1986 - 1990 (Aspen Systems Corporation and Koba Associates provide
peer review for the National Institute of Justice and Office of Juvenile Justice and Delinquency
Prevention).
I have served as a consultant to numerous mental health and legal professionals on children's eyewitness
testimony. I have also co-chaired an APA Division 41 Task Force on Child Abuse and a Division 7 Task
Force on Physical Punishment of Children, and I have frequently served on the Advisory Boards of a
large number of grant-related projects. In addition, I have given invited testimony before legislative
committees and to the U.S. Advisory Committee on Child Abuse concerning research on child witnesses.
VIII.
COMMITTEE WORK
Psychology Department Committees:
Departmental Teaching Assistant Committee, UCLA
Human Development Interdisciplinary Faculty Committee, UCR
Ethics Committee, University of Denver
Minority Committee, University of Denver
Computer Committee, University of Denver
Colloquium Committee, University of Denver
Space Committee, University of Denver
Graduate Affairs Committee (Chair, 1982-86), University of Denver
Personnel Committee, University of Denver
Planning Committee, SUNY-Buffalo
Personnel Committee, SUNY-Buffalo
Graduate Committee, SUNY-Buffalo
Cognitive Search Committee, SUNY-Buffalo and UC Davis
Graduate Admissions Subcommittee, UC Davis, 1993
Space Committee, UC Davis, 1994, 1997
Graduate Curriculum Committee, UC Davis, 1994-95, 1998-99
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Chair, Social/Personality Search Committee, UC Davis, 1995-96
Graduate Advising Committee, UC Davis, 1995-96
Psychology Department Rep. to Faculty Senate, UC Davis, 1996-1997
Space Committee, UC Davis 1997-1998
Psychology-Human Development Committee (1998)
Chair, Developmental Psychology Search Committee, UC Davis, 2000-01
Member, Developmental Psychology Search Committee, UC Davis, 2004-2005
Area head, Developmental Psychology, UC Davis, 2000-2007
Chair, Developmental Psychology Search Committee (cognitive/language development),
UC Davis, 2005-2006
Space Committee (Chair), UC Davis, 2006-2009
Developmental Psychology Search Committee, UC Davis, 2006-2007
Teaching Load Committee, 2008-2009
Subject Pool Committee, Chair, 2007-2012
Member, Developmental Psychology and Poverty Center Search Committee, 2014-2015
Search Committee, Developmental Psychology, UC Davis, 2015-2016
Psychology Mentoring and Personnel Committee, 2017-present
University and Non-Psychology Department Committees:
Women's Studies Faculty, University of Denver
Human Subjects Review Board, University of Denver
Dean's Psychology Department Chair Search Committee, SUNY-Buffalo
Women's Studies Resources Review Committee, UC Davis, 1993
Human Subjects Review Committee, UC Davis, 1994 - 1996, 1998 (summer)
Ad Hoc Committees on Promotion, UC Davis, 1993 - 1995, 1997 - 1999,
2002 - 2003, 2004
Advisory Committee to Dean of Social Sciences, UC Davis, 1995 - 1996,
1998 - 1999
UC Extension Committee on Forensic Studies, 1997 - 2004
Chair, Colloquium Committee, Graduate Group in Human Development, 1997 - 2000
Executive Committee, Graduate Group in Human Development, 1997 - 2002
Law School Dean Recruitment Committee, UC Davis, 1997 - 1998
Steering Committee for UCD-California Youth Authority Memorandum of
Understanding, 1998 - 2002
Ad Hoc Reviewer of the Graduate Group in Education, UCD (1998)
UCD Honors Committee, 1998 - 2000 (Chair, 1998 - 2000)
Chair, Committee to Establish a Joint Doctoral Program in Forensic and Behavioral
Sciences, 1998 - 2010
Recruitment Committee of the 4-H Youth Development Assistant Cooperative Extension
Specialist, Department of Human and Community Development, 1998
Planning Committee for the Chancellor's Fall Conference, 1999
Human Development Search Committee, 2004 - 2005
Advisory Committee, UC Davis-Davis Unified School District, 2001 - 2003
Committee on Academic Personnel (CAP), UC Davis 1999 - 2002
(CAP is the Tenure and Promotion Committee for the entire UC Davis campus)
Committee on Academic Personnel Appeals, UC Davis, 2005 - 2006
Individual Majors Review Committee, 2006
Board of Visitors, Psychology Department, UC Merced, 2007 - 2016
Advisory Committee for the Selection of a Dean of Social Sciences, UC Davis, 2007 - 2009
Student-Faculty Relations Committee, 2007 - 2009
School Personnel Committee, School of Law, UC Davis, 2008 - 2013 (Chair, 2010-2013)
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UC Davis Chancellor's Awards Committee, 2009 -2010
Search Committee, UC Davis Extension, Chair of Human Services Division, 2011
Vice Provost Confidential Committee, UC Davis 2011
Ad Hoc CAP Committee, 2012
Committee on Committees, UC Davis 2011-2013
Ad Hoc Orals Committee, UC Davis Graduate Studies, 2014
Advisory Committee to the Vice Provost of International Programs and Outreach, UC
Davis, 2000 - 2015
Welfare/Bylaws Committee, Graduate Council, UC Davis, 2014-2015
Internal Fellowships Committee, Graduate Council, UC Davis, 2016-2017
Committee on Academic Personnel (CAP), UC Davis, 2017-2019
(CAP is the Tenure and Promotion Committee for the entire UC Davis campus)
Graduate Fellowship Award Committee, UC Davis, 2020-2021
IX. DISSERTATION
Goodman, G.S. (1977, July). Pictorial recognition memory: A search for developmental changes in the type of
information retained. Doctoral dissertation submitted to the University of California at Los
Angeles. Dr. W. E. Jeffrey, Chairperson.
X. PUBLICATIONS
Greitzer (aka, Goodman), G.S., & Jeffrey, W. E. (1973). Negative effects of the pretest in training
conservation of length. Developmental Psychology, 9, 435.
Goodman, G.S. (1980). Picture memory: How the action schema affects retention. Cognitive Psychology,
12, 473-495.
Goodman, G.S., & Michelli, J. A. (1981, November). Would you believe a child witness? Psychology Today.
(This article won an award from the American Bar Association.)
Haith, M. M., & Goodman, G.S. (1982). Eye movement control in newborns under conditions of darkness
and unstructured light. Child Development, 53, 974-977.
Guttentag, R., Haith, M. M., Goodman, G. S., & Hauch, J. (1984). Processing words in two languages
simultaneously: A test of the bilingual "input-switch" hypothesis. Journal of Verbal Learning and
Verbal Behavior, 23, 178-188.
Goodman, G.S. (1984). The accuracies and inaccuracies of children's eyewitness reports. In D. Bross
(Ed.), Multidisciplinary advocacy for mistreated children. Denver, CO: National Association of
Counsel of Children.
Goodman, G.S. (Ed.). (1984). The child witness. Journal of Social Issues, 40(2).
Goodman, G.S. (1984). The child witness: An introduction. Journal of Social Issues, 40(2), 1-8.
Goodman, G.S. (1984). Children's testimony in historical perspective. Journal of Social Issues, 40(2), 9-32.
(Reprinted in B. Finkelman [Ed.]. [1996]. Child abuse: A multidisciplinary survey. NY: Garland.)
Goodman, G.S., Golding, J., & Haith, M. M. (1984). Jurors' reactions to child witnesses. Journal of Social
Issues, 40(2), 139-156.
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Goodman, G.S. (1984). The child witness: Conclusions and future directions for psychology and legal
practice. Journal of Social Issues, 40(2), 157-176. (Reprinted in J. Bulkley [Ed.]. [1985]. Papers from a
national policy conference on innovative legal procedures in child sexual abuse cases. Wash, D.C.:
American Bar Association and in A. Haralambie [Ed.]. [1986]. New issues for child advocates.
Phoenix, AZ: Arizona Council of Attorneys for Children.)
Goodman, G.S., & Helgeson, V. (1985). Child sexual abuse: Children's memory and the law. In J. Bulkley
(Ed.), Papers from a national policy conference on innovative legal procedures in child sexual abuse cases.
Washington, D.C.: American Bar Association. (Reprinted in the Miami Law Review, Nov, 1985.)
Goodman, G.S., Haith, M. M., Guttentag, R., & Rao, S. (1985). Automatic processing of word meaning:
Intralingual and interlingual interference. Child Development, 56, 103-118.
Goodman, G.S., Hepps, D., & Reed, R.S. (1986). The child victim's testimony. In A. Haralambie (Ed.),
New Issues for child advocates. Phoenix, AZ: Arizona Council of Attorneys for Children.
Goodman, G. S., & Reed, R. S. (1986). Age differences in eyewitness testimony. Law and Human Behavior,
10, 317-332.
Goodman, G.S., & Hahn, A. (1987). Evaluating eyewitness testimony. In I. Weiner & A. Hess (Eds.),
Handbook of forensic psychology (pp. 258-292). New York: Wiley.
Goodman, G.S., & Rosenberg, M. (1987). The child witness to family violence. In D. Sonkin (Ed.),
Domestic violence on trial (pp. 97-126). New York: Springer-Verlag.
Goodman, G.S., Golding, J., Helgeson, V., Haith, M. M., & Michelli, J. (1987). When a child takes the
stand: Jurors' perceptions of children's eyewitness testimony. Law and Human Behavior, 11, 27-40.
Goodman, G.S., Aman, C., & Hirschman, J. (1987). Child sexual and physical abuse: Children's
testimony. In S. Ceci, M. Toglia, & D. Ross (Eds.), Children's eyewitness memory (pp. 1-23). New
York: Springer-Verlag.
Corwin, D., Berliner, L., Goodman, G.S., Goodwin, J., & White, S. (1987). Child sexual abuse and custody
disputes--No easy answers. Journal of Interpersonal Violence, 2, 91-105.
Goodman, G.S., & Haith, M.M. (1987). Memory development and neuro-physiology: Accomplishments
and limitations. Child Development, 58, 713-717.
Goodman, G.S. & Lloyd D. (1988). The child witness: Evaluation and preparation. In D. Bross, R.
Krugman, D. A. Rosenberg, & B. D. Schmitt (Eds.), The new child protection team handbook (pp. 414-
444). NY: Garland.
Haith, M. M., Hazan, C., & Goodman, G.S. (1988). Expectation and anticipation of dynamic visual events
by 3.5 month-old babies. Child Development, 59, 467-479.
Goodman, G.S., & Helgeson, V. (1988). Children as witnesses: What do they remember? In L. Walker
(Ed.), Handbook on sexual abuse of children (pp. 109-136). New York: Springer.
Goodman, G.S., Jones, D. P. H., & the University of Denver Child Sexual Assault Research Group. (1988).
The child in court: A preliminary report on the emotional effects of criminal court testimony on
child sexual assault victims. In G. Davies & J. Drinkwater (Eds.), Proceedings from the Oxford
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Conference on children in courts: Do the courts abuse children? Oxford, England: British
Psychological Association. (This article was cited by the U.S. Supreme Court.)
Helgeson, V., Goodman, G. S., Shaver, P., & Lipton, J. (1989). Attitudes concerning the rights of children
and adults. Children's Legal Rights Journal, 10, 2-12.
Goodman, G.S., Bottoms, B., Herscovici, B. B., & Shaver, P. (1989). Determinants of the child victim's
perceived credibility. In S. Ceci, D. Ross, & M. Toglia (Eds.), Perspectives on children's testimony (1-
22). NY: Springer-Verlag.
Price D. W. W., & Goodman, G.S. (1990). Visiting the wizard: Children's memory of a recurring event.
Child Development, 61, 664-680.
Goodman, G.S., Rudy, L., Bottoms, B. L., & Aman, C. (1990). Children's concerns and memory: Issues of
ecological validity in the study of children's eyewitness testimony. In R. Fivush & J. Hudson
(Eds.), Knowing and remembering in young children (pp. 249-284). NY: Cambridge University Press.
Farrar, M.J., & Goodman, G.S. (1990). Developmental differences in the relation between episodic and
semantic memory: Do they exist? In R. Fivush & J. Hudson (Eds.), Knowing and remembering in
young children (pp. 30-64). NY: Cambridge University Press.
Schwartz-Kenney, B., Wilson, M., & Goodman, G.S. (1990). An examination of child witness accuracy
and the emotional effects on children of testifying in court. In K. Oates (Ed.), Understanding and
managing child sexual abuse (pp. 293-311). W. B. Sanders Publishing Co.
Saywitz, K.J., Goodman, G.S., & Myers, J. (1990). Can children provide accurate eyewitness reports? In
J. Conte (Ed.), Violence Update. Newbury Park, CA: Sage.
Goodman, G.S., & Aman, C.J. (1991). Children's use of anatomically detailed dolls to recount an event.
Child Development, 61, 1859-1871. (Reprinted in J. DeLoache [Ed.], [1994]. Current readings in child
development, 2nd ed., NY: Allyon & Bacon)
Goodman, G.S., Levine, M., Melton, G. B., & Ogden, D. (1991). Craig vs. Maryland. Amicus Brief to the
US Supreme Court on behalf of the American Psychological Association, Law and Human Behavior,
15, 13-30.
Goodman, G.S., Hirschman, J., Hepps, D., & Rudy, L. (1991). Children's memory for stressful events.
Merrill-Palmer Quarterly, 37, 109-158. (Reprinted in R. Baker [Ed.], [1998]. Child sexual abuse and
false memory syndrome. Buffalo, NY: Prometheus Books.)
Goodman, G.S., Bottoms, B. L., Schwartz-Kenney, B., & Rudy, L. (1991). Children's memory for a
stressful event: Improving children's reports. Journal of Narrative and Life History, 1, 69-99.
Pipe, M.E., & Goodman, G.S. (1991). Elements of secrecy: Implications for children's testimony.
Behavioral Sciences and the Law, 9, 33-41.
Shaver, P. R., Goodman, G.S., Rosenberg, M. S., & Orcutt, H. (1991). The search for a definition of
psychological maltreatment. Development and Psychopathology, 3, 79-86. (Reprinted in B.
Finkelman [Ed.]. [1996]. Child Abuse: A multidisciplinary survey. NY: Garland.)
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Rudy, L., & Goodman, G.S. (1991). Effects of participation on children's reports: Implications for
children's testimony. Developmental Psychology, 27, 1-26.
Goodman, G. S., & Clarke-Stewart, A. (1991). Suggestibility in children's testimony: Implications for
child sexual abuse investigations. In J. Doris (Ed.) The suggestibility of children's recollections (pp.
92 - 105). Washington, D.C.: American Psychological Association. (Reprinted in D. Bender & B.
Leone [Eds.]. [1993]. Child abuse: Opposing viewpoints, Greenhaven Press)
Goodman, G.S. (1991). Stress and children's testimony: Commentary on Peters. In J. Doris (Ed.), The
suggestibility of children's recollections (pp. 77-82). Washington, D.C.: American Psychological
Association.
Saywitz, K. J., Goodman, G.S., Nicholas, E., & Moan, S. (1991). Children's memories of physical
examinations involving genital touch: Implications for reports of child sexual abuse. Journal of
Consulting and Clinical Psychology, 59, 682-691. (This paper was published as a "Special Feature"
article.)
Farrar, M. J., & Goodman, G.S. (1992). Developmental differences in event memory. Child Development,
63, 173-187.
Goodman, G.S., Levine, M., & Melton, G. (1992). The best evidence produces the best law. Law and
Human Behavior, 16, 244-251. (Reprinted in B. Finkelman [Ed.]. [1996]. Child physical, emotional, and
sexual abuse of children: Multidisciplinary literature 1932-1993. Hamden, CT: Garland Publisher.)
Goodman, G.S., & Schwartz-Kenney, B. (1992). Why knowing a child's age is not enough: Effects of
cognitive, social, and emotional factors on children's testimony. In R. Flin & H. Dent (Eds.),
Children as witnesses (pp. 15-32). London: Wiley.
Goodman, G.S., Pyle-Taub, E., Jones, D. P. H., England, P., Port, L., Rudy, L., & Prado, L. (1992).
Testifying in criminal court: Emotional effects on child sexual assault victims. Monographs of the
Society for Research in Child Development, 57 (5), Serial No. 229.
Tobey, A., & Goodman, G.S. (1992). Children's eyewitness memory: Effects of participation and forensic
context. Child Abuse & Neglect, 16, 779-796.
Goodman, G.S., & Bottoms, B. L. (Eds.). (1993). Child victims, child witnesses: Understanding and improving
children's testimony. NY: Guilford Publishers, Inc.
Batterman-Faunce, J. M., & Goodman, G.S. (1993). Effects of context on the accuracy and suggestibility of
child witnesses. In G.S. Goodman & B. L. Bottoms (Eds.), Child victims, child witnesses:
Understanding and improving children's testimony (pp. 301-330). NY: Guilford Publishers, Inc.
Goodman, G.S. (1993). Understanding and improving children's testimony. Children Today, 22, 13-15, 32.
Steward, M., Bussey, K., Goodman, G.S., & Saywitz, K. (1993). Developmental considerations in
interviewing children. Child Abuse & Neglect, 17, 25-38.
Goodman, G.S., Batterman, J., & Kenney, R. (1993). Optimizing children's testimony: Research and
social policy issues concerning allegations of child sexual abuse. In D. Cicchetti & S. Toth (Eds.),
Child abuse, child development, and social policy (pp. 139-166). Norwood, NJ: Ablex.
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Goodman, G.S., Duchan, J., & Sonnenmeier, R. M. (1993). Children's development of scriptal knowledge.
In J. Duchan, L. Hewitt, & R. M. Sonnenmeier (Eds.), Pragmatics: From theory to practice (pp.120-
133). NY: Wiley.
Goodman, G.S., & Tobey, A. (1994). Memory development in the context of child sexual abuse
investigations. In C. Fischer & R. Lerner (Eds.), Applied developmental psychology (pp. 46-75). NY:
McGraw-Hill.
Goodman, G.S., & Tobey, A. E. (1994). Ethical issues in child witness research. Child Abuse & Neglect, 18,
290-293.
Whitcomb, D., Goodman, G.S., Runyan, D. K., & Hoak, S. (1994). The emotional effects of testifying on
sexually abused children. Research in Brief. Washington, D. C.: National Institute of Justice.
Goodman, G.S. (1994). When interviewing young children, technique is key. Brown University
Newsletter.
Bottoms, B. L., & Goodman, G.S. (1994). Evaluation of children's testimony: Factors influencing the jury.
Journal of Applied Social Psychology, 24, 702-732.
Goodman, G.S. (1994). Review of The suggestibility of children's recollections: Implications for eyewitness
testimony. Child Development Abstracts and Bibliography, 68, 101-102.
Goodman, G.S., & Saywitz, K.S. (1994). Memories of abuse: Interviewing children when sexual
victimization is suspected. Clinics of Child and Adolescent Psychiatry of North America, 3, 645-662.
Goodman, G.S., Quas, J. A., Batterman-Faunce, J. M., Riddlesberger, M., & Kuhn, J. (1994). Predictors of
accurate and inaccurate memories of traumatic events experienced in childhood. Consciousness
and Cognition, 3, 269-294. (Reprinted in K. Pezdek & W. Banks [Eds.]. [1996]. The recovered
memory/false memory debate, NY: Academic Press.)
Tobey, A., Goodman, G.S., Batterman-Faunce, J. M., Orcutt, H., & Sachsenmaier, T. (1995). Balancing the
rights of children and defendants: Effects of closed-circuit television on children's accuracy and
jurors' perceptions. In M. Zaragoza, J. Graham, & G. Hall (Eds.), Memory and testimony in the child
witness (pp. 214-239). Thousand Oaks, CA: Sage.
Bottoms, B. L., Shaver, P. R., Goodman, G.S., & Qin, J. (1995). In the name of God: Religion and child
abuse. Journal of Social Issues, 51, 85-111. (Reprinted in J. Hurley [Ed.]. [1998]. Child abuse. Malden,
MA: Blackwell.)
Goodman, G. S., Sharma, A., Thomas, S. F., & Considine, M. (1995). Mother knows best: Effects of
relationship status and interviewer bias on children's memory. Journal of Experimental Child
Psychology, 60, 195-228.
Koocher, G., Goodman, G.S., White, S., Friedrich, W., Sivan, A., & Reynolds, C. (1995). Psychological
science and the use of anatomically detailed dolls in child sexual abuse assessments. Psychological
Bulletin, 118, 199-222. (Product of APA Working Group on Anatomical Dolls; Winner of the 1995
Robert Chin Award from SPSSI, Division 9 of APA; Reprinted in M. Hertzig & E. Farber [Eds.]
Annual progress in child psychiatry and child development. NY: Bruner/Mazel).
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Goodman, G.S., & Quas, J. A. (1995). On the utility of anatomically detailed dolls when interviewing
children. Psychologie Francaise, 40, 295-302. (Special issue on the psychology of eyewitness
testimony.)
Melton, G. B., Goodman, G.S., Kalichman, S. C., Levine, M., Saywitz, K.J. & Koocher, G. P. (1995).
Empirical research on child maltreatment and the law. Journal of Child Clinical Psychology, 24, 47-
77. (Product of the APA Working Group on Legal Issues Related to Child Maltreatment.)
Saywitz, K. J., & Goodman, G.S. (1995). Interviewing children in and out of court: Current research and
practical implications. In J. Briere, L. Berliner, J. Bulkley, C. Jenny, & T. Reid (Eds.), The APSAC
handbook on child maltreatment (pp. 297-318). Newbury Park, CA: Sage.
Bottoms, B. L., Shaver, P. R., & Goodman, G.S. (1996). An analysis of ritualistic and religion-related child
abuse allegations. Law and Human Behavior, 20, 1-34.
Quas, J., DeCicco, V., Bulkley, J., & Goodman, G.S. (1996). District attorneys' views of innovative
practices for child witnesses. APLS Newsletter, 16(2), 5-8.
Goodman, G.S., & Quas, J. A. (1996). Trauma and memory: Individual differences in children's memory
for a stressful event. In N. Stein, P. A. Ornstein, C. Brainerd, & B. Tversky (Eds.), Memory for
emotional and everyday events (pp. 267-294). Mahwah, NJ: Erlbaum.
Schwartz-Kenney, B., Bottoms, B. L., & Goodman, G.S. (1996). Improving children's person
identification. Child Maltreatment, 1, 121-133.
Bottoms, B. L., & Goodman, G.S. (Eds.). (1996). International perspectives on child abuse and children's
testimony. Newbury Park, CA: Sage.
Bottoms, B. L., & Goodman, G.S. (Eds.). (1996). International perspectives on children's testimony.
Special Issue, Criminal Justice and Behavior, 23.
Bottoms, B. L., Shaver, P. R., & Goodman, G.S. (1996). Religion and child abuse. American Professional
Society on the Abuse of Children Advisor.
Myers, J. E. B., Saywitz, K. J., & Goodman, G.S. (1996). Psychological research on children as witnesses:
Practical implications for children's interviews and courtroom testimony. Pacific Law Review, 28,
1-91.
Goodman, G.S., Emery, R., & Haugaard, J. (1997). Developmental psychology and law: Divorce, child
maltreatment, foster care, and adoption. In I. Sigel & A. Renninger (Eds.), Handbook of child
psychology: Vol. 4. Child psychology in practice (pp. 775-876). (5th ed.). New York: Wiley. (The
Mussen Handbook).
Qin, J., Quas, J., Redlich, A., & Goodman, G.S. (1997). Children's eyewitness memory. In N. Cowan
(Ed.). Memory development in childhood (pp. 301-342). London: Psychology Press.
Goodman, G. S., Quas, J. A., Batterman-Faunce, J. M., Riddlesberger, M., & Kuhn, J. (1997). Children's
reactions to and memory for a stressful experience: Influences of age, knowledge, anatomical
dolls, and parental attachment. Applied Developmental Sciences, 1, 54-75.
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Qin, J. J., Tyda, K., & Goodman, G. S. (1997). Retractors' experiences: What we can and cannot conclude.
Psychological Inquiry, 8, 312-316.
Goodman, G. S., Quas, J., Bottoms. B. L., Qin, J. J., Shaver, P. R., Orcutt, H., & Shapiro, C. (1997).
Children's religious knowledge: Implications for understanding satanic ritual abuse allegations.
Child Abuse & Neglect, 21, 1111-1130.
Goodman, G.S., Bottoms, B. L., Redlich, A., Shaver, P. R., & Beety, K. (1998). Emotional correlates of
multiple victimization in religion-related child abuse cases. In R. Rossman, & M. Rosenberg
(Eds.), Multiple victimization of children: Conceptual, developmental, research, and treatment issues (pp.
273-296). Philadelphia, PA: Haworth Press. (Also in Aggression, Maltreatment, and Trauma, 1998, 2,
273-296)
Goodman, G.S., Tobey, A., Batterman-Faunce, J., Orcutt, H., Thomas, S., Shapiro, C., & Sachsenmaier, T.
(1998). Face-to-face confrontation: Effects of closed-circuit technology on children's eyewitness
testimony and jurors' decisions. Law and Human Behavior, 22, 165-203. (Reprinted in R. Bull [Ed.].
[2001]. Children and law: Essential readings. Malden, MA: Blackwell.)
Goodman, G.S., & Schaaf, J. M. (1998). A decade of child witness research: What have we learned? Where
do we go from here? Applied Cognitive Psychology, 11, 5-20. (Reprinted in R. Roesch & N. Gagnon
[Eds.]. [2007]. Psychology and law: Criminal and civil perspectives. London: Ashgate.)
Pipe, M-E., Goodman, G. S., Quas, J. A., Bidrose, S., Ablin, D. & Craw, S. (1998). Remembering early
experiences during childhood: Are stressful events special? In D. Read &S. Lindsay (Eds.),
Recollections of trauma: Scientific research and clinical practice (pp. 417-424). New York: Plenum.
Quas, J., Qin, J. J., Schaaf, J., & Goodman, G.S. (1998). Individual differences in children's and adults'
suggestibility and false event memory. Learning and Individual Differences, 9, 359-390.
Myers, J. E. B., Goodman, G. S., & Saywitz, K. (1998). Handbook on child witnesses. Alexandria, Virginia:
State Justice Institute.
Qin, J. J., Goodman, G.S., Bottoms, B. L., & Shaver, P.R. (1998). Repressed memories of ritualistic and
religion-related abuse. In S. Lynn & K. McConkey (Ed.), Truth in memory (pp. 260-283). NY:
Guilford.
Eisen, M., Goodman, G. S., Qin, J.J., & Davis, S. (1998). Memory and suggestibility in maltreated children:
New research relevant to evaluating allegations of abuse. In S.Lynn & K. McConkey (Ed.), Truth
in memory (pp. 163-189). NY: Guilford.
Goodman, G.S., Quas, J., & Redlich, A. D. (1998). The ethics of conducting false memory studies with
children: A reply to Herrmann and Yoder. Applied Cognitive Psychology, 12, 207-217.
Goodman, G.S., Redlich, A., Qin, J.J., Ghetti, S., Tyda, K., Schaaf, J., & Hahn, A. (1999). Evaluating
eyewitness testimony in adults and children. In I. Weiner & A. Hess (Eds.), Handbook of forensic
psychology (pp. 218-272). New York: Wiley.
Eisen, M., Goodman, G.S., Davis, S., & Qin, J.J. (1999). Individual differences in maltreated children's
memory and suggestibility. In L. Williams (Ed.), Trauma and memory (pp. 31-46). Newbury Park,
CA: Sage.
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Eisen, M., & Goodman, G. S. (1999). Trauma, memory, and suggestibility in children. Development and
Psychopathology, 10, 717-738.
Schwartz-Kenney, B., & Goodman, G.S. (1999). Children's memory of a naturalistic event following
misinformation. Applied Developmental Sciences, 3, 34-46.
Quas, J., Goodman, G.S., Bidrose, S., Pipe, M-E., Craw, S., & Ablin, D. (1999). Emotion and memory:
Children's remembering, forgetting, and suggestibility. Journal of Experimental Child Psychology,
72, 235-270. (Reprinted in R. Bull [Ed.]. [2001]. Children and law: Essential readings. Malden, MA:
Blackwell.)
Goodman, G.S., Quas, J., Bulkley, J., & Shapiro, C. (1999). Innovations for child witnesses: A national
survey. Psychology, Public Policy, and Law, 5, 255-281.
Myers, J. E. B., Redlich, A., Goodman, G.S., Prizmich, L., & Imwinkelreid, E. (1999). Jurors' perceptions of
hearsay in child sexual abuse cases. Psychology, Public Policy, and Law, 5, 388-419.
Bidrose, S., & Goodman, G.S. (2000). Testimony and evidence: A scientific case study of memory for child
sexual abuse. Applied Cognitive Psychology, 14, 197-214. (This article was featured in Science News.
It was also featured in the 25th Anniversary Issue of Applied Cognitive Psychology [2010])
Quas, J. A., Schaaf, J., Alexander, K., & Goodman, G. S. (2000). Do you really remember it happening or
do you only remember being asked about it happening? Children's source monitoring in forensic
contexts. In K. Roberts & M. Blades (Eds.), Memory development and source monitoring (pp. 197-
226). Mahwah, NJ: Erlbaum.
Alexander, K., & Goodman, G.S. (2000). Child witnesses. Encyclopedia of Women and Crime (pp. 25-26).
Phoenix, AZ: Oryx Press.
Quas, J., Goodman, G.S., Ghetti, S., & Redlich, A. (2000). Questioning the child witness: What can we
conclude from research thus far? Trauma, abuse, and violence, 1, 223-249.
Goodman, G.S., & Quas, J. A. (2000). Family violence. In A. Kazdin (Ed.), Encyclopedia of psychology, Vol. 3
(pp. 333-336). Washington, D.C.: American Psychological Association.
Goodman, G.S., Bottoms, B. L., Rudy, L., Davis, S., & Schwartz-Kenney, B. M. (2001). Effects of past
abuse experiences on children's eyewitness memory. Law and Human Behavior, 25, 235-256.
Orcutt, H., Goodman, G.S., Tobey, A., Batterman-Faunce, J. M., & Thomas, S. (2001). Detecting deception
in children's testimony: Factfinders' abilities to reach the truth in open court and closed-circuit
trials. Law and Human Behavior, 25, 339-372.
Ondersma, S., Chaffin, M., Berliner, L., Cordón, I., Goodman, G.S., & Barnett, D. (2001). Sex with children
is abuse: Comment on Rind et al. (1998). Psychological Bulletin, 127, 707-714.
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Saywitz, K. J., Goodman, G.S., & Lyon, T. (2001). Interviewing children in and out of court: Current
research and practice implications. In J. Myers et al. (Eds.), APSAC Handbook on child maltreatment
(pp. 349-378). Newbury Park, CA: Sage.
Ghetti, S., & Goodman, G.S. (2001). Mechanisms underlying resistance to memory distortion, including
false memory, in children and adults. The Psychologist, 14, 592-595.
Goodman, G.S., Batterman-Faunce, J., Schaaf, J., & Kenney, R. (2002). Children's memory nearly four
years after an event: Professionals' and nonprofessionals' assessments of children's accuracy.
Child Abuse & Neglect, 26, 849-884.
Eisen, M., Quas, J. A., & Goodman, G.S. (Eds.). (2002). Memory and suggestibility in the forensic interview.
Mahwah, NJ: Erlbaum. (Also translated into Korean)
Schaaf, J., Alexander, K., Goodman, G. S., Ghetti, S., Edelstein, R., & Castelli, P. (2002). Children's
eyewitness memory. In B. L. Bottoms, M. Kovera, & B. MacAulliff (Eds.), Children and the law (pp.
342-377). NY: Cambridge University Press.
Edelstein, R., Goodman, G. S., Quas, J., Redlich, A., Ghetti, S., & Alexander, K. (2002). Emotional effects
on children of legal involvement. In G. Davies, H. Westcott, & R. Bull (Eds.), Evaluating children as
witnesses (pp. 261-278). London: Wiley.
Myers, J. E. B., Cordón, I., Ghetti, S., & Goodman, G.S. (2002). Hearsay exceptions: Adjusting the ratio of
intuition to psychological science. Law and Contemporary Problems, 65, 3-46.
Ghetti, S., Alexander, K., & Goodman, G.S. (2002). Societal interventions in child abuse cases.
International Journal of Psychiatry and Law, 25, 235-251.
Bottoms, B. L., Goodman, G.S., Schwartz-Kenney, B., & Thomas, S. (2002). Understanding children's use
of secrecy in the context of eyewitness reports. Law and Human Behavior, 26, 285-313.
Ghetti, S., Qin, J. J., & Goodman, G. S. (2002). False memories in children and adults: Age, distinctiveness,
and subjective experience. Developmental Psychology, 38, 705-718.
Eisen, M., Qin, J. J., Goodman, G.S., & Davis, S. (2002). Memory and suggestibility in maltreated children.
Journal of Experimental Child Psychology, 83, 167-212.
Ghetti, S., Goodman, G.S., Eisen, M., Qin, J.J., & Davis, S. (2002). Consistency in children's reports of
sexual and physical abuse. Child Abuse & Neglect, 26, 977-95.
Alexander, K., Goodman, G. S., Schaaf, J., Shaver, P. R., & Quas, J. A. (2002). The role of attachment and
cognitive inhibition in children's memory for a stressful event. Journal of Experimental Child
Psychology, 83, 262-290.
Redlich, A., Myers, J., Goodman, G.S., & Qin, J. (2002). A comparison of two forms of hearsay in child
sexual abuse cases. Child Maltreatment, 7, 312-28.
Alexander, K. W., Quas, J. A., & Goodman, G.S. (2002). Theoretical advances in understanding children's
memory for distressing events: The role of attachment. Developmental Review, 22, 490-519.
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Quas, J. A., Goodman, G. S., & Jones, D. P. H. (2003). Predictors of attributions of self-blame and
internalizing behavior problems in sexually abused children. Journal of Child Psychology and
Psychiatry, 44, 1-14.
Goodman-Brown, T. B., Edelstein, R., Goodman, G. S., Jones, D. P. H., & Gordon, D. (2003). Why children
tell: A model of children's disclosure of sexual abuse. Child Abuse & Neglect, 27, 525-540. (This
article was translated into Japanese for the Japanese Child Abuse and Neglect Journal and was cited
by the U.S. Supreme Court in Kennedy V. Louisiana, 2008)
Cordón, I., Goodman, G.S., & Anderson, S. (2003). Children in court. In P. Van Koppen & S. Penrod
(Eds.), Adversarial versus inquisitorial legal systems (pp. 167-189). NY: Kluwer Academic.
Goodman, G.S., Ghetti, S., Quas, J. A., Edelstein, R., Alexander, K., Cordón, I., & Jones, D. P. H. (2003). A
prospective study of memory for child sexual abuse: New findings relevant to the repressed
memory controversy. Psychological Science, 14, 113-118.
Alexander, K. S., Redlich, A., Christian, P., & Goodman, G.S. (2003). Interviewing children. In M.
Peterson & M. Durfee (Eds.), Child abuse and neglect: Guidelines for identification, assessment, and case
management (pp. 17-19). Volcano Press.
Redlich, A., & Goodman, G.S. (2003). Taking responsibility for an act not committed: The influence of age
and suggestion. Law and Human Behavior, 27, 141-156. (This article was cited in several amicus
briefs submitted to the U.S. Supreme Court or lower courts, e.g., in the APA amicus brief in
Roper V. Simmons on the juvenile death penalty).
Ghetti, S., Schaaf, J., Qin, J. J., & Goodman, G.S. (2004). Eyewitness testimony. In W. O'Donohue, D.
Laws, & C. Hollin (Eds.), Forensic psychology (pp. 513-554). NY: Westview/Basic Books.
Edelstein, R., Alexander, K., Goodman, G. S., & Newton, J. (2004). Emotion and eyewitness memory. In D.
Reisberg & P. Hertel (Eds.), Memory and emotion (pp. 308-346). Series in affective science. NY:
Oxford University Press.
Cordón, I., Pipe, M-E., Sayfan, L., Melinder, A., & Goodman, G.S. (2004). Memory for traumatic events in
early childhood. Developmental Review, 24, 101-132.
Pezdek, K., Morrow, A., Blandon-Gitlin, I., Goodman, G.S., Quas, J., Saywitz, K., Bidrose, S., Pipe, M-E.,
Rogers, M., & Brodie, L. (2004). Detecting deception in children: The effect of event familiarity on
Criterion Based Content Analysis ratings. Journal of Applied Psychology, 89, 119-126.
Edelstein, R.S., Alexander, K. W., Shaver, P. R., Schaaf, J. M., Quas, J. A., & Goodman, G.S. (2004). Adult
attachment style and parental responsiveness during a stressful event. Attachment and Human
Development, 6, 31-52.
Melinder, A. M. D., Goodman, G.S., Eilertson, D., & Magnussen, S. (2004). Beliefs about child witnesses:
A national survey. Psychology, Crime, and Law, 10, 347-365.
Castelli, P., Goodman, G. S., & Ghetti, S. (2005). Effects of interview style and witness age on perceptions
of children's credibility in sexual abuse cases. Journal of Applied Social Psychology, 35, 297-319.
Alexander, K., Quas, J., Goodman, G.S., Ghetti, S., Edelstein, R., Redlich, A., Cordón, I., & Jones, D. P. H.
(2005). Traumatic impact predicts long-term memory of documented child sexual abuse.
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Psychological Science, 16, 33-40. (This article was translated into Japanese for the Japanese Child
Abuse and Neglect Journal.)
Cordón, I., Goodman, G. S., & Saetermoe, C. (2005). Facilitating children's accurate responses:
Conversational rules and interview style. Applied Cognitive Psychology, 19, 249-266.
Edelstein, R., Ghetti, S., Quas, J. A., Goodman, G.S., Alexander, K., Redlich, A., & Cordón, I. (2005).
Avoidant attachment and memory for child sexual abuse. Social and Personality Psychology
Bulletin, 31, 1549-1560. (Reprinted in Funder, D. & Ozer, D. [Eds.]. [2010], Pieces of the Personality
Puzzle: Readings in Theory and Research. NY: W. W. Norton.)
Quas, J. A., Goodman, G. S., Ghetti, S., Redlich, A., Edelstein, R., Alexander, K., Cordón, I., & Jones, D.P.
H. (2005). Childhood sexual assault victims: Long-term outcomes of testifying in criminal court.
Monographs of the Society for Research in Child Development, 70, Serial No. 280.
Castelli, P., Goodman, G.S., Edelstein, R., Mitchell, E., Paz-Alonso, P., Lyons, K., & Newton, J. (2005).
Evaluating eyewitness testimony in children and adults. In I. Weiner & A. Hess (Eds.), Handbook
of forensic psychology, 3rd edition (pp. 243-304). Hoboken, Wiley Press.
Mikulincer, M., & Goodman, G.S. (Eds.). (2006). Dynamics of romantic love. NY: Guilford Press.
Goodman. G.S. (2006). Attachment to attachment theory. In M. Mikulincer & G.S. Goodman (Eds.),
Dynamics of romantic love (pp. 3-22). NY: Guilford Press.
Goodman, G.S., & Paz-Alonso, P. (2006). Trauma and memory: Normal versus special memory
mechanisms. In R. Uttl, Ohta, N., & A. Sigenthaler (Eds), Emotion and memory (pp. 233-257).
London: Blackwell Press.
Goodman, G.S., Myers, J. E. B., Qin, J., Quas, J. A., Castelli, P., Redlich, A., & Rogers, L. (2006). Hearsay
versus children's testimony: Effects of truthful and deceptive statements on jurors' decisions. Law
and Human Behavior, 30, 363-401.
Edelstein, R., Luten, T., Ekman, P., & Goodman, G.S. (2006). Detecting lies in children and adults. Law
and Human Behavior, 30, 1-10. (Reprinted in W. Lesko (Ed.). (2008). Readings in social psychology:
General, classic, and contemporary selections. NY: Allyn Bacon.)
Magnussen, S., Andersson, J., Cornoldi, C., De Beni, R., Endestad, T., Goodman, G.S., Helstrup, T.,
Koriat, A., Larsson, M., Melinder, A., Nilsson, L-G., Rönnberg, J., & Zimmer,H. (2006). What
people believe about memory. Memory, 14, 595-613.
Goodman, G.S. (2006). Children's eyewitness memory: A modern history and contemporary
commentary. Journal of Social Issues, 62, 811-832.
Malloy, L., Mitchell, E., Block, S., Quas, J., & Goodman, G.S. (2006). Children's eyewitness memory:
Balancing children's needs and defendants' rights when seeking the truth. In M. Toglia, D. Reed,
D. Ross, & R. C. L. Lindsay (Eds.), Handbook of eyewitness psychology (pp. 545 - 576). Mahwah, NJ:
Erlbaum.
Ghetti, S., Edelstein, R., Goodman, G.S., Quas, J. A., Alexander, K., Redlich, A., Cordón, I., & Jones, D. H.
P. (2006). Subjective and objective memory for child sexual abuse. Memory & Cognition, 34, 1011-
1025.
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Goodman, G.S, & Melinder, A. (2007). The development of autobiographical memory: A new model. In
S. Magnussen & T. Helstrup (Eds.), Everyday memory (pp. 111-134). London: Psychology Press.
Goodman, G.S., Magnussen, S., Andersson, J., & Helstrup, T. (2007). False memory and everyday
memory. In S. Magnussen & T. Helstrup (Eds.), Everyday memory (pp. 157-182). Psychology Press.
Goodman, G.S., & Melinder, A. (2007). Child witness research and forensic interviews of young children.
Legal and Criminological Psychology, 12, 1-19. [Reprinted in V.V.L. Gayathri (Ed.), Child witness: Legal
issues. India: AMICUS Books, Institute of Chartered Financial Analysts of India University.]
Quas, J. A., Davis, E., Goodman, G.S., & Myers, J. E. B. (2007). Repeated questions, deception, and
children's true and false reports of body touch. Child Maltreatment, 12, 60-67. (This article was
cited by the U.S. Supreme Court in Kennedy V. Louisiana, 2008)
Quas, J. A., Malloy, L., Melinder, A. M., Goodman, G.S., D'Mello, M., & Schaaf, J. (2007). Developmental
differences in the effects of repeated interviews and interviewer bias on young children's event
memory and false reports. Developmental Psychology, 43, 823-837.
Goodman, G. S., Ghetti, S., & Castelli, P. (2007). Trauma, memory, and child maltreatment. In F.
Petruccelli, V. Verrastro, & M. Santilli (Eds.), Memoria e suggestionabilità nell' evolutiva: Studi e
ricerche. Milano, Italy: Franco Angeli.
Eisen, M., Goodman, G. S., Qin, J. J., Davis, S., & Crayton, J. (2007). Maltreated children's memory:
Accuracy, suggestibility, and psychopathology. Developmental Psychology, 43, 1275-1294.
Goodman, G.S., Sayfan, L., Lee, J., Sandhei, M., Walle-Olsen, A., Magnussen, S., Pezdek, K., & Amaral, P.
(2007). The development of memory for own and other race/ethnicity faces. Journal of
Experimental Child Psychology, 98, 233-242.
Goodman, G.S., & Goodman-Brown, T. (2007). Forward. M.E. Pipe, M. E. Lamb, Y. Orbach, & A. C.
Cederberg (Eds.). Child sexual abuse: Disclosure, delay, & denial (pp. vii-ix). Mahwah, NJ: Erlbaum.
Paz-Alonso, P., & Goodman, G.S. (2008). Trauma and memory: Effects of post-event misinformation,
retrieval order, and retention interval. Memory, 16, 58-75.
Howe, M., Goodman, G.S., & Cicchetti, D. (2008). Stress, trauma, and memory development. NY:
Cambridge University Press.
Ogle, C. M., Block, S. D., Culver, M., Harris, L. T., Augusti, E. M., & Goodman, G.S. (2008). Accuracy and
specificity of autobiographical memory in childhood trauma victims: Developmental
considerations. In M. Howe, G.S. Goodman, & D. Cicchetti (Eds.), Trauma and memory
development (pp. 171-203). NY: Oxford University Press.
Paz-Alonso, P., Ghetti, S., Donohue, S., Goodman, G.S., & Bunge, S. (2008). Neurodevelopmental
correlates of true and false recognition. Cerebral Cortex, 18, 2208-2216.
Goodman, G. S., Edelstein, R., Mitchell, E., & Myers, J. E. B. (2008). Outcomes of legal representation for
children in dependency court. Child Abuse & Neglect, 32, 497-501.
Schaaf, J., Alexander, K., & Goodman, G.S. (2008). Predictors of children's true disclosure and false
memory. Journal of Experimental Child Psychology, 100, 157-185.
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Goodman, G.S., & Quas, J. A. (2008). Repeated interviews and children's memory: It's more than just how
many. Current Directions in Psychological Science, 17(6), 386-390. doi:
http://dx.doi.org/10.1111/j.1467-8721.2008.00611.x
Qin, J., Ogle, C. M., & Goodman, G.S. (2008). Adults' memories of childhood: True and false reports.
Journal of Experimental Psychology: Applied, 14(4), 373-391. doi:http://dx.doi.org/10.1037/a0014309
Sayfan, L., Mitchell, E., Goodman, G.S., Eisen, M., & Qin, J. (2008). Predictors of expressed emotion
during disclosure of child maltreatment. Child Abuse & Neglect, 32, 1026-1036.
Goodman, G.S., Ogle, C. M., Troxel, N., Lawler, M.J., & Cordón, I. M. (2009). Child victims in the
judiciary system: Optimizing accuracy, avoiding revictimization. In B. dos Santos & I. Goncalves
(Eds.), Testimony without fear(?) Non-revictimizing cultures and practices (pp. 21-34). Brasilia, Brazil:
Childhood Brazil.
Paz-Alonso, P., Larson, R. P., Castelli, P., Alley, D., & Goodman, G.S. (2009). Memory development:
Emotion, stress, and trauma. In M. Courage & M. Cowan (Eds.), Memory development (pp. 197-
240). Sussex, UK: Psychology Press.
Harris, L. S., Goodman, G.S., Augusti, E. M., Chae, Y., & Alley, D. (2009). Children's resistance to
suggestion. In K. Kuehnle & M. Connell (Eds.), The evaluation of child sexual abuse allegations: A
comprehensive guide to assessment and testimony (pp. 181-202). John Wiley & Sons.
Schneider, R., Baumrind, N., Pavao, J., Stockdale, G., Castelli, P., Goodman, G.S., & Kimerling, R. (2009).
What happens to youth removed from parental care?: Health and economic outcomes for
women with a history of out-of-home placement. Children and Youth Services Review, 31, 440-444.
Chae, Y., Goodman, G.S., Ducker, J., & Haralambie, A. (2009). Children's development, memory, and
testimony. In A. Haralambie (author), Handling child custody, abuse, and adoption cases (pp. 595-
606). Eagan, MN: Thomson.
Ducker, J., Chae, Y., Goodman, G.S., & Haralambie, A. (2009). Children's development, memory, and
testimony. In A. Haralambie (author), Handling child custody, abuse, and adoption cases (pp. 606-
619). Eagan, MN: Thomson
Paz-Alonso, P., Chae, Y., & Goodman, G.S. (2009). Children's testimony. In B. Cutler (Ed.), The
encyclopedia of psychology and law. Newbury Park, CA: Sage.
Bottoms, B. L., Harris, L., Augusti, E. M., Odereck, B., & Goodman, G.S. (2009). Child maltreatment. In B.
Cutler (Ed.). The encyclopedia of psychology and law. Newbury Park, CA: Sage.
Chae, Y., Ogle, C., & Goodman, G.S. (2009). Remembering negative childhood experiences: An
attachment theory perspective. In J. A. Quas & R. Fivush (Eds.), Emotion and memory (pp. 3-27).
New York, NY: Oxford University Press.
Block, S. D., Greenberg, S. N., & Goodman, G.S. (2009). Remembrance of eyewitness testimony: Effects of
emotional content, self-relevance, and emotional tone. Journal of Applied Social Psychology, 39(12),
2859-2878.
Mongetta, J. N., Salerno, J. M., Najdowski, C.J., Bottoms, B. L., & Goodman, G.S. (2009). Children as
victims, witnesses, and offenders: An introduction through legal cases. In B. L. Bottoms, C.
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Nadjowski, & G.S. Goodman (Eds.), Children as victims, witnesses, and offenders: Psychological science and the
law (pp. 1-15). New York, NY: Guildford Press.
Bottoms, B. L., Nadjowski, C., & Goodman, G.S. (Eds.). (2009). Child victims, child witnesses, and child
offenders: Psychological science and law. New York, NY: Guilford.
Troxel, N., Ogle, C. M., Cordón, I. M., Lawler, M.J., & Goodman, G.S. (2009). Child witnesses in criminal
court. In B. L. Bottoms, C. Nadjowski, & G.S. Goodman (Eds.), Child victims, child witnesses, and
child offenders: Psychological science and law (pp. 150-166). NY: Guildford.
Block, S. D., Segovia, D., & Goodman, G.S. (2009). Children: Suggestibility of. In C. Edwards (Ed.), Wiley
encyclopedia of forensic science (pp. 1-4). Chichester, UK: John Wiley.
doi: 10.1002/9780470061589.fsa236
Melinder, A., Alexander, K., Cho, Y., Goodman, G.S., Thoresen, C., Lonnum, K., & Magnussen, S. (2010).
Children's eyewitness memory: A comparison of two interviewing strategies as realized by
forensic professionals. Journal of Experimental Child Psychology, 105, 156-177.
Goodman, G.S., Quas, J. A., & Ogle, C.M. (2010). Child maltreatment and memory. Annual Review of
Psychology, 61, 325-351. doi: http://dx.doi.org/10.1146/annurev.psych.093008.100403
Ogle, C. M., Chae, Y., & Goodman, G.S. (2010). Eyewitness testimony. In I. Weiner & W. E. Craighead
(Eds.), Corsini encyclopedia of psychology (4th ed., Vol. 2, pp. 632-634). UK: Wiley.
Saywitz, K.J., Lyon, T. D., & Goodman, G. S. (2010). Interviewing children. In J. E.B. Myers (Ed.), APSAC
handbook on child maltreatment (3rd ed., pp. 337-360). Newbury Park, CA: Sage.
Block, S. D., Oran, H., Oran, D., Baumrind, N., & Goodman, G.S. (2010). Abused and neglected children
in court: Knowledge and attitudes. Child Abuse & Neglect, 34, 659-670. doi:
http://dx.doi.org/10.1016/j.chiabu.2010.02.003
Quas, J. A., Alexander, K. W., Goodman, G. S., Ghetti, S., Edelstein, R. S., & Redlich, A. (2010). Long-term
autobiographical memory for legal involvement: Individual and sociocontextual predictors.
Cognitive Development, 25, 394-409.
Toth, S. L., Harris, L.S., Goodman, G.S., & Cicchetti, D. (2011). Influence of violence and aggression on
children's psychological development: Trauma, attachment, and memory. In P. Shaver & M.
Mikulincer (Eds.), Human aggression and violence: Causes, manifestations, and consequences (pp. 351-
365). Washington, DC: American Psychological Association.
Lawler, M. J., Shaver, P. R., & Goodman, G.S. (2011). Toward relationship-based child welfare services.
Children and Youth Services Review, 33, 473-480.
Goodman, G.S., Ogle, C. M., Block, S. D., Harris, L., Larsen, R., Augusti, E-M., Young, C., Beber, J.,
Timmer, S., & Urquiza, A. (2011). False memory for trauma-related Deese-Roediger-McDermott
lists in adolescents and adults with histories of child sexual abuse. Development and
Psychopathology, 23, 423-438.
Chae, Y., Goodman, G.S., Bederian-Gardner, D., & Lindsay, A. (2011). Methodological issues and
practical strategies in research on child maltreatment victims' abilities and experiences as
witnesses. Child Abuse & Neglect, 35, 240-248.
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Chae, Y., Goodman, G.S., & Edelstein, R.S. (2011) Autobiographical memory development from an
attachment perspective: The special role of negative events. Advances in child development and
behavior (Vol. 40, pp. 1-49). New York, NY: Academic Press.
Chae, Y., Goodman, G.S., Eisen, M. L., & Qin, J. (2011). Event memory and suggestibility in abused and
neglected children: Trauma-related psychopathology and cognitive functioning. Journal of
Experimental Child Psychology, 110, 520-538.
Goodman, G.S., Haralambie, A., Chae. Y., Ducker, J., Baker, J., & Burkholder, R. (2011). Children's
development, memory, and testimony. In A. M. Haralmabie (Ed.), Handling child custody, abuse,
and adoption cases. Eagan, MN: Thomson Reuters/West.
Raskauskas, J. L., Cordón, I. M., & Goodman, G.S. (2011). Relations between maternal attitudes toward
bullying and children's bullying and peer victimization status. International Perspectives in
Victimology, 6, 20-29.
Goodman, G. S., Pipe, M., & McWilliams, K. (2011). Children's eyewitness memory: Methodological
issues. In B. Rosenfeld & S. Penrod (Eds.), Research methods in forensic psychology (pp. 257-282).
New York, NY: Wiley.
Block, S. D., Shestowsky, D., Segovia, D., Goodman, G. S., Schaaf, J. M., & Alexander, K. W. (2012). "That
never happened": Adults' ability to discern children's true and false memory reports. Law and
Human Behavior, 36, 365-374.
Goodman, G.S., Haralambie, A., Chae. Y., Ducker, J., Baker, J., & Burkholder, R. (2012). Children's
development, memory, and testimony. In A. M. Haralmabie (Ed.), Handling child custody, abuse,
and adoption cases. Eagan, MN: Thomson Reuters/West.
Quas, J. A., & Goodman, G.S. (2012). Consequences of criminal court involvement for child victims.
Psychology, Public Policy, and Law, 18, 392-414.
McWilliams, K., Bederian-Gardner, D., Hobbs, S. D., Bakanosky, S., & Goodman, G.S. (2012). Children's
eyewitness memory and suggestibility: Revisiting Ceci and Bruck's review. In A. Slater & P.
Quinn (Eds.), Developmental psychology: Revisiting the classic studies (pp. 101-117). London: Sage.
Lawler, M.J., Bederian-Gardner, D., & Goodman, G.S. (2012). Conclusions and next steps for researchers
and practitioners. In R. Holliday & T. Marche (Eds.), Child forensic psychology (pp. 273-285).
Hampshire, UK: Palgrave Macmillan.
Ogle, C. M., Block, S. D., Harris, L., Goodman, G.S., Pineda, A., Timmer, S., Urquiza, A., & Saywitz, K.S.
(2013). Autobiographical memory specificity in child sexual abuse victims. Development and
Psychopathology, 25, 321-332.
Cordón, I. M., Melinder, A. M. D., Goodman, G.S., & Edelstein, R.S. (2013). Children's and adults'
memory for emotional pictures: Examining age-related patterns using the developmental
affective photo system. Journal of Experimental Child Psychology, 114, 339-356.
Melinder, A., Baugerud, G. A., Ovenstad, K.S., & Goodman, G.S. (2013). Children's memories of
removal: A test of attachment theory. Journal of Traumatic Stress, 26, 125-133. doi:
http://dx.doi.org/10.1002/jts.21784.
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Paz-Alonso, P., Ogle, C. M., & Goodman, G.S. (2013). Children's memory and testimony in "scientific
case studies" of child sexual abuse: A review. In M. Ternes, D. Griesel, & B. Cooper (Eds.), Applied
issues in investigative interviewing, eyewitness memory, and credibility assessment (pp. 143-172). New
York, NY: Springer.
Malloy, L., Johnson, J., & Goodman, G.S. (2013). Children's memory and event reports: The current
state of knowledge and best practice. Journal of Forensic Social Work, 3, 1-30.
Alley, D., Narr, R., Melinder, A. M., & Goodman, G.S. (2013). Child maltreatment, trauma-related
psychopathology, and memory development. In T. Plante (Ed.), Abnormal psychology through the
ages. Santa Barbara, CA: Greenwood Press/ABC-CLIO.
Paz-Alonso, P., Goodman, G. S., & Ibabe, I. (2013). Adult eyewitness memory and compliance: Effects of
post-event misinformation on memory for a negative event. Behavioral Sciences & Law, 31, 541-558.
McWilliams, K., Narr, R., Goodman, G.S., Mendoza, M., & Ruiz, S. (2013). Children's memory for
their mother's murder: Accuracy, suggestibility, resistance to suggestion. Memory, 21, 591-598.
Haralambie, A., Chae, Y, Hobbs, S. D, Goodman, G.S., Baker, J., & Burkholder, R. (2013). Children's
development, memory, and testimony. In A. M. Haralambie (Ed.), Handling child custody, abuse,
and adoption cases. Eagan, MN: Thomson Reuters/West.
Melton, G., Ben-Arieh, A., Cashmore, J., Goodman, G.S., & Worley, N. (Eds.). (2014). The Sage handbook of
child research. Newbury Park: Sage.
McWilliams, K., Augusti, E-M., Dion, J., Block, S. D., Melinder, A. M., Cashmore, J., & Goodman, G.S.
(2014). The child witness. In G. Melton, A. Ben-Arieh, J. Cashmore, G.S. Goodman, & N. Worley
(Eds.), The Sage handbook of child research (pp. 300-315). Newbury Park, CA: Sage.
Makariev, D., Hobbs, S., & Goodman, G.S. (2014). Challenges and innovations in research on
childhood. In G. Melton, A. Ben-Arieh, J. Cashmore, G.S. Goodman, & N. Worley (Eds.), The
Sage handbook of child research (pp. 285 - 299). Newbury Park, CA: Sage.
McWilliams, K., Goodman, G.S., Raskauskas, J., & Cordón, I. M. (2014). Child abuse and bullying. In G.
Melton, A. Ben-Arieh, J. Cashmore, G.S. Goodman, & N. Worley (Eds.), The Sage handbook of child
research (pp. 300-315). Newbury Park, CA: Sage.
Goodman, G.S., Ogle, C. M., McWilliams, K., Narr, R., & Paz-Alonso, K. (2014). Memory development in
the forensic context. In P. Bauer & R. Fivush (Eds.), Handbook on the development of children's
memory (pp.920-942). New York, NY: Wiley-Blackwell.
Hobbs, S. D., Johnson, J., Goodman, G.S., Bederian-Gardner, D., Lawler, M.J., Vargas, I., & Mendoza, M.
(2014). Children's eyewitness memory. In I. Weiner & R. Otto (Eds.), Handbook of forensic
psychology (pp. 561-613). New York: Wiley.
Lawler, M. J., Sayfan, L., Goodman, G. S., Narr, R., & Cordón, I. M. (2014). Comprehensive residential
education: A promising model for emerging adults in foster care. Children and Youth Services
Review, 38, 10-19.
McWilliams, K., Goodman, G.S., Lyons, K. E., Newton, J., & Avila-Mora, E. (2014). Memory for child
sexual abuse information: Simulated memory error and individual differences. Memory &
Cognition, 42, 151-163.
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Chae, Y., Goodman, G.S., Larson, R., Augusti, E-M., Alley, D., VanMeenen, K., Culver, M., & Coulter, K.
P. (2014). Children's memory for distressing events: The role of children's and parents'
attachment. Journal of Experimental Child Psychology, 123, 90-111.
Hobbs, S. D., Goodman, G. S., & Goodman-Shaver, D. (2014). Repeated interviews about repeated
abuse: Evaluation of a case study. Child Abuse & Neglect, 38, 212-216.
Castelli, P., & Goodman, G. S. (2014). Children's perceived emotional behavior at disclosure and
prosecutors' evaluations. Child Abuse & Neglect, 38, 1521-1532.
Goodman, G.S., Goldfarb, D. A., Chong, J., & Goodman-Shaver, L. (2014). Children's eyewitness
memory: The influence of cognitive and socio-emotional factors. Roger Williams University Law
Review, 19, 476-512.
Goldfarb, D. A., & Goodman, G.S. (2014). Cross-examination's big effect on the criminal system's
smallest witnesses: How the judiciary can alleviate the negative effects of cross-examination
Chronicle. London, UK: International Association of Youth and Family Judges and Magistrates.
Hobbs, S., Goodman, G.S., Oran, D., Block, S. D., Quas, J. A., Park, A., Widaman, K. F., & Baumrind, N.
(2014). Child maltreatment victims' attitudes about appearing in dependency and criminal
courts: A preliminary study. Children and Youth Services Review, 44, 407-416.
Hobbs, S., & Goodman, G.S. (Eds.). (2014). Child witness research. Behavioral Sciences & the Law, 32.
Hobbs, S., & Goodman, G.S. (Eds.). (2014). Child witnesses in the legal system: Improving child
interviews and understanding juror decisions. Behavioral Sciences & the Law, 32, 681-685
McWilliams, K., Harris, L. S., & Goodman, G.S. (2014). Child maltreatment, trauma-related
psychopathology, and eyewitness memory in children and adolescents. Behavioral Sciences & the
Law, 32, 702-717.
Bottoms, B. L., Peter-Hagene, L. C., Stevenson, M. C., Wiley, T. R. A., Mitchell, T.S., & Goodman, G.S.
(2014). Explaining gender differences in jurors' reactions to child sexual assault cases. Behavioral
Sciences & the Law, 32, 798-812.
Alley, D., Chae, Y., Cordón, I. M., Kalomiris, A., & Goodman, G.S. (2015). Child maltreatment and
autobiographical memory development: Emotion regulation and trauma-related
psychopathology. In D. Berntsen & L. Watson (Eds.), Clinical perspectives on autobiographical
memory (pp. 85-108). New York, NY: Cambridge University Press.
Goldfarb, D. A., Goodman, G.S., & Lawler, M.J. (2015). The United Nations Convention on the Rights of
the Child: Evidence by children. In S. Mahmoudi (Ed.), Child-friendly justice (pp. 85-109).
Stockholm, Sweden: Brill Nijhoff Publishers.
Johnson, J., McWilliams, K. E., Goodman, G.S., Shelley, A. E., & Piper, B. (2015). Basic principles of
interviewing the child eyewitness. In. W. O'Donohue & M. Fanetti (Eds.), Forensic interviews
regarding child sexual abuse - A guide to evidence-based practice (pp. 179-196). New York: Springer.
Goldfarb, D. A., & Goodman, G.S. (Eds.). (2015). Child victim witnesses: Context, testimony, and legal
cases. Behavioral Sciences & the Law, 33. Special issue on child witnesses.
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Larson, R. P., Goldfarb, D. A., & Goodman, G.S. (2015). Children's eyewitness memory and testimony in
context. Behavioral Sciences & the Law, 33, 367-371.
Bottoms, B. L., Goodman, G.S., Toulou-Shams, M, Diviak, K R., & Shaver, P. R. (2015). Religion-
related child maltreatment: A profile of cases encountered by legal and social service agencies.
Behavioral Sciences & the Law, 33, 561-579.
Schaaf, J. M., Bederian-Gardner, D., & Goodman, G.S. (2015). Gating out misinformation: Can young
children follow instructions to ignore false information? Behavioral Sciences & the Law, 33, 390-406.
Harris, L., Block, S. D., Ogle, C. M., Goodman, G.S., Augusti, E-M., Larson, R., Culver, M., Pineda, A.,
Timmer, S., & Urquiza, A. (2015). The relation between coping style and autobiographical
memory specificity in adolescents and adults with histories of child sexual abuse. Memory, 24,
1078-1090.
Silberkleit, G., Chopra, S., & Goodman, G.S. (2015). Witness preparation. In E. Krauss, S. Chopra, & W.
Roundtree (Eds). Jurywork: Systematic techniques. Minneapolis, MN: Thomas Reuters.
Goodman, G. S., Goldfarb, D. A., Quas, J. A., Narr, R. K., Milojevich, H., & Cordón, I. M.. (2016).
Memory development, emotion regulation, and trauma-related psychopathology. In
D. Cicchetti (Ed.), Developmental psychopathology (pp. 555-590). New York, NY: Wiley.
Larson, R. P., Cartwright, A., & Goodman, G.S. (Eds). (2016). Child victims and witnesses. Behavioral
Sciences & the Law, 34.
Cordón, I. M., Silberkleit, G., & Goodman, G.S. (2016). Getting to know you: Familiarity, stereotypes,
and children's eyewitness memory. Behavioral Sciences & the Law, 34, 74-94.
Paz-Alonso, P., & Goodman, G.S. (2016). Developmental differences across middle childhood in memory
and suggestibility for negative and positive events. Behavioral Sciences & the Law, 34, 30-54.
Tashjian, S. M., Goldfarb, D., Goodman, G.S., Quas, J. A., & Edelstein, R.S. (2016). Delay in disclosure of
nonparental child sexual abuse in the context of emotional and physical maltreatment. Child
Abuse & Neglect, 58, 149-159.
Goodman, G. S., Jones, O., & McLeod, C. (2017). Is there consensus about children's memory and
suggestibility? Journal of Interpersonal Violence, 32, 926-939.
Goodman, G. (2017, March 1). Why positive parenting trumps physical punishment when it comes to
disciplining kids [Blog post]. Retrieved from
http://psychologybenefits.org/2017/03/01/positive-parenting-physical-punishment-
disciplining-kids/.
Wardecker, B. M., Edelstein, R.S., Quas, J. A., Cordón, I. M., & Goodman, G.S. (2017). Emotion
language in trauma narratives is associated with better psychological adjustment among
survivors of childhood sexual abuse. Journal of Language and Social Psychology, 36, 628-653.
Saywitz, K. J., Lyon, T., & Goodman, G.S. (2017). When interviewing children: A review and update. In J.
Conte & B. Klika (Eds.), APSAC handbook on child maltreatment (pp. 310-329). Newbury Park, CA:
Sage.
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Goldfarb, D., Goodman, G. S., Larson, R.P., Gonzalez, A., & Eisen, M. L. (2017). Putting children's
memory and suggestibility in their place: An analysis considering person, topic, and context. In.
H. Otgaar & M. L. Howe (Eds.), Finding the truth in the courtroom: Dealing with deception, lies, and
memories (pp. 137-162). New York, NY: Oxford University Press.
Tashjian, S. M., Goldfarb, D., & Goodman, G.S. (2017). Considering parent-child relationship factors in
delayed disclosure of child sexual abuse. The Insider Newsletter, 22, Section on Child Maltreatment,
Division 37, American Psychological Association (Reprinted in the California Society on the Abuse
of Children Newsletter, Spring, 2017).
Goodman, G. S., Goldfarb, D., Quas, J. A., & Lyon, A. (2017). Psychological counseling and memory for
child sexual abuse. American Psychologist, 72, 920-931.
Bederian-Gardner, D., Goldfarb, D., & Goodman, G.S. (2017). Empathy's relation to the appraisal of
emotional child witnesses. Applied Cognitive Psychology.
Haralambie, A., Hobbs, S. D., Chae, Y., Goodman, G.S., Baker, J., & Burkholder, R. (2017). Children's
development, memory, and testimony. In A. M. Haralambie (Ed.), Handling child custody, abuse,
and adoption cases. Eagan, MN: Thomson Reuters/West.
Chae, Y., Goodman, M., Goodman, G.S., Troxel, N., McWilliams, K., Thompson, R. A., Shaver, P. R., &
Widaman, K. F. (2018). How children remember the Strange Situation Procedure. Journal of
Experimental Child Psychology, 166, 360-379.
Gershoff, E. T., Goodman, G. S., Miller-Perrin, C., Holden, G., Jackson, Y., & Kazdin, A. (2018). The
strength of the causal evidence against physical punishment of children and its implications for
parents, psychologists, and policymakers. American Psychologist, 73, 626-638.
Goodman, G.S. (2018). Award for Distinguished Senior Career Contributions to Psychology in the
Public Interest: Biography. American Psychologist.
Johnson, J. L., Goodman, G.S., & Mundy, P. (Eds.). (2018). The Wiley handbook on memory, Autism Spectrum
Disorder, and the law. London, UK: Wiley.
Johnson, J. L., Goodman, G.S., & Mundy, P. (2018). Autism Spectrum Disorder, memory, and the legal
system: Knowns and unknowns. In J. L. Johnson, G.S. Goodman, & P. Mundy (Eds.). The Wiley
Handbook on memory, Autism Spectrum Disorder, and the law. London, UK: Wiley.
Bederian-Gardner, D., Hobbs, S. D., Ogle, C. M., Goodman, G.S. et al. (2018). Instability in the lives of
foster and nonfoster youth: Attachment insecurities and mental health outcomes. Children and
Youth Services Review.
Johnson, J., Hobbs, S. D., Chae, Y., Goodman, G.S., Shestowsky, D., & Block, S. D. (2018). "I didn't do
that!" Adults' evaluations of children's true and false reports and denials. Journal of Interpersonal
Violence.
Goodman, G.S., Quas, J. A., Goldfarb, D., Gonzalves, L., & Gonzalez, A. (2018). Can trauma help long-
term memory for childhood events? Impact matters! Child Development Perspectives, 13, 3-9.
Hobbs, S. D., & Goodman, G.S. (2018). Self-representation: Pro se cross-examination and revisiting
trauma upon child witnesses. International Journal on Child Maltreatment, 1, 77-95.
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Goldfarb, D., Goodman, G. S., Larson, R. P., Eisen, M. L., & Qin, J. (2019). Long-term memory in
adults exposed to childhood violence: Remembering genital contact nearly 20 years later.
Clinical Psychological Science, 7, 381-396.
Prohilo, S., Goldfarb, D., Shestowsky, D., Sampana, J., Williams, L., & Goodman, G.S. (2018). Parental
alienation and child sexual abuse. Journal of Child Custody, 15, 302-329.
Goodman, G.S., Gonzalves, L., & Wolpe, S. (2019). False memory and true memory of childhood
trauma: Balancing the risks. Clinical Psychological Science. 7, 29-31.
Gershoff, E. T., Goodman, G. S., Miller-Perrin, C., Holden, G., Jackson, Y., & Kazdin, A. (2019). There is
still no evidence that physical punishment is effective or beneficial. American Psychologist, 74, 503-
505.
Goodman, G. S., & Bottoms, B. L. (2019). Karen Jill Saywitz (1956-2018). American Psychologist, 74, 515.
Goldfarb, D., Tashjian, S. D., Goodman, G.S., Bederian-Gardner, D., Hobbs, S. D., Cordón, I. M., Ogle, C.
M., Bakanosky, S., Narr, R. K., Chae, Y., and the NYTD/CYTD Research Group. (2019). After
child maltreatment: The importance of voice for youth in foster care. Journal of Interpersonal
Violence.
Hobbs, S. D., Bederian-Gardner, D., Ogle, C. M., Goodman, G.S., Cordón, I. M., Chong, J. and the NYTD-
CYTD Research Group. (2019). Psychological security in at-risk youth: Attachment, emotion
regulation, and PTSD symptom severity. International Journal on Child Maltreatment, 2, 17-36.
Eisen, M. L., Goodman, G.S., Diep, J., Lacsamana, M., Olomi, J., Goldfarb, D., & Quas, J. A. (2019). Effects
of interviewer support on the memory and suggestibility of maltreated and at-risk children.
International Journal on Child Maltreatment, 2, 55-78.
Alley, D., Silberkleit, G., Bederian-Gardner, D., & Goodman, G.S. (2019). Race-based stereotypes
influence ratings of child victims in sexual abuse cases. International Journal on Child Maltreatment,
2, 287-308.
McWilliams, K., & Goodman, G.S. (2019). Parental bias, parent-child discussion, and children's
eyewitness reports. International Journal on Child Maltreatment, 2, 219-237.
Goldfarb, D., Priolo-Filho, S., Sampana, J., Shestowsky, D., Wolpe, S., Williams, L., & Goodman, G.S.
(2019). International comparison of family court professionals' perceptions of parental alienation
and child sexual abuse allegations. International Journal on Child Maltreatment, 2, 323-341.
Goodman, G. S., & Wolpe, S. (Eds.). (2019). Child witness research in a rights-conscious era. International
Journal on Child Maltreatment, 2, 211-355.
Wolpe, S., & Goodman, G.S. (2019). Child witness research and children's rights. International Journal on
Child Maltreatment, 2, 211-217.
Goodman, G.S., Harris, L.S., Goldfarb, D., & Wang, Y. (2020). Children, race, psychology, and law: We
have no time to lose. In M. Stevenson, B. L. Bottoms, & K. Burke (Eds.), The legacy of racism for
children: Psychology, public policy, and law. New York, NY: Oxford University Press.
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Goldfarb, D., Goodman, G. S., Gonzalves, L., Gonzalez, A., Wang, Y., Wu, Y., & Vidales, D. (2020). Long-
term memory for child sexual abuse. In M. Miller & B. Bornstein (Eds.), Advances in psychology and
law (pp. 51-82). New York, NY: Springer.
McWilliams, K., Hobbs, S. D., Bederian-Gardner, D., Bakanosky, S. & Goodman, G.S. (2021). Children's
eyewitness memory and suggestibility: Revisiting Ceci and Bruck's (1993) review. In A. M. Slater
& P.C. Quinn (Eds.), Developmental psychology: Revisiting the classic studies (pp. 135-158). Thousand
Oaks, CA: Sage.
Wu, Y., Grandchamp, J., & Goodman, G.S. (in press). Child maltreatment and eyewitness memory. In
R. Roesch (Ed.), Routledge encyclopedia of psychology in the real world. New York, NY: Routledge.
Cleveland, K., Wu, Y., Hartman, D., Brown, L. F., & Goodman, G.S. (in press). Children's memory
development: Emotion, distress, and trauma. In M. L. Courage & N. Cowan (Eds.), The
development of memory in infancy and childhood. Psychology Press.
Eisen. M. E., Goodman, G. S., Diep, J., Lacsamana, M., Ristrom, L., & Qin, J. (in press). Disclosures of
sexual and physical abuse across repeated interviews. Journal of Child Sexual Abuse.
Enriquez, R., Brown, L. F., Metcalf, S. A., Quas, J. A., & Goodman, G.S. (in press). The developmental
science of children in criminal and dependency court: Emotional and attitudinal outcomes. In A.
D. Redlich & J. A. Quas (Eds.), The Oxford handbook on developmental psychology and law.
Oxford University Press.
Chae, Y., Goodman, G.S., Wang, Y., Goodman, M., McWilliams, K., Thompson, R. A., Shaver, P. R., &
Widaman, K. F. (in press). Parents' attachment orientation, interviewers' support, and children's
memory for a distressing event. Memory.
Wu, Y., Goodman, G. S., Goldfarb, D., Wang, Y., Vidales, D., Brown, L., Qin, J., & Eisen, M. L.
(in press). Memory accuracy for interviews about childhood trauma after 20 years. Child
Maltreatment.
Cordón, I. M., Chong, J., Grimm, K., Chong, J. Y., Christo, C., Mendoza, M., Clinton, A., & Goodman, G.
S. (submitted). Identifying learning disabilities screens for Spanish-speaking adults.
Gonzalves, L. C., Chae, Y., Widaman, K. F., Bederian-Gardner, D., Goodman-Wilson, M., Thompson, R.
A., Shaver, P.R., & Goodman, G.S. (submitted). Remembering years later: Attachment anxiety,
distress, and age.
Goldfarb, D., Goodman, G. S., Wang, Y., Fisher, R., Vidales, D., Gonzalves, L., Wu, Y., Hartman, D., Qin,
J., & Eisen, M. L. (accepted with minor revisions). Adults' memory for childhood traumatic
events: Protocols. Clinical Psychological Science.
XI. SELECTED BOOKS AND PAPERS IN PREPARATION
Goodman, G. S., Hobbs, S. D., & Lyon, T. D. Child witness research, child protection, and law.
To be submitted to American Psychological Association.
Wu, Y., Goodman, G. S., Goldfarb, D., Wang, Y., Vidales, D., Brown, L., Qin, J., & Eisen, M. L. Subjective
and objective memory for child maltreatment and maltreatment-related experiences.
Goodman, G. S., & Quas, J. A. Memory for child sexual abuse: Empirical findings.
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XII. AMICUS BRIEFS
Goodman, G.S., Levine, M., Melton, G., & Ogden, D. (1990). Craig V. Maryland. Amicus Brief to the U.
S. Supreme Court on behalf of the American Psychological Association. (This Amicus Brief was
cited by the U.S. Supreme Court.)
Myers, J. B., Goodman, G.S., & Saywitz, K.J. (1990). Wright V. Idaho. Amicus Brief to the U.S. Supreme
Court on behalf of the American Professional Society on the Abuse of Children, the American
Medical Association, the American Academy of Pediatrics, the National Association of Counsel
for Children, the National Organization of Women, and several other organizations.
XIII. PAPERS
Goodman, G.S., & O'Connor, M.J. (1976, September). Backward habituation curves: Infant cardiac responses
to repetitive auditory stimulation. American Psychological Association Convention, Washington D.C.
Goodman, G.S. Action schemata and memory. (1980, January). Paper presented at the Fifth Annual Inter-
Disciplinary Conference, Jackson Hole, Wyoming.
Goodman, G.S., Haith, M. M., & Guttentag, R. (1980, September). Reading in a second language: Automatic
processing and semantic interference. Paper presented at the 88th Annual Convention of the
American Psychological Association, Montreal, Canada.
Goodman, G.S., & Michelli, J. (1981. April). Psychology and the law: Effects of children's courtroom testimony.
Paper presented at the Annual Convention of the Rocky Mountain Psychological Association,
Denver, CO.
Goodman, G.S., & Loftus, G. R. (1981, August). Relevancy and expectancy: Visual scanning and memory
for action scenes. In A. Graesser (Chair), The use of schemata in human information processing.
Symposium presented at the 89th Annual Convention of the American Psychological Association,
Los Angeles, CA.
Goodman, G. S., Price, D. W. W., Cohen, K. M., & Haith, M. M. (1981, August). What you see is what you
get: Scanning action scenes. Paper presented at the 89th Annual Convention of the American
Psychological Association, Los Angeles, CA.
Goodman, G.S., & Loftus, G. R. (1982, January). When what's relevant is unexpected. Invited paper
presented at the Seventh Inter-Disciplinary Conference, Jackson Hole, Wyoming.
Demany, L., Goodman, G.S., & Haith, M. M. (1982, March). Infant's perception of rhythmic invariants in
melodic tone sequences. Paper presented, International Conference on Infant Studies, Austin, Texas.
Haith, M. M., Goodman, G.S., Goodwyn, M., & Montgomery, L. (1982, March). A longitudinal study of
infant's visual scanning and discrimination of form. Paper presented at the International Conference
on Infant Studies, Austin, Texas.
Goodman, G.S. (1982, May). A new direction in judicial research: Children's courtroom testimony. Invited
paper presented at the Nags Head Conference on New Directions in Judicial Research, Nags
Head, North Carolina.
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Goodman, G.S., & Golding, J. (1982, April). Effects of real-world knowledge on memory development.
In K. Nelson (Chair), Children's memory for real-world events. Symposium presented at the Society
for Research in Child Development Meetings, Detroit, MI.
Goodman, G.S., Haith, M. M., Guttentag, R., & Rao, S. (1982, April). Automatic processing of word meaning
by bilingual children. Paper presented at the Society for Research on Child Development meetings,
Detroit, MI.
Goodman, G.S., Golding, J., & Haith, M. M. (1983, August). Jurors' reactions to children's testimony. Paper
present at the 91st American Psychological Association Convention, Anaheim, CA.
Goodman, G.S. (Chair). (1983, August). The child witness: Psychological and legal issues. Symposium
presented at the 91st American Psychological Association Convention, Anaheim, CA.
Haith, M. M., Hazan, C., & Goodman, G.S. (1984, April). Infants' expectation and anticipation of future visual
events. Paper presented at the International Conference on Infant Studies, New York.
Haith, M. M., Hazan, C., & Goodman, G.S. (1984, May). Anticipation of future events in early infancy. Paper
presented at Third Developmental Psychobiology Research Group Retreat, Estes Park, CO.
Goodman, G.S. (1985, March). Suggestibility, memory, and child witnesses. Invited paper presented at "A
national policy conference on innovative legal procedures in child sexual abuse cases."
American Bar Association & the National Center on Child Abuse and Neglect, Washington, D.C.
Roberts, R., & Goodman, G.S. (1985, April). Reverse developmental trends: Development as the acquisition
of constraints. Paper presented Society for Research on Child Development Meeting,
Toronto, Canada.
Price, D. W. W., & Goodman, G.S. (1985, April). Children's comprehension of recurring episodes. Paper
presented at the Society for Research on Child Development Meeting, Toronto, Canada.
Goodman, G.S., Bormann, C., McKinnen, C., & Golding, J. (1985, August). Schema confirmation and schema
deployment. Paper presented at 93rd American Psychological Association Convention, LA, CA.
Goodman, G.S., Reed, R.S., & Hepps, D. (1985, August). The child victim's testimony. In M. Toglia
(Chair), Current trends in evaluating children's memory for witnessed events. Symposium presented
at American Psychological Association meeting, LA, CA.
Goodman, G.S., Helgeson, V., Shaver, P., & Lipton, J. (1986, March). Attitudes towards children's self-
determination rights. Paper presented at the American Psychology-Law Association meetings,
Tucson, AZ.
Goodman, G.S. The reliability of children's testimony. (1986, March). In D. Raskin (Chair), Investigative
practices in child sexual abuse cases. Symposium presented at the American Psychology and Law
Association meetings, Tucson, AZ.
Goodman, G.S., Golding, J. M., Helgeson, V., & Haith, M. M. (1986. August). When a child takes the
stand. In S. Ceci (Chair), Jurors' reactions to child witnesses. Symposium presented at the
American Psychological Association Convention, Washington, D.C., August, 1986.
Goodman, G.S., Hirschman, J., & Rudy, L. (1987, April). Children's testimony: Research and policy
implications. In S. Ceci, D. Ross, & M. Toglia (Chairs), Children's testimony: Social policy
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implications. Symposium presented at the Society of Research on Child Development Meetings,
Baltimore, Maryland.
Goodman, G.S., & Aman, C. (1987, April). Children's use of anatomically correct dolls to report an
event. In M. Steward (Chair), Anatomically correct dolls: Developmental, clinical, and legal
implications. Symposium, Society for Research in Child Development Meetings,
Baltimore, Maryland.
Goodman, G.S., Jones, D. P. H., & the Child Sexual Assault Research Group. (1987, August). Children in
court: Emotional reactions to court involvement. American Psychological Assoc. Meeting, N.Y., N.Y.
Pyle, E., & Goodman, G.S. (1987, August). Sex differences in the initial impact of child sexual abuse. Paper
presented at the American Psychological Association meetings, N.Y.
Goodman, G.S., & Aman, C. (1987, September). Children's use of anatomically detailed dolls: An
experimental study. Paper presented at the National Center on Child Abuse and Neglect's
Symposium on Interviewing Children, Washington, D.C.
Farrar, M.J., & Goodman, G.S. (1987, October). The relation between episodic and semantic memory in
children's scripts. Paper presented at the Emory Cognition Project's Conference, "What young
children remember and why." Department of Psychology, Emory University, Atlanta, GA.
Goodman, G.S. (1987, October). Ecological issues in the study of children's eyewitness testimony. Paper
presented at the Emory Cognition Project's Conference, "What young children remember and
why." Department of Psychology, Emory University, Atlanta, GA.
Goodman, G.S., Jones, D. P. H., & the Child Sexual Assault Research Group. (1987, December). The
treatment of child victim/witnesses in criminal court: Empirical findings. Paper presented at the
Conference on Child Abuse, Sponsored by the American Professional Society on the Abuse of
Children, Costa Mesa, CA, December, 1987.
Goodman, G.S., Saywitz, K. J., Aman, C., & Powders, M. (1988, March). A new view of children's
suggestibility. Presented in D. Peters (Chair), Children's testimony. Symposium, American
Psychology and Law Association meetings, Miami Beach, Florida.
Farrar, M.J., & Goodman, G.S. (1988, March). Event experience and autobiographical memory development.
Tenth Biennial Conference on Human Development, Charleston, South Carolina.
Goodman, G.S., Bottoms, B. L., & Herscovici, B. (1988, April). Psychological and legal issues in the
study of jurors' reactions to child witnesses. In M. Levine (Chair), Methodological issues in the
study of jury decision making. Eastern Psychological Association meetings, Buffalo, NY.
Goodman, G.S., Wilson, M. E., Hazan, C., & Reed, R.S. (1989, April). Children's testimony nearly four years
after an event. Eastern Psychological Association, Boston, MA.
Bottoms, B. L., & Goodman, G.S. (1989, April). The credibility of child victims of sexual assault. Eastern
Psychological Association, Boston, MA.
Goodman, G.S. (Chair). (1989, April). Current topics in research on children's testimony. Invited
symposium. Society for Research in Child Development, Kansas City, Missouri.
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Renouf, A., & Goodman, G.S. (1989, April). Emotional effects of child sexual abuse. Paper presented at the
Society for Research in Child Development, Kansas City, Missouri.
Saywitz, K. J., Goodman, G.S., Nicholas, E., & Moan, S. (1989, April). Children's memory of a genital
examination: Implications for cases of child sexual assault. In G.S. Goodman (Chair), Current
research on children's testimony. Society for Research in Child Development, Kansas City, Kansas,
Goodman, G.S., Rudy, L., Port, L. K., England, P., Bottoms, B. L., & Renouf, A. (1989, August). Do past
abuse experiences intrude into children's reports? In G.S. Goodman, (Chair). Child sexual abuse:
Understanding& improving children's testimony. Am. Psychological Assoc. Meeting, New Orleans,
LA.
Bottoms, B. L., Goodman, G.S., Rudy, L., Port, L. K., England, P., Aman, C., & Wilson, M. (1989, August).
Children's testimony for a stressful event: Improving children's reports. In G.S. Goodman,
(Chair). Child sexual abuse: Understanding and improving children's testimony. American
Psychological Association Meetings, New Orleans, LA.
Goodman, G.S., Taub, E., Jones, D. P. H., Port, L., England, P., & Prado, L. (1989, August). Emotional
effects of court involvement on children. In G.S. Goodman (Chair). Child abuse victims in court.
Symposium, American Psychological Association Meetings, New Orleans, LA. (This conference
paper was cited by the U.S. Supreme Court)
Bottoms, B. L., Goodman, G.S., Schwartz-Kenney, B., Sachsenmaier, T., & Thomas, S. (1990, March).
Keeping secrets: Implications for children's testimony. American Psychology and Law Meetings,
Williamsburg, VA.
Goodman, G.S. (1990, August). Media effects and children's testimony. In D. Singer (Chair), The impact
of the media on the judicial system. Invited symposium. American Psychological Association.
Boston, MA.
Goodman, G.S. (1990, October). When something bad may have happened: The accuracy of children's
reports. In S. Kassin (Chair), How the law informs psychology. Invited presentation, Society of
Experimental Social Psychologists, Buffalo, NY.
Goodman, G.S., Sharma, A., Golden, M., & Thomas, S. (1991, April). Mothers' versus strangers'
interviews of young children: Memory and suggestibility for a real-life event. In P. Ornstein &
N. Stein (Chairs), Children's autobiographical memory. Symposium presented at the Meetings of the
Society for Research in Child Development, Seattle, WA.
Schwartz-Kenney, B., & Goodman, G.S. (1991, April). Memory impairment in children. Paper presented at
the Meetings of the Society for Research in Child Development, Seattle, WA.
Goodman, G.S. (Chair). (1991, August). The assessment and diagnosis of child sexual abuse. Invited
symposium, American Psychological Association, San Francisco, CA.
Bottoms, B. L., Shaver, P. R., Goodman, G. S. & The Child Abuse Research Group (1991, August).
Prevalence and characteristics of alleged cases of ritual abuse of children. In G.S. Goodman & P.
R. Shaver (Chairs), Allegations of ritual abuse of children. Invited symposium, American
Psychological Association, San Francisco, CA.
Goodman, G.S., Sachsenmaier, T., Batterman-Faunce, J., Tobey, A., Thomas, S., Orcutt, H., & Schwartz-
Kenney, B. (1992, August). Impact of innovative court procedures on children's testimony. In B.
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L. Bottoms & M. Levine (Chairs), Children's eyewitness testimony. Symposium presented at the
American Psychological Association Convention, Washington, D. C.
Schwartz-Kenney, B., Bottoms, B. L., Goodman, G.S., & Wilson, M. (1992, August). Improving children's
accuracy for person identification. In B. L. Bottoms & M. Levine (Chairs), Children's eyewitness
testimony. Symposium, American Psychological Association Convention, Washington, D.C.
Tobey, A., & Goodman, G.S. (1992, August). Effects of participation and forensic context on children's
testimony. Paper presented at the American Psychological Association Convention, Wash, D.C.
Goodman, G.S. (1993, March). Children's memory for stressful events: Theoretical and developmental
considerations. In N. Stein (Chair), Emotional events and memory. Symposium presented at the
Society for Research in Child Development, New Orleans, LA.
Koocher, G., Friedrich, W., Goodman, G.S., Reynolds, C., Sivan, A., & White, S. (1993, August). Scientific
knowledge and anatomical dolls in child sexual abuse evaluations. Paper presented at the American
Psychological Association Convention, Toronto, Canada.
Orcutt, H., Goodman, G.S., Tobey, A., Batterman-Faunce, J., Thomas, S., & Shapiro, C. (1993, August).
Factfinders' abilities to detect deception in children's testimony. Paper presented at the American
Psychological Association Convention, Toronto, Canada.
Goodman, G.S. (1993, October). Individual differences in children's memory of stressful events. Invited
colloquium. Institute on Human Development, University of California, Berkeley.
Goodman, G.S. (1993, December). Repressed memory: Insights from ritual abuse allegations and from socially
sanctioned traumas. Paper presented at the conference on Memory for Trauma, Clark University.
Goodman, G. S., Qin, J. J., Bottoms, B. L., & Shaver, P.R. (1994, March). Repressed memory and allegations of
ritualistic and religion-related child abuse. Paper presented at the American Psychology and Law
Conference, Sante Fe, New Mexico.
Bottoms, B. L., Shaver, P. R., & Goodman, G.S. (1994, March). Claims of ritualistic child abuse in the U.S.
Paper presented at the American Psychology and Law Conference, Sante Fe, New Mexico.
Quas, J., Goodman, G.S., Bottoms, B. L., Qin, J. J., Shaver, P. R., Orcutt, H., & Shapiro, C. (1995, June).
Developmental differences in children's knowledge of ritual abuse. Poster presented at the Third
National Colloquium, American Professional Society on the Abuse of Children, Phoenix, AZ.
Goodman, G.S., Quas, J., & Batterman-Faunce, J. (1994, July). Forgotten childhoods: Children's reticence,
omissions, and forgetting. In L. Terr (Chair), Forgotten childhoods. International Meeting of Child
and Adolescent Psychiatry. San Francisco, CA.
Goodman, G.S. (1994, July). Trauma and children's memory: Processing traumatic events. In N. Stein
(Chair), Memory for emotional events. International Society on the Study of Emotions. Cambridge
University, England.
Goodman, G.S. (1994, September). Update on developmental research on child sexual abuse. In J.
Lipowsky (Chair), Update on child sexual abuse. Invited symposium, American Psychological
Association Convention, LA, CA.
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Goodman, G.S., Bottoms, B. L., Shaver, P. R., & Qin, J. (1995, March). Factors affecting children's
susceptibility versus resistance to false memory. In C. Brainerd (Chair), False memory in children.
Symposium, Society for Research in Child Development Meetings, Indianapolis, IN.
Goodman, G.S., & Baker-Ward, L. (1995, March). Children's memory for emotional and traumatic events.
Symposium, Society for Research in Child Development Meetings, Indianapolis, IN.
Goodman, G.S., Dunn, J., & Quas, J. (1995, March). Children's memory for a stressful event:
Developmental, individual difference, and interviewing considerations. In G.S. Goodman & L.
Baker-Ward (Chairs). Children's memory for traumatic and stressful events. Symposium, Society
for Research in Child Development Meetings, Indianapolis, IN.
Eisen, M., Goodman, G. S., & Qin, J.J. (1995, April). Memory and suggestibility for an emotional event in
maltreated children. In P. Ornstein (Chair), Stress and memory in children. Invited symposium,
Midwestern Psychological Association, Chicago, IL.
Bottoms, B. L., Beety, K., Goodman, G. S., Tyda, K., & Shaver, P. R. (1995, June). Repressed memory of
childhood abuse: A survey of clinicians. In B. L. Bottoms (Chair), Reactions to repressed memory
cases. Symposium presented at the American Psychological Society Meetings, New York, NY.
Goodman, G.S., Myers, J. E. B., Qin, J., Redlich, A., Quas, J.A., Schuder, M., & Rogers, L. (1995, July).
Effects of live testimony vs. hearsay on jurors' perceptions of children's evidence. Invited paper, U.S.
Department of Justice, Conference on Criminal Justice Research and Evaluation. Washington,
D.C.
Goodman, G. S., Eisen, M., & Qin, J. (1995, July). Eyewitness testimony in victims of child malteatment:
Stress, memory, and suggestibility. In J. Parker (Chair), Children's eyewitness memory: Stress and
arousal. Invited symposium, Society for Applied Research on Memory and Cognition, Vancouver.
Shaver, P. R., Bottoms, B. L., & Goodman, G.S. (1995, August). Did clinicians and clients co-create satanic
ritual abuse? R. Baumeister (Chair), Bizarre social phenomena. Symposium presented at the
American Psychological Association Convention, New York, NY.
Goodman, G.S., Eisen, M., & Qin, J. (1995, August). Trauma, memory, and child abuse: Preliminary results.
Invited paper, American Psychological Association Convention, New York, NY.
Eisen, M., Goodman, G.S., & Qin, J. (1995, August). Trauma, memory, and child abuse: Implications of
research to evaluation of child abuse. Invited paper, American Psychological Association
Convention, New York, NY.
Quas, J., & Goodman, G.S. (Chairs). (1996, February). Children's eyewitness memory: True and false reports.
Symposium presented at the American Psychology and Law Society meetings, Hilton Head, SC.
Bidrose, S., & Goodman, G.S. A case study of children's memories of abuse. (1996, February). In J. Quas
& G.S. Goodman (Chairs), Children's eyewitness memory: True and false reports. Symposium
presented at the American Psychology and Law Society meetings, Hilton Head, SC.
Quas, J., Denton, M, Goodman, G.S., & Myers, J. Consistency in children's true and false reports. (1996,
February). In J. Quas & G.S. Goodman (Chairs), Children's eyewitness memory: True and false
reports. Symposium, American Psychology-Law Society meetings, Hilton Head, SC.
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Goodman, G.S., Myers, J., Qin, J. J., Quas, J., Schuder, M., Rogers, L., & Redlich, A. (1996, February).
Should interviews of children be videotaped or adults testify in children's place?: Effects of
hearsay on jurors' decisions. In B. L. Bottoms (Chair), Jurors' reactions to child witnesses.
Symposium presented at the American Psychology and Law Society meetings, Hilton Head, SC.
Bottoms, B. L, Beety, K., Goodman, G. S., & Shaver, P.R. (1996, February). Individual differences in
therapists' reactions to allegations of ritual abuse. American Psychology and Law Society meetings,
Hilton Head, SC.
Quas, J. A., & Goodman, G.S. (1996, June). Predictors of self-blame in sexually abused children. Paper
presented at the APSAC Convention, Chicago, IL.
Redlich, A., Myers, J., Goodman, G.S., Qin, J. J., & Taus, M. (1996, June). Perceptions of children's evidence
in sexual abuse cases: Videotaped testimony and hearsay. American Psychological Society Convention,
San Francisco, CA.
Quas, J., Goodman, G.S., & Bulkley, J. (1996, June). District attorneys' views of innovative legal techniques for
children. American Psychological Society Convention, San Francisco, CA.
Pipe, M-E, Goodman, G.S., Quas, J., Bidrose, S., Ablin, D., & Craw, S.(1996, July). Remembering early
experiences during childhood: Are stressful events special? Invited paper, NATO Advanced Study
Institute, France.
Eisen, M., Goodman, G. S., Qin, J, & Davis, S. (1996, July). Maltreated children's memory for an anogenital
examination. Trauma and Memory conference, University of New Hampshire, New Hampshire.
Goodman, G.S., & Pipe, M.-E. (Co-Chairs). (1996, August). Remembering events from childhood: Children's
memory for stressful events after long delays. Invited symposium, International Society for the Study
of Behavioral Development, Quebec City, Canada.
Goodman, G. S., Quas, J. A., Bidrose, S., Pipe, M-E., & Ablin, D. (1996, August). Do children forget
traumatic events?: Children's memory for stressful events after long delays. In G.S. Goodman, &
M-E Pipe (Co-Chairs). Remembering events from childhood: Children's memory for stressful events after
long delays. Invited symposium, International Society for the Study of Behavioral Development,
Quebec City, Canada.
Eisen, M., Goodman, G.S., Qin, J, & Davis, S. (1996, August). Individual differences in maltreated children's
memory. American Psychological Association convention, Toronto, Canada.
Eisen, M., Goodman, G. S., Qin, J.J., & Davis, S. (1996, Nov.). Individual differences in maltreated children
related to memory, suggestibility, and consistency of abuse reports across interviews. International
Society for Traumatic Stress Studies, San Francisco, CA.
Eisen, M., Goodman, G.S., Qin, J. J., & Davis, S. (1996, Nov.). The impact of dissociation and psychopathology
on maltreated children's memory and suggestibility. International Society for Traumatic Stress
Studies, San Francisco, CA.
Goodman, G.S. (1996, Nov.). Discussant. In M. Eisen (Chair), Controversies surrounding interviews of abused
children: Memory, suggestibility, and the use of anatomical dolls. International Society for Traumatic
Stress Studies, San Francisco, CA.
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Goodman, G.S., & Redlich, A. (Chairs). (1997, March). New directions and dilemmas for ethical issues in
developmental research. Invited symposium, Society for Research in Child Development meetings,
Washington, D.C.
Quas, J. A., & Goodman, G.S. (Chairs). (1997, March). Individual differences in children's memory and
suggestibility. Symposium presented at the Society for Research in Child Development meetings,
Washington, D.C.
Qin, J., Eisen, M., Goodman, G.S., Davis, S., Hutchins, D., & Tyda, K. (1996, August). Maltreated
children's memory and suggestibility: Individual difference predictors. Paper presented in J.
Quas & G.S. Goodman (Chairs). 1997, March). Individual differences in children's memory and
suggestibility. Society for Research in Child Development meetings, Washington, D.C.
Quas, J. A., Goodman, G.S., & Schaaf, J. (1997, March). Children's source monitoring. Paper presented at the
Society for Research in Child Development meetings, Washington, D.C.
Quas, J. A., Schaaf, J., Goodman, G.S., & Luenberger, J. (1998, March). Children's memory and suggestibility
in repeated interviews. Paper presented at the American Psychology-Law Society Biennial
Convention, Redondo Beach, CA.
Goodman, G.S., Myers, J. E. B., Redlich, A., Qin, J., Quas, J., & Prizmich, L. (1998, March). Children's out-
of-court statements: Effects of hearsay on jurors' decisions. Paper presented at the American
Psychology-Law Society Biennial Convention, Redondo Beach, CA.
Redlich, A., Goodman, G.S., Lowery, M., & Barry, S. (1998, March). Community notification: Perceptions of
its effectiveness in preventing child sexual abuse. Paper presented at the American Psychology-Law
Society Biennial Convention, Redondo Beach, CA.
Qin, J. J., Goodman, G.S., & Barry, S. (1998, March). Predictors of false memory reports in adults. Paper
presented at the American Psychology-Law Society Biennial Convention, Redondo Beach, CA.
Ghetti, S., Eisen, M., Goodman, G.S., Qin, J. J., & Davis, S. (1998, August). Consistency in children's
allegations of physical and sexual abuse. Paper presented at the International Conference on Applied
Psychology, San Francisco, CA.
Eisen, M., Qin, J. J., Goodman, G.S., Davis, S., Hutchins, D., & Tyda, K. (1998, August). Maltreated
children's memory. Paper, International Conference on Applied Psychology, San Francisco, CA.
Ghetti, S., Eisen, M., Goodman, G.S., Qin, J. J., & Davis, S. (1998, March). The consistency of children's
disclosures of abuse. Paper presented at the American Psychology-Law Society Meetings, Redondo
Beach, CA.
Qin, J. J., Goodman, G.S., & Barry, S. (1998, July). Individual differences in adults' true and false memories of
childhood events. Paper presented at the American Professional Society on the Abuse of Children
Convention, Chicago, IL.
Goodman, G.S., Myers, J. E. B., Redlich, A., Qin, J. J., Quas, J., & Prizmich, L. (1998, August). Jurors'
reactions to hearsay in child sexual abuse cases. In G. Davies & H. Westcott (Chairs), Children as
witnesses. Invited symposium, International Conference Applied Psychology, San Francisco, CA.
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Ghetti, S., Eisen, M., Goodman, G.S., & Qin, J.J. (1998, August). Children's disclosures of sexual and physical
abuse. International Conference on Applied Psychology, San Francisco, CA.
Eisen, M., & Goodman, G. S. (1998, August). (Chairs). The effects of stress and trauma on children's memory
and suggestibility. Symposium, American Psychological Association Convention, San Francisco,
CA.
Eisen, M., Goodman, G. S., Qin, J.J., & Davis, S. (1998, August). The interactive effects of dissociation and
stress-arousal on maltreated children's memory. In M. Eisen & G.S. Goodman (Chairs). The effects
of stress and trauma on children's memory and suggestibility. Symposium presented at the American
Psychological Association Convention, San Francisco, CA.
Eisen, M., Goodman, G. S., Qin, J., & Davis, S. (1998, November). The effects of psychopathology and stress on
maltreated children's memory and suggestibility. The International Society for Traumatic Stress
Studies, Washington, D. C.
Quas, J. A., & Goodman, G. S. (Chairs). (1999, April). Children's victimization, eyewitness memory, and legal
experiences. Symposium, Society for Research on Child Development, Albuquerque, NM.
Goodman, G.S., Ghetti, S., Quas, J. A., Redlich, A., & Alexander, K. (1999, April). Memories of abuse 12
years after legal involvement. In J. A. Quas & G.S. Goodman (Chairs). (1999). Children's
victimization, eyewitness memory, and legal experiences. Symposium presented at the Society for
Research on Child Development Meetings, Albuquerque, NM.
Quas, J. A., Redlich, A., Goodman, G.S., Ghetti, S., & Alexander, K. (1999, April). Long-term
consequences on child sexual abuse victims of testifying in criminal court. In J. A. Quas & G.S.
Goodman (Chairs). (1999). Children's victimization, eyewitness memory, and legal experiences.
Symposium presented at the Society for Research on Child Development Meetings, Albuquerque,
NM.
Schaaf, J. M., Goodman, G.S., & Alexander, K. (1999, April). Effects of repeated interviewing on children's
memory and suggestibility for true and false events. In M. Welch & L. Fasig (Chairs). Symposium
presented at the Society for Research on Child Development Meetings, Albuquerque, NM.
Eisen, M., Goodman, G. S., Ghetti, S., & Qin, J. (1999, July). Disclosure of abuse in maltreated children. Society
for Applied Research in Memory and Cognition, Boulder, CO.
Qin, J., & Goodman, G.S. (1999, November). Individual differences and characteristics of false memory.
Psychonomics Society Convention, Los Angeles, CA.
Qin, J., Goodman, G.S., Myers, J. E. B., Orcutt, H., Quas, J. A., & Redlich, A. (2000, July). Children's
deception and jurors' deception detection. In K. Lee (Chair), New research on children's deception.
International Society for Behavioral Development, Beijing, China.
Goodman, G. S., Quas, J. A., & Ghetti, S. (Chairs). (2000, March). Children in legal cases: Experiences and
consequences. Symposium presented at the American Psychology-Law Society Convention, New
Orleans, LA.
Edelstein, R., Quas, J. A., Redlich, A., Alexander, K., Goodman, G. S., & Ghetti, S. (2000, March).
Disclosing, discussing, and remembering child sexual abuse and legal experience. In G.S.
Goodman, J. A. Quas, & S. Ghetti (Chairs). Children in legal cases: Experiences and consequences.
Symposium presented at the American Psychology-Law Society Convention, New Orleans, LA.
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Ghetti, S., Goodman, G.S., Quas, J. A., Redlich, A., Alexander, K., & Edelstein, R. (2000, March). Child
sexual abuse victims' perceptions and experiences years after legal involvement. In G.S.
Goodman, J. A. Quas, & S. Ghetti (Chairs). Children in legal cases: Experiences and consequences.
Symposium presented at the American Psychology-Law Society Convention, New Orleans, LA.
Alexander, K., Goodman, G.S., Schaaf, J., Quas, J. A. Edelstein, R., & Shaver, P. R. (2000, March).
Individual differences in children's memory for stressful experiences. Paper presented at the American
Psychology-Law Society Convention, New Orleans, LA.
Qin, J.J, & Goodman, G.S. (2000). Can adults distinguish true and false childhood memories? Paper
presented at the American Psychology-Law Society Convention, New Orleans, LA.
Ghetti, S., & Goodman, G.S. (2000, March). Competence and culpability: Judgments of juvenile offenders.
In A. Redlich & S. Ghetti (Chairs). Juvenile justice and children's competence. Symposium
presented at the American Psychology-Law Society Convention, New Orleans, LA.
Castelli, P., Goodman, G. S., & Ghetti, S. (2000, March). Effects of interviewing style and witness age on
jurors' reactions in child sexual abuse cases. In B. Bottoms & M. Kovera (Chairs), Juror-decision
making in cases involving child witnesses. Symposium presented at the American Psychology-Law
Society Convention, New Orleans, LA.
Qin, J., Goodman, G.S., Myers, J., Orcutt, H., Redlich, A., & Quas, J. A. (2000, March). Procedural reforms
in the courtroom and detecting deception in children. In R. Lindsay & K. Lee (Chairs), Children's
competence and testimony in legal proceedings. Symposium presented at the American Psychology-
Law Society Convention, New Orleans, LA.
Ghetti, S., Goodman, G. S., Quas, J. A., Alexander, K., Redlich, A., & Edelstein, R. (2000, June). Attitudes
toward the legal system: Effects of legal involvement on child abuse victims and their caretakers.
In M. Lamb & C. Brainerd (Chairs), Children in forensic contexts. American Psychological Society,
Miami, Florida.
Bottoms, B. L., Nysse, K., Tolou-Shams, M., Shaver P. R., Goodman, G. S., & Qin, J. J. (2000, July). Religion-
related child abuse and neglect: A survey of legal professionals. Paper presented at the American
Professional Society on the Abuse of Children, Chicago, IL.
Qin, JJ., Goodman, G. S., Orcutt, H., Redlich, A., & Myers, J. (2000, July). How well can children lie in
court? In K. Lee (Chair), Children's honesty and lying. International Society of Behavior and
Development, Beijing, China.
Ghetti, S., Goodman, G.S., Quas, J. A. Redlich, A., Alexander, K., Edelstein, R., Cordón, I., & Jones, D.
(2000, October). Sistema giudiziario e Child sexual abuse; Percezioni anni dopo il coinvolgimento. Paper
presented at the Annual Conference of the Italian Psychology-Law Society, Milan, Italy.
Goodman, G.S. (2001, January). Children's treatment in court. In D. Mossteller (Chair), Children in court.
Invited symposium. Society of Law Professors, San Francisco, CA.
Edelstein, R. Alexander, K., Schaaf, J., Goodman, G.S., Shaver, P.R., & Quas, J. A. (2001, February).
Parental attachment style and children's reactions to a stressful event. Society for Personality and Social
Psychology Annual Conference. San Antonio, Texas.
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Quas, J. A., Goodman, G. S., et al. (2001, April). Memory for sexual abuse and courtroom testimony. In K.
Alexander & J. A. Quas (Chairs), Children's and adults' memory for traumatic events. Symposium
presented at the Society for Research in Child Development. Minneapolis, MN.
Ghetti, S., Qin, J. J., & Goodman, G.S. (2001, April). False-memory formation in children and adults:
Recalling, recognizing, and attributing source to events that never happened. In S. Ghetti & J.
Schaaf (Chairs), Developmental changes in false-memory formation: Errors as byproducts of a functional
system? Symposium presented at Society for Research in Child Development. Minneapolis, MN.
Alexander, K., Goodman, G.S., Quas, J. A., Ghetti, S., Edelstein, R., Redlich, A., & Cordón, I. (2002). Long-
term memory for child sexual abuse and legal involvement. In A. Melinder & J. A. Quas (Chairs),
Child witnesses. European Psychology and Law Association, Leuven, Belgium.
Melinder, A., Alexander, K., & Goodman, G.S. (2002). Interviewing child witnesses: What is helpful? In
A. Melinder & J. A. Quas (Chairs), Child witnesses. European Psychology and Law Association,
Leuven, Belgium.
Alexander, K. W., Goodman, G. S., Edelstein, R., Schaaf, J., Quas, J. A., & Shaver, P. R. (2002, December).
Attachment and children's eyewitness memory. Memoria e suggestionabilita nell'eta evolutiva.
Universita degli Studi di Cassino, Cassino, Italy.
Castelli, P., Goodman, G. S., & Ghetti, S. (2002, December). Jurors' reactions to children's testimony: Effects of
age and leading questions. Presented at the Memoria e suggestionabilita nell'eta evolutiva.
Universita degli Studi di Cassino, Cassino, Italy.
Melinder, A., Kornes, M., Cordón, I, Goodman, G.S, & Gabrieli, J. (2003, April). Memory for emotional
pictures; A developmental study. Society for Research in Child Development, Tampa, FL.
Newton, J.W., Ghetti, S., & Goodman, G.S. (2003, June). Simulated amnesia: Does it really initiate genuine
forgetting of a crime event. American Psychological Society. Atlanta, GA.
Paz, K., Goodman, G. S., Ibabe, O., & DePaul, E. (2003, July). Effects of emotion on child eyewitness memory.
European Psychology and Law Conference. Edinburough, Scotland.
Goodman, G.S., Luten, T., Edelstein, R., & Ekman, P. (2003, August). Detecting lies in children and
adults. In T. Lyon (Chair), Veracity of children: The psychological and legal implications. American
Psychological Association Convention, Toronto, Canada.
Quas, J. A., Alexander, K., Ghetti, S., Goodman, G.S., Edelstein, R., Redlich, A., & Cordón, I. (2003,
August). Traumatization, post-traumatic stress, and long-term memory for child sexual abuse. In T. Lyon
(Chair), Interviewing children about trauma. American Psychological Association Convention,
Toronto, Canada.
Castelli, P., Ghetti, S., & Goodman, G.S. (2004, March). Reducing false memories by encouraging
metamemory assessments. American Psychology-Law Society (Division 41 of APA) Convention,
Scottsdale, AZ.
Goodman, G.S., Edelstein, R., Luten, T., & Block, S. (2004, March). Are children's lies more easily detected
than adults' lies? In K. Nysse-Carris (Chair). Cutting-edge developments in children and youths'
deception and adults' ability to detect it. American Psychology-Law Society (Division 41 of
APA)Convention, Scottsdale, AZ.
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Mitchell, E., Sayfan, L., & Goodman, G.S. (2004, March). Children's expressed emotional expression when
disclosing child abuse. American Psychology-Law Society Convention, Scottsdale, AZ.
Newton, J., Ghetti, S., & Goodman, G.S. (2004, March). How simulated amnesia affects forgetting of a crime
event. American Psychology-Law Society Convention. Scottsdale, AZ.
Malloy, L., Quas, J. A., Melinder, A., D'Mello, M., & Goodman, G.S. (2004, March). Effects of repeated
interviews on the information retrieved by child-witnesses in forensic interviews. In M. Pipe
(Chair). Repeated interviews in the forensic context. American Psychology-Law Society Convention,
Scottsdale, AZ.
Goodman, G.S., Discussant. In M. Pipe (Chair). Repeated interviews in the forensic context. American
Psychology-Law Society Convention, Scottsdale, AZ.
Block, S., Greenberg, S., & Goodman, G.S. (2004, June). Emotional relevance and jurors' memory. American
Psychological Society. Chicago, IL.
Cordón, I., Quas, J. A., Ghetti, S., Edelstein, R., Alexander, K., Redlich, A., & Goodman, G.S. (2004, July).
Revictimization in child sexual abuse victims. American Psychological Society. Chicago, IL.
Goodman, G.S., & Quas, J. A. (2004, July). Parental attachment and child memory for distressing events.
American Psychological Association Convention. Honolulu, Hawaii.
Goodman, G. S., Sayfan, L., & Mitchell, E. (2004, July). Consequences of emotion at disclosure during forensic
interviews of children. American Psychological Association Convention. Honolulu, Hawaii.
Block, S. D., Oran, D., Goodman, G.S., & Oran, H. (2005, March). Children in dependency court. Paper
presented at the American Psychology-Law Society Meetings, La Jolla, CA.
Castelli, P., Sayfan, L., Mitchell, E., Culver, M., & Goodman, G.S. (2005, March). Children's emotional
expressions when disclosing abuse. In L. Malloy &J. A. Quas (Chairs), Disclosing child abuse:
Insight from forensic and courtroom settings. Symposium paper presented at the American
Psychology-Law Society Meetings, La Jolla, CA.
Block, S., Goodman, G.S., Oran, D., & Oran, H. (2005, April). Children's reactions to dependency court
involvement: Attitudes and knowledge. Society for Research in Child Development, Atlanta, GA.
Schaaf, J., Alexander, K., & Goodman, G.S. (2005, April). Individual differences in children's true and false
memory. Society for Research in Child Development, Atlanta, GA.
Howe, M., & Goodman, G.S. (Chairs). (2005, April). Stress, trauma, and children's memory. A symposium
presented at the Society for Research in Child Development, Atlanta, GA.
Alexander, K., Quas, J. A., Ghetti, S., Edelstein, R., Redlich, A., Cordón, I., & Goodman, G.S., (2005,
April). Childhood stress and long-term memory. Society for Research in Child Development, Atlanta,
GA.
Goodman, G.S. (2005, May). Discussant: Effects of childhood trauma on memory. American Psychological
Society Convention, Los Angeles, CA.
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Goodman, G. S., Ghetti, S., Quas, J. A., Edelstein, R., & Alexander, K. (2005, May). Subjective and objective
forgetting of documented child sexual abuse. American Psychological Society Convention, Los
Angeles, CA.
Lyons, K., Newton, J. W., & Goodman, G.S. (2005, May). Simulated amnesia impairs memory of child sexual
abuse. American Psychological Society Convention, Los Angeles, CA.
Goodman, G.S. (2005, August). Child witnesses and social policy. In B. Bottoms (Chair), Division 37
Presidential Symposium: Cross cutting topics in social policy for children. American Psychological
Association. Washington, D. C.
Goodman, G.S. (2006, March). Jurors and child witness: Discussion comments. In B. Bottoms & J. Golding
(Chairs), Jurors & reactions to child and elderly witnesses. American Psychology - Law Society
Convention. St. Petersburg, FL.
Donohue, S. E., Paz-Alonso, P. M., Ghetti, S., Teng, S., Goodman, G.S., & Bunge, S.A. (2006, April).
Developmental changes in brain activation associated with true and false recognition. Annual Cognitive
Neurosciences Society (CNS) meeting, San Francisco, CA.
Cordón, I., Edelstein, R., Melinder, A., & Goodman, G.S. (2006, May). Children's memory for emotional and
nonemotional pictures. Association of Psychological Science, New York.
Block, S. D., Goodman, G.S., Harris, L., Ogle, C., Urquiza, A., Timmer, S., & Culver, M. (2006, May).
Child maltreatment and DRM false memory. In S. D. Block & G.S. Goodman. Trauma and
cognitive processing. Symposium, Association of Psychological Science, New York.
Augusti, E-M., Ogle, C., Block, S. D., Harris, L., Urquiza, A., Timmer, S., Pineda, R., & Goodman, G.S.
(2006, May). Emotional Stroop and autobiographical memory in traumatized children and adults.
Association of Psychological Science, New York.
Donohue, S. E., Paz-Alonso, P. M., Ghetti, S., Goodman, G. S., & Bunge, S. A. (2006, June). Brain activation
associated with veridical and illusory recognition: A developmental study. Annual Human Brain
Mapping (HBM) meeting, Florence (Italy).
Paz-Alonso, P. M., & Goodman, G.S. (2006, July). Effects of centrality criteria on misinformation results. 4th
International Conference on Memory (ICOM), Sidney (Australia).
Paz-Alonso, P. M., Donohue, S. E., Ghetti, S., Goodman, G.S., & Bunge, S. A. (2006, October).
Neurodevelopmental correlates of brain activation during true and false recognition. Society for
Neuroscience, Atlanta, GA.
Ogle, C. M., Block, S. D., Harris, L., Augusti, E-M., Pineda, R., Urquiza, A., Timmer, S., & Goodman, G.S.
(2007, April). PTSD severity and DRM recall predict adolescents' autobiographical memory accuracy.
Society for Research in Child Development, Boston, MA.
Harris, L., Block, S. D., Ogle, C., Larson, R., Culver, M., Urquiza, A., Timmer, S., & Goodman, G.S. (2007,
April). Deese/Roediger-McDermott (DRM) false memory in maltreated and non maltreated adolescents
and adults with PTSD symptoms. Society for Research in Child Development, Boston, MA.
Block, S.D., Shestowsky, D., Schaaf, J., & Goodman, G.S. (2007, February). Can adults discern true from
false memories in children? On the Witness Stand Conference. John Jay College, NY.
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Block, S. D., Shestowsky, D., Schaaf, J., & Goodman, G.S. (2007, April). Detecting deception in children:
Implications for legal cases involving children. L. Baker-Ward (Chair). Preschool children's event
reports: Predicting, increasing, and identifying the provision of accurate information. Society for
Research in Child Development, Boston, MA.
Paz-Alonso, P. M., Donohue, S. E., Ghetti, S., Goodman, G. S., & Bunge, S. A. (2007, April). Neurocognitive
development in true and false recognition. Society for Research in Child Development, Boston, MA.
Goodman, G.S. (2007, April). Discussant: The Deese-Roediger McDermott task: Child sexual abuse victims have
less false memory for trauma-related than nontrauma-related words. Society for Research in Child
Development, Boston, MA.
Block, S. D., Shestowsky, D., Segovia, D., Schaaf, J., & Goodman, G.S. (2008, March). Adults' abilities to
discern true and false memory in preschoolers. American Psychology-Law Society Convention.
Jacksonville, FL.
Chae, Y., Augusti, E-M., Larson, R., Alley, D., Culver, M., Hansen, R., & Goodman, G.S. (2008, March).
The role of authenticity in children's memory and suggestibility for a stressful event. American
Psychology-Law Society Convention. Jacksonville, FL.
Harris, L., Block, S. D., Ogle, C. M., Augusti, E. M., Larson, R., Pineda, A., Culver, M., & Goodman, G.S.
(2008, May). The relation between coping style and autobiographical memory specificity in maltreated and
nonmaltreated adolescents. Association of Psychological Science, Chicago, IL.
Block, S. D., Shestowsky, D., Segovia, D., Schaaf, J., & Goodman, G.S. (2008, August). Can adults
distinguish between children's true and false memories? American Psychological Association
Convention. Boston, MA.
Goodman, G.S. & Melinder, A. M.D. (Chairs). (2009, April). Child maltreatment and memory: Contributions
to a scientific understanding. Symposium presented at the Society for Research in Child
Development meetings, Denver, CO.
Baugerud, G-A., Melinder, A. M. D., Goodman, G. S., & Goodman-Brown, T. (2009, April). Maltreated children's
memory for removal from home. In G.S. Goodman. & A. M. D. Melinder (Chairs). Child
maltreatment and memory: Contributions to a scientific understanding. Symposium presented at the
Society for Research in Child Development meetings, Denver, CO.
Block, S. D., Ogle, C. M., Harris, L., Augusti, E. M., Larson, R., Culver, M., Pineda, A., Urquiza, A., Timer,
S., & Goodman, G.S. (2009, April). False memory findings in maltreated adolescents and adults.
In G.S. Goodman & A. M. D. Melinder (Chairs). Child maltreatment and memory: Contributions to
a scientific understanding. Society for Research in Child Development meetings, Denver, CO.
Greenhoot, A., & Goodman, G.S. (Chairs). (2009, May). Does trauma adversely affect autobiographical
memory? Symposium presented at the Association of Psychological Science, San Francisco, CA.
Larson, R., Chae, Y., Augusti, EM, Alley, D., Hansen, R., & Goodman, G.S. (2009, May). Children's use of
body drawings to recall a stressful event. In M. Bruck & M. Lamb (Chairs), Children's memories
and reports of touching events. Symposium presented at the Association of Psychological
Science, San Francisco, CA.
Harris, L., Block, S., Ogle, C. M., Pineda, A., Urquiza, A., Timmer, S., & Goodman, G.S. (2009, May).
Coping and memory in adolescents and adults with maltreatment histories. In A. Greenhoot &
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G.S. Goodman (Chairs). Does trauma adversely affect autobiographical memory? Symposium
presented at the Association of Psychological Science, San Francisco, CA.
Bederian-Gardner, D., Cooper, V., Augusti, E-M., Paz-Alonzo, P., & Goodman, G.S. (2009, May). The role
of gist and monitoring processes in emotional true and false memory. Paper presented at the
Association of Psychological Science, San Francisco, CA.
Goodman, G.S., Block, S. D., Segovia, D., Schaaf, J. M., Alexander, K. W., & Shestowsky, D. (2009,
November). Adults' discernment of children's true and false memory reports. Paper presented at
the Conference on Empirical Legal Studies, University of Southern California, Los Angeles, CA.
Block, S. D., Shestowsky, D., Segovia, D., Schaaf, J., & Goodman, G.S. (2010, March). Adults' difficulties
in detecting false denials: Implications for policy and practice. In E. Krackow (Chair), Improving
and evaluating eyewitness reports. Symposium presented at the American Psychology-Law
Society Conference, Vancouver, Canada.
Bederian-Gardner, D., Cooper, V., Augusti, E-M., Hembacher, E., Paz-Alonzo, P., & Goodman, G.S.
(2010, March). Emotional true and false memory: The influence of gist and monitoring processes. Paper
presented at the American Psychology-Law Society Conference, Vancouver, Canada.
McWilliams, K., Goodman, G.S., Lyons, K., & Newton, J. (2010, May). Simulated memory impairment
affects recall of child sexual abuse. Paper presented at the Association for Psychological
Science, Boston, MA.
Błażek, M., Kazmierczak, M., Lewandowska-Walters, A., & Goodman, G.S. (2010, July). A change in the
range of parental custody and emotional bounds in the family. Paper submitted to the International
Association for Relationship Research, Herzliya, Israel.
McWilliams, K., Chae, Y., Larson, R., Augusti, E-M., Alley, D., Hansen, R., & Goodman, G.S. (2011,
March). The association of children's stress level and parent emotion talk during the discussion
of a distressing event. Society for Research in Child Development, Montreal, Canada.
Bederian-Gardner, Paz-Alonso, K., Hembacher, E., & Goodman, G. (2011, March). Developmental
differences in emotional true and false memory: The role of gist and monitoring processes. In T.
Marche (Chair). Children's memory for emotional information. Society for Research in Child
Development, Montreal, Canada.
Ogle, C. M., Block, S. D., Harris, L.T., Augusti, E-M., Pineda, A., Timmer, S., Urquiza, A., &
Goodman, G.S. (2011, March). Attachment and abuse-related false memory in maltreated adolescents
and young adults. Society for Research in Child Development, Montreal, Canada.
Larsen, R., Chae, Y., Alley, D., Augusti, E.-M., Culver, M., Hansen, R. L., & Goodman, G.S. (2011,
March). Individual differences in children's memory: Human figure drawings, attachment, and
distress. American Psychology Law Society meetings, Miami, FL.
Lawler, M. J., Goodman, G.S., Cordón, I. M., & O'Brien, S. (2011, July). Inter-agency data sharing and
protection: Measuring child well-being in the United States. Child Indicator Conference, York, UK.
Melinder, A. M., Baugerud, G., Ovenstad, K., & Goodman, G.S. (2012, March). Children's memory of
removal: A test of attachment theory. American Psychology-Law Society Conference, San Juan,
Puerto Rico.
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McWilliams, K. E., Harris, L.T., & Goodman, G.S. (2012, March). Child maltreatment and eyewitness
memory. American Psychology-Law Society Conference, San Juan, Puerto Rico.
Johnson, J., Goodman, G. S., Quas, J. A., Cordón, I. M., & Alexander, K. W. (2013, March). Betrayal trauma
and memory for child sexual abuse. American Psychology-Law Society Convention, Portland, OR.
Goodman, G.S., (2013, April). Child witnesses and social support: Symposium discussant. American
Psychology-Law Society Convention, Portland, OR.
Hobbs, S. D., Goodman, G. S., Oran, D., Block, S. D., Quas, J. A., Park, A., Widaman, K. F., & Baurmind, N.L.
(2013, March). Child abuse victims' responses to appearing in dependency and criminal courts. American
Psychology-Law Society Convention, Portland, OR.
Johnson, J., Shelley, A. E., Goodman-Shaver, L., & Goodman, G.S. (2013, March). Adults' perceptions of
child victims interviewed at Child Advocacy Centers. American Psychology-Law Society Convention,
Portland, OR.
Troxel, N., Goodman, G.S., & Hastings, P. (2013, March). Judgments of same-sex, juvenile-on-juvenile sexual
offenses. American Psychology-Law Society Convention, Portland, OR.
McWilliams, K., Harris, L., & Goodman, G.S. (2013, April). Child maltreatment and memory for
emotional information. Society for Research in Child Development Meetings, Seattle, WA.
Procida, K., Bederian-Gardner, D, & Goodman, G.S. (2013, April). Empathy and the relation between child
emotional display and juror decision making. Presented at the 24th Annual Undergraduate Research,
Scholarship, & Creative Activities Conference. University of California, Davis.
Goodman, G.S., (2013, April). Eliciting honesty from children: Symposium discussant. Society for Research in
Child Development Meetings, Seattle, WA.
Troxel, N., Goodman, G.S., & Hastings, P. (2013, April). Perceptions and judgments of same-sex, juvenile-
on-juvenile sexual offenses. Society for Research in Child Development Meetings, Seattle, WA.
Oran, D., Hobbs, S. D., Goodman, G. S., Block, S. D., Quas, J. A., Park, A., Widaman, K. F., & Baumrind,
N. (2013, April). Child maltreatment victims' attitudes about appearing in dependency and criminal
court. UCLA 12th Annual Research and Evidence-Based Practice Conference, Los Angeles, CA.
Chae, Y., Goodman, M., Goodman, G.S., McWilliams, K., Troxel, N., Thompson, R., Shaver, P. R., &
Widaman, K.F. (2013, July). Children's remembering and misremembering of an attachment-
evoking stressful event. American Psychological Association, Honolulu, Hawaii.
Cordón, I. M., Goodman, G.S., Mendoza, M., Vargas, I., Ruiz, S., & Narr, R. (2013, July). Spanish
Language Learning Experiences Project: Developmental correlates of adult learning disabilities in low
income Spanish speakers. American Psychological Association, Honolulu, Hawaii.
Johnson, J. L., Hobbs, S., Chae, Y., Goodman G.S., Shestowsky, D., & Block, S. D. (2013, September). Child
age and event valence influence adults' detection of children's true and false narratives. 15th Conference
on Partnerships for Children and Families, California State University, Los Angeles, CA.
Johnson, J. L., Shelley, A. E., Goodman-Shaver, L., & Goodman, G.S. (2013, September). Do child
advocacy center protocols influence mock-juror perceptions of child reporters? 15th Conference
on Partnerships for Children and Families, California State University, Los Angeles, CA.
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Goldfarb, D., Narr, R., Kalomiris, A., Goodman, G. S., Eisen, M. E., & Qin, J. (2013, September). Poverty
and perceptions of fairness of the legal system. 15th Conference on Partnerships for Children and
Families, California State University, Los Angeles, CA.
Oran, D., Hobbs, S. D., Goodman, G. S., Block, S. D., Quas, J. A., & Baumrind, N. (2013, October).
Children's participation in court, the debate continues. What does the preliminary evidence say?" US
Psychiatric and Mental Health Congress. Las Vegas, NV.
McWilliams, K., Goodman, G.S., Narr, R., Ruiz, S., & Mendoza, M. (2014, November). Children's
memory for their mother's murder: Accuracy, suggestibility, and resistance to suggestion. In M.
Howe & M. Conway (Chairs), Memory & the law. Psychonomic Society, Toronto, Canada.
Wardecker, B., Edelstein, R., Goodman, G.S., Quas, J. A., Alexander, K. W., & Cordón, I. M. (2014,
February). Emotion language in trauma narratives is associated with mental health symptoms for
survivors of childhood sexual abuse. Society for Personality and Social Psychology, Austin, TX.
Narr, R., Bederian-Gardner, D., Goodman, G. S., Bakanosky, S., & Hastings, P. (2014, March ). The role of
emotion regulation in adolescent attachment and mental health. Society for Research on Adolescence
Convention, Austin, TX, submitted.
Bederian-Gardner, D., Procida, K. J., & Goodman, G.S. (2014, March). Mock jurors' expectations of
emotions displayed by child witnesses. American Psychology-Law Society Meetings, New
Orleans, LA.
Chae, Y., Goodman, M., Goodman, G.S., Troxel, N., McWilliams, K., Shaver, P. R., Thompson, R. A., &
Widaman, K. W. (2014, March). Children's memory and suggestibility about a stressful event: The
role of attachment orientations. American Psychology-Law Society Meetings, New Orleans, LA.
Johnson, J., Hobbs, S., Chae, Y., Goodman, G.S., Shestowsky, D., & Block, S. D. (2014, March). Child age,
child gender, and event valence influence adults' abilities to detect the truth of children's
eyewitness memory reports. American Psychology-Law Society Meetings, New Orleans, LA.
McWilliams, K., & Goodman, G.S. (2014, March). Parent-child conversations and children's eyewitness
memory. American Psychology-Law Society Meetings, New Orleans, LA.
Goodman, G.S. (2014, March). Discussant comments. In J. Klemfess & K. Saywitz (Chairs), Improving
children's recall and reports. American Psychology-Law Society Meetings, New Orleans, LA.
Lyon, A., & Goodman, G.S. (2014, April). The relation between attending therapy and the accuracy of child
sexual abuse memory. University of California Undergraduate Research Conference, Davis, CA.
Alley, D., Bederian-Gardner, D., & Goodman, G.S. (2014, May). Implicit/explicit stereotyping effects on
adults' perceptions of child sexual abuse victims. Association for Psychological Science Convention,
San Francisco, CA.
Bederian-Gardner, D., Goldfarb, D., Ross, J., & Goodman, G.S. (2014, May). Emotion attribution and child
sexual abuse. Association for Psychological Science Convention, San Francisco, CA.
Otgaar, H., Howe, M. L., & Goodman, G.S., & (2014, June). A new look at children's testimonial
accuracy. In V. Nadege (Chair), The implications of suggestibility and false memories for eyewitness
testimony. 28th International Congress of Applied Psychology, Paris, France.
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Johnson, J. L., Goodman, G.S., & Shelley, A. E. (2014, September). Modeling the effects of child advocacy
centers on mock-jurors' perceptions. 16th Conference on Partnerships for Children and Families in
Los Angeles County, California State University, Los Angeles, CA.
Bederian-Gardner, D., Goldfarb, D., Ross, J., & Goodman, G.S. (2014, September). Emotion attribution and
child sexual abuse testimony. 16th Conference on Partnerships for Children and Families in Los
Angeles County, California State University, Los Angeles, CA.
Alley, D., Bederian-Gardner, D., & Goodman, G.S. (2014, September). Implicit/explicit stereotyping effects on
adults' perceptions of child sexual abuse victims. 16th Conference on Partnerships for Children and
Families in Los Angeles County, California State University, Los Angeles, CA.
Wardecker, B., Edelstein, R., Goodman, G.S., Quas, J. A., Alexander, K. W., & Cordón, I. M. (2014,
September). Emotion language in trauma narratives is associated with mental health symptoms for
survivors of childhood sexual abuse. 16th Conference on Partnerships for Children and
Families in Los Angeles County, California State University, Los Angeles, CA.
Kinsler, P., & Goodman, G.S. (2014, October). The good, the bad, and the ugly in child interviewing.
International Society for the Study of Trauma and Dissociation, Long Beach, CA.
Tashjian, S., Goldfarb, D. A., Goodman, G.S., & Quas, J. A. (2015, March). Attachment orientation and
caregiver supportiveness shape perceptions of fairness. Society for Research on Child
Development Meetings, Philadelphia, PA.
Goodman, G.S., Bederian-Gardner, D., Cordón, I. M., Hobbs, S. D., Narr, R., Bakanosky, S., and the
California NYTD-CYTD Research Group. (2015, March). Attachment and emotion regulation:
Predictors of child well-being in foster youth. In L. Newland & M. L. Lawler (Chairs).
Understanding children's subjective well-being across age groups and contexts Society for Research on
Child Development Meetings, Philadelphia, PA.
Tashjian, S., Goldfarb, D. A., Goodman, G.S., & Quas, J. A. (2015, March). Child sexual abuse victims delay
disclosure when caregivers are emotionally or physically abusive. American Psychology-Law
Society Conference, San Diego, CA.
McWilliams, K., Goodman, G.S., Shelley, A., & Omoli, J. (2015, March). Parent-child discussion, parental
bias, and children's eyewitness memory. American Psychology-Law Society, San Diego, CA.
Lyon, A., Goldfarb, D., Goodman, G.S., & Quas, J. A. (2015, March). The relation between attending
therapy and accuracy of child sexual abuse memory. American Psychology-Law Society, San
Diego, CA. (This paper won 1st place in the AP-LS Undergraduate Paper Award competition.)
Goodman, G.S. (2015, August). Effects of hitting children: Science and policy. In E.T. Gershoff (Chair).
Changing attitudes about and use of spanking across contexts and cultures. American
Psychological Association Convention, Toronto, Canada.
Bederian-Gardner, D., Goodman, G.S., & Chae, Y. (2015, August). Predictors of children's lying: The role
of attachment. In A. Evans (Chair), Children's disclosure of wrongdoing. American Psychological
Association Convention, Toronto, Canada.
Hobbs, S. D., Bederian-Gardner, D., & Goodman, G.S. (2015, August). Attachment anxiety and PTSD in at
risk foster youth. American Psychological Association Convention, Toronto, Canada.
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Tashjian, S. M., Goldfarb, D., Goodman, G.S., Bederian-Gardner, D., Hobbs, S. D., Bakanosky, S., Narr,
R., & the California NYTD-CYTD Research Team (2015, September). Opportunity for voice
predicts foster youth's views of the dependency courts. Annual Partnership Conference: A New
Beginning for Partnerships, Children & Families in LA County. California State University and
LA County Dependency Court, LA, CA. (Winner, CAPSAC Paul Crissey Research Award).
Tashjian, S. M., Goldfarb, D., Goodman, G.S., & Quas, J. A. (2015, September). Parental abuse contributes
to delays in non-parental child sexual abuse disclosure. Annual Partnership Conference: A New
Beginning for Partnerships for Children & Families in Los Angeles County. California State
University-Los Angeles and Los Angeles County Dependency Court, Los Angeles, CA.
Bederian-Gardner, D., Chae, Y., & Goodman, G.S. (2015, October). Predictors of children's lying
to conceal parental transgression. UC Consortium on Social Sciences and Law
Conference, University of California, Irvine.
Johnson, J., Hobbs, S. D., Chae, Y., Goodman, G.S., Shestowsky, D., & Block, S. D. (2015,
October). Detecting children's true and false accounts: Effects of child age, event valence,
or adult attitudes towards child eyewitnesses. UC Consortium on Social Sciences and
Law Conference, University of California, Irvine.
Hobbs, S. D., Bederian-Gardner, D., Goodman, G.S., and the California CYTD/NYTD Research
Group. (2015, October). Residential instability and foster children well-being. UC Consortium
on Social Sciences and Law Conference, University of California, Irvine.
Silberkleit, G., Cordón, I. M., & Goodman, G.S. (2016, March). Who spilled the jelly? Familiarity,
stereotypes, and children's memory. American Psychology-Law Society Convention,
Atlanta, GA.
Goldfarb, D. A., Tashjian, S. M., Goodman, G.S., Bederian-Gardner, D., Hobbs, S. D., Cordón, I.
M., Ogle, C., Bakanosky, S., Narr, R. K., Chae, Y., and the NYTD/CYTD Research Group
(2016, March). The importance of voice: Legal socialization and dependency court. American
Psychology-Law Society Convention, Atlanta, GA.
Goodman. G.S., & Goldfarb, D. A. (2016, March). Disclosure and child abuse: Discussant
comments. In S. Stolzenberg Roosevelt (Chair). Children's disclosures: Overcoming
reluctance, understanding recantation, and promoting clarity. American Psychology-Law
Society Convention, Atlanta, GA.
Chae, Y., Goodman, M., Goodman, G.S., Troxol, N., McWilliams, K. Thompson, R. T.,
Shaver, P. R., & Widaman, K. F. (2016, March). Attachment, interviewer support, and
children's eyewitness memory about a distressing event. American Psychology-Law Society
Convention, Atlanta, GA.
Alley, D., Bederian-Gardner, D., & Goodman, G.S. (2016, July). Race and media effects in child
sexual abuse cases. Society for the Study of Culture, Ethnicity, and Race Research Conference.
Stanford University, Palo Alto, CA.
Melinder, A. M. D., Baugerud, G.A., & Goodman, G.S. (2016, July). A longitudinal study of children's
memories of a stressful separation from biological parents. International Memory Conference,
Budapest, Hungry.
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Hobbs, S. D., Bederian-Gardner, D., Goodman, G.S., Goldfarb, D., Tashjian, S. M., and the CA
NYTD/CYTD Research Group. (2016, August). Foster youth and emerging adulthood.
In G.S. Goodman & M. E. Lamb (Chairs), Child abuse and neglect: From basic research to foster
care and mental health. American Psychological Association, Denver, CO.
Olomi, J. M., Goldfarb, D., Goodman, G. S., Eisen, M. L., Quas, J. A., & Qin, J. (2016, August). Child
maltreatment, social support, and children's eyewitness memory. American Psychological
Association, Denver, CO.
Johnson, J. L., & Goodman, G.S. (2017, March). Eyewitness memory in youth with and without high
functioning Autism Spectrum Disorder. American Psychology-Law Society Convention, Seattle.
Harris, L., Johnson, J. L., & Goodman, G.S. (2017, March). The interplay of anxiety, executive function, and
problem solving in maltreated children. American Psychology-Law Society Convention, Seattle,
WA.
Silberkleit, G., Alley, D., Bederian-Gardner, D., & Goodman, G.S. (2017, March). Effects of race-based,
sexual stereotyping in child sexual abuse cases. American Psychology-Law Society Convention,
Seattle, WA.
Goodman, G.S. (2017, March). Discussant. In M. Stevenson (Chair), Child sexual abuse: Understanding case
outcomes and consequences for victims and offenders. Symposium, American Psychology-Law Society
Convention, Seattle, WA.
Hobbs, S., Bederian-Gardner, D., Ogle, C. M., & Goodman, G.S. (2017, April). Emancipating foster youth:
Factors influencing outcomes and mental health. Western Psychological Association, Sacramento, CA.
Chae, Y., Goodman, G.S., Larson, R. P., Augusti, E.-M., & Alley, D. (2017, June). Parents' preparation of
children for medical procedures and children's memory: The role of avoidant attachment. In J.
Cassidy &J. Stern (Chairs), Adult attachment style: Implications for parenting behavior and child
outcomes. International Attachment Conference, London, UK.
Goodman, G.S. (2017, August). What is true and false in "false memory"? Discussant comments. In C.J.
Brainerd & M. E. Lamb (Chairs), Developmental differences across memory paradigms: Can we
generalize from the lab to the courtroom? Am. Psychological Assoc. Convention, Washington, DC.
Eisen, M. E., Goodman, G.S., & Diep, J. (2018). Disclosures of sexual and physical abuse across repeated
forensic interviews. In K. McWilliams & T.D. Lyon (Chairs), Children's disclosures and recantations:
Developmental and legal factors. American Psychology-Law Society Conference, Memphis, TN.
Gonzalves, L., Bederian-Gardner, D., Goodman, G.S., Chae, Y., & Thompson, R. A. (2018, May). Child
attachment anxiety predicts commission errors to misleading questions. Association for
Psychological Science Convention, San Francisco, CA.
Johnson, J. L., Goodman, G.S., & DeVault, B. (2018, May). Memory deficits, communicative ability, and
self-monitoring limit utility of existing forensic interviewing methods for youths with high functioning
Autism Spectrum Disorder. International Society for Autism Research, Rotterdam, Netherlands.
Cartwright, A., Appell, J., Goldfarb, D., Eisen, M. L., Qin, J., & Goodman, G.S. (2018, July). "Did he ask
you about your family?": Effects of age and trauma-related psychopathology. The European
Conference on Psychology & the Behavioral Sciences, Brighton, UK.
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Hobbs, S., & Goodman, G.S. (Chairs) (2018, August). Applied developmental psychology: Forensic issues and
clinical interventions. Symposium, American Psychological Association Convention, San
Francisco, CA.
Goldfarb, D., Goodman, G. S., Larson, R.P. Eisen, M. L., & Qin, J. (2018, August). Adults' memory for
childhood violence. In S. Hobbs & G.S. Goodman (Chairs), Applied developmental psychology:
Forensic issues and clinical interventions. Symposium, American Psychological Association
Convention, San Francisco, CA.
Johnson, J. L., & Goodman, G. (2018, August). Memory deficits in youth with high functioning
Autism Spectrum Disorder. In J. L. Johnson (Chair), Memory and Autism symposium, American
Psychological Association Convention, San Francisco, CA.
Goldfarb, D., Appell, J., Vidales, D., Cartwright, A., Wang, Y., Wu, Y., Gonzalves, L. C., Eisen, M. L.,
Qin, J, & Goodman, G.S. (2019, March). Children's cooperation in and memory for a trauma-
focused forensic interviews. In J. Klemfuss (Chair), Interpersonal engagement and children's reporting
in interview contexts. American Psychology-Law Society Conference, Portland, OR.
Goodman, G.S. (2019, March). Discussant. In S. Woodhouse (Chair), Adult attachment style: Implications
for parenting behavior and child outcomes. Society for Research on Child Development,
Baltimore, MD.
Hobbs, S. D., Bederian-Gardner, D., Ogle, C. M., & Goodman, G. S. (2019, March). Factors related to
negative outcomes for foster youth who are nearing the age of emancipation from care. American
Psychology-Law Society Conference, Portland, OR.
Wu, J., Wang, Y., Gonzalves, L., Vidales, D., Goldfarb, D., Eisen, M. L., Qin, J., & Goodman, G.S. (2019,
May). Memory accuracy for interviews about childhood trauma after 20 Years. Association for
Psychological Science Convention, Washington, DC.
Johnson, H., Block, S. D., Shestowsky, D., Gonzales, J., Shockley, K., & Goodman, G.S. (2020, March.).
Police officers' and laypeople's difficulties in detecting false denials. American Psychology-Law
Society Conference, New Orleans, LA.
Wang, Y. Goodman, G.S. Goldfarb, D., Gonzalves, L., Vidales, D., Wu, Y., & Eisen, M. L. (2020, October).
Long-term memory for physical touch: Trauma experience and attachment security. Western
Psychological Association, San Francisco, CA. (delayed/changed to online due to Coronavirus)
Goodman, G.S., & Wu, Y. (2020, May). (Chairs). Adults' long-term memory for childhood traumatic
events. Association for Psychological Science, Chicago, IL (cancelled due to Coronavirus).
Wu, Y., Wang, Y., Vidales, D., Brown, L., Eisen, M. L., & Goodman, G.S. (2002, May). Memory accuracy
and subjective forgetting in adults who experienced child maltreatment. In G.S. Goodman & Y. Wu
(Chairs). Adults' long-term memory for childhood traumatic events. Association for Psychological
Science, Chicago, IL (accepted but conference was cancelled due to Coronavirus).
Wu, Y., Wang, Y., Vidales, D., Brown, L., Eisen, M. L., & Goodman, G.S. (2020, May). Memory accuracy
and subjective forgetting in adults who experienced child maltreatment. Society for Research in Child
Development Meeting.
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Hartman, D. T., Goodman, G.S., Grandchamp, J., Vidales, D., Lawler, M.J., & Shaver, P. R. (2020, Dec).
Promoting academic achievement in foster youth: An evaluation of a special residential education
program. Scholarship of Teaching and Learning Conference, UC Davis.
Hartman, D. T., Grandchamp, J., Vidales, D., Shaver, P.R., Lawler, M. J., & Goodman, G. S. (2021,
April). A special program for foster youth: Predictors of long-term outcomes. Society for Research
in Child Development Meeting.
Wu, Y., Goldfarb, D., Wang, Y., Vidales, D., Brown, L., Eisen, M. L., & Goodman, G.S. (2021, April).
Memory accuracy and subjective forgetting in adults who experienced child maltreatment. Society for
Research in Child Development Meeting. Interdisciplinary Research and Policy Research Strategic
Poster Award.
Hartman, D. T., Goodman, G.S., Moriarty, N., Grandchamp, J., & Kramer, M. (2021, submitted). Trust in
pandemic-related information and vaccine attitudes. American Psychology-Law Society
Convention, Denver, CO.
XIV.
SELECTED INVITED COLLOQUIA AND ADDRESSES
Goodman, G.S. Developmental changes in pictorial memory. Invited colloquium, Department of
Psychology, University of California, Riverside, 1976.
Goodman, G.S. Memory for action events. Invited colloquium, Department of Psychology, The
Graduate Center, CUNY, New York, 1980.
Goodman, G.S. The development of action-related memory. Invited colloquium, Department of
Psychology, Rutgers University, 1980.
Goodman, G.S., & Haith, M. M. Picture-word interference: Reading in a second language.
Invited colloquium, Developmental Psychobiology Research Group Meeting,
University of Colorado Medical Center, January, 1980.
Goodman, G.S. On the believability of children. Invited keynote address, Thirteenth Annual
Conference on Child Abuse and Neglect, Keystone, CO, May, 1984.
Goodman, G.S. Explorations in memory development. Colloquium, Department of Psychology,
University of California, Santa Barbara, February, 1985.
Goodman, G.S. The child witness. Colloquium, Department of Psychology, Boston University,
March, 1985.
Goodman, G.S. The child as witness. Invited colloquium. Department of Psychology, State
University of New York, Buffalo, New York, April, 1985.
Goodman, G.S. Can we believe child witnesses? Invited keynote address, Conference on Child
Witnesses, Mankato State University, Minnesota, May, 1985.
Goodman, G.S. Memory development: Implications for child witnesses. Invited talk, Conference
on Child Witnesses, Mankato State University, Minnesota, May, 1985.
Goodman, G.S. Memory development. Invited colloquia (10 lectures), Department of Psychology,
University of Padua, Italy, June, 1985.
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Goodman, G.S. Children's memory: Legal and psychological implications. Invited address,
Colorado Psychological Association Conference. Denver, CO. November, 1985.
Goodman, G.S. Children's memory and children's testimony. Invited keynote address,
Conference on children and the law, Arizona Council of Attorneys for Children and the
Arizona Psychological Association, Apachee Sunrise, Arizona, February, 1986.
Goodman, G.S. Children's eyewitness testimony: Research and policy issues. The Bush Center in
Child Development and Social Policy, Yale University, New Haven, Connecticut,
February, 1986.
Goodman, G.S. Suggestibility and children's memory. Invited address. Celebration of the 50th
Anniversary of The School of Social Work, University of Hawaii at Manoa, Honolulu,
Hawaii, April, 1986.
Goodman, G.S. Age differences in eyewitness testimony. Invited colloquium. Department
of Psychology, University of Nevada, Reno, Nevada, May, 1986.
Goodman, G.S. The abused child before the law. Invited keynote address, Sixth International
Congress on Child Abuse and Neglect, Sydney, Australia, August, 1986.
Goodman, G.S. Children in the court system. Invited colloquium. University of Western
Australia, Perth, Australia, August, 1986
Goodman, G.S. Children's eyewitness testimony. Invited colloquium, Department of
Psychology, University of Nebraska, Lincoln, NE, September, 1986.
Goodman, G.S., Jones, D.P.H., and the University of Denver Child Sexual Assault Research
Group. The child witness in the courtroom. Invited address. International Symposium on
Child Witnesses, the British Psychological Association, Wolfson College, Oxford
University, Oxford, England, December, 1986.
Goodman, G.S. Out of the mouths of babes: Children's memory for real-life events. Invited
colloquium, Department of Psychology, SUNY, Buffalo, NY, February, 1987.
Goodman, G.S. Children's memory for real-life events: Children's testimony. Invited principal
address, Child Sexual Abuse Conference, Fordham University School of Law and the
Appellate Division of the N.Y. State Supreme Court, Fordham University, March, 1987.
Goodman, G.S. Children's memory and eyewitness testimony. Invited colloquium, Department
of Psychology, University of Oregon, Eugene, Oregon, March, 1987.
Goodman, G.S. Current research on children's use of anatomically detailed dolls. Invited
address, California Professional Society on Child Abuse, Los Angeles, CA, June, 1987,
and San Francisco, CA, September, 1987.
Goodman, G.S. Child sexual abuse victims in the legal setting. Series of 18 invited addresses
given throughout New Zealand. Sponsored by the National Advisory Committee on the
Prevention of Child Abuse and the New Zealand government. June, 1987.
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Goodman, G.S. Memory capabilities of children. Invited address. In Search of Truth.
Conference sponsored by the Annenberg Center for Health Sciences at the Eisenhower
Medical Center and Barbara Sinatra Children's Center at Eisenhower, Palm Springs, CA,
October, 1987.
Goodman, G.S. The effects of misleading questions on children's reports. Invited colloquium.
Department of Psychology, University of Colorado, Colorado Springs, CO, Dec, 1987.
Goodman, G.S. Interviewing child victims. Invited keynote address. National Conference on
the Videotaping of Children in Child Abuse Cases. The Justice Institute of British
Columbia, Vancouver, B. C., June, 1988.
Goodman, G.S. Children's testimony in child abuse cases. Invited address. Conference on Child
Sexual Abuse. Institute for the Prevention of Child Abuse. Toronto, Canada, October,
1988.
Goodman, G.S. Should we believe children's reports? Invited address. Department of
Psychology, Union College, Schenectady, NY, April, 1989.
Goodman, G.S. Reconstructing children's memories. Invited talk, Ebbinghaus Empire,
Department of Psychology, University of Toronto, April, 1989.
Goodman, G.S. Sexual abuse and children's reports. Invited talk. Task Force on Child Sexual
Abuse of Erie County. Judges' Conference. Buffalo, NY, October, 1989.
Goodman, G.S. Children's Memory. Invited talk. National Center on Child Abuse and Neglect,
Department of Health and Human Services, Children's Justice Act Conference.
Washington, D. C., November, 1989.
Goodman, G.S. Child abuse and children's testimony. Invited colloquium. Human Development
Colloquium Series, Harvard University, Cambridge, MA, November, 1989.
Goodman, G.S. Children's testimony: Accuracy and Impact. Invited colloquium, Department of
Psychology, University of Florida at Gainesville, Gainesville, FL, January, 1990.
Goodman, G.S. Child abuse and children's testimony: Current research findings. Invited
colloquium, Department of Psychology and Department of Psychiatry (Division of
Children and Adolescents), University of Rochester, Rochester, NY, May, 1990.
Goodman, G.S. Social and cognitive influences on children's testimony. Invited colloquium.
Department of Psychology, University of California at Davis, Davis, CA, May, 1990.
Goodman, G.S. An overview of current research on children's testimony. Two invited addresses to
commemorate Australia's First National Child Abuse Prevention Week. Sponsored by
the Department of Health and Welfare, Adelaide, Australia, August, 1990.
Goodman, G.S. Effects of court experience on child victim/witnesses. Invited address.
Conference on Child Abuse sponsored by the Society for the Prevention of Child Abuse
and Neglect, Toronto, Canada, October, 1990.
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Goodman, G.S. Understanding children's testimony. Invited address. New York Society for the
Prevention of Cruelty to Children, Family Court Luncheon Series, New York, NY, March,
1991.
Goodman, G.S. Interviewing children: Accuracies and inaccuracies in children's reports.
Keynote address. Conference on Child Mental Health and the Law. Department of
Psychology, Judge Baker Children's Center, Boston, MA, May, 1991.
Goodman, G.S. Understanding children's testimony. Invited address, Division 7 (Developmental
Psychology). American Psychological Association, San Francisco, CA, August, 1991
Goodman, G.S. Children's memory: Effects of socioemotional factors. Department of
Psychology, University of Virginia, Charlottesville, VA, October, 1991.
Goodman, G.S. A review of recent research on child witnesses. Department of Law and Mental
Health, University of Southern Florida, Tampa, FL, October, 1991.
Goodman, G.S. Child witness research: Current trends in the United States. Conference on
Children's Evidence, Faculty of Law, Hebrew University, Israel, December, 1991.
Goodman, G.S. Effects of stress on children's memory for real-life traumatic events. Invited
address, American College of Psychiatrists Annual Meeting, San Francisco, CA,
February, 1992.
Goodman, G.S. The development of children's eyewitness memory. Invited colloquium, Office
of Child Development, University of Pittsburgh, PA, April, 1992.
Goodman, G.S. Advances in the study of children's testimony. Invited address, Eastern
Psychological Association, Boston, MA, April, 1992.
Goodman, G.S. Children's memory for stressful events: Theoretical and methodological issues.
Invited presentation, Annual Developmental Psychobiology Research Group Retreat,
University of Colorado Health Sciences Center, Estes Park, CO, May, 1992.
Goodman, G.S. Listening to children. Invited address, NATO Conference on children's
testimony. Italy, May, 1992.
Goodman, G.S. Forms of abuse and forms of dispute. Division 37 Presidential address,
American Psychological Association Convention, Washington, D.C., August, 1992.
Goodman, G.S. The development of memory for real-life stressful events. Department of
Psychology, Randolph Macon Woman's College, Lynchburg, VA. April, 1993.
Goodman, G.S. Effects of closed circuit television on children's testimony and jurors' decisions.
Department of Psychology, Kent State University, Kent, Ohio. Conference on Eyewitness
Memory and Suggestibility in Adults and Children, April, 1993.
Goodman, G.S. Children's memory for a painful medical procedure. Conference on Memory
Development, University of Chicago (NIMH sponsored conference organized by Dr. N.
Stein), May, 1993.
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Goodman, G.S. Child victims, child witnesses. Invited address. American Psychological
Association, Toronto, Canada, August, 1993
Goodman, G.S. Children's memory for traumatic events. Invited address. International
Association of Sex Researchers, Asilomar, CA, June, 1993.
Goodman, G.S. Investigation of child sexual abuse: Interviewing the victim. Conference on
"Investigating child sexual abuse: Research issues for the decade." Sponsored by the
National Institute of Child Health and Human Development and the
Allmanna/Barnhuset Fond (organized by Dr. Michael Lamb). Satra Bruk, Sweden,
September, 1993.
Goodman, G.S. Child sexual abuse allegations and custody disputes: Parental and nonparental
influences on children's testimony. Center for the Study of Child Abuse, University of
Texas, Austin, TX, March, 1994.
Goodman, G.S. Children's memory for traumatic events: Do children misremember and forget?
Conference on Applied Cognitive Psychology, Claremont Graduate School, Claremont,
CA, April, 1994
Goodman, G.S. Ritual abuse research findings. Conference on Child Abuse, University of
California, Davis Medical Center. Sacramento, CA, May, 1994.
Goodman, G.S., Integrating psychology and law: A scientific perspective on children's memory
in legal contexts. Invited address as part of an "Eminent Psychologists" university-wide
colloquium series, University of Kentucky, Lexington, November, 1994. (The other
invited speakers were Robert Sternberg, Richard Petti, and Gordon Bower.)
Goodman, G.S. Memories of abuse: Causes and consequences. Invited colloquium, Bar-Ilan
University, Tel Aviv, Israel, February, 1995 (cancelled due to death in family).
Goodman, G.S. The child witness: A research update. Invited address, Western Psychological
Association. Los Angeles, CA, March, 1995 (cancelled due to death in family).
Goodman, G.S. A review of child-witness research. Invited presentation at the annual New York
Judicial Conference. Terrytown, NY, July, 1995.
Goodman, G.S. Nonhypnotic influences on children's memory and suggestibility. Invited
address, Division on Clinical Hypnosis, American Psychological Association. NY,
August, 1995.
Goodman, G.S. Interviewing children in child abuse cases. Invited address, Gioretto Institute and
the Multidisciplinary Interview Centers of California, California State Department of
Justice, Children's Justice Act, September, 1995
Goodman, G.S. Allegations of ritualistic child abuse. Invited presentation, UC Davis Extension,
September, 1995.
Goodman, G.S. Current research on children's eyewitness memory. Invited presentation, Conference
on Child Maltreatment. Children's Hospital of San Diego, January, 1996.
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Goodman, G.S. The ritual abuse scare: Eyewitness testimony, repressed memory, and child
abuse. American River College, Sacramento, CA May, 1997.
Goodman, G.S. The new wave of child witness research. Presidential address to the American
Psychology-Law Society/Division 41, American Psychological Association, August, 1997.
Goodman, G.S. Child witnesses. Utah Judicial Conference. Snowbird, Utah, September, 1997.
Goodman, G.S. (1998). Memory, suggestibility, and trauma in maltreated and nonmaltreated
children. Child Protection Conference, University of California, Davis Medical School.
Goodman, G.S. (1998). Trauma, memory, and suggestibility in children. Invited colloquium,
University of Southern California, Los Angeles, CA.
Goodman, G.S. (1998). Testimony about childhood events: Psychological, legal, and social policy
issues. Institute on Governmental Affairs, UC Davis.
Goodman, G.S. (1999). Child maltreatment. Presidential address, Section on Child Maltreatment,
American Psychological Association, Boston, MA.
Goodman, G.S. (1999). Child victims, child witnesses. Profiling the Social Sciences, UC Davis.
Goodman, G.S. (1999). Child witnesses. Invited talk, American Bar Association/American
Psychological Association Conference, Psychological Expertise & Criminal Justice,
Washington, D.C.
Goodman, G.S. (1999). Trauma and memory in children: Implications for reactions to medical
procedures. Kaiser Hospital, Santa Rosa, CA.
Goodman, G.S. (1999). Children with disabilities as witnesses in legal cases. National Academy
of Sciences Meeting on Victims with Disabilities. UC Irvine.
Goodman, G.S. (2000). Memory and maltreatment. Invited address,
Department of Psychology, University of Otago, Dunedin, New Zealand. (Declined due
to family health issues)
Goodman, G.S. (2000). Why study children in the legal system?: Theoretical and applied issues
concerning memory and socio-emotional development. University of California, Santa
Barbara.
Goodman, G.S. (2000). Child maltreatment: Forensic, mental health, and research issues.
Presidential address, Section on Child Maltreatment, American Psychological
Association, Washington, D.C.
Goodman, G.S. (2000). Current research on children's eyewitness memory and suggestibility:
Pre-interview influences. National Institute on Child Health and Human Development
sponsored meeting (M. Lamb, chair). Salt Lake City, Utah.
Goodman, G.S. (2000). Children in legal cases: Memory and emotion. Invited colloquium,
Department of Psychology, University of Nevada, Reno.
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Goodman, G.S. (2001). Memory and much more. Festschrift for Marshall Haith. Invited talk.
University of Denver, Denver, CO
Goodman, G.S. (2001). Memory for traumatic events in childhood: New findings relevant to the
repressed/lost memory controversy. Stanford University.
Goodman, G.S. (2002, March). Child abuse and child memory. Invited address, American
Psychology-Law Society Biennial Conference. Austin. TX.
Goodman, G.S. (2002, April). Children's eyewitness memory: Consensus and debate. Invited
talk. University of Oslo, Norway.
Goodman, G.S. (2002). Interviewing children. Invited talk to the California Consortium on Multi-
Disciplinary Interview Centers. Marin County, CA.
Goodman, G.S. (2002). Children in maltreatment investigations. Invited talk to the Child
Protection Group, Department of Pediatrics, UCDMC, Sacramento, CA.
Bottoms, B. L., Shaver, P. R., Goodman, G.S., Qin, J. J., Nysse-Carris, K., Toulou-Shams, M. (2002,
August). In the name of God: A profile of child maltreatment justified by religious beliefs and
perpetrated by religious authorities. Invited talk at the Conference on Family Violence.
Portsmouth, New Hampshire.
Goodman, G.S. (2002, September). Post-Traumatic Stress Disorder and memory. Invited address,
Department of Psychology, University of Oslo, Norway.
Goodman, G.S. (2002, October). Memory, trauma, and law. Invited address, Speakers Series on
Psychology and Law, Claremont Men's College, Claremont, CA.
Goodman, G.S. (2002, December). Child abuse and memory. Invited address presented at the
Memoria e suggestionabilita nell'eta evolutiva. Universita degli Studi di Cassino,
Cassino, Italy.
Goodman, G.S. (2003, March). Memory, child abuse, and post-traumatic stress disorder. Invited
colloquium, Department of Psychology, University of Arkansas.
Goodman, G.S. (2003, August). Child maltreatment and child testimony. Nicholas Hobbs Award
address. American Psychological Association, Toronto, Canada.
Goodman, G.S., (2003, December). Long-term effects of criminal court involvement on child victims.
SCAN meeting, UCDMC, Sacramento, CA.
Goodman, G.S. (2004, January). What do we know from research on child witnesses? David Chadwick
Conference on Child Maltreatment, San Diego Children's Hospital, San Diego, CA.
Goodman, G.S. (2004, April). Trauma and memory. Invited address, Western Psychological
Association, Phoenix, AZ.
Goodman, G.S. (2004, May). Lost and found memory. Invited colloquium. Department of
Psychology, University of Oslo, Norway.
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Goodman, G. S., (2004, November). Adults' memory for childhood trauma. Invited address. Lipsitt
Conference on True and False Memory, Brown University, Providence, Rhode Island.
Goodman, G.S. (2005, January). Children's memory and suggestibility: Some surprising findings.
Invited colloquium. Department of Psychology, University of California, San Diego.
Goodman, G.S., (2005, March). Emotion and children's memory. Invited address. Conference on
Emotion and Memory, Tsukuba International Conference on Memory, Tsukuba, Japan.
Goodman, G.S. (2005, June). Victimization and memory. Invited address. International Society of
Traumatic Stress. Stockholm, Sweden.
Goodman, G.S. (2005, August). Science and social policy: Child witness research. In K. Nysse & B.
Bottoms (Chairs), Children's services and social policy. American Psychological
Association Convention, Washington, D.C.
Goodman, G.S., (2005, August). Child maltreatment and memory. Distinguished contributions
awards address. American Psychological Association Convention, Washington, D.C.
Goodman, G.S. (2005, September). Attachment and memory. Invited talk, Trauma Institute, Oslo,
Norway.
Goodman, G.S. (2005, December). Child development and child witness. Beyond the Bench
Conference, California Judicial Council, San Diego, CA.
Goodman, G.S. (2006, April). Autobiographical memory and parent - child attachment. Emory
Cognitive Conference, Emory University, Atlanta, GA.
Goodman, G.S. (2006, May). Remembrance of childhood trauma. Invited address, American
Psychological Society. NY.
Goodman, G.S., (2006, September). Trauma, memory, and attachment. Invited colloquium,
University of Oslo, Norway.
Goodman, G.S. (2006. November). Children's memory and attachment theory. Invited colloquium,
Department of Psychology, University of California, Santa Barbara.
Goodman, G.S. (2006, December). Children in dependency court. Judicial Council of California,
Monterey, CA.
Goodman, G.S. (2006, December). Children's memory, trauma, and suggestibility. Sacramento Child
Advocates, Sacramento, CA.
Goodman, G.S. (2007, February). PTSD and memory development. Tuzla University. Tuzla, Bosnia.
Goodman, G.S. (2007, April). Memory and trauma in children and adults. Invited colloquium,
Department of Psychology, Carlton College, Minnesota.
Goodman, G.S. (2007, August). Developmental psychology, children, and law. In A. O'Connell
(Chair), Twenty-seventh symposium on eminent women in psychology: Historical and
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personal perspectives. Invited address. American Psychological Association, San
Francisco, CA.
Goodman, G.S. (2007, September). Understanding trauma and memory. Department of Psychology,
University of Gothenburg, Sweden.
Goodman, G.S. (2008, August). Urie Bronfenbrenner Award Address. Division 7 (Developmental
Psychology), American Psychological Association Convention. Boston, MA.
Goodman, G.S. (2009, March). Child abuse and aggression. Herzliya Conference on Personality and
Social Psychology. Herzliya, Israel.
Goodman, G.S. (2009, May). Child abuse and memory. Science in the service of the family,
University of Gdansk, Gdansk, Poland.
Goodman, G.S. (2009, July). Memory, trauma, and childhood: Psychological and forensic implications.
European Conference on Psychology, Oslo, Norway.
Goodman, G.S. (2009, August). Children in judicial proceedings. International Symposium on
Alternative Methods of Hearing Children in Judicial Proceedings, Sponsored by
Childhood Brazil, National Association of Judges and Public Prosecutors for the Rights of
the Child, National Council for the Rights of the Child, and the National Secretariat for
Human Rights, Brazilia, Brazil.
Goodman, G.S. (2009, September). Kids in court: Involving children and youth in their court hearings.
UC Davis National Child Abuse and Neglect Conference, Sacramento, CA.
Goodman, G.S. (2009, November). Trauma and children's memory. Frontiers in translational
research on trauma. Mt. Hope Family Center, University of Rochester. Rochester, NY.
Goodman, G.S. (2009, December). Memory and maltreatment. Department of Psychology,
University of California, Merced.
Goodman, G.S. (2010, March). Forensic interviewing of children in Child Advocacy Centers. National
Association of Child Advocacy Centers Conference. Huntsville, AL.
Goodman, G.S. (2010, March). The child witness. California Association for Criminal Justice
Research, Sacramento, CA.
Goodman, G.S. (2010, April). Remembering trauma in childhood. Western Psychological
Association, Cancun, Mexico.
Goodman, G.S. (2010, July). Children's testimony. European Association of Psychology and Law.
Gothenburg, Sweden.
Goodman, G.S. (2010, August). Marshalling memory. American Psychological Association, San
Diego, CA.
Goodman, G.S., & Shestowski, D. (2010, November). "That didn't happen": Children's false reports
and false denials. Invited address, Child Welfare Conference, University of California,
Davis.
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Goodman, G.S. (2010, December). Child abuse and memory. Invited address, Department of
Psychology and Neuroscience. University of Maastricht, Netherlands.
Goodman, G.S. (2011, July). Relationships, memory, and law. Keynote address, International
Association of Relationship Researchers, Gdansk, Poland.
Goodman, G.S. (2012, March). Psychological research and child witnesses. National Association of
Child Advocacy Centers Conference. Huntsville, AL.
Goodman, G.S. (2012, April). Enhancing children's eyewitness memory. Invited address. California
Psychological Association, Monterey, CA.
Goodman, G.S. (2012, May). James McKeen Cattell Award invited address. Invited address.
Association for Psychological Science Convention, Chicago, IL.
Goodman, G.S. (2012, June). Child maltreatment and memory: A review of research. Invited address.
Cognitive Development Research Unit. Department of Psychology, University of Oslo,
Norway.
Goodman, G.S. (2012, October). Child sexual abuse and memory. Invited address. Brazilian
Psychological Society. San Paolo, Brazil.
Goodman, G.S. (2012, October). Children, trauma, and legal involvement. Invited address. Brazilian
Psychological Society. San Paolo, Brazil.
Goodman, G.S. (2013, February). Children's eyewitness memory and testimony. Invited address
Roger Williams University School of Law, Providence, Rhode Island.
Goodman, G.S. (2013, June). Autobiographical memory development: Social factors. Conference on
Clinical Implications of Autobiographical Memory, University of Aarhus, Aarhus,
Denmark.
Goodman, G.S. (2013, July). Children and the law. Invited workshop, Division 7 (Developmental
Psychology), American Psychological Association, Honolulu, Hawaii.
Goodman, G.S. (2013, September). Children in court: Current research and future directions.
Invited address, Annual Partnership Conference: A New Beginning for Partnerships for
Children & Families in Los Angeles County. California State University-Los Angeles and
Los Angeles County Dependency Court, Los Angeles, CA.
Goodman, G.S. (2014, May). Children in criminal court. Conference on Child-Friendly Justice.
Stockholm Centre for the Rights of the Child, Faculty of Law, University of Stockholm.
Goodman, G.S. (2014, June). Child sexual abuse and memory. University of Granada, Spain.
Goodman, G.S. (2014, August). Division 7 Presidential address: Child victims, law, and memory.
Division 7 (Developmental Psychology), American Psychological Association,
Washington, DC.
Goodman, G.S. (2014, October). Children's memory, trauma, and dissociation: Implications for
therapeutic interventions. Plenary address. International Society for the Study of Trauma
and Dissociation, Long Beach, CA.
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Goodman, G.S., (2014, November). Three possible myths about child maltreatment, child emotion, and
child memory. Keynote address. Nordic Network of Psychology and Law, University of
Oslo, Norway.
Goodman, G.S., (2014, December). Myths about child witnesses. Keynote address, Child and
Adolescent Abuse Resources and Evaluation (CAARE) Center, Children's Hospital,
University of California, Davis
Goodman, G.S. (2015, January). Remembering trauma in children exposed to violence. Invited
address, San Diego Conference on Child Abuse and Neglect, Chadwick Center and
Children's Hospital, San Diego, CA.
Goodman, G.S. (2015, January). The science of child forensic interviewing. Invited address,
San Diego Conference on Child Abuse and Neglect, Chadwick Center and Children's
Hospital, San Diego, CA.
Goodman, G.S. (2015, March). What we have learned (and what we still need to know) about child
victims and law. Invited award address, American Psychology-Law Society Conference,
San Diego, CA.
Goodman, G.S., (2015, April). Child abuse, emotional effects, and memory. Invited address to the
Woodland Rotary Club, Woodland, CA.
Goodman, G.S. (2015, May). Children's abilities and experiences as victim/witnesses. Invited
address. Children's Justice Conference. Seattle, WA.
Goodman, G. (2015, May). Children's memories. Invited address. Children's Justice Conference.
Seattle, WA.
Goodman, G.S. (2015, July). Effects of child physical punishment. Roundtable speaker, American
Psychological Association, Washington, DC.
Goodman, G.S. (2015, October). Long-term eyewitness memory in children exposed to violence.
National Institute of Justice, Washington, DC.
Goodman, G.S. (2015, October). Children, maltreatment, & memory: The dreaded early morning talk!"
Invited talk, UC Consortium on Social Sciences and Law, University of California, Irvine.
Goodman, G.S. (2015, November). Memorial: Wendell Jeffrey. University of California, Los
Angeles.
Goodman, G.S. (2015, December). Children's reactions to foster care and legal involvement.
University of California Sacramento Center, University of California Office of the
President, Sacramento, CA.
Goodman, G.S. (2016, July). Trauma and memory in children exposed to violence. International
Conference on Memory, Budapest, Hungry.
Goodman, G.S., & Lamb, M.E. (Chairs). (2016, August). Child abuse and neglect: From basic research
to foster and mental health care. American Psychological Association, Denver, CO.
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Goodman, G.S. (2016, September). The importance of studying children as witnesses and
children exposed to violence. University of Stockholm, Sweden.
Goodman. G.S. (2016, November). Retrospective recall and prospective observation of childhood
adversity. Conference on Identifying Adults at High Risk for III Health by Virtue of
Remembered or Experienced Childhood Adversity. National Institute of Aging/NIH,
Bethesda, Maryland.
Goodman, G.S. (2017, April). Childhood trauma, memory, and suggestibility. Western Psychological
Association, Sacramento, CA.
Goodman, G.S. (2017, July). Effects of trauma on memory in children and adolescents. Sacramento
Child Protective Services and District Attorney (Sexual Assault Unit) Meeting.
Sacramento, CA.
Goodman, G.S. (2017, August). APA Distinguished Contributions to Research in the Public
Interest (senior). Award address, American Psychological Association, Washington, DC.
Goodman, G.S. (2017, September). "There are no children here": Trauma and memory in children
exposed to violence. Honorary doctorate award address, University of Oslo, Norway.
Goodman, G.S. (2018, September). Long-term memory accuracy and psychopathology in child
abuse victims: A longitudinal perspective. Invited address, Department of Psychology and
Pedagogics, Altia State University, Barnaul, Russia.
Goodman, G.S. (2018, September). The science of child witnesses. Invited address, Department of
Psychology and Pedagogics, Altia State University, Barnaul, Russia.
Goodman, G.S. (2018, November). Possible myths about children's eyewitness memory. Department of
Psychology, Florida International University, Miami, FL.
Goodman, G.S. (2019, April). From UC Davis to University President. Pacific Northwest
University of Health Sciences, Yakima, WA.
Goodman, G.S. (2019, May). Interviewing children about maltreatment: Disclosure and memory.
Brown School, Washington University in St. Louis.
Goodman, G.S. (2019, September). Children and legal involvement: Emotional effects and legal
attitudes. Psychology and Pedagogics, Altia State University, Barnaul, Russia.
Goodman, G.S., (2020, April). Child and adult forensic interviewing research: An overview. Arizona
State University, Glendale/Phoenix, Arizona (cancelled due to Coronavirus).
Goodman, G.S. (2020, Aug). Disclosure and memory of trauma in childhood. Section on Child
Maltreatment Invited Presidential Address, American Psychological Association,
Washington DC.
Goodman, G.S. (2021, March). Interviewing children and adults about childhood traumatic touch: A
tribute to Karen J. Saywitz. California American Professional Society on the Abuse of
Children (CAPSAC) Karen J. Saywitz Legacy Award Address. Los Angeles, CA.
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Goodman, G.S. (2022, January). Trauma-related psychopathology, memory, and child sexual abuse:
Controversy in science, law, and career trajectory. UC Davis Mental Health Initiative.
University of California Conference Center.
XV. WORKSHOPS
I have given numerous workshops on child witnesses and child maltreatment to attorneys, law
enforcement, judges, social workers, psychologists, legislative staff, and medical professionals.
XVI. STATE/COUNTY/COUNTRY REPORTS AND TESTIMONY
I have authored and co-authored reports and legal documents for the California State government as well
as for various state counties and countries. I have also testified as an expert in State and Federal Courts,
and given reports and/or testimony to countries' Supreme Courts.
XVII. TEACHING INTERESTS
Graduate: Child Maltreatment, Trauma and Memory, Developmental Psychology and Law, Memory
Development, Psychology and Law, Eyewitness Testimony, Child Witnesses, Victimization.
Undergraduate: Psychology and Law, Developmental Psychology and Law, Child Witnesses, Memory
Development, Advanced Child Development, Attachment Theory, Research Methods.
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