# docs_fts_content

c1: EFTA00024795
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024795.pdf
c6: pdf
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c0:
=== Page 1 ===
From:
"
)"
To:
(USANYS) [Contractor]"
Cc:
(USANYS) [Contractor]"
Subject: RE: US V. Epstein
Date: Mon, 02 Nov 2020 20:55:55 +0000
Got it, thank you!
From:
(USANYS) [Contractor]
Sent: Monday, November 2, 2020 3:43 PM
To:
Cc:
(USANYS) [Contractor]
Subject: US V. Epstein
Hello,
The password to the hard drive is
EFTA00024795


c1: EFTA00024905
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024905.pdf
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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
)"
Subject: RE: Limiting instructions letter
Date: Sat, 20 Nov 2021 17:44:29 +0000
Attachments: 2021-11-20,_GM,_edits_to_limiting_instructions_v2.docx
Hi team,
After some editing, here's a draft response as a starting point.
Thanks,
From:
Sent: Saturday, November 20, 2021 12:04 PM
To:
is
>;
Subject: Limiting instructions letter
Hey team,
Per the attached order on MV-3, we owe Judge Nathan our views on the proposed limiting instructions. Can we add this
to the list for our call? I've written two responsive letters because I'm not sure exactly what she's going for with the
second instruction.
Thanks,
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00024905


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=== Page 1 ===
From:
"
)"
To: Jill Greenfield
Cc:
"
)"
Bcc:
"
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Date: Tue, 06 Oct 2020 19:32:15 +0000
Embedded: RE:_Epstein_[FFW-DOCS.FID6003375].msg
Sender:
Subject: RE: Epstein [FFW-DOCS.FID6003375]
Message-Id:
<CY1P110MB0486CE14C3E1234D00C7B7DD840D0@CY1P110MB0486.NAMP110.PROD.OUTLOOK.CO
M>
Cc:
EFTA00026585


c1: EFTA00026643
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026643.pdf
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c0:
=== Page 1 ===
From:
)"
To:
)"
,
)"
Subject: Epstein defense bail submission due
Date: Mon, 08 Jul 2019 20:41:43 +0000
Importance: Normal
Attachments: unnamed
EFTA00026643


c1: EFTA00026692
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026692.pdf
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=== Page 1 ===
From:
To:
)"
Subject: FW: [EXTERNAL] Re: Ghislaine Maxwell 02879-509
Date: Sun, 10 Oct 2021 23:04:15 +0000
From: BOBBI C STERNHEIM
Sent: Sunday, October 10, 2021 7:03 PM
To:
(BOP)
Cc:
(BOP)
>; Christian Everdell
(USANYS)
Subject: [EXTERNAL] Re: Ghislaine Maxwell 02879-509
Good evening-
You failed to provide any update concerning the whereabouts of Ms. Maxwell's legal mail that I had placed in the legal
mailbox on 10/2.
However, on Friday afternoon, I was informed by Ms. Maxwell and Unit Manager
that the envelope had
been located and affixed to it
was a bar-code type sticker, not generated by the MDC, but of the type issued by the U.S. Post Office.
I had placed the envelope in the legal mailbox. It did not have postage. If, for some questionable reason, it had been
handled by the U.S. Postal Service
(which is highly unlikely and, if so, deliberately caused by the MDC), the Post Office would have returned it to my office
address (at the return address on the envelope),
not deliver it to the MDC without postage.
This suggests some type of foul play on the part of the MDC, or at least some type of cover-up.
I am informed that the Warden is aware of this. Today, I received the envelope from Unit Manager
Today, Christian Everdell, Esq. and I had a scheduled legal visit with Ms. Maxwell.
Rather than permitting us to use a somewhat larger room, we were required to use a room for two.
This completely defeated the purpose of COVID protective measures. The plastic partition did not shield
Mr. Everdell and there was little or no table surface for him to use. The room was unnecessarily cramped
when a larger room was available. My request to use a larger room was denied. The officer claimed the team could not
position the camera
to focus on the larger room. This response was bogus. I requested to see the Warden, but that request was never
honored.
Further, defense counsel at large have heard about the current electricity issues affecting water, toilet flushing, and meals.
Ms. Maxwell received a bologna sandwich despite being on no-flesh (vegetarian) diet.
This is yet another blunder on the part of the MDC which needs to be immediately corrected.
I will not waste my energy requesting a response because even if forthcoming it will likely be insufficient.
These matters will be brought to the Court's attention, so you can start preparing excuses for consideration by Judge
Nathan.
Enjoy your holiday.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
EFTA00026692

=== Page 2 ===
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be
confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
On Oct 7, 2021, at 7:45 AM, BOBBI C STERNHEIM
wrote:
Good morning-
If by 9:30 this morning (10/7) Ms. Maxwell does not receive the legal mail deposited in the MDC legal mailbox on
Saturday (10/2), an order to show cause will be filed with the Court.
I urge you to respond and comply immediately.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
On Oct 6, 2021, at 7:00 PM, BOBBI C STERNHEIM
wrote:
Good afternoon-
Ms. Maxwell still has not received the legal mail (a properly addressed manila envelope)
that I deposited in the East Building legal mailbox on Saturday 10/2 shortly after 3 pm
while I was escorted to the lobby by a male guard.
Please contact me immediately.
Thank you-
Bobbi
EFTA00026693

=== Page 3 ===
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may
be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete
this message. Thank you.
On Oct 6, 2021, at 4:53 AM,
wrote:
I will follow up with the appropriate departments.
BOBBI C STERNHEIM
10/5/2021 7:12 PM
Good evening-
As of this writing, Ms. Maxwell has not received legal mail which I
personally placed in the
East Building legal mailbox on Saturday, October 2. On that same day,
in that same mailbox,
I deposited legal mail for a client housed in the west building. That
client confirmed that he received his legal mail.
Ms. Maxwell has not.
Please explain why delivery of Ms. Maxwell's mail has been delayed.
Time is of the essence. Her trial begins on November 29th.
Every delay caused by the MDC interferes with her ability to prepare
for trial.
Your prompt response is requested.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
EFTA00026694

=== Page 4 ===
Main:
Cell:
Fax:
This message and any attached documents contain information from the
Law Offices of Bobbi C. Sternheim that may be confidential and/or
privileged.
If you are not the intended recipient, you may not read, copy,
distribute, or use this information.
If you have received this transmission in error, please notify the
sender immediately by reply e-mail and then delete this message. Thank
you.
EFTA00026695


c1: EFTA00024660
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024660.pdf
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=== Page 1 ===
From: Jack Scarola
To:
)"
Cc: Wetjets
Mary McCann
)"
(NY) (FBI)"
Subject: Re:
Date: Thu, 16 Jul 2020 14:37:28 +0000
-
I look forward to our video meeting tomorrow.
,
Mike, and I will be together (socially distancing)
in a conference room in my office. I am available to talk in advance if that may be helpful. (561-889-9536)
Below is a list of persons with whom
interacted in her contact with Epstein. This will probably assist
you in organizing your interview.
- brought
over 1st time.
ex boyfriend of
- Had been with
but
drove
and her to
Epstein Palm Beach residence.
knew
and
going over to Epstein house. (In past
dealings with
I have found him to be less than fully cooperative and less than completely reliable)
ex boyfriend, drove over to Epstein house once or twice in beginning
Ghislaine Maxwell- met about 10 times at Epstein. Saw nude photos of Ghislaine
took her there 1 time,
stayed outside of room while
with Epstein
went with her several times to Epstein house
Called
many times to make appointments and
arrangements. Acted like secretary
- thinks she saw her there
2 times
Some older man came over to Epstein's house and
Epstein 1 time while another girl was with them.
- may have been leaving once when
arriving.
- saw him at house
male drivers from Epstein picked her up about 50 times and brought her to house.
Epstein- saw her over 100 times.
,
, Epstein
several times.
2 housekeeping couples -saw
often. One couple quit as did not want to be there.
Cooks -saw her many times and gave her food in kitchen.
Sent from my iPad
On Jul 15, 2020, at 8:05 PM,
)
wrote:
Jack, Mike,
Thanks very much again for being in touch, and for your assistance with this progress. We will send information to log in
via WebEx, our video conference program, which is secure and has worked well for us so far. The only thing we need is
the email address or any other attendees, so I'm going to include the following email addresses (realizing that you likely
will not log on using all of them), but please let us know if you need us to include any other email addresses for logging
on:
EFTA00024660

=== Page 2 ===
And please let us know if either of you would like to chat tomorrow in advance of the discussion, otherwise we'll look
forward to seeing you electronically on Friday at 9:30.
thanks,
From: Jack Scarola
Sent: Tuesday, July 14, 2020 13:37
To: Wetjets
Cc:
>; Mary McCann
Subject: Re:
That will work.
Mr.
Please provide details as to how you want to handle the connection.
On Jul 14, 2020, at 12:26 PM, Wetjets
wrote:
Jack
I am confirming Friday 7/17/20 at 9:30AM for
to be at your office.
I will pick her up and bring her.
I
assume you have video conference abilities in your office, and we of course will bring masks and social distance.
Please advise if any problems.
Michael Danchuk
*
I Privileged and Confidential I Electronic communication is not a secure mode of communication and may be
accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola
Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-
2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud.
Admin. 2.420 and information intended only for the use of the individual(s) named above. If the reader of this
message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of
this communication is strictly prohibited. Personal messages express views solely of the sender and shall not be
attributed to the law firm. If you received this communication in error, please notify the sender immediately by
e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank you.
EFTA00024661


c1: EFTA00026926
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c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026926.pdf
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=== Page 1 ===
From:
To: BOBBI C STERNHEIM
Cc: Christian Everdell
Subject: RE: Ghislaine Maxwell
Date: Wed, 14 Apr 2021 03:06:19 +0000
Got a quick response. The Marshals will need an order from the Court. You may note that my office does not object to
the request.
Best,
From:
Sent: Tuesday, April 13, 2021 11:00 PM
To: 'BOBBI C STERNHEIM'
Cc: Christian Everdell
Subject: RE: Ghislaine Maxwell
Hi Bobbi,
I will forward your request to my contact with the USMS and note that I have no objection. And no objection to you
contacting the Court.
Best,
From: BOBBI C STERNHEIM
Sent: Tuesday, April 13, 2021 7:38 PM
To:
Cc: Christian Everdell
Subject: Ghislaine Maxwell
Good evening-
Might you have any sway in persuading the Marshal permit Ms. Maxwell
to have her legal materials while in the cell block?
She arrived today at ~ 5:15 am and remained idle in the cell block
until ~ 8:30 am when she was brought to the fifth floor.
Otherwise, any opposition to me contacting the Court for an order
(per the Marshal)?
Enjoy the evening. See you tomorrow.
Best-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
EFTA00026926

=== Page 2 ===
New York, NY 10011
**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.
EFTA00026927


c1: EFTA00025441
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025441.pdf
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=== Page 1 ===
From: Law360 Alerts <news-q@law360.com>
To:
Subject: New Epstein Docs Unsealed As Maxwell Fails To Gag Boies
Date: Fri, 24 Jul 2020 21:18:26 +0000
Law360
In case you missed it...
New Epstein Docs Unsealed As Maxwell Fails To Gag Boies
Former Jeffrey Epstein associate Ghislaine Maxwell suffered a pair of courtroom setbacks Thursday morning,
losing a bid to gag federal prosecutors and lawyers for witnesses in her sex trafficking case, and failing to
convince a judge in a defamation suit to keep a trove of documents under seal.
Judge Says 'Bright Light' Must Be Shined On Liebowitz
A Manhattan federal judge is refusing to halt a sanctions order requiring copyright lawyer Richard Liebowitz to
inform current and future clients about his "extraordinary record of misconduct," citing the maxim that "sunlight is
said to be the best of disinfectants."
If you are unable to login, click here to reset your password.
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EFTA00025441


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=== Page 1 ===
From:
To:
Cc:
Bcc: "USAHUB-USAJourmal111"
Subject: RE: Epstein investigation
Date: Mon, 26 Oct 2020 19:41:19 +0000
Embedded: RE:_Epstein_investigation.msg
Sender:
Subject: RE: Epstein investigation
Message-Id:
<BN3P110MB02920D34AADB79EFCAB009FE84190@BN3P110MB0292.NAMP110.PROD.OUTLOOK.CO
M>
To:
Cc:
Cc:
EFTA00024738


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c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025519.pdf
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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: FW: financial documents (Epstein)
Date: Tue, 23 Jul 2019 14:31:28 +0000
just called me to check in. Is there a time this afternoon that works for everyone? He's around.
From:
>
Sent: Thursday, July 18, 2019 7:33 PM
To:
is
>;
is
) (FBI)
Cc:
Subject: RE: financial documents (Epstein)
Looking forward to working with you as well. My Tuesday is open. Set a time that works for you.
Best
From:
)
[mailto:
Sent: Thursday, July 18, 2019 6:58 PM
To:
is
>;
) (FBI)
is
Cc:
Subject: RE: financial documents (Epstein)
Hi
looking forward to working with you again! Aside from a court conference at 11 on Tuesday, I can make any
time work. Thanks.
From:
>
Sent: Thursday, July 18, 2019 6:56 PM
To:
is
)
(FBI)
i
Cc:
is
)
Subject: RE: financial documents (Epstein)
great to have you onboard, welcome - and as of now I don't have anything scheduled for Tuesday.
From:
,
Sent: Thursday, July 18, 2019 16:49
To:
)
[Contractor]
Cc:
is
) (FBI)
is
is
is
Subject: Re: financial documents (Epstein)
EFTA00025519

=== Page 2 ===
I've CC'd the forensic accountan
in our squad who will be assisting in this investigation. Let's try and plan a
day next week to meet briefly and discuss a game plan. Are you guys around Tuesday to chat?
On Jul 18, 2019, at 11:17,
)
[Contractor]
wrote:
I have the discs, where should I bring them?
From:
)
Sent: Wednesday, July 17, 2019 8:47 PM
To:
)
[Contractor]
Cc:
) (FBI)
is
is
)
is
)
Subject: RE: financial documents (Epstein)
Tomorrow morning could you please burn the following folders to a disc:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\nvestigation\# 2018 SDNY
investigation\Subpoena Returns\American Express
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY
investigation\Subpoena Returns\Deutsche Bank
and put the disc in an envelope addressed to:
Special Agent
Detective
If it's possible to get the disc by 11:30, we'll give the disc to
t the conference, or if not, if you could put
the envelope with security and reply all that it's ready, they can pick up when convenient.
thanks,
Assistant U.S. Attorney
Southern District of New York
212.637.2415
EFTA00025520


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=== Page 1 ===
From: Martin Weinberg
To:
)"
Cc: "Miller, Michael"
"Weingarten, Reid"
,
Subject: Re: US V Epstein
Date: Sat, 10 Aug 2019 23:43:09 +0000
Thank you
Sent from my iPhone
On Aug 10, 2019, at 7:31 PM,
)
wrote:
Mike, Marty, Reid,
I just wanted to let you know that I don't expect we'll have any further updates today, and so wanted to send you a brief
note to let you know that since we hadn't otherwise been in touch since earlier this afternoon. I imagine we will
continue to be in contact in the coming days; meanwhile, I appreciate you being in touch today, and I hope the
investigations of these events will be thorough and swift.
respectfully,
From:
Sent: Saturday, August 10, 2019 14:14
To: Miller, Michael
>; ; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
)
>
Subject: RE: US V Epstein
Following up on the below, wanted to make sure the attached letter from the Warden immediately got to Mike as well
(in addition to Marty and Reid having been copied and emailed). As the letter indicates, there are now investigations
ongoing, including as initiated by the Attorney General himself. Separately, we have not received additional information
on topics such as the apparent cause of death, the status of observation of Mr. Epstein at the time, etc., but we will
continue to be in touch immediately if that changes.
thank you,
From:
Sent: Saturday, August 10, 2019 11:57
To: Miller, Michael
>; ; Martin G. Weinberg
>; Weingarten, Reid
Cc:
is
Subject: Re: US V Epstein
EFTA00024359

=== Page 2 ===
Mike, Marty, Reid,
Following up on my conversations with Mike and Marty this morning, and my discussion with Mike moments
ago, attached is a press release just sent to us (and I believe also issued publicly) some minutes ago. It
represents all the information we have from BOP so far, but of course if we are successful in our continuing
efforts to get additional information we will pass it along immediately.
Separately, we can tell you that the reports that an FBI investigation into the death has been initiated are
accurate, and I fully expect that investigation to be extremely rigorous.
As always please don't hesitate to reach out to us directly at any time if that would be useful.
thank you,
EFTA00024360


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=== Page 1 ===
From:
Subject: [EXTERNAL] Letter from Client
"Confidential Communication"
Date: Fri, 19 Nov 2021 20:27:16 +0000
Attachments: PRIVATE_AND_CONFIDENTIAL_2.pdf
To All Concerned: Please find the attached letter authored by my Client
Cordially,
EFTA00024902


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=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: WBTW Motions/Letters
Date: Wed, 10 Feb 2021 22:17:17 +0000
Attachments: 2021-01-10_Letter_Response_to_GM_Request_for_Bill_of_Particulars_(final).docx
Thanks, team. How can I pitch in? I'm attaching the letter we sent defense counsel last month in Maxwell re: a bill of
particulars. Also happy to do additional research on the accountant issue-just let me know how I can be useful.
From:
Sent: Wednesday, February 10, 2021 5:08 PM
To:
is
Subject: RE: WBTW Motions/Letters
Yes, I am aiming to get you a draft of the opposition at some point this weekend. Would be grateful for you to handle the
other items. Thanks.
From:
Sent: Wednesday, February 10, 2021 5:07 PM
To:
i
Subject: WBTW Motions/Letters
Hey - What's the plan on this motion? If you were planning on working on it, Rob, I can tackle the
BOP/Brady letters
and the accountant privilege letter.
tates Attorney
United States Attorney's Office
Southern District of New York
EFTA00023909


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=== Page 1 ===
From:
To:
Cc:
Subject: AUSA
ECC package
Date: Mon, 05 Oct 2020 20:53:06 +0000
Importance: High
Attachments:
-_London_10.12.20.pdf
Hi RMP,
Please see the attached ECC request package for AUSA
If required, please inform the traveler how to determine who the POC is for this trip.
Please advise the traveler of any additional steps they may need take.
Hi
Please let EOUSA know if you have checked to see if a visa is required for your destination.
View the state dept. link for the country you are traveling to visa link for the country you are traveling to.
Visa policies may be found on the Department of State's website or on the website hosted by each country's embassy.
https://travel.state.gov/content/passports/en/country.html
Traveler, Consult EOUSA
mailbox to obtain a visa for you.
To provide sufficient time for the State Dept. to issue the authorization letter and for the foreign government to process the visa
request, it is recommended that visa request package be submitted to EOUSA's RMP Travel.
Staff 15 business days prior to the proposed date of departure.
Thank you
EFTA00026582


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=== Page 1 ===
Event: Epstein defense bail submission due
Start Date: 2019-07-11 16:00:00 +0000
End Date: 2019-07-11 16:30:00 +0000
Organizer:
)
Location: Berman
Class: X-PERSONAL
Date Created: 2019-07-08 20:52:14 +0000
Date Modified: 2019-07-08 20:52:14 +0000
Priority: 5
DTSTAMP: 2019-07-08 20:41:41 +0000
Attendee:
.V.
Alarm: Display the following message 15m before start
Reminder
EFTA00026644


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=== Page 1 ===
From: "
(USANYS)"
To: "
(USANYS)"
Cc:
"
,
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE:
discovery/notes
Date: Thu, 01 Oct 2020 13:57:27 +0000
Embedded: RE:
Sender:
Subject: RE:
discovery/notes
Message-Id:
<CY1P110MB05171A21CF629CA9D2542304FA300@CY1P110MB0517.NAMP110.PROD.OUTLOOK.COM
>
To:
Cc:
EFTA00025268


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c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024428.pdf
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c0:
=== Page 1 ===
From:
To:
Subject: Re: Urgent!
,an Epstein victim, just told me that she was able to get child care and
would like to fly to New York for the hearing Tuesday. What is your telephone number,
so
that I can call you a.s.a.p.?
Date: Sun, 25 Aug 2019 13:33:07 +0000
I can try, but I suspect it's just too late.
On Aug 25, 2019, at 8:20 AM,
wrote:
Are you able to connect with
and work on the
problem? Thanks.
Sent from my iPhone
Begin forwarded message:
From: Gloria Allred
Date: August 25, 2019 at 1:41:10 AM EDT
To:
Subject: FW: Urgent!
,an Epstein victim, just told me that she was able to get child care
and would like to fly to New York for the hearing Tuesday. What is your telephone number,
so
that I can call you a.s.a.p.?
Is there a cell number for
that I can call to make travel arrangements for
? I sent
the email below
and left a voice mail for her on her office phone but she did not respond. I understand.
It is the weekend ,but is there a way that I can reach her or another agent to arrange
trip from Las Vegas to
New York on Monday morning ? It would mean so much to her to attend the hearing and
does not have funds
to pay for the flight and get reimbursed after that.
Gloria Allred
Allred, Maroko & Goldberg
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.jpg>
From: Gloria Allred
Sent: Saturday, August 24, 2019 4:09 PM
To:
(USANYS)
Cc:
Subject: Urgent!
,an Epstein victim, just told me that she was able to get child care and would like to fly to
New York for the hearing Tuesday. What is your telephone number,
so that I can call you a.s.a.p.?
EFTA00024428

=== Page 2 ===
Sorry about the late notice.
Gloria Allred
Allred, Maroko & Goldberg
www.amglaw.com
www.gloriaallred.com
<image001.png>
<image002.jpg>
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
EFTA00024429


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=== Page 1 ===
90A-NY-3151227 Serial 4
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Evidence
Date: 08/14/2019
NYC023578
Approved By:
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S) ;
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) MCC-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Evidence NYC023578: One (1) Seagate Barracuda 500GB
HDD, ST500DM002, S/N Z3T6CJJA, from MCC Nice Vision DVR2 Surveillance
System (1 of 18).
Item Type
Description
1B Digital
(U) NYC023578: One (1) Seagate Barracuda 500GB HDD,
ST500DM002, S/N Z3T6CJJA, from MCC Nice Vision DVR2
Surveillance System (1 of 18).
Collected On: 08/10/2019 04:30 PM EDT
Seizing Individual:
Collected By:
Device Type: Hard Drive
Designation: Original
Number of Devices Collected: 1
UNCLASSIFIED
This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its
contents are not to be distributed outside your agency.
EFTA00023975


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: FW: US V. Maxwell Case No. 20-3061, [Unredacted Opening Brief & Sealed Appendix Vol.
2]
Date: Fri, 25 Sep 2020 00:17:10 +0000
Attachments: 2020.09.24_Opening_Brief_(Unredacted)pdf; Appendix_Vol_2_(124-314)_SEALED.pdf;
2020.09.24_Motion_for_Leave_to_File_Under_Seal.pdf
Inline-Images: image001.jpg
From: Nicole Simmons
Sent: Thursday, September 24, 2020 7:58 PM
To: 'newcases@ca2.uscourts.gov'
Cc: Adam Mueller
>; Ty Gee
is
;
(USANYS)
is
is
is
(USANYS)
Subject: US V. Maxwell Case No. 20-3061, [Unredacted Opening Brief & Sealed Appendix Vol. 2]
To Whom It May Concern:
At the request of Adam Mueller, please see attached the Unredacted version of Ms. Maxwell's Opening Brief and the
Sealed Appendix Vol. 2 in the above referenced matter. Please let me know if you have any questions or concerns.
Regards,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
www.hmflaw.com
EFTA00023748


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=== Page 1 ===
From:
)"
To: "Hudgens, Johanna Rae"
, "Bloom, Suzanne Jaffe"
Cc:
>, "Calvar, Cristina I."
)"
Subject: RE: Following up
Date: Wed, 04 Dec 2019 18:58:08 +0000
Attachments: 19_Civ._10788.pdf
Suzanne and Johanna,
In addition to the topic we discussed this morning, we wanted to let you know that we would appreciate the
opportunity to discuss with your client the allegations set forth on page 7 of the attached complaint, as a follow
up to some of the topics from our last meeting.
We're of course happy to discuss with you at your office before we start this afternoon.
Thanks,
Original Message
From: Hudgens, Johanna Rae
Sent: Wednesday, December
2019 12:32 PM
To:
)
Cc: Bloom, Suzanne Jaffe
; Calvar, Cristina I.
)
Subject: RE: Following up
Thanks,
-
We'll see you then.
Best,
Johanna
Johanna Rae Hudgens
Associate Attorney
Winston & Strawn LLP
D:
http://www.winston.com
Please consider the environment before printing this e-mail.
Original Message
From:
Sent: Wednesday, December 04, 2019 12:28 PM
To: Hudgens, Johanna Rae
Cc: Bloom, Suzanne Jaffe
; Calvar, Cristina I.
EFTA00025103

=== Page 2 ===
Subject: RE: Following up
Hi Johanna,
That's not a problem, we're available at 3 p.m. and can plan to meet than. Thanks.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Original Message
From: Hudgens, Johanna Rae
Sent: Wednesday, December
2019 12:18 PM
To:
Cc: Bloom, Suzanne Jaffe
)
)
>; ; Calvar, Cristina I.
Subject: RE: Following up
and
,
Would it be possible to start our meeting at 3pm?
Thanks,
Johanna
Johanna Rae Hudgens
Associate Attorney
Winston & Strawn LLP
D:
http://www.winston.com
Please consider the environment before printing this e-mail.
Original Message
From: Hudgens, Johanna Rae
Sent: Wednesday, December 04, 2019 10:15 AM
To:
Cc: Bloom, Suzanne Jaffe
)
)
>; ; Calvar, Cristina I.
Subject: Re: Following up
and
-
Suzanne and I had a quick follow up. We are available at Suzanne's office -
Please give us a call
EFTA00025104

=== Page 3 ===
when you have a chance.
Thanks,
Johanna
Johanna Rae Hudgens
Associate Attorney
Winston & Strawn LLP
> On Dec 3, 2019, at 17:05,
)
wrote:
>
and I will both be tied up at that time. Would a slightly earlier time work for you? Say 9:45?
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Original Message
From: Bloom, Suzanne Jaffe
Sent: Tuesday, December 3, 2019
:10 PM
To:
Cc:
>; Calvar, Cristina I.
>; ; Hudgens, Johanna Rae
;
)
Subject: Re: Following up
Does 10:15 tomorrow work for you?
Suzanne Jaffe Bloom
Partner
Winston & Strawn LLP
<x-apple-data-detectors://2/1><x-apple-data-detectors./4/1>200 Park Avenue<x-apple-data-detectors://0/1>
New York, NY 10166-4193<x-apple-data-detectors.//0/1>
D:
<tel:+
F:
<tel:+
EFTA00025105

=== Page 4 ===
Bio<http://www.winston.com/en/who-we-are/attorneys/bloom-suzanne-jaffe.html>
VCard<http://www.winston.com/vcards/1022.vcf> | Email<mailto:
winston.com<http://www.winston.com/>
On Dec 3, 2019, at 1:35 PM,
)
wrote:
Hi Suzanne,
Do you have a few minutes for a quick call in advance of our meeting tomorrow? Nothing urgent, but we wanted
to check in with you about the scope of topics for tomorrow's meeting.
Between
,
,
and me, some combination of our team should be available most times between now
and our meeting tomorrow (with the exception of 3 p.m. to 5 p.m. today), if there's a time that works best for you
today or tomorrow morning.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Original Message
From:
)
Sent: Wednesday, November 27, 2019 11:35 AM
To: Bloom, Suzanne Jaffe
Cc:
; Calvar, Cristina I.
>; Hudgens, Johanna Rae
Subject: RE: Following up
Thanks Suzanne.
,
and I are all available on Wednesday, December 4 at 2pm. The three of us will
plan to come to your office at that time.
Hope everyone has a good Thanksgiving.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00025106

=== Page 5 ===
1 St. Andrew's Plaza
New York, NY 10007
Original Message
From: Bloom, Suzanne Jaffe
Sent: Tuesday, November 26, 2019 8:31 PM
To: Bloom, Suzanne Jaffe
Cc:
>; Calvar, Cristina I.
Hudgens, Johanna Rae
Subject: Re: Following up
Oops. Adding Cristina and Johanna.
Suzanne Jaffe Bloom
Partner
Winston & Strawn LLP
<x-apple-data-detectors://2/1><x-apple-data-detectors:///1>200 Park Avenue<x-apple-data-detectors://0/1>
New York, NY 10166-4193<x-apple-data-detectors.//0/1>
D:
<tel:+
F:
<tel:+
Bio<http://www.winston.com/en/who-we-are/attorneys/bloom-suzanne-jaffe.html>
VCard<http://www.winston.com/vcards/1022.vcf> | Email<mailto:
winston.com<http://www.winston.com/>
On Nov 26, 2019, at 8:30 PM,
wrote:
Thanks again for your time today. We can meet with you next Wednesday at 2:00 pm. Please let me know if that
works for you.
Best,
Suzanne
Suzanne Jaffe Bloom
Partner
Winston & Strawn LLP
<x-apple-data-detectors://2/1><x-apple-data-detectors//1>2 Park Avenue<x-apple-data-detectors.//0/1>
New York, NY 10166-4193<x-apple-data-detectors://0/1>
EFTA00025107

=== Page 6 ===
D:
<tel:+
F:
<tel:+
Bio<http://www.winston.com/en/who-we-are/attorneys/bloom-suzanne-jaffe.html>
VCard<http://www.winston.com/vcards/1022.vcf> I Email<mailto:
winston.com<http://www.winston.com/>
The contents of this message may be privileged and confidential. If this message has been received in error,
please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege.
Please do not disseminate this message without the permission of the author. Any tax advice contained in this
email was not intended to be used, and cannot be used, by you (or any other taxpayer) to avoid penalties under
applicable tax laws and regulations.
EFTA00025108


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=== Page 1 ===
From:
To:
Subject: 21-58 United States of America V. Maxwell "Attorney ADDED"
Date: Tue, 26 Jan 2021 18:20:25 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 01/26/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Docket Text:
ATTORNEY,
for Appellant Ghislaine Maxwell, in case 21-58, [12], ADDED.[3021136]
[21-58]
Notice will be electronically mailed to:
Mr. Christian Romeyn Everdell, Assistant U.S. Attorney:
Assistant U.S. Attorney:
,
Assistant U.S. Attorney:
Ms. Bobbi C. Sternheim, -:
Notice will be stored in the notice cart for:
Quality Control 1
EFTA00026477


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: Meeting with Geoff on Epstein
Date: Tue, 26 Feb 2019 17:29:18 +0000
Importance: Normal
Attachments: unnamed
EFTA00024485


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc: Christian Everdell
>, , Laura Menninger
>, Jeff Pagliuca
Subject: U.S. V. Maxwell 20 Cr. 330 (AJN)
Date: Tue, 16 Feb 2021 23:04:17 +0000
Attachments: MDC_Conditions_Letter_2-16_FINAL.pdf;ATT00001.htm
Good evening-
Attached please find a courtesy copy of today's ECF fling.
Best-
Bobbi
EFTA00026566


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 379 Filed 10/28/21 Page 1 of 2
UNITED STATES DISTRICT COURT
USDC SDNY
SOUTHERN DISTRICT OF NEW YORK
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 10/28/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
As noted in its previous order, the Court will hold an in-person pretrial conference on
November 1, 2021 at 11:00 a.m. Dkt. No. 330. The conference will take place in Courtroom 518
of the United States District Court for the Southern District of New York, Thurgood Marshall
U.S. Courthouse at 40 Foley Square, New York, New York. In accordance with its prior Order,
the Court will ensure access for alleged victims and any members of the Defendant's family.
Dkt. No. 344. Two pool reporters will be permitted in the courtroom proper.
In order to comply with the District's COVID-19 protocols, the public will be able to
access the proceeding in overflow Courtrooms 110, 506, 619, 905, and 906 of the Thurgood
Marshall U.S. Courthouse. These overflow rooms will have live video and audio feeds of the
proceeding. The use of any electronic devices during the proceeding in the overflow rooms
is strictly prohibited.
The Court anticipates seating capacity in the overflow rooms for at least 100 members of
the public. If capacity is reached, no additional persons will be admitted. Per the S.D.N.Y.
Response to COVID-19, anyone who appears at any S.D.N.Y. courthouse must complete a
questionnaire on the date of the proceeding prior to entering the courthouse. All visitors must
also have their temperature taken when they arrive at the courthouse. Only persons who meet
1
EFTA00024233

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 379 Filed 10/28/21 Page 2 of 2
the entry requirements established by the questionnaire and whose temperatures are below 100.4
degrees will be allowed to enter the courthouse. All visitors must wear a mask that covers the
person's nose and mouth. Bandannas, gaiters, and masks with valves are not permitted. If a
person does not have an approved mask, a screener will provide one. Anyone who fails to
comply with the COVID-19 protocols that have been adopted by the Court will be required to
leave the courthouse. There are no exceptions. For more information, please see
https://www.nysd.uscourts.gov/covid-19-coronavirus.
SO ORDERED.
Dated: October 28, 2021
Alim D.Nitto
New York, New York
ALISON J. NATHAN
United States District Judge
2
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=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
SEALED
UNITED STATES OF AMERICA
:
INDICTMENT
:
- V. -
:
20 Cr.
:
GHISLAINE MAXWELL,
:
:
20 Cr. 330
Defendant.
:
:
X
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
OVERVIEW
1.
The charges set forth herein stem from the role
of GHISLAINE MAXWELL, the defendant, in the sexual exploitation
and abuse of multiple minor girls by Jeffrey Epstein. In
particular, from at least in or about 1994, up to and including
at least in or about 1997, MAXWELL assisted, facilitated, and
contributed to Jeffrey Epstein's abuse of minor girls by, among
other things, helping 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 certain victims were in fact under the age of 18.
2. As a part and in furtherance of their scheme to
abuse minor victims, GHISLAINE MAXWELL, the defendant, and
Jeffrey Epstein enticed and caused minor victims to travel to
EFTA00024594

=== Page 2 ===
Epstein's residences in different states, which MAXWELL knew and
intended would result in their grooming for and subjection to
sexual abuse. Moreover, in an effort to conceal her crimes,
MAXWELL repeatedly lied when questioned about her conduct,
including in relation to some of the minor victims described
herein, when providing testimony under oath in 2016.
FACTUAL BACKGROUND
3.
During the time periods charged in this
Indictment, GHISLAINE MAXWELL, the defendant, had a personal and
professional relationship with Jeffrey Epstein and was among his
closest associates. In particular, between in or about 1994 and
in or about 1997, MAXWELL was in an intimate relationship with
Epstein and also was paid by Epstein to manage his various
properties. Over the course of their relationship, MAXWELL and
Epstein were photographed together on multiple occasions,
including in the below image:
2
EFTA00024595

=== Page 3 ===
4.
Beginning in at least 1994, GHISLAINE MAXWELL,
the defendant, enticed and groomed multiple minor girls to
engage in sex acts with Jeffrey Epstein, through a variety of
means and methods, including but not limited to the following:
a. MAXWELL first attempted to befriend some of
Epstein's minor victims prior to their abuse, including by
asking the victims about their lives, their schools, and their
families. MAXWELL and Epstein would spend time building
friendships with minor victims by, for example, taking minor
victims to the movies or shopping. Some of these outings would
involve MAXWELL and Epstein spending time together with a minor
victim, while some would involve MAXWELL or Epstein spending
time alone with a minor victim.
b.
Having developed a rapport with a victim,
MAXWELL would try to normalize sexual abuse for a minor victim
by, among other things, discussing sexual topics, undressing in
front of the victim, being present when a minor victim was
undressed, and/or being present for sex acts involving the minor
victim and Epstein.
C.
MAXWELL'S presence during minor victims'
interactions with Epstein, including interactions where the
minor victim was undressed or that involved sex acts with
Epstein, helped put the victims at ease because an adult woman
was present. For example, in some instances, MAXWELL would
3
EFTA00024596

=== Page 4 ===
massage Epstein in front of a minor victim. In other instances,
MAXWELL encouraged minor victims to provide massages to Epstein,
including sexualized massages during which a minor victim would
be fully or partially nude. Many of those massages resulted in
Epstein sexually abusing the minor victims.
d. In addition, Epstein offered to help some
minor victims by paying for travel and/or educational
opportunities, and MAXWELL encouraged certain victims to accept
Epstein's assistance. As a result, victims were made to feel
indebted and believed that MAXWELL and Epstein were trying to
help them.
e. Through this process, MAXWELL and Epstein
enticed victims to engage in sexual activity with Epstein. In
some instances, MAXWELL was present for and participated in the
sexual abuse of minor victims. Some such incidents occurred in
the context of massages, which developed into sexual encounters.
5. GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims knowing that he had a
sexual preference for underage girls and that he intended to
engage in sexual activity with those victims. Epstein's
resulting abuse of minor victims included, among other things,
touching a victim's breast, touching a victim's genitals,
placing a sex toy such as a vibrator on a victim's genitals,
4
EFTA00024597

=== Page 5 ===
directing a victim to touch Epstein while he masturbated, and
directing a victim to touch Epstein's genitals.
MAXWELL AND EPSTEIN'S VICTIMS
6.
Between approximately in or about 1994 and in or
about 1997, GHISLAINE MAXWELL, the defendant, facilitated
Jeffrey Epstein's access to minor victims by, among other
things, inducing and enticing, and aiding and abetting the
inducement and enticement of, multiple minor victims. Victims
were groomed and/or abused at multiple locations, including the
following:
a.
A a multi-story private residence on the
Upper East Side of Manhattan, New York owned by Epstein (the
"New York Residence"), which is depicted in the following
photograph:
5
EFTA00024598

=== Page 6 ===
b.
An estate in Palm Beach, Florida owned by
Epstein (the "Palm Beach Residence"), which is depicted in the
following photograph:
C.
A ranch in Santa Fe, New Mexico owned by
Epstein (the "New Mexico Residence"), which is depicted in the
following photograph:
6
EFTA00024599

=== Page 7 ===
d.
MAXWELL's personal residence in London,
England.
7. Among the victims induced or enticed by GHISLAINE
MAXWELL, the defendant, were minor victims identified herein as
Minor Victim-1, Minor Victim-2, and Minor Victim-3. In
particular, and during time periods relevant to this Indictment,
MAXWELL engaged in the following acts, among others, with
respect to minor victims:
a.
MAXWELL met Minor Victim-1 when Minor
Victim-1 was approximately 14 years old. MAXWELL subsequently
interacted with Minor Victim-1 on multiple occasions at
Epstein's residences, knowing that Minor Victim-1 was under the
age of 18 at the time. During these interactions, which took
place between approximately 1994 and 1997, MAXWELL groomed Minor
Victim-1 to engage in sexual acts with Epstein through multiple
means. First, MAXWELL and Epstein attempted to befriend Minor
Victim-1, taking her to the movies and on shopping trips.
MAXWELL also asked Minor Victim-1 about school, her classes, her
family, and other aspects of her life. MAXWELL then sought to
normalize inappropriate and abusive conduct by, among other
things, undressing in front of Minor Victim-1 and being present
when Minor Victim-1 undressed in front of Epstein. Within the
first year after MAXWELL and Epstein met Minor Victim-1, Epstein
began sexually abusing Minor Victim-1. MAXWELL was present for
7
EFTA00024600

=== Page 8 ===
and involved in some of this abuse. In particular, MAXWELL
involved Minor Victim-1 in group sexualized massages of Epstein.
During those group sexualized massages, MAXWELL and/or Minor
Victim-1 would engage in sex acts with Epstein. Epstein and
MAXWELL both encouraged Minor Victim-1 to travel to Epstein's
residences in both New York and Florida. As a result, Minor
Victim-1 was sexually abused by Epstein in both New York and
Florida. Minor Victim-1 was enticed to travel across state
lines for the purpose of sexual encounters with Epstein, and
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-1 after Minor-Victim-1 traveled to Epstein's
properties, including in the context of a sexualized massage.
b. MAXWELL interacted with Minor Victim-2 on at
least one occasion in or about 1996 at Epstein's residence in
New Mexico when Minor Victim-2 was under the age of 18. Minor
Victim-2 had flown into New Mexico from out of state at
Epstein's invitation for the purpose of being groomed for and/or
subjected to acts of sexual abuse. MAXWELL knew that Minor
Victim-2 was under the age of 18 at the time. While in New
Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and
MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed
Minor Victim-2's school, classes, and family with Minor Victim-
2. In New Mexico, MAXWELL began her efforts to groom Minor
Victim-2 for abuse by Epstein by, among other things, providing
8
EFTA00024601

=== Page 9 ===
an unsolicited massage to Minor Victim-2, during which Minor
Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to
massage Epstein.
C.
MAXWELL groomed and befriended Minor
Victim-3 in London, England between approximately 1994 and 1995,
including during a period of time in which MAXWELL knew that
Minor Victim-3 was under the age of 18. Among other things,
MAXWELL discussed Minor Victim-3's life and family with Minor
Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and
arranged for multiple interactions between Minor Victim-3 and
Epstein. During those interactions, MAXWELL encouraged Minor
Victim-3 to massage Epstein, knowing that Epstein would engage
in sex acts with Minor Victim-3 during those massages. Minor
Victim-3 provided Epstein with the requested massages, and
during those massages, Epstein sexually abused Minor Victim-3.
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-3 on multiple occasions, including at times when
Minor Victim-3 was under the age of 18, including in the context
of a sexualized massage.
MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT
8. In or around 2016, in the context of a deposition
as part of civil litigation, GHISLAINE MAXWELL, the defendant,
repeatedly provided false and perjurious statements, under oath,
regarding, among other subjects, her role in facilitating the
9
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=== Page 10 ===
abuse of minor victims by Jeffrey Epstein, including some of the
specific events and acts of abuse detailed above.
STATUTORY ALLEGATIONS
9.
From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, enticement, in violation of Title 18, United States Code,
Section 2422.
10. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did knowingly persuade, induce,
entice, and coerce one and more individuals to travel in
interstate and foreign commerce, to engage in sexual activity
for which a person can be charged with a criminal offense, in
violation of Title 18, United States Code, Section 2422.
Overt Acts
11. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
10
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=== Page 11 ===
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with Epstein
and Minor Victim-1 in New York and Florida.
b.
In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
New York Residence, in violation of New York Penal Law, Section
130.55.
C.
In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d.
Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Enticement of a Minor to Travel to Engage in Illegal Sex Acts)
The Grand Jury further charges:
12. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
11
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=== Page 12 ===
13. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
persuade, induce, entice, and coerce an individual to travel in
interstate and foreign commerce to engage in sexual activity for
which a person can be charged with a criminal offense, and
attempted to do the same, and aided and abetted the same, to
wit, MAXWELL persuaded, induced, enticed, and coerced Minor
Victim-1 to travel from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2422 and 2.)
COUNT THREE
(Conspiracy to Transport Minors with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
14. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
15. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
12
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=== Page 13 ===
wit, transportation of minors, in violation of Title 18, United
States Code, Section 2423 (a)
16. It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did, knowingly transport an
individual who had not attained the age of 18 in interstate and
foreign commerce, with intent that the individual engage in
sexual activity for which a person can be charged with a
criminal offense, in violation of Title 18, United States Code,
Section 2423 (a) .
Overt Acts
17. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a. Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with EPSTEIN
and Minor Victim-1 in New York and Florida.
b. In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
13
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=== Page 14 ===
New York Residence, in violation of New York Penal Law, Section
130.55.
C. In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d.
Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT FOUR
(Transportation of a Minor with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
18. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
19. From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did
transport an individual who had not attained the age of 18 in
interstate and foreign commerce, with the intent that the
individual engage in sexual activity for which a person can be
charged with a criminal offense, and attempted to do so, and
14
EFTA00024607

=== Page 15 ===
aided and abetted the same, to wit, MAXWELL arranged for Minor
Victim-1 to be transported from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2423 (a) and 2.)
COUNT FIVE
(Perjury)
The Grand Jury further charges:
20. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
21. On or about April 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7344, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q.
Did Jeffrey Epstein have a scheme to recruit
underage girls for sexual massages? If you know.
A.
I don't know what you're talking about.
15
EFTA00024608

=== Page 16 ===
Q.
List all the people under the age of 18 that you
interacted with at any of Jeffrey's properties?
A.
I'm not aware of anybody that I interacted with,
other than obviously [the plaintiff] who was 17
at this point.
(Title 18, United States Code, Section 1623.)
COUNT SIX
(Perjury)
The Grand Jury further charges:
22. The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
23. On or about July 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under
docket number 15 Civ. 7344, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q:
Were you aware of the presence of sex toys or
devices used in sexual activities in Mr.
Epstein's Palm Beach house?
A:
No, not that I recall.
Q.
Do you know whether Mr. Epstein possessed sex
toys or devices used in sexual activities?
A. No.
16
EFTA00024609

=== Page 17 ===
Q.
Other than yourself and the blond and brunette
that you have identified as having been involved
in three-way sexual activities, with whom did Mr.
Epstein have sexual activities?
A. I wasn't aware that he was having sexual
activities with anyone when I was with him other
than myself.
Q. I want to be sure that I'm clear. Is it your
testimony that in the 1990s and 2000s, you were
not aware that Mr. Epstein was having sexual
activities with anyone other than yourself and
the blond and brunette on those few occasions
when they were involved with you?
A. That is my testimony, that is correct.
Q. Is it your testimony that you've never given
anybody a massage?
A. I have not given anyone a massage.
Q. You never gave Mr. Epstein a massage, is that
your testimony?
A.
That is my testimony.
Q. You never gave [Minor Victim-2] a massage is your
testimony?
A. I never gave [Minor Victim-2] a massage.
(Title 18, United States Code, Section 1623.)
The
FOREPERSON
AUDREY
Audy STRAUSS Straws
Acting United States Attorney
17
EFTA00024610

=== Page 18 ===
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
GHISLAINE MAXWELL,
Defendant.
INDICTMENT
(18 U.S.C. $$ 371, 1623, 2422, 2423 (a),
and 2)
AUDREY STRAUSS
Acting United States Attorney
John
Foreperson
18
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=== Page 1 ===
From:
To:
Subject: 5/13/21 Videoconference with Counsel for Bill Richardson
Date: Thu, 13 May 2021 16:08:07 +0000
5/13/21 Videoconference (WebEx)
Steven Cozen
Stephen Miller
Barry Boss
(Counsel for Bill Richardson)
AUSAs
Provided background on Richardson's history of public service
Background re Epstein and GM
Never attended parties hosted by JE or GM
Never discussed topic of massages with JE or GM
Never received a massage from anyone connected to JE or GM
Never met any women through JE or GM
Never met
Never travelled on JE's private airplane
Met JE/GM a few times during political campaigns in NM
JE donated to BR's political campaigns; returned donation when could and otherwise donated to charity
Polygraph examination in March 2021 by Barry Colvert; BR was asked if ever had intimate physical contact with
or if ever engaged in sexual act with
and BR said no; results of examination were not indicative of deception on
one scale; on another scale probability of deception is less than .01 and probably of deception on another scale
was less than .001
August 2019 - Judge Preska unsealed passages from
May 3, 2016 deposition in which
named BR as person
GM directed her to have sex with
"Catastrophic" impact on reputation, finances, and humanitarian efforts (e.g., lost speaking opportunities, lost
Board opportunities, lost Netflix deal, impact on Richardson Center for Global Engagement to do its work)
Requesting that can represent that BR is neither subject nor target of investigation and SDNY does not intend to call
him as a witness
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00024683


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein/Maxwell Upload
Date: Fri, 25 Sep 2020 14:46:59 +0000
How are we handling producing to Maxwell vs. Counsel? With these files there are tons of text and excel files that need to
be converted in order to be sent to MDC. Are we also producing the converted versions to defense or rather the original
natives?
From:
Sent: Thursday, September 24, 2020 2:34 PM
To:
;
Cc:
;
;
Subject: RE: Epstein/Maxwell Upload
The zip files have been copied to the below location. Please let me know if there are any issues with the data in the zip
files.
Thank you.
From:
Sent: Thursday, September 24, 2020 11:42 AM
To:
is
Cc:
>;
;
Subject: RE: Epstein/Maxwell Upload
That's what I figured. Thanks! Now that they are all good to go would you please export both Deutsche Bank and
JPMorgan productions to the shared here: \\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-
2018R01618\Discovery\GM\04 Fourth Production\TO BE PRODUCED
From:
Sent: Thursday, September 24, 2020 11:39 AM
To:
is
Cc:
is
;
Subject: RE: Epstein/Maxwell Upload
No way to put a confidential stamp on a excel file. There should be an image placeholder that says document produced in
native format which has the confidential stamp.
From:
Sent: Thursday, September 24, 2020 11:36 AM
To:
is
Cc:
is
;
Subject: RE: Epstein/Maxwell Upload
Thanks
These look great. One quick question, on documents in native format (excel files) is there a confidential
stamp? I've checked and it seems the answer is no but I just want to be sure that I'm not missing anything.
From:
Sent: Thursday, September 24, 2020 11:20 AM
To:
is
EFTA00023688

=== Page 2 ===
Cc:
>;
Subject: RE: Epstein/Maxwell Upload
The documents should now be available for review. Please let me know if there are any questions.
Thank you.
From:
Sent: Thursday, September 24, 2020 9:11 AM
To:
is
Cc:
>;
is
;
Subject: RE: Epstein/Maxwell Upload
These documents are not supposed to be privileged reviewed. The only documents that need to be privilege reviewed are
the electronic search warrant returns.
Thanks,
From:
Sent: Thursday, September 24, 2020 9:05 AM
To:
Cc:
>;
is
;
is
Subject: RE: Epstein/Maxwell Upload
The data is probably secured for privilege review. Please let me know if these documents are not supposed to be
privileged reviewed.
Thank you.
From:
Sent: Wednesday, September 23, 2020 5:39 PM
To:
Cc:
>;
is
is
Subject: RE: Epstein/Maxwell Upload
Hey
When I click on each of those links I'm brought to a Relativity page with no data. Am I doing something wrong?
Thanks,
From:
Sent: Wednesday, September 23, 2020 11:32 AM
To:
Cc:
>;
i
is
Subject: RE: Epstein/Maxwell Upload
The production of the documents has been completed. The below are links to the production for you to review:
Deutsche Bank - https://d1pe.nss.pae.com/Relativity/go?id=1420850-2343058
JP Morgan - https://d1pe.nss.pae.com/Relativity/go?id=1420850-2343059.
Please review the documents and let me know if anything needs to be adjusted with the production.
Thank you.
From:
Sent: Friday, September 18, 2020 10:26 AM
To:
Cc:
is
is
EFTA00023689

=== Page 3 ===
is
Subject: RE: Epstein/Maxwell Upload
1. Yes, we want to mark all of them confidential
2. We are working on that.
3. I suppose database load files? We want to retain the files as they are currently formatted as best we can.
4. That won't be an issue. I don't think we will be searching through them; the purpose is just to be able to stamp
them.
Thanks!
From:
Sent: Friday, September 18, 2020 10:10 AM
To:
Cc:
>;
>;
>;
Subject: RE: Epstein/Maxwell Upload
I know you want to produce these documents can you please tell me the following:
1. Will you placing a Confidential stamp on these documents?
2. What bates number do you wish to use on the documents?
3. How do you want to produce the documents (single page tiff images, database load files or PDF production).
4. Also please note that once the documents have been loaded to Relativity there is no way to run any searches for
these images since they are mostly images and video.
Please let me know if there are any questions.
Thank you.
From:
Sent: Thursday, September 17, 2020 4:54 PM
To:
Cc:
is
is
is
Subject: Epstein/Maxwell Upload
Hey
We have some materials that we need uploaded to Relativity to the Epstein database for the purpose of stamping them.
The files in question number about 40,000 and are about 300GB in size. They are currently copying onto a drive to be sent
to Relativity and should be ready by tomorrow. Do you want to see them first or can they go directly to PAE?
Folder/Subfolder in Relativity: US V. Epstein
FBI Case File
Images Seized During Search
Thanks,
Paralegal Specialist
U.S. Attorney's Office SDNY
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Cc:
Subject: Pitman deputy contact info??
Date: Sun, 07 Jul 2019 17:19:32 +0000
Importance: Normal
Hi guys - this is a long shot, but by any chance do you happen to have a cell phone number for Judge Pitman's deputy? Or
even an email address? We've been asked to try to tee up the Epstein unsealing for him tomorrow morning-I think we
could just call him at 9:00 when the court opens, but far more important people than I would like us to try to reach out
today. We have all the Moses duty info since she's on this weekend, but nothing for Pitman (and he doesn't list any email
address in his individual rules). Thanks either way!
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
To: Andrew Patel
Cc: Jill Shellow
Don Yannella
)"
)"
Subject: RE:
Epstein
Date: Fri, 20 Dec 2019 22:56:20 +0000
Thanks Andy, we will review and get back to you early next week.
Original Message
From: Andrew Patel
Sent: Friday, December 20, 2019 5:14 PM
To:
Cc: Jill Shellow
Don Yannella
)
>; Andrew Patel
Subject: RE:
Epstein
,
We have attached a proposed disclosure cover letter that is modeled on a letter sent by the Government in United
States V. Madonna, 17 Cr. 89 (CS). We have also attached proposed redacted disclosures. As you and I discussed,
we offer this as a means to ensure our client's safety while permitting the Government to comply with what you
believe are your disclosure obligations.
As an alternative, we are willing to apply under seal to Judge Torres for a Protective Order to preclude the
disclosure. Our client is not a witness, and so this is not 3500 material, nor is it Rule 16 material. We do not
believe that this is in fact Brady material, but rather is an error made by our client that we understand is
contradicted by the surveillance video evidence. While we applaud your efforts, we have an obligation to make
sure that our client is not harmed by the possible release of the fact that he met with your Office.
We understand that you have time constraints. Please let us know how you want to proceed so that we can file a
motion before Judge Torres promptly if that is necessary.
Andy
Andrew G. Patel
Attorney at Law
CONFIDENTIALITY NOTICE: This e-mail message is covered by the Electronic Communications Privacy Act,
18 U.S.C. 2510-2521. It is legally privileged. The information it contains is confidential information and is
intended only for the use of the individual or entity named above. If the reader of this message is not the intended
recipient, or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified
that any dissemination, distribution or copying of the communication is strictly prohibited. If you have received
this e-mail in error, please notify me immediately by telephone at (212) 349-0230 and by return e-mail, and
delete all copies of the message from your computer. Thank you.
EFTA00027031

=== Page 2 ===
Original Message
From:
) [mailto:
Sent: Friday, December 20, 2019 10:01 AM
To: Andrew Patel
Cc: Jill Shellow; Don Yannella;
);
)
Subject: RE:
Epstein
Andy,
Attached are unredacted and redacted copies of the notes. As discussed, we intend to produce redacted copies of
the notes pursuant to the protective order, and produce Mr.
name and your contact information to
defense counsel on an AEO basis. The file name will be changed to the bates number so it will not include his
name.
I'm also copying my co-counsel
please include them on emails going forward. Finally,
is aware that we are providing these notes to you.
Thanks, and please feel free to give us a call to discuss.
Original Message
From: Andrew Patel
Sent: Friday, December 20, 2019 8:15 AM
To:
Cc: Andrew Patel
>; ; Jill Shellow
>; Don Yannella
Subject:
/Epstein
Please send us a copy of the disclosure that you are considering as to Mr.
Seeing the planned
disclosure about our client will help us fashion a means of addressing the concerns we discussed last night.
Many thanks,
Andy
Andrew G. Patel
Attorney at Law
Sent from my phone
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=== Page 1 ===
From: Sigrid McCawley
To:
)"
Cc:
)"
Subject: RE:
follow-up request
Date: Fri, 08 May 2020 18:46:06 +0000
If that does not work she also said she could do it this Monday morning - 10:00 Eastern (9:00 Texas) if that is better for
your team.
Just let me know.
Thanks
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Friday, May 8, 2020 1:59 PM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize
the sender.
Sigrid,
Thanks for getting back to us so quickly. Goes without saying that we of course would be happy for you to be on the call
as well- I should have mentioned that in my initial email. On timing, let us just check with the agents on the case to see if
that works for them, and we hope to be able to confirm with you in the next couple hours.
thanks,
From: Sigrid McCawley
Sent: Friday, May 08, 2020 13:27
To:
Cc:
Subject: RE:
follow-up request
EFTA00025305

=== Page 2 ===
Hello
-
said she has time tomorrow if that would work for you team. She is in Texas so an hour behind us. I
would like to be on the call as well. Would it work to do something tomorrow at 11:00 EST? Let me know. If that does not
work I can try to get other times.
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
[mailto:
Sent: Friday, May 8, 2020 11:02 AM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize
the sender.
I unfortunately was on trial during the previous interview, but I think somewhat less time than how long it went last time.
Ordinarily we try not to go longer than about 90 minutes in any event, so I think if she is able to block out that amount of
time, that would be great - and we'll try to be as efficient as possible and hopefully take less than that. If that sounds
alright?
thanks,
From: Sigrid McCawley
Sent: Thursday, May 07, 2020 18:57
To:
Cc:
Subject: RE:
follow-up request
Hello
I am sure
will be happy to help in any way she can. Let me find out what her patient schedule is like for next week
and find a time that works. How much time do you think she should allot for the interview - just so she can plan?
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
EFTA00025306

=== Page 3 ===
www.bsfllp.com
From:
[mailto:
Sent: Thursday, May 7, 2020 6:41 PM
To: Sigrid McCawley
Cc:
Subject: RE:
follow-up request
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
Hi Sigrid,
We wanted to follow up in connection with
- our supervisors have asked us to do an additional interview with her,
both to follow up on some specific aspects of her recollection but also do basically go through her experiences again. As
I'm sure you know, we have no doubts whatsoever, at all, about her candor and truthfulness in our previous interview,
which also was broadly consistent with what she has said in other interviews, but we are nevertheless hoping she might
be willing to speak with us sometime in the next week or two? Obviously due to the current situation we would plan to
do it via phone, and we would be happy to chat about logistics with you if that would be helpful, or to answer any
questions at all. And if
is willing to speak with us again, we're happy to work around her schedule, including talking
during an evening or weekend if that's easier for her than during the day-whatever you and she would prefer.
Please let us know if any questions, or if it would be useful to chat, and thanks very much.
From:
Sent: Thursday, January 16, 2020 14:35
To: Sigrid McCawley
Cc:
is
)
Subject: RE:
follow-up request
Got it, thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 2:29 PM
To:
EFTA00025307

=== Page 4 ===
Cc:
is
)
Subject: RE:
follow-up request
I checked back with
and she said that the last entry in her journal is in late February and she
went to New Mexico in April.
Thanks
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
Sent by Boxer
On January 16, 2020 at 1:05:54 PM EST,
)
wrote:
Thank you very much, Sigrid.
Just to confirm, does
have any journal entries regarding the time when she traveled to New Mexico? I
believe she told us during our interview that she does not have any entries from that time, but I just wanted to
make sure.
Thanks again,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Thursday, January 16, 2020 12:31 PM
To:
Cc:
)
i
)
Subject: RE:
follow-up request
EFTA00025308

=== Page 5 ===
Hello - attached are the pages
sent me to provide to you. Here is a bit of an explanation and I also
asked her to take a copy of the front and back of the journal book which she did. Hope this helps. Please let
me know if you need anything else:
"The shortest page and the one that is the hardest to read is the first entry from 12/95. It is written in colored
pencil and is fading. There are then two pages from 01/07/1996 where I talk about the highlights of my NY
trip and going to Epstein's house and then the next entry from 01/25/1996 is where I talk about going to the
movies with him."
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 4:01 PM
To: Sigrid McCawley
Cc:
)
i
)
Subject: RE:
follow-up request
Thanks very much, Sigrid. Yes, we received the photographs from
,
which we very much appreciate.
Anything else she is willing to share, including her journal entries, would be very helpful.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Sigrid McCawley
Sent: Friday, January 10, 2020 3:59 PM
To:
Cc:
)
)
Subject: RE:
follow-up request
EFTA00025309

=== Page 6 ===
Hello
Let me follow up with
about her journal. I know she shared some pictures with you from around the
time period when she was with Epstein/Maxwell. I will ask her about the journal ASAP and will get back to
you and will check with her to see if she has anything else that might be helpful to the investigation.
All my best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
www.bsfllp.com
From:
)
[mailto:
Sent: Friday, January 10, 2020 3:30 PM
To: Sigrid McCawley
Cc:
)
)
Subject:
follow-up request
Hi Sigrid,
Hope you had a wonderful holiday season and very happy New Year. We wanted to follow up on a request we
made after interviewing
a few months ago. During her interview,
referred to several
entries in her journal that had helped refresh her recollection of the events involving Epstein and Maxwell. As
we mentioned at the end of the interview, it would be very helpful to our investigation if we could review
those journal entries, as well as any other records or documents
may have that relate to her experiences
with Epstein and Maxwell.
Would
be willing to share with us any relevant journal entries (or any other relevant documents she may
have) to assist in our investigation?
Happy to have a call to discuss if that would be helpful.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00025310

=== Page 7 ===
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: RE:
Date: Thu, 06 Aug 2020 17:27:58 +0000
Embedded: RE:_Witness_torpedoes_Prince_Andrews_denials_about_alleged_Epstein_sex_slave_Toront
o_Sun.msg
That's obviously disappointing but not hugely surprising - she was on a warpath about us meeting with that client, who
says she saw PA dancing in the club. Not an obvious federal crime! We also corresponded about this a little ago in the
attached.
However, searching back for this stuff also reminded me that we never heard back from them on CDB, so just sent a
reminder email on that.
From:
Sent: Thursday, August 06, 2020 13:21
To:
is
Subject: FW:
FYI, Lisa Bloom apparently told a reporter that we did not want to interview one of her clients.
From:
Sent: Thursday, August 6, 2020 9:35 AM
To:
Subject:
https://www.newsweek.com/prince-andrew-was-club-jeffrey-epstein-young-girl-witness-says-1522580.
EFTA00023864


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=== Page 1 ===
From:
To:
Subject: FW:
Date: Fri, 31 Jan 2020 23:48:29 +0000
Hey
,
The woman who is interviewed in the below article claims to have been interviewed by the FBI in the past. Any chance
you could please check to see whether that is true, and if so please send us the 302?
https://foxwilmington.com/headlines/prince-andrew-must-cooperate-in-jeffrey-epstein-probe-give-up-ghislaine-
maxwell-royal-cousin-says/
Thanks,
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 309 Filed 07/01/21 Page 1 of 3
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
July 1, 2021
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 to bring to the Court's attention an opinion
piece (the "Op-Ed") published yesterday in the New York Daily News, which was authored by
David Markus, Esq., who represents the defendant in connection with this case. Mr. Markus's
statements in the Op-Ed were in violation of Local Rule 23.1, which contains provisions relating
to extrajudicial public statements by attorneys. Accordingly, for the reasons stated below, the
Government respectfully requests that the Court order Mr. Markus to comply with Local Rule
23.1.
A. Mr. Markus's Statements to the Media
David Markus represents the defendant in connection with appellate matters in this case.
In particular, Mr. Markus has handled the defendant's bail appeals in this case, including an
argument on her behalf in the Second Circuit. As the Court may recall, on April 14, 2021, Mr.
Markus emailed Chambers requesting permission to bring electronics to the courthouse to attend
the defendant's arraignment on the superseding indictment. The Court informed Mr. Markus that
he would need to file a notice of appearance before making such an application to the Court. Mr.
Markus did not file a notice of appearance, but he attended the arraignment and spoke to members
of the media thereafter. I
I See Stephen Rex Brown, Ghislaine Maxwell Makes First Court Appearance, N.Y. Daily News (Apr. 23, 2021),
http://www.nydailynews.com/new-york/ny-ghislaine-maxwel-arraignment-20210423-
b3aza5eh7bddna7r247px2yb7e-story.html (quoting Mr. Markus, speaking outside the courthouse following the
defendant's arraignment and identifying him as "her attorney").
EFTA00023532

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 309 Filed 07/01/21 Page 2 of 3
Honorable Alison J. Nathan
July 1, 2021
Page 2
Mr. Markus has made multiple statements to the media in the past few months.2 On May
11, 2021, the Government emailed the defendant's counsel of record in this case and expressed
concern about Mr. Markus's statements, citing Local Rule 23.1. Defense counsel did not respond.
Most recently, on June 30, 2021, Mr. Markus authored an Op-Ed in the New York Daily
News. The Op-Ed compared the defendant to Bill Cosby and argued that this case should be
dismissed in the wake of Mr. Cosby's release from prison. The Op-Ed claims that Jeffrey Epstein's
non-prosecution agreement is binding in this District, but that "[t]he trial court, just like the trial
court and intermediate appellate court in Cosby's case, has agreed to let the government out of its
deal." The Op-Ed further claims that this case is "extremely weak" and asserts that "[a] jury should
reject those flimsy and stale charges." The Op-Ed also identifies Mr. Markus as "Maxwell's
appellate counsel." Other news outlets have subsequently issued articles regarding the Op-Ed.⁴
B. Relief Is Warranted Under Local Rule 23.1
Local Rule 23.1 generally prohibits extrajudicial statements of opinion that a reasonable
person would expect to create "a substantial likelihood that such dissemination will interfere with
a fair trial or otherwise prejudice the due administration of justice." SDNY Local Rule 23.1(a).
The Rule further provides, in relevant part, that statements of "opinion as to the accused's guilt or
innocence or as to the merits of the case or the evidence in the case" are among those that
"presumptively involve a substantial likelihood that their public dissemination will interfere with
a fair trial or otherwise prejudice the due administration of justice." SDNY Local Rule 23.1(d)(7).
The Rule applies to all statements made by lawyers "in connection with pending or imminent
criminal litigation with which they are associated." SDNY Local Rule 23.1(a). Furthermore, the
Rule provides that the Court "may issue a special order governing such matters as extrajudicial
statements by parties and witnesses likely to interfere with the rights of the accused to a fair trial
by an impartial jury
SDNY Local Rule 23.1(h).
Mr. Markus is plainly governed by Local Rule 23.1, because he is not only "associated"
with this criminal case, but he is also counsel of record in the defendant's appeals in connection
with this matter. Mr. Markus's comments to the media-most egregiously, the Op-Ed-were
clearly in violation of Local Rule 23.1. Not only did his statements directly comment on the merits
of this case, but they did so in a manner designed to appeal directly to the pool of potential jurors
2 See Ben Feuerherd, Feds Detail Ghislaine Maxwell's 'Enhanced Security Schedule' In Prison, N.Y. Post (May 5,
2021), https://nypost.com/2021/05/05/ghislaine-maxwell-on-enhanced-security-schedule-lockup-feds/(quoting Mr.
Markus); David Oscar Markus, Ghislaine Maxwell Should Be Released: She Should Await Her Trial Outside
Confinement, N.Y. Daily News (Feb. 24, 2021), https://www.nydailynews.com/opinion/ny-oped-ghislaine-maxwell-
should-be-released-20210224-xocbnloc25exflbqbaf6fp76he-story.html (Op-Ed authored by Mr. Markus).
3 See David Oscar Markus, Bill Cosby is Free; Ghislaine Maxwell Should Be, Too, N.Y. Daily News (June 30, 2021),
http://www.nydailynews.com/opinion/ny-oped-cosby-maxwel-free-20210630-gqlcsn6yczaivp5h7g7x731fzu-
story.html (Op-Ed authored by Mr. Markus).
4 See Louis Casiano, Bill Cosby Ruling Should be Used to Free Ghislaine Maxwell, Her Lawyer says, Fox News (July
1, 2021), https://www.foxnews.com/us/bill-cosby-free-ghislaine-maxwell,Daniel Villarreal, Bill Cosby Ruling Shows
Why Ghislaine Maxwell Should Be Freed, Her Lawyer Says, Newsweek (June 30, 2021),
https://www.newsweek.com/bill-cosby-ruling-shows-why-ghislaine-maxwel-should-freed-her-lawyer-says.
1605828.
EFTA00023533

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 309 Filed 07/01/21 Page 3 of 3
Honorable Alison J. Nathan
July 1, 2021
Page 3
in this case: the Op-Ed was published in a local newspaper, and it contained an express overture
to jurors, discussing the verdict defense counsel wishes jurors to reach in this case. What is more,
the Op-Ed falsely suggested to potential jurors that this prosecution is barred by a non-prosecution
agreement-a legal contention this Court has considered and squarely rejected.
This Court has already entered an Order-at the request of the defendant-indicating the
Court's expectation that "all involved parties will exercise great care to ensure compliance with
this Court's local rules, including Local Criminal Rule 23.1." (Dkt. No. 28). Mr. Markus's
continued comments are in violation of that Order, are inappropriate, and are likely to interfere
with the Court's ability to conduct a fair trial with an impartial jury in this case. Accordingly, the
Government respectfully requests that the Court issue an order pursuant to Local Rule 23.1(h)
directed specifically to Mr. Markus and instructing him to comply with Local Rule 23.1.
Respectfully submitted,
AUDREY STRAUSS
United States Attorney
By:
/s
/
/
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2225
Cc:
Christian Everdell, Esq. (by ECF)
Mark Cohen, Esq. (by ECF)
Bobbi Sternheim, Esq. (by ECF)
Laura Menninger, Esq. (by ECF)
Jeffrey Pagliuca, Esq. (by ECF)
David Markus, Esq. (by email)
EFTA00023534


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=== Page 1 ===
From:
To:
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 18:25:40 +0000
Inline-Images: image001.png
Thanks so much,
From
Sent: Thursday, July 2, 2020 1:27 PM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Congrats, guys - amazing work!!!
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 NOFFICE 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,
EFTA00024539

=== Page 2 ===
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00024540

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
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=== Page 1 ===
Mod AO 442 (09/13) Arrest Warrant AUSA Name & Telno:
212-637-2225
UNITED STATES DISTRICT COURT
for the
Southern District of New York
United States of America
20 CR 330
V.
)
)
Case No.
)
)
)
Ghislaine Maxwell
)
Defendant
ARREST WARRANT
To:
Any authorized law enforcement officer
YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
(name of person to be arrested) Ghislaine Maxwell
,
who is accused of an offense or violation based on the following document filed with the court:
Indictment
Superseding Indictment
Information
Superseding Information
Complaint
Probation Violation Petition
Supervised Release Violation Petition
Violation Notice
Order of the Court
This offense is briefly described as follows:
Title 18, United States Code, Section 371 (conspiracy to entice minors)
Title 18, United States Code, Sections 2422 and 2 (enticement of a minor)
Title 18, United States Code, Section 371 (conspiracy to transport minors)
Title 18, United States Code, Sections 2423(a) and 2 (transportation of a minor)
Title 18, United States Code, Section 1623 (perjury)
Lisa Margaret Sun
Date:
06/29/2020
Issuing officer's signature
City and state:
White Plains, NY
Hon. Lisa Margaret Smith, U.S. Magistrate Judge
Printed name and title
Return
This warrant was received on (date)
, and the person was arrested on (date)
at (city and state)
Date:
Arresting officer's signature
Printed name and title
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=== Page 1 ===
From:
"
)"
To:
)"
Subject: just in case
Date: Fri, 09 Oct 2020 18:29:00 +0000
Attachments: 2020-01-10, JE,
nonprosecution_agreement,_draft.docx; 2020-01-
13, JE,
_nonprosecution_agreement,_draft.docx; 2020-02-
14, JE,
_nonprosecution_agreement,_draft.docx; 2020-02-
17, JE,
,_plea_agreement.docx
These are in my AUSA folder so I think wouldn't otherwise be obvious if and when it gets to the point that they might be
useful sending along in the hopes that they ever are (!).
Assistant U.S. Attorney
Southern District of New York
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=== Page 1 ===
From:
"
To:
"
Cc:
"
Bcc: "USAHUB-USAJourmal111"
Subject: RE: Maxwell Financial Report Appendices
Date: Fri, 11 Dec 2020 14:42:21 +0000
Embedded: RE:_Maxwell_Financial_Report_Appendices.msg
Sender:
Subject: RE: Maxwell Financial Report Appendices
Message-Id:
<BN3P110MB0260D34AC605D6186FADBA22E3CA0@BN3P110MB0260.NAMP110.PROD.OUTLOOK.CO
M>
Cc:
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=== Page 1 ===
From:
To:
Subject: Travel Authorization 11061344 approved by
, now awaiting further
approval
Date: Wed, 19 Feb 2020 23:32:32 +0000
Importance: Normal
Dear
Travel authorization 11061344 has been approved by
, now awaiting further approval.
Trip ID: 11061344
Traveler name:
Purpose: R20NYS13402 - Epstein Investigation - Witness interview
Destination: Los Angeles, CA, United States
Dates: 2020-02-26 - 2020-02-29
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0007
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
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=== Page 1 ===
7/6/19 "Location: 9 East 11st street, New york, NY-loth Floor
31E-NY-3127571 Preparer: SA
2
Direction
A-216a
OH TO scale
e: 7/11/19 Pnepainer. SOS
91.7
19'11'1/2"
30'1'
Infill Steel l'late Panel
1'4"
With Copper
New Brick and CMU
7'1'
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EFTA00025136


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=== Page 1 ===
From:
To: Brad Edwards <brad@epllc.com>, Brittany Henderson <brittany@epllc.com>
Cc:
Subject: Rule 412 Motion
Date: Thu, 28 Oct 2021 23:35:58 +0000
Attachments: Def.412_Mot_for_Edwards_Redacted.pdf; Ex. Ex._C.pdf;
2021.10.28_order_re_November_1_Conference.pdf
Brad, Brittany,
Attached please find a redacted version of the defense's memorandum of law in support of her Federal Rule of Evidence
412 motion and related exhibits. As we mentioned earlier, this was filed under seal by the defense. Any response is due
on November 1, 2021. Likewise, any and all responses will also be filed under seal and will not be docketed. The Court
also ordered that any in camera hearing is tentatively scheduled for November 5, 2021. We are happy to discuss further
tomorrow.
I'm also attaching the Court's Order about the November 1 in-person pretrial conference.
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
EFTA00024248


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=== Page 1 ===
ATTACHMENT 1
USER LITIGATION HOLD NOTICE AND CERTIFICATION FORM
PRIVACY ACT PROTECTED
I. NOTICE
Please be advised that, by and through this Notice, we, the United States Attorney's Office for the Southern District of
New York ("USAO"), are hereby instituting a "Litigation Hold" in light of a request emailed by representatives of Jeffrey
Epstein for the preservation of all documents and evidence relating to or potentially shedding light on the circumstances
of his incarceration and of his recent death at the Metropolitan Correctional Center ("MCC"). Specifically, the family's
represenatives request as follows: "Mr. Epstein's family has asked me to send to you and
at the MCC a
request for the preservation of any and all documents, records, reports, videos, pictures, physical evidence, electronic
communication data, tape recordings, logs, notes, papers, emails and any and all other forms of information that would
be in the possession of the MCC, its Warden, their legal counsel, the USMS, the FBI, the Inspector General, the USAO for
the SDNY or any other federal or relevant state or city agency that relate to Jeffrey Epstein's imprisonment/detention
since July 6, 2019 and that relate particularly but not exclusively to the July 23, 2019 occurrence which was investigated
as an attempted suicide by the MCC and the events relating to his death on August 10, 2019. The request encompasses
but is not limited to any videos of the 9th floor area in the proximity of his cell during the evening of August 9 through
the time Mr. Epstein was taken out of his cell for the last time on August 10, 2019, or videos of the cell itself during that
time period, records of the identities of (i.e. MCC employees or independent contractors or anyone else) who were on
duty from midnight through 8 AM on August 10, 2019 or otherwise had access to the 9th floor unit where Mr. Epstein
was incarcerated during this time period, records of any observations of Mr. Epstein on August 9-10, 2019, any and all
photographs of Mr. Epstein or his cell taken on August 10, 2019, any and all electronic or tape recordings or records of
any internal communications within the MCC or any external communciations by MCC staff on August 9 and August 10,
2019, records of any mental health interviews or assessements of Mr. Epstein at anytime during his detention, records of
any decision to put him on or take Mr Epstein off suicide watch, photos of his cell taken on or before August 9 or on or
after August 10, 2019, memoranda of interviews with any prisoners who were in Mr. Epstein's SHU unit on the 9th floor
on or about July 23 or on August 9-10, 2019 relating to Mr. Epstein, the same request for interview memoranda of any
MCC employee or independent contractor or any other person in the MCC midnight-8 AM August 10, 2019, any and all
medical and EMS and hospital records from July 23 and/or August 10, 2019, and the future pathology and toxicology and
medical examiner's reports. Additionally, we would request the preservation of any note or notes found in Mr. Epstein's
cell on August 10, 2019, any ligature or other physical evidence related to his cause of death, any bedding, any
medication or vitamins, any log showing who entered or were present in the MCC for the 12 hour period before 6:30 AM
on August 10, 2019, as well as a list of inmates who were in Mr. Epstein's unit during the evening of August 9 and the
morning of August 10, 2019. In short, the family requests a preservation and production of any and all records and
documents relevant to his detention, treatment, and death." I am sending this notice and requesting the suspension of
routine email and ESI deletions from all persons
has identified as potentially involved in such
investigations or possessing such records. Each recipient should respond by informing me of the USAO number of any
investigation or matter that falls within the ambit of the request for preservation; we may choose to create backup,
preserved copies of relevant shared directories and/or to take other steps to preserve pertinent data. Please do not
discard or delete any potentially responsive records; detailed instructions follow.
To institute this Litigation Hold, we are implementing preservation procedures regarding any and all records, data, or
other information, whether they exist in paper form or as electronically stored information ("ESI"), within the USAO's
possession, custody or control relating to the Complaint/Claims (collectively, "Information"). The USAO's obligation to
preserve this Information pertains not only to paper copies, or "hard copies" (whether in draft or final, partial or
complete, versions), but also to ESI in its originally-created, or "native" format, as it exists on any computer system
(whether it be on the USAO's system or your personal computer), as well as removable or portable electronic storage
media. Specific examples of Information subject to this Litigation Hold include, but are not limited to, e-mails and other
electronic communications, word processing documents, records, spreadsheets, databases, calendars, telephone logs,
internet usage files, network access information, and information on other kinds of media, including PDAs (such as Palm
Attachment 1, USAP 3-13.300.003
Page 1
EFTA00023996

=== Page 2 ===
ATTACHMENT 1
Pilots, BlackBerries, and cell phones), thumb drives, CDs, as well as digital voicemail and text messages.
Because the USAO must take reasonable steps to preserve such Information in whatever form it has been created and
maintained, the USAO's Lit Hold Coordinator and Systems Manager must coordinate with all those who may have such
Information. We therefore require your assistance to both identify and preserve any and all Information relating to the
Complaint/Claims, whether or not the Information is ultimately discoverable. Furthermore, we must confirm that you
understand and accept your preservation obligations under this Litigation Hold.
Accordingly, you are required to take the two following steps: (1) Identify to us all such Information and where it resides
(in Section II below); and (2) Certify having received notice of this Litigation Hold and understanding and accepting your
preservation obligations under this Litigation Hold (in Section III below). [NOTE: While seeking to identify all such
Information, please refrain to the maximum extent possible from opening emails/files you believe to be relevant.]
II. IDENTIFY ALL INFORMATION SUBJECT TO THE LITIGATION HOLD
Please identify all locations where the Information described above may exist: CHECK ALL THAT APPLY
Hard Copy Documents:
Printed Emails
Case Files/Logs
Calendars/Appointment Books
Other
USAO System - Microsoft Outlook:
USAO System - EVoIP:
Email Messages
Calendar Items
Tasks
Telephone Data
Notes
Public Folders
Contacts
.PST Files ("Archive")
Office Communicator
(continued on next page)
Attachment 1, USAP 3-13.300.003
Page I 2
EFTA00023997

=== Page 3 ===
ATTACHMENT 1
(continued from previous page)
USAO System - Network Data (i.e., documents/files and folders residing on network drives):
Personal (N, H& M) Drive Document/Files/Folders
Shared Files/Folders
LIONs/Alcatraz/USA-5
Inter- and Intra-net
Other
USAO System - Mobile PIN/SMS:
USAO System - Classified/Special Data:
Blackberry/Other
Document/Files/Folders/Other
Non-Network Data (i.e., documents/files and folders residing on local hard drives and thumb drives):
Local (C & D) Drives
Portable Media/Thumb Drives
Deleted Items (Recycle Bin)
Personal Non-Network Data (located or residing somewhere other than the USAO System):
Document/Files/Folders
Internet
Email Messages
Portable Media/Thumb Drives
PDAs/Other
III. CERTIFICATION
By this Notice and Certification, I acknowledge that I have received, understand, and accept my obligations to preserve
any and all Information (as defined above) I may have now, as well as all such Information I may subsequently receive,
create or modify. I further understand and accept that my continuing Litigation Hold obligations require that I preserve
all such Information in "native" format and, conversely, that I not delete or destroy any such Information until I receive
formal written notice that this Litigation Hold is discontinued. To fulfill these continuing obligations, I will undertake the
necessary steps to preserve this Information, be it "hard copy" and/or ESI, in coordination with the USAO's Lit Hold
Coordinator and Systems Manager.
***
Please be advised that failure to preserve and retain this Information may result in sanctions and/or implicate
professional conduct rules. Consequently, if you are unsure whether certain information should be preserved, err on the
side of caution and preserve the information until you have spoken to the USAO's Lit Hold Coordinator about it. If you
have any questions about whether to preserve certain ESI, or its native formatting, please contact the USAO's Lit Hold
Coordinator or Systems Manager.
Please sign below to acknowledge you have read this Notice and Certification and understand and accept your
preservation obligations, then return the executed copy to the USAO's Lit Hold Coordinator. Thank you.
User Signature:
Date of User Signature:
CC:
USAO Lit Hold Coordinator
National Preservation Officer
USAO Systems Manager
INFORMATION CONTAINED IN THIS FORM MAY CONSTITUTE PRIVATE, CONFIDENTIAL AND/OR SENSITIVE, AS
WELL AS PERHAPS ALSO PRIVILEGED AND/OR OTHERWISE PROTECTED, INFORMATION
Attachment 1, USAP 3-13.300.003
Page I 3
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=== Page 1 ===
From:
Cc:
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - non-testifying witness production
Date: Fri, 23 Jul 2021 21:31:51 +0000
Attachments: 2021.07.23_Maxwell_Cover_Letter_Final.pdf;
2021.07.23_U.S._v_Ghislaine_Maxwell_Non-
Testifying_Witness_Material_Index_Defense_Copy).pdf
Counsel,
A supplemental production of non-testifying witness material is now ready to produce. Attached please find the cover
letter and index accompanying this production. Because the production contains audio and video files, it is too large to
produce via USAfx. Would you please provide our office with two drives (128 GB should be more than sufficient) for us to
load with one copy for you and one copy to be sent to Ms. Maxwell at the MDC?
One thing to note: as indicated in the cover letter, DOJ has recently directed our office to cease production of materials
marked with the word "confidential" in order to avoid confusion with markings reserved for classified documents.
Accordingly, we have noted the appropriate designation for this production by using the label, "SUBJECT TO PROTECTIVE
ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17," which references the relevant paragraphs in the Protective Order governing
confidential materials. Please let us know if you have any objection to this marking or would like to discuss.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From:
To:
Subject: BOP Devices
Date: Wed, 04 Mar 2020 14:31:46 +0000
Attachments: CYBER_ROFE_2019-010614_Aug_22_Phones.zip
The DOJ OIG Cyber team completed the analysis of the BOP devise. Attached is the report, they found one discussion of
Epstein in a text exchange.
U.S. Department of Justice
Office of the Inspector General
New York Field Office
One Battery Park Plaza, 29th Floor
New York, NY 10004
EFTA00023535


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
)"
)"
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 ?
Date: Wed, 23 Oct 2019 13:10:20 +0000
FYI
Sent from my iPhone
Begin forwarded message:
From:
)"
Date: October 23, 2019 at 09:06:18 EDT
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
?
Gloria,
We just needed a little time to rearrange schedules, as we had planned to do noon to 1:00 based on your
request. However we will plan to come to your office as soon as the meeting this morning is concluded,
including any individual questions that occur immediately after the general presentation, which occurred but
was relatively limited following the corresponding meeting in Florida last week. My hope is that we'll be able
to get to your office by 11:30, and we can email to let you know that we're on our way if that's helpful.
Alternatively, if you and
would prefer to meet at the FBI, that should be fine, you just may have to wait
for a few minutes following the meeting. We can discuss either way this morning in person, but the upshot is
that we'll meet with you as soon as possible after the meeting.
thanks,
On Oct 23, 2019, at 08:57, Gloria Allred
wrote:
I will not have a means to communicate with you after 9:30 this morning, because I will be at the F.B.I. Victim Services
meeting and they will take my phone. Would you please respond to my message below prior to that time in order that
I may know the plan for meeting with
and me today?
Gloria Allred
Allred, Maroko & Goldberg
EFTA00024299

=== Page 2 ===
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image005.jpg>
<image006.png>
From: Gloria Allred
Sent: Tuesday, October 22, 2019 8:26 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 ?
Is there a place at the FBI for you to interview
at the end of the meeting with Victim Services ? I am on a tight
schedule tomorrow. Please advise if you want to interview her there at 11:A.M or 11:30.at the end of their meeting or
do wish to use my office at 305 Broadway? I need to leave the interview with her by 12:30. I must take the 2P.M. train
to D.C.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image007.jpg>
<image008.png>
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=== Page 1 ===
From:
"
(USANYS)"
To: "Berman, Geoffrey (USANYS)"
(USANYS)"
>, "Stewart, Craig (USANYS)"
:
,
(USANYS)"
Cc:
(USANYS)"
Subject: Epstein OCME
Date: Fri, 16 Aug 2019 18:48:14 +0000
The team has just learned from the City Medical Examiner that OCME has officially concluded Epstein's cause of death
was hanging and the manner of death was suicide.
OCME plans to issue a press release and the official death certificate indicating as much later this afternoon.
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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: Epstein priv review -- 1B71 report
Date: Fri, 06 Nov 2020 04:58:18 +0000
Embedded: RE:_Epstein_priv_review__1B71_report.msg
Sender:
Subject: RE: Epstein priv review -- 1B71 report
Message-Id:
<DM3P110MB0570839229949F124A3572158FED0@DM3P110MB0570.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
Cc:
Cc:
Cc:
Cc:
Cc:
Cc:
EFTA00024814


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=== Page 1 ===
UNITED STATES DEPARTMENT OF JUSTICE
Office of the Inspector General
WARNINGS AND ASSURANCES TO EMPLOYEE REQUIRED
TO PROVIDE INFORMATION
You are being asked to provide information as part of an investigation being conducted by the Office
of the Inspector General. This investigation is being conducted pursuant to the Inspector General
Act of 1978, as amended.
This investigation pertains to
You have a duty to reply to the questions posed to you during this interview and agency disciplinary
action, including dismissal, may be undertaken if you refuse to answer or fail to reply fully and
truthfully.
Neither your answers nor any information or evidence gained by reason of your answers can be
used against you in any criminal proceeding. However, if you knowingly and willfully provide false
statements or information in your answers, you may be criminally prosecuted for that action. The
answers you furnish and any information or evidence resulting from them may be used in the
course of agency disciplinary proceedings.
ACKNOWLEDGMENT
I have read and understand my rights and obligations as set forth above.
Signature of the Office of the Inspector
Employee's Signature
General Special Agent
Name of the Office of the Inspector
Employee's Name
General Special Agent
Signature of Witness
Date and Time
Name of Witness
Place
OIG Form III-226/3 (05/03/21), Warnings and Assurances to Employee Required to Provide Information
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=== Page 1 ===
Original
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re: Warrants and Orders For
Prospective and Historical Location
APPLICATION
Information and Pen Register
Information for the Cellphones
20
6770
Mag.
Assigned Call Numbers
and
USAO Reference
No. 2018R01618
Application for Warrants and Orders
for Cellphone Location and Pen Register Information
The United States of America, by its attorney,
Acting United States
Attorney for the Southern District of New York,
Assistant United States
,
Attorney, of counsel, respectfully requests that the Court issue the accompanying proposed
Warrants and Orders for prospective and historical location information and pen register
information for two cellphones. As grounds for this Application the Government relies on the
following facts and authorities.
I. Introduction
1. I am an Assistant United States Attorney in the U.S. Attorney's Office for the Southern
District of New York. This Application is submitted in conjunction with the accompanying
affidavit of a law enforcement agent ("Agent Affidavit"), to be sworn before this Court, and
incorporated by reference herein. I make this Application based on information and belief,
including the Agent Affidavit, my review of other documents in the case, and information received
from investigative personnel.
2. The Investigating Agency, Target Cellphones, Subscribers, Target Subject, Service
Providers, Subject Offenses, Successor Service Provider, and Successor Cellphone referenced in
this Application are as specified in the Agent Affidavit.
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=== Page 2 ===
II. Legal Authority
A. Prospective Location Information
3. The Government seeks to obtain both precision location information and cell site data
for the Target Cellphones on a prospective basis (the "Prospective Location Information") for a
period of 45 days from the date of this order - the same period of time for which a warrant for a
tracking device may be granted under Rule 41(e)(2)(C). It bears noting, however, that while the
Prospective Location Information may permit "tracking" the user of the phone in the colloquial
sense, this is not an application for a warrant for a "tracking device" as defined in Fed. R. Crim.
P. 41(a)(2)(E) and 18 U.S.C. $ 3117(b). Those provisions only apply where an agent is seeking to
physically install a tracking device on a given object. Instead, the Prospective Location
Information will be obtained by requiring the Service Provider to provide the information.
4. The authority for this application is found in 18 U.S.C. § 2703(c)(1), which authorizes
a court of competent jurisdiction to require any electronic communication service provider (which
includes a cellular telephone service provider¹) to disclose any "record or other information
pertaining to a subscriber" other than the "contents of communications," when the government
obtains, inter alia, a warrant under the applicable procedures of Rule 41. See 18 U.S.C. $
2703(c)(1)(A). Because data concerning a subscriber's location, such as precision location
information and cell site data, constitutes "information pertaining to a subscriber" that does not
include the "contents of communications," that data is among the types of information available
1 See 18 U.S.C. $ 2711(1) (incorporating by cross-reference statutory definitions set forth in 18
U.S.C. $ 2510); 18 U.S.C. $ 2510(15) (defining "electronic communication service" as "any
service which provides to users thereof the ability to send or receive wire or electronic
communications").
2
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=== Page 3 ===
under $ 2703(c)(1)(A).² Further, as specified in 18 U.S.C. $ 2711(3), this Court is a court of
competent jurisdiction under the Stored Communications Act because it has jurisdiction over the
Subject Offenses.
5. The Government's request for cell site data also implicates the pen register statute,
because such data constitutes signaling information used by the Service Providers to route
communications to and from the Target Cellphones. In order to collect such data, a valid pen
register order is required.³ Accordingly, I hereby certify pursuant to 18 U.S.C. § 3122 that such
signaling information is relevant to an ongoing investigation being conducted by the Investigating
Agency into suspected violations of the Subject Offenses by the Target Subject.
B. Historical Location Information
6. The Government also seeks historical cell site data for the Target Cellphones for the
period from June 1, 2020 to the present (the "Historical Location Information"). Because such
data-like "Prospective Location Information"-constitutes information concerning a subscriber,
the Court is authorized to order the Service Providers to provide this data pursuant to a warrant
2 See In re Application, 460 F. Supp. 2d 448, 459-60 & n. 55 (S.D.N.Y. 2006) (Kaplan, J.)
(cellphone location information falls within $ 2703(c)(1)); accord, e.g., United States V. Caraballo,
963 F. Supp. 2d 341, 361 (D.Vt. 2013); In re Order, 632 F. Supp. 2d 202, 207 (E.D.N.Y. 2008);
In re Application, 405 F. Supp. 2d 435, 444-45 (S.D.N.Y. 2005). But see In re Application, 849
F. Supp. 2d 526, 574 (D.Md. 2011) (rejecting view that cellular location data falls within the scope
of the SCA and finding that phone must be treated as "tracking device" for purposes of Rule 41
where used to collect location data); In re Application, 2009 WL 159187, at *5-*6 (S.D.N.Y.
Jan. 13, 2009) (McMahon, J.) (same).
3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order
under the pen register statute); 3127(3) & (4) (defining pen register and trap and trace device to
include devices or processes that record, inter alia, signaling information). Although cell site data
constitutes "signaling" information within the meaning of the pen register statute, a separate statute
precludes the Government from relying "solely" on the authority provided by the pen register
statute to ascertain a subscriber's location. 47 U.S.C. § 1002(a). Here, the Government seeks to
obtain such data pursuant to 18 U.S.C. $ 2703(c) as well as the pen register statute, rather than
"solely" under the latter statute. See In re Application, 460 F. Supp. 2d at 456-59.
3
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=== Page 4 ===
application under 18 U.S.C. $ 2703(c), under the applicable procedures of Rule 41. See 18 U.S.C.
$ 2703(c)(1)(A). I respectfully submit that the same probable cause supporting the Government's
request for a warrant to obtain the Prospective Location Information requested above also supports
the issuance of a warrant under $ 2703(c) for the requested Historical Location Information. In
addition, the Government seeks toll records for the same period as the Historical Location
Information. Pursuant to 18 U.S.C. § 2703(d), I respectfully submit that the Agent Affidavit offers
specific and articulable facts showing that there are reasonable grounds to believe that the toll
record information sought is relevant and material to an ongoing criminal investigation.
C. Pen Register Information
7. Finally, the Government seeks an order pursuant to 18 U.S.C. §§ 3121-26 authorizing
the use of a pen register on the Target Cellphones for a period of 45 days from the date of this
order. Specifically, the Government seeks an order directing the Service Providers to furnish any
information, facilities, and technical assistance necessary to operate, unobtrusively and with
minimum disruption of service, a pen register and trap and trace device to capture all dialing,
routing, addressing, or signaling information associated with each call transmitted to or from the
Target Cellphones, as specified further in the proposed Warrants and Orders (the "Pen Register
Information").
4 The Government is also not seeking authorization to obtain post-cut-through dialed digits
("PCTDD"), or digits that are dialed after a telephone call from the Target Cellphones has been
connected. Pursuant to the attached Order, if possible, the Service Provider will forward only pre-
cut-through-dialed digits to the Investigating Agency. However, if the Service Providers'
technical capabilities require it to forward all dialed digits, including PCTDD, to the Investigating
Agency, the Investigating Agency will only decode and forward to the agents assigned to the
investigation the numbers that are dialed before the call is cut through.
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=== Page 5 ===
8. I hereby certify pursuant to 18 U.S.C. $ 3122 that the Pen Register Information is
relevant to an ongoing investigation being conducted by the Investigating Agency into suspected
violations of the Subject Offenses by the Target Subject.
D. Sealing and Non-Disclosure Order to Service Providers
9. When the Government obtains records or information under $ 2703(c), it is not required
to notify the subscriber or customer. 18 U.S.C. § 2703(c)(3). Additionally, the Government may
obtain an order precluding the Service Providers from notifying the subscriber or any other third-
party of the warrant or order obtained, for such period as the Court deems appropriate, where there
is reason to believe that such notification will result in endangering the life or physical safety of
an individual, flight from prosecution, destruction of or tampering with evidence, or intimidation
of potential witnesses, or will otherwise seriously jeopardize the investigation. 18 U.S.C.
$ 2705(b).
10. Further, 18 U.S.C. $ 3123(d) provides that an order directing installation of a pen
register or trap and trace device shall direct the pertinent service provider "not to disclose the
existence of the pen register or trap and trace device or the existence of the investigation to the
listed subscriber, or to any other person unless or until otherwise ordered by the Court."
11. Accordingly, as explained further in the Agent Affidavit, in light of the confidential
nature of the continuing criminal investigation and the adverse consequences expected in the event
of premature notification, the Government respectfully requests that the Court direct the Service
Providers not to notify the Subscribers or any other person of the Warrants and Orders sought
herein for a period of one year, subject to extension upon application to the Court, if necessary.
12. For similar reasons, I respectfully request that the proposed Warrants and Orders, this
Application, and the accompanying Agent Affidavit, be maintained under seal until the Court
orders otherwise, except that the Government be permitted without further order of this Court to
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=== Page 6 ===
serve these Warrants and Orders on the Service Providers; provide copies of the Warrants and
Orders or the supporting Application and Agent Affidavit as need be to personnel assisting the
Government in the investigation and prosecution of this matter; and disclose these materials as
necessary to comply with discovery and disclosure obligations in any prosecutions related to this
matter.
III. Prior Requests
13. Except as may be set forth above, no prior request for the relief requested herein has
been made.
Dated: New York, New York
June 29, 2020
Assistant United States Attorney
Tel.:
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Original
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re: Warrants and Orders For
Prospective and Historical Location
AGENT AFFIDAVIT
Information and Pen Register
Information for the Cellphones
20
6770
Assigned Call Numbers
Mag.
and
USAO Reference
No. 2018R01618
Agent Affidavit in Support of Warrants and Orders
for Cellphone Location and Pen Register Information
STATE OF NEW YORK
)
) SS.
COUNTY OF NEW YORK )
,
being duly sworn, deposes and states:
I. Introduction
1. I have been a Special Agent with the Federal Bureau of Investigation ("FBI" or
"Investigating Agency") since 2017. As such, I am a "federal law enforcement officer" within the
meaning of Federal Rule of Criminal Procedure 41(a)(2)(C), that is, a government agent engaged
in enforcing the criminal laws and duly authorized by the Attorney General to request a search
warrant. I am currently assigned to investigate violations of criminal law relating to the sexual
exploitation of children as part of an FBI Task Force. I have gained expertise in this area through
classroom training and daily work related to these types of investigations. As part of my
responsibilities, I have been involved in the investigation of cases involving sex trafficking,
enticement of minors, and transportation of minors for illegal sex acts, and have participated in the
execution of search warrants involving electronic evidence.
2. Requested Information. I respectfully submit this Affidavit pursuant to 18 U.S.C.
§§ 2703(c) and (c)(1)(A) and the applicable procedures of Federal Rule of Criminal Procedure 41;
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18 U.S.C. §§ 2703(d) & 2705; and 18 U.S.C. §§ 3121-3126, in support of two warrants and orders
for prospective location information, historical location information, toll records, and pen register
information, for the Target Cellphones identified below (collectively, the "Requested
Information").
3. Basis for Knowledge. This Affidavit is based upon my participation in the
investigation, my examination of reports and records, and my conversations with other law
enforcement agents and other individuals, as well as my training and experience. Because this
Affidavit is being submitted for the limited purpose of obtaining the Requested Information, it
does not include all the facts that I have learned during the course of this investigation. Where the
contents of documents and the actions, statements, and conversations of others are reported herein,
they are reported in substance and in part, except where otherwise indicated. In addition, unless
otherwise indicated, statements by others referenced in this Affidavit were not necessarily made
to me, but may have been provided to me by someone else to whom I have spoken or whose report
I have read (and who in turn may have had either direct or indirect knowledge of the statement).
Similarly, unless otherwise indicated, information in this Affidavit resulting from surveillance
does not necessarily set forth my personal observations, but may have been provided to me by
other law enforcement agents who observed the events, and to whom I have spoken or whose
report I have read.
4. Target Cellphones, Subscribers, Target Subject, and Service Providers. The
Target Cellphones referenced in this Affidavit are the cellphone assigned call number
("Target Cellphone-1") and the cellphone assigned call number
("Target
Cellphone-2," and collectively with Target Cellphone-1, the "Target Cellphones"). As further
discussed below, Target Cellphone-1 is subscribed to in the name of "Terramar Project, Inc."
2
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=== Page 9 ===
("Subscriber-1"), and Target Cellphone-2 is subscribed to in the name of "G Max" ("Subscriber-
2," and collectively with Subscriber-1, the "Subscribers"). GHISLAINE MAXWELL is believed
to use the Target Cellphones and is a Target Subject of this investigation. T-Mobile is the Service
Provider for Target Cellphone-1, and AT&T is the Service Provider for Target Cellphone-2.
5. Precision Location Capability. Cellphone service providers have technical
capabilities that allow them to collect at least two kinds of information about the locations of the
cellphones to which they provide service: (a) precision location information, also known as E-911
Phase II data, GPS data, or latitude-longitude data, and (b) cell site data, also known as
"tower/face" or "tower/sector" information. Precision location information provides relatively
precise location information about a cellphone, which a provider can typically collect either via
GPS tracking technology built into the phone or by triangulating the device's signal as received
by the provider's nearby cell towers. Cell site data, by contrast, reflects only the cell tower and
sector thereof utilized in routing any communication to and from the cellphone, as well as the
approximate range of the cellphone from the tower during the communication (sometimes referred
to as "per-call measurement" ("PCM") or "round-trip time" ("RTT") data). Because cell towers
are often a half-mile or more apart, even in urban areas, and can be ten or more miles apart in rural
areas, cell site data is typically less precise than precision location information. Based on my
training and experience, I know that the Service Providers have the technical ability to collect
precision location information from any cellphone on its network, including by initiating a signal
on the Service Providers' network to determine the phone's location. I further know that cell site
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=== Page 10 ===
data is routinely collected by the Service Providers in the course of routing calls placed to or from
any cellphone on their network.¹
6. Successor Service Provider. Because it is possible that the Target Subject may change
cellphone service provider during the course of this investigation, it is requested that the warrant
and investigative order requested apply without need for further order to any Successor Service
Provider who may provide service to the Target Cellphones during the time frames at issue herein.
II. Facts Establishing Probable Cause
7. Although I understand that probable cause is not necessary to obtain all of the
Requested Information, I respectfully submit that probable cause exists to believe that the
Requested Information will lead to the location of a person, GHISLAINE MAXWELL, to be
arrested for the crimes of conspiracy to entice minors to travel to engage in illegal sex acts, in
violation of 18 U.S.C. $ 371; enticement of a minor to travel to engage in illegal sex acts, in
violation of 18 U.S.C. $ 2422; conspiracy to transport minors with intent to engage in criminal
sexual activity, in violation of 18 U.S.C. $ 371; transporting a minor with intent to engage in
criminal sexual activity, in violation of 18 U.S.C. $ 2423(a); and perjury, in violation of 18 U.S.C.
$ 1623 (the "Subject Offenses").
8. On June 29, 2020, a grand jury in the Southern District of New York returned an
indictment charging GHISLAINE MAXWELL with the Subject Offenses. The Indictment
charging MAXWELL is attached as Exhibit A hereto (the "Indictment"). That same day, United
States Magistrate Judge Lisa Margaret Smith signed a warrant for MAXWELL's arrest, which is
attached as Exhibit B hereto (the "Arrest Warrant").
1 Toll records are sometimes necessary or helpful in order to obtain or interpret historical cell site
data and are therefore also requested herein.
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=== Page 11 ===
9. In light of these pending charges in the Indictment and the issuance of the Arrest
Warrant, GHISLAINE MAXWELL is subject to arrest for the Subject Offenses.
10. Based on my review of T-Mobile records, I have learned that Target Cellphone-1 is
subscribed in the name of "Terramar Project, Inc." Based on my review of publicly available
videos and related information, I know that GHISLAINE MAXWELL has given multiple public
addresses in her capacity as the founder and president of an organization known as the TerraMar
Project, a non-profit organization that, as noted, was founded and run by MAXWELL and devoted
to ocean protection.
11. As set forth in Paragraph 3 of Exhibit A, MAXWELL was a close associate and
employee of Jeffrey Epstein's. Additionally, as set forth in Paragraphs 1 through 19 of Exhibit A,
MAXWELL is charged with committing four of the Subject Offenses together with Epstein. I
know from my participation in this investigation that on or about July 6, 2019, Epstein was arrested
by the FBI on federal sex trafficking charges. During that arrest, the FBI seized an iPhone from
Epstein's possession (the "Epstein Phone"). Pursuant to a judicially authorized search warrant,
the FBI subsequently searched the contents of the Epstein Phone. Among other things, that search
revealed that the phone number associated with Target Cellphone-1 was saved as a contact in the
Epstein Phone under the name "Ghislaine."
12. I further know from my review of T-Mobile records the following:
a. Target Cellphone-1 has been active within the last 30 days.
b. Target Cellphone-1 has been in contact with a phone subscribed to in the name
of "Joshua Perry," which I know from my review of a law enforcement database is the name of
the husband of a former employee of Jeffrey Epstein (the "Joshua Perry Phone"). The most recent
contact between Target Cellphone-1 and the Joshua Perry Phone occurred in or about May 2020.
5
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=== Page 12 ===
c. Target Cellphone-1 has also been in contact with a phone subscribed to the
business "Haddon, Morgan, & Foreman," which I know from my review of court records is the
name of a law firm that currently represents GHISLAINE MAXWELL in civil litigation (the
"Haddon, Morgan, & Foreman Phone"). The most recent contact between Target Cellphone-1 and
the Haddon, Morgan, & Foreman Phone occurred in or about February 2020.
d. Target Cellphone-1 has also been in contact with a phone subscribed to in the
name of "Isabel Maxwell," which I know from my review of a law enforcement database is the
name of GHISLAINE MAXWELL's sister (the "Isabel Maxwell Phone"). The most recent
contact between Target Cellphone-1 and the Isabel Maxwell Phone occurred in or about August
2019.
e. Target Cellphone-1 has also been in contact with a phone subscribed to in the
name of "Laura Menninger," which I know from my review of court records is the name of an
attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
Menninger Phone"). The most recent contact between Target Cellphone-1 and the Laura
Menninger Phone occurred in or about August 2019.
f. Target Cellphone-1 has also been in contact with a phone subscribed to in the
name of "Scott Borgerson," which I know from my review of bank records and Amazon records
is the name of an individual with whom GHISLAINE MAXWELL shares a joint bank account
and to whom MAXWELL's Amazon account has sent multiple packages within approximately
the last year (the "Scott Borgerson Phone"). The most recent contact between Target Cellphone-1
and the Scott Borgerson Phone occurred in or about August 2019.
13. Accordingly, I respectfully submit there is probable cause to believe that the location
of Target Cellphone-1 will reveal the location of GHISLAINE MAXWELL.
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=== Page 13 ===
14. Based on my review of AT&T records, I have learned that Target Cellphone-2 is
subscribed in the name of "G Max," which appears to be a shortened version of GHISLAINE
MAXWELL's name. I further know from my review of AT&T records that Target Cellphone-2
has been active within the last 30 days. In particular, within the last 30 days, Target Cellphone-2
has been in contact with the Isabel Maxwell Phone, the Laura Menninger Phone, the Haddon,
Morgan, & Foreman Phone, and the Scott Borgerson Phone.
15. Accordingly, I respectfully submit that there is probable cause to believe that the
location of Target Cellphone-2 will reveal the location of GHISLAINE MAXWELL.
III. Request for Warrants and Orders
16. Based on the foregoing, I respectfully request that the Court require the Service
Providers to provide the Requested Information as specified further in the Warrants and Orders
proposed herewith, including prospective precision location and cell site data for a period of 45
days from the date of this Order, historical cell site data and toll records for the period from June
1, 2020 through the date of this Order, and pen register information for a period of 45 days from
the date of this Order.
1.
Nondisclosure. The scope of this ongoing criminal investigation and existence of
the Indictment and Arrest Warrant are not publicly known. As a result, premature public disclosure
of this affidavit or the requested Warrants and Orders could alert GHISLAINE MAXWELL that
she is under investigation and subject to arrest, causing her to destroy evidence, flee from
prosecution, or otherwise seriously jeopardize the investigation. Specifically:
a. As evidenced by the charges alleged in the Indictment, MAXWELL is known
to have participated in acts of sexual abuse of minors. Alerting her to the existence and scope of
the investigation may lead her to intimidate witnesses. See 18 U.S.C. $ 2705(b)(1),(4).
7
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=== Page 14 ===
b. Additionally, the Target Subject is at liberty in the community. Premature
disclosure of the existence of this application and the charges contained in the Indictment could
result in the Target Subject fleeing from prosecution if she were made aware of the pending charges
before arrest. See 18 U.S.C. $ 2705(b)(2).
17. Accordingly, there is reason to believe that, were the Service Providers to notify the
subscribers or others of the existence of the warrant, the investigation would be seriously
jeopardized. Pursuant to 18 U.S.C. $ 2705(b), I therefore respectfully request that the Service
Providers be directed not to notify the subscribers or others of the existence of the Warrants and
Orders for a period of one year, and that the Warrants and Orders and all supporting papers be
maintained under seal until the Court orders otherwise, as specified in the Application submitted
in conjunction with this Affidavit.
S
Special Agent
Federal Bureau of Investigation
Sworn to before me this
29 day of June, 2020
Kathaw H Parke
HONORABLE KATHARINE H. PARKER
United States Magistrate Judge
Southern District of New York
Sworn to before me by reliable electronic means in
accordance with Fed. R. Crim. P. 4.1 and 41(d)(3).
8
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=== Page 15 ===
Original
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re: Warrant and Order For Prospective
and Historical Location Information and
WARRANT AND ORDER
Pen Register Information for the
Cellphone Assigned Call Number
USAO Reference No.
20
Mag.
6770
,
2018R01618
Warrant and Order
for Cellphone Location Information and Pen Register Information
and for Sealing and Non-Disclosure
TO:
T-Mobile ("Service Provider"), and any subsequent provider of service to the Target
Cellphone specified below ("Subsequent Service Provider")
Federal Bureau of Investigation ("Investigative Agency")
Upon the Application and Agent Affidavit submitted by the Government in this matter:
I. Findings
The Court hereby finds:
1. The Target Cellphone (the "Target Cellphone") that is the subject of this Order is
assigned call number
,
is subscribed to in the name of "Terramar Project, Inc." (the
"Subscriber"), and is currently serviced by the Service Provider.
2. Pursuant to 18 U.S.C. $ 2703(c)(1)(A) and the applicable provisions of Rule 41 of the
Federal Rules of Criminal Procedure, the Government's application sets forth probable cause to
believe that the prospective and historical location information for the Target Cellphone will reveal
the location of a person to be arrested for suspected violations of 18 U.S.C. §§ 371, 2422, 2423(a),
and 1623 ("the Subject Offenses").
3. Pursuant to 18 U.S.C. $ 2703(d), the Government's application also sets forth specific
and articulable facts showing that there are reasonable grounds to believe that the toll records for
the Target Cellphone are relevant and material to an ongoing criminal investigation.
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=== Page 16 ===
4. Pursuant to 18 U.S.C. $ 3123(b)(1), the Government has certified that the pen register
information for the Target Cellphone is relevant to an ongoing investigation by the Investigating
Agency of GHISLAINE MAXWELL and others unknown in connection with suspected violations
of the Subject Offenses.
5. Pursuant to 18 U.S.C. $ 2705(b), there is reason to believe that notification of the
existence of this Warrant and Order will result in flight from prosecution, and/or intimidation of
potential witnesses, or otherwise will seriously jeopardize an ongoing investigation.
NOW, THEREFORE, pursuant to Fed. R. Crim. P. 41, 18 U.S.C. §§ 3121 et seq., 18 U.S.C.
§§ 2701 et seq., and 18 U.S.C. $ 3103a, IT IS HEREBY ORDERED:
II. Order to Service Provider
6. Service Provider. This Order shall apply to the Service Provider specified above, and
to any subsequent provider of service to the Target Cellphone without need for further Order of
this Court.
7. Prospective Location Information. The Service Provider shall provide to the
Investigating Agency on a prospective basis, for a period of 45 days from the date of this Order,
information concerning the location of the Target Cellphone ("Prospective Location
Information"), including all available:
a. precision location information, including GPS data, E-911 Phase II data, and
latitude-longitude data; and
b. cell site data, including any data reflecting (a) the cell towers and sectors thereof
utilized in routing any phone, text, or data communication to or from the Target Cellphone, and
(b) the approximate range of the target phone from the cell towers during the communication
(including per-call measurement ("PCM") or round-trip time ("RTT") data);
2
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=== Page 17 ===
8. Historical Location Information and Toll Records. The Service Provider shall
provide to the Investigating Agency all available historical cell site location information reflecting
the cell towers and sectors thereof utilized in routing any phone, text, or data communication to or
from the Target Cellphone, and the approximate range of the target phone from the cell towers
during the communication (PCM/RTT data), for the period from June 1, 2020 through the present,
as well as all available toll records (including call detail, SMS detail, or data session detail records)
for the communications.
9. Pen register with caller identification and/or trap and trace device. The Service
Provider shall provide to the Investigating Agency, for a period of 45 days from the date of this
order, all dialing, routing, addressing, or signaling information associated with each voice, text, or
data communication transmitted to or from the Target Cellphone, including but not limited to:
a. any unique identifiers associated with the phone, including ESN, MEIN,
MSISDN, IMSI, IMEI, SIM, MIN, or MAC address;
b. source and destination telephone numbers and/or Internet protocol ("IP")
addresses;
c. date, time, and duration of the communication; and
d. cell-site information as specified above.
1 The Service Provider is not required to provide post-cut-through dialed digits ("PCTDD"), or
digits that are dialed after a telephone call from the Target Phone has been connected. If possible,
the Service Provider will forward only pre-cut-through-dialed digits to the Investigative Agency.
However, if the Service Provider's technical capabilities require it to forward all dialed digits,
including PCTDD, to the Investigative Agency, the Investigative Agency will only decode and
forward to the agents assigned to the investigation, the numbers that are dialed before the call is
cut through.
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=== Page 18 ===
10. Technical Assistance. The Service Provider shall furnish the Investigating Agency all
information, facilities, and technical assistance necessary to accomplish the disclosure of all of the
foregoing information relating to the Target Cellphone unobtrusively and with the minimum
interference to the service presently provided to the Subscriber.
11. Non-Disclosure to Subscriber. The Service Provider, including its affiliates, officers,
employees, and agents, shall not disclose the existence of this Warrant and Order, or the underlying
investigation, to the Subscriber or any other person, for a period of one year from the date of this
Warrant and Order, subject to extension upon application to the Court, if necessary.
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=== Page 19 ===
III. Additional Provisions
12. Compensation for Costs. The Investigating Agency shall compensate the Service
Provider for reasonable expenses incurred in complying with the Warrant and this Order.
13. Sealing. This Warrant and Order, and the supporting Application and Agent Affidavit,
shall be sealed until otherwise ordered by the Court, except that the Government may without
further order of this Court: serve this Warrant and Order on the Service Provider; provide copies
of the Warrant and Order or the supporting Application and Agent Affidavit as need be to
personnel assisting the Government in the investigation and prosecution of this matter; and
disclose these materials as necessary to comply with discovery and disclosure obligations in any
prosecutions related to this matter.
Dated: New York, New York
6/29/2020
2:07 p.m.
Date Issued
Time Issued
Kathaw H Parke
UNITED STATES MAGISTRATE JUDGE
Southern District of New York
5
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=== Page 20 ===
Original
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re: Warrant and Order For Prospective
and Historical Location Information and
WARRANT AND ORDER
Pen Register Information for the
Cellphone Assigned Call Number
USAO Reference No.
20
Mag.
6770
,
2018R01618
Warrant and Order
for Cellphone Location Information and Pen Register Information
and for Sealing and Non-Disclosure
TO: AT&T ("Service Provider"), and any subsequent provider of service to the Target
Cellphone specified below ("Subsequent Service Provider")
Federal Bureau of Investigation ("Investigative Agency")
Upon the Application and Agent Affidavit submitted by the Government in this matter:
I. Findings
The Court hereby finds:
1. The Target Cellphone (the "Target Cellphone") that is the subject of this Order is
assigned call number
,
is subscribed to in the name of "G Max" (the "Subscriber"),
and is currently serviced by the Service Provider.
2. Pursuant to 18 U.S.C. $ 2703(c)(1)(A) and the applicable provisions of Rule 41 of the
Federal Rules of Criminal Procedure, the Government's application sets forth probable cause to
believe that the prospective and historical location information for the Target Cellphone will reveal
the location of a person to be arrested for suspected violations of 18 U.S.C. §§ 371, 2422, 2423(a),
and 1623 ("the Subject Offenses").
3. Pursuant to 18 U.S.C. $ 2703(d), the Government's application also sets forth specific
and articulable facts showing that there are reasonable grounds to believe that the toll records for
the Target Cellphone are relevant and material to an ongoing criminal investigation.
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=== Page 21 ===
4. Pursuant to 18 U.S.C. $ 3123(b)(1), the Government has certified that the pen register
information for the Target Cellphone is relevant to an ongoing investigation by the Investigating
Agency of GHISLAINE MAXWELL and others unknown in connection with suspected violations
of the Subject Offenses.
5. Pursuant to 18 U.S.C. $ 2705(b), there is reason to believe that notification of the
existence of this Warrant and Order will result in flight from prosecution, and/or intimidation of
potential witnesses, or otherwise will seriously jeopardize an ongoing investigation.
NOW, THEREFORE, pursuant to Fed. R. Crim. P. 41, 18 U.S.C. §§ 3121 et seq., 18 U.S.C.
§§ 2701 et seq., and 18 U.S.C. $ 3103a, IT IS HEREBY ORDERED:
II. Order to Service Provider
6. Service Provider. This Order shall apply to the Service Provider specified above, and
to any subsequent provider of service to the Target Cellphone without need for further Order of
this Court.
7. Prospective Location Information. The Service Provider shall provide to the
Investigating Agency on a prospective basis, for a period of 45 days from the date of this Order,
information concerning the location of the Target Cellphone ("Prospective Location
Information"), including all available:
a. precision location information, including GPS data, E-911 Phase II data, and
latitude-longitude data; and
b. cell site data, including any data reflecting (a) the cell towers and sectors thereof
utilized in routing any phone, text, or data communication to or from the Target Cellphone, and
(b) the approximate range of the target phone from the cell towers during the communication
(including per-call measurement ("PCM") or round-trip time ("RTT") data);
2
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=== Page 22 ===
8. Historical Location Information and Toll Records. The Service Provider shall
provide to the Investigating Agency all available historical cell site location information reflecting
the cell towers and sectors thereof utilized in routing any phone, text, or data communication to or
from the Target Cellphone, and the approximate range of the target phone from the cell towers
during the communication (PCM/RTT data), for the period from June 1, 2020 through the present,
as well as all available toll records (including call detail, SMS detail, or data session detail records)
for the communications.
9. Pen register with caller identification and/or trap and trace device. The Service
Provider shall provide to the Investigating Agency, for a period of 45 days from the date of this
order, all dialing, routing, addressing, or signaling information associated with each voice, text, or
data communication transmitted to or from the Target Cellphone, including but not limited to:
a. any unique identifiers associated with the phone, including ESN, MEIN,
MSISDN, IMSI, IMEI, SIM, MIN, or MAC address;
b. source and destination telephone numbers and/or Internet protocol ("IP")
addresses;
c. date, time, and duration of the communication; and
d. cell-site information as specified above.
1 The Service Provider is not required to provide post-cut-through dialed digits ("PCTDD"), or
digits that are dialed after a telephone call from the Target Phone has been connected. If possible,
the Service Provider will forward only pre-cut-through-dialed digits to the Investigative Agency.
However, if the Service Provider's technical capabilities require it to forward all dialed digits,
including PCTDD, to the Investigative Agency, the Investigative Agency will only decode and
forward to the agents assigned to the investigation, the numbers that are dialed before the call is
cut through.
3
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=== Page 23 ===
10. Technical Assistance. The Service Provider shall furnish the Investigating Agency all
information, facilities, and technical assistance necessary to accomplish the disclosure of all of the
foregoing information relating to the Target Cellphone unobtrusively and with the minimum
interference to the service presently provided to the Subscriber.
11. Non-Disclosure to Subscriber. The Service Provider, including its affiliates, officers,
employees, and agents, shall not disclose the existence of this Warrant and Order, or the underlying
investigation, to the Subscriber or any other person, for a period of one year from the date of this
Warrant and Order, subject to extension upon application to the Court, if necessary.
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=== Page 24 ===
III. Additional Provisions
12. Compensation for Costs. The Investigating Agency shall compensate the Service
Provider for reasonable expenses incurred in complying with the Warrant and this Order.
13. Sealing. This Warrant and Order, and the supporting Application and Agent Affidavit,
shall be sealed until otherwise ordered by the Court, except that the Government may without
further order of this Court: serve this Warrant and Order on the Service Provider; provide copies
of the Warrant and Order or the supporting Application and Agent Affidavit as need be to
personnel assisting the Government in the investigation and prosecution of this matter; and
disclose these materials as necessary to comply with discovery and disclosure obligations in any
prosecutions related to this matter.
Dated: New York, New York
6/29/2020
2:08 p.m.
Date Issued
Time Issued
Kathaw H Parke
UNITED STATES MAGISTRATE JUDGE
Southern District of New York
5
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c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026837.pdf
c6: pdf
c7: images
c0:
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To:
(USANYS)"
Cc:
(USANYS)"
)"
)"
(USANYS)"
Subject: RE: Maxwell
Date: Sat, 17 Apr 2021 14:45:26 +0000
Attachments: 2020-10-07_GM_letter_to_Judge_Nathan_re_discovery_from_other_agencies_(FINAL).pdf
Attached.
From:
(USANYS)
Sent: Saturday, April 17, 2021 10:17 AM
To:
Cc:
(USANYS)
is
>;
(USANYS)
Subject: Re: Maxwell
If someone is online before our call, would you mind recirculating our letter from last fall where we laid out what we were
- and were not - obtaining by way of SDFL materials, and what we planned to do with the
emails? Thanks
Sent from my iPhone
On Apr 16, 2021, at 7:38 PM,
)
wrote:
Thanks very much - the team is free at 11:30 a.m. tomorrow morning, so I'll send around a calendar invitation for then.
From:
(USANYS)
Sent: Friday, April 16, 2021 7:24 PM
To:
(USANYS)
Cc:
>;
is
is
(USANYS)
Subject: Re: Maxwell
Me too.
On Apr 16, 2021, at 7:22 PM,
(USANYS)
wrote:
I saw that and figured we would need to discuss. Would tomorrow morning work? I am fairly flexible before 12:30.
Sent from my iPhone
On Apr 16, 2021, at 7:17 PM,
wrote:
EFTA00026837

=== Page 2 ===
Could we please schedule a call to discuss this portion of Judge Nathan's opinion (on page 8):
"The Government shall confirm in writing within one week whether it views any evidence supporting Maxwell's
interpretation of the NPA as material it is required to disclose, and, if so, whether it has disclosed any and all
such evidence in its possession."
Would it be possible to have a call this weekend?
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00026838


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c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
)"
Subject: Epstein - Forfeiture
Date: Mon, 08 Apr 2019 17:32:16 +0000
Importance: Normal
Attachments: FY20_Request_Form-_Large_Case_Related_Expenses.docx;FY19_Request_Form_ -
Large_Case_Related_Expenses_-_650_Fifth_Fraud.docx
Following up on our Brass meeting just now, It's that time of year when we need to do forfeiture funding requests. These
are basically short write-ups of cases that may involve forfeiture and are also likely to incur significant investigative costs
(e.g., traveling to Florida a dozen times, hiring a vendor retaining an expert). Could you guys do a super quick Epstein
write up this afternoon and send it back to me (unfortunately need to get these done today - sorry for the short notice)?
I've attached a blank form and a go-by (you'll see just how short these can be).
Also, notwithstanding what the form says, please do NOT email it down to DC - please send it back to me.
Thanks,
EFTA00026445


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c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Joint/Separate
Date: Thu, 10 Jun 2021 22:23:39 +0000
Attachments: 2020.04.24_Opposition_to_Thomas_Motion_to_Compel_-_final.docx;
2020.06.09_Torres_Order_on_Thomas_Discovery_Motion.pdf
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
EFTA00025550


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c3: VOL00008
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c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Exhibit
Date: Wed, 16 Dec 2020 20:15:25 +0000
Attachments: Y145170_titled_Montpelier_Trust_(previously_the_Angara_Trust).pdf
EFTA00024310


c1: EFTA00026783
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026783.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: Sigrid McCawley
Cc:
Subject: RE: Epstein investigation
(
Date: Mon, 24 Feb 2020 21:44:59 +0000
Sigrid,
Thank you again for speaking with us this afternoon, we appreciate it. As discussed, we wanted to follow up with you via
email about a possible meeting with Ms.
-it sounded like it might be convenient to do a meeting next week
while you're in New York, if that would work for her? If so, if you could give us the dates and time ranges that might be
possible, we can coordinate on scheduling on our end as well. And of course as always we're happy to address any
questions that you or she might have in advance.
thanks very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00026783


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
April 12, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing certain materials relating to individuals the Government does not
currently intend to call as witnesses at trial in the above-referenced case. Attached please find an
index detailing the materials included in today's production. Please note that both the index and
the enclosed materials are governed by the July 31, 2020 Protective Order in this case. The index
is itself designated as "confidential," because it includes information regarding records
designated as "confidential" under the Protective Order. Please note that many of these
individuals are represented by counsel, as detailed in the attached index. The Government reserves
its right to amend and supplement these disclosures.
This production should not be taken to indicate that the Government believes it has any
obligation to provide all of these materials; rather, we make this production as a courtesy.
Moreover, although the Government presently does not intend to call the individuals listed in the
EFTA00026913

=== Page 2 ===
Page 2
enclosed index, we reserve the right to do so and will notify you should the Government determine
that it intends to call any of these individuals at trial.
Very truly yours,
United States Attorney
by: s/
Assistant United States Attorneys
EFTA00026914


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c7: images
c0:
=== Page 1 ===
From: BOBBI C STERNHEIM
To:
S
Cc:
Christian Everdell
Subject: Re: Ghislaine Maxwell 02879-509
Date: Thu, 21 Jan 2021 13:49:54 +0000
Thank you for responding.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
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 Jan 21, 2021, at 8:19 AM,
wrote:
Good morning Bobbi:
While I understand the mail you have sent is time sensitive, there are
BOP policies that must be complied with. All mail must be processed in
a particular manner prior to being provided to an inmate. The legal
department is not involved in the processing of mail for any inmates in
Institution. The institution is not allowing visitors, therefore the
mail may not be hand delivered, but again, the mail must be properly
processed before provided to the inmate. Unfortunately, this is not
something I can assist with.
Best
BOBBI C STERNHEIM
1/20/2021 1:27 PM
EFTA00025015

=== Page 2 ===
Ms. Maxwell needs to review time-sensitive documents for filing on
Monday 1/25.
It appears that overnight express mail is not received next day and
delivery to Ms. Maxwell is further delayed.
Please let me know if we can hand-deliver legal mail for Ms. Maxwell to
the MDC for direct deposit in the legal mail box.
If so, can delivery to Ms. Maxwell be expedited?
Your assistance is greatly appreciated.
Bobbi
BOBBI C. STERNHEIM, ESQ.
I Offices of Bobbi C. Sternheim
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 Jan 19, 2021, at 7:48 AM,
wrote:
Confirmed.
BOBBI C STERNHEIM
1/18/2021 8:32 PM
Hope you enjoyed the weekend.
Confirming this week's VTCs
Tues- Fri. 12:30- 3:30.
Thank you-
Bobbi
EFTA00025016

=== Page 3 ===
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
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.
EFTA00025017


c1: EFTA00024684
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024684.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Joe Nascimento
Cc:
(USANYS)"
)"
Subject: RE:
)
- Epstein
Date: Fri, 14 May 2021 15:33:45 +0000
Attachments:
Hi Joe,
Attached is the proffer agreement for today-I'll discuss this at the beginning of our meeting, but in terms of mechanics
it's fine with me if you and your client sign after the proffer, and you can just email it to me whenever that's done.
Thanks,
From: Joe Nascimento
Sent: Monday, April 26, 2021 9:53 AM
To:
Cc:
(USANYS)
is
Subject: Re:
)
- Epstein
Perfect, I received the invite with the link. Unfortunately (or fortunately sometimes) WebEx has been a part a
daily part of my life the past year, so we should be OK. See you all then, let me know if you need anything
further from us in the meantime.
Sent from my iPhone
Joseph E. Nascimento, Esq.
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 Apr 26, 2021, at 9:31 AM,
)
wrote:
Hi Joe,
Thanks very much. Let's plan for May 14th at 12 p.m., if that works for you. I'll send a WebEx link for the
videoconference shortly. Please let us know if you have any tech issues/questions about WebEx.
Thanks,
EFTA00024684

=== Page 2 ===
From: Joe Nascimento
Sent: Wednesday, April 21, 2021 1:53 PM
To:
Cc:
(USANYS)
is
)
Subject: Re:
- Epstein
Good afternoon,
I spoke with
,
and she can make herself available the following dates:
May 3, 4 (before 2pm), 5, 6, 12, 13 or 14.
She is going to take the day off of work, so no need to do it after-hours (thank you for the offer). Let me know if you
need additional availability.
Thanks,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
<image001.jpg>
From:
)
Date: Friday, April 16, 2021 at 1:31 PM
To: Joe Nascimento
Cc:
(USANYS)
)
Subject: RE:
)
- Epstein
Thanks very much - let's plan for 9:30 a.m. on Monday, if that works for you. Should I just call your desk line, or would
you prefer a different number?
Thanks,
From: Joe Nascimento
Sent: Friday, April 16, 2021 1:00 PM
To:
Cc:
(USANYS)
is
)
Subject: Re:
- Epstein
EFTA00024685

=== Page 3 ===
Hi
Yes, I'm free Monday morning between 9:30 and 12 or Tuesday between 11-3. If that doesn't work for you, I
can try to move something around. Let me know.
Have a nice weekend,
Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Apr 16, 2021, at 11:58 AM,
)
wrote:
Hi Joe,
Hope you're doing well. Are you available for a call sometime early next week? Nothing urgent, but we wanted to talk
with you about potentially scheduling an interview (by video conference) with your client for sometime in early May.
Thanks,
From: Joe Nascimento
Sent: Monday, March 8, 2021 1:54 PM
To:
Cc:
is
Subject: Re:
- Epstein
Yes, 10:30 works for me. Thank you!
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
t.
f.
EFTA00024686

=== Page 4 ===
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,
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:
EFTA00024687

=== Page 5 ===
Hi Joe,
Thanks for reaching out, we were planning to email you. We continue to appreciate your client's cooperation with
our investigation, and her status from our perspective has not changed. We'll be in touch going forward,
-
All the best,
From: Joe Nascimento
Sent: Thursday, July 2, 2020 11:07 AM
To:
Cc:
is
Subject: Re:
)
- Epstein
Good morning,
Hope you are all well. Just wanted to check in after seeing the reports of Ghislaine's arrest.
If you need anything from us,
let us know.
-Joe
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
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.
EFTA00024688

=== Page 6 ===
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
e.
www.crimlawfirm.com
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,
EFTA00024689

=== Page 7 ===
From:
Sent: Saturday, November 30, 2019 14:42
To: Joe Nascimento
Cc:
is
Subject: Re:
- Epstein
Hi Joe,
Thanks for checking in-
,
so no issues on our end, but we appreciate
your following up.
Thanks,
Sent from my iPhone
On Nov 30, 2019, at 8:54 AM, Joe Nascimento
wrote:
Good morning,
Just wanted to check-in as
Please let us know if you need anything from us.
Thanks,
Joe
Sent from my iPhone
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
EFTA00024690

=== Page 8 ===
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,
Thanks for letting us know. Let's plan to meet on Tuesday. Would 11:30 work?
Thanks,
From: Joe Nascimento
Sent: Wednesday, September 4, 2019 10:13 AM
To:
Cc:
is
Subject: Re:
Epstein
EFTA00024691

=== Page 9 ===
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,
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
EFTA00024692

=== Page 10 ===
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
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3rd Avenue
Miami Florida 33129
EFTA00024693

=== Page 11 ===
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:
>;
^
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
e.
www.crimlawfirm.com
From:
)"
Date: Friday, August 2, 2019 at 3:34 PM
To: Joe Nascimento
Cc:
)"
)"
Subject: RE:
)
- Epstein
EFTA00024694

=== Page 12 ===
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:
>;
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
e.
www.crimlawfirm.com
From:
)"
Date: Thursday, August 1, 2019 at 6:10 PM
To: Joe Nascimento
EFTA00024695

=== Page 13 ===
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 | 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,
EFTA00024696

=== Page 14 ===
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
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.
EFTA00024697

=== Page 15 ===
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
EFTA00024698

=== Page 16 ===
On Jul 10, 2019, at 11:39 AM, Joe Nascimento
<mailto:
wrote:
Of course
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-detectors:/2/0>rd<x-apple-data-
detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com/>
On Jul 10, 2019, at 11:34 AM,
<mailto:
wrote:
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. 3<x-apple-data-detectors/2/0>rd<x-apple-data-
detectors://2/0><x-apple-data-detectors://2/0> Avenue<x-apple-data-detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com><http:/www.crimlawfirm.com/
EFTA00024699

=== Page 17 ===
On Jul 9, 2019, at 4:56 PM,
)
<mailto:
<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. 3<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
EFTA00024700

=== Page 18 ===
e.
<mailto:
<mailto:
www.crimlawfirm.com http://www.crimlawfirm.comhttp://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
EFTA00024701

=== Page 19 ===
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza 4th Floor
2250 S.W. 3<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:
i
<mailto:
>mailto:
<mailto:
<mailto:
EFTA00024702

=== Page 20 ===
Cc:
<mailto:
<mailto:
Subject:
) - Epstein
My former partner, Alan Ross, represented
), prior to
his passing in 2018. Agent
served
with a grand jury subpoena earlier
today, and as Alan's former partner and FL Bar appointed inventory attorney, she has
contacted me. Unfortunately, I am unable to meet with her until Tuesday, but I would
appreciate a few minutes of your time at your convenience as I am getting up to speed.
Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3<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/>
EFTA00024703


c1: EFTA00024930
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024930.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: Unit Updates for May
Date: Wed, 05 May 2021 17:52:00 +0000
Attachments:PC_Unit_-Short_Form_Update.5.7.21.docx
EFTA00024930


c1: EFTA00024542
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024542.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Subject: Accepted: GHISLAINE MAXWELL Removal Hearing 20mj132-01
Date: Thu, 02 Jul 2020 17:16:58 +0000
Importance: Normal
Attachments: unnamed
EFTA00024542


c1: EFTA00023549
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00023549.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
05:15
-
4G+ 75%
Nigel Oakes
British businessman
OVERVIEW
PEOPLE ALSO SEARCH FOR
Nigel John Oakes is a British businessman,
and the founder and CEO of Behavioural
Dynamics Institute and SCL Group, the
parent company of Cambridge Analytica.
Wikipedia
Born: July 1962 (age 58 years)
Education: Eton College
Parent(s): Major John Waddington Oakes
Title: Founder and CEO of SCL Group
Organization founded: SCL Group
EFTA00023549


c1: EFTA00024868
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024868.pdf
c6: pdf
c7: images
c0:
=== 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
May 3, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These discovery materials
are stamped with control numbers SDNY_GM_02753399 through SDNY_GM_02753431.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
SDNY GM 02753399
SDNY GM 02753431
Photographs
Confidential
EFTA00024868

=== Page 2 ===
Page 2
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials.
Very truly yours,
AUDREY STRAUSS
United States
by:
Assistant United States Attorneys
EFTA00024869


c1: EFTA00026961
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026961.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
"
)"
:
Subject: RE:
materials
Date: Fri, 08 Jan 2021 20:05:15 +0000
Thank you.
From:
)
Sent: Friday, January 8, 2021 3:03 PM
To:
(USANYS)
is
(USANYS)
is
;
(USANYS)
is
(USANYS)
Cc:
(USANYS)
is
(USANYS)
is
is
(USANYS)
Subject:
materials
All,
We understand that
spoke with
attorneys this morning, and we appear to be at an impasse in the
negotiations. To facilitate discussion of next steps, attached please find the full collection of defense submissions we have
received from counsel for
to date. I have also attached the team's most recent memo regarding
EFTA00026961


c1: EFTA00025406
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025406.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
1
MCC NEW YORK
Friday August 09, 2019
NEW YORK, NY
Page 1
Daily Assignment Roster
6 07:00 15:00
9 12:00 20:00
Post
Split Shift 2 00:00 - 08:00
3 06:00 - 14:00
8 08:00 16:00
10 14:00 22:00
12 16:00 - 00:00
CAPTAIN
6
CAPTAIN SEC
**
06:00 14:00
OPS LT
A1
8
**12
ACT LT
**
**10
$
OT
OT 16:00 22:00
SHU LT
**3 <unassigned>
SIS LT
**6 <unassigned>
SIS LT #2
6 <unassigned>
SIA
8 <unassigned>
SIS TECH #1
8 <unassigned>
PHONE MONITOR
**8 <unassigned>
SEC OFFICER #1
3 <unassigned>
SEC OFFICER #2
8
d $
TOOL ROOM
6 <unassigned>
SEARCH OFFICER
8
2 SALLY OFF
**8 <unassigned>
3 SALLY OFF
**8
LOBBY
**10
$
OT
CONTROL #1
**2
C
8
12
C
$
OT
CONTROL #2
**3
10
INTERNAL
$
12
OT
INTERNAL #2
**2
12
OT (NC)
ATTY CONF
**8
$
UNIT 2
**2
$
**8
12
(NC)
UNIT 3
5 NORTH
5 SOUTH
7 NORTH
(NC)
7 SOUTH
9 NORTH
SHU #1
(NC)
SHU #2
SHU #3
SHU #4
**12 <unassigned>
06:00 14:00
10 SOUTH #1
**8
$
OT
OT
10 SOUTH #2
3 <unassigned>
REC OFFICER #1
3 <unassigned>
3/10/2019 7:18:56 PM
EFTA00025406

=== Page 2 ===
Friday August 09, 2019
Page 2
REC OFFICER #2
**3 <unassigned>
**12
R
11 NORTH
**2
J
e
-
11 SOUTH
0
(NC)
0
11 SOUTH #2
8
REAR GATE
OSP #1
2
g $
m
SANITATION OFF
"2 <unassigned>
9
VISIT #1
VISIT #2
VISIT #3
****Special Assignments***
PHONE RM
PHONE RM 2
**8 <unassigned>
EPO OFFICE
07:00 15:00
LOBBY #2
ESCORT OFF #1
06:30 14:30
ESCORT OFF #2
06:30 14:30
TNWDVR
oT 14:00
ESCORT OFF #3
TREATY LT
**10
TREATY 1
oT 16:00 22:30
TREATY 2
30
DRY CELL
****Back Page Categories***
DAY OFF
SICK LEAVE
ANNUAL LEAVE
LWOP(M)
3/10/2019 7:18:59 PM
EFTA00025407

=== Page 3 ===
Friday August 09, 2019
Page 3
AWOL
SUSPENSION
OFFICIAL TIME
COP
IF TRAINING
****Change Records****
Relieved Officer's
Relieving Officer's
Ret
Spit Shft Officer
New Status
Relieving Officer
Previous Status
Shft
Changed By
Post
3 <Unassigned>
8 PHONE RM 2(sp)
KS 7/28 13:49
LOBBY
8 PHONE RM 3(sp)
KS 7/28 13:49
(sp)PHONE RM 2
8 <Unassigned>
SHU #1
2
COP
<Unassigned>
KS 8/4 09:39
[Sick / Annual]
KS 8/4 11:56
Day Off
KS 8/4 12:00
[Sick / Annual]
[Removed]
12 SHU #1
KS 8/4 12:51
MILITARY LEAVE
SHU #1
12
Sick Leave
<Unassigned>
KS 8/4 12:52
11 SOUTH
8
COP
<Unassigned>
KS 8/4 12:54
[Inserted NCS]
[Sick/Annual]
RW 8/5 08:33
SHU #2
2 <Unassigned>
[Sick / Annual]
RW 8/5 08:34
8 <Unassigned>
2 UNIT 3
Y
RW 8/5 08:42
INTERNAL
Shift
Staff
OT/CT Start End
INTERNAL
OT
UNIT 3
2 <Unassigned>
12 OSP #1
Y
RW 8/5 08:58
7 SOUTH
Shift
Staff
OT/CT Start End
7 SOUTH
oT
OSP #1
[Inserted NCS]
[Sick/Annual]
RW 8/5 09:09
INTERNAL #2
2 <Unassigned>
[Sick / Annual]
RW 8/5 09:09
2 <Unassigned>
$
8 SHU #1
Y
RW 8/5 09:40
11 SOUTH
Shift
Staff
OT/CT Start End
11 SOUTH
$
OT
SHU #1
$
[Inserted NCS]
[Sick/Annual]
RW 8/5 09:53
[Sick / Annual]
RW 8/5 09:53
SHU #1
2 <Unassigned>
[Inserted NCS]
$
[Sick/Annual]
RW 8/5 09:53
SHU #4
12 <Unassigned>
$
[Sick / Annual]
RW 8/5 09:53
SHU #4
12
$
[Time Change]
RW 8/5 09:54
Shift
Staff
OT/CT Start End
SHU #4
$
CT
3/10/2019 7:19:00 PM
EFTA00025408

=== Page 4 ===
Friday August 09, 2019
Page 4
Relieved Officer's
Relieving Officer's Ret
Post
Splt Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
12 ATTY CONF
Y RW 8/5 09:59
10 SOUTH #1
2 <Unassigned>
Shift
Staff
OT/CT Start End
10 SOUTH #1
OT
ATTY CONF
7 SOUTH
12 <Unassigned>
2 9 NORTH
Y RW 8/5 10:22
Shift
Staff
OT/CT Start End
7 SOUTH
OT
9 NORTH
(sp)ESCORT OFF #2
8 <Unassigned>
$
2 UNIT 2
Y RW 8/5 11:02
Shift
Staff
OT/CT Start End
ESCORT OFF #2
$
oT
UNIT 2
$
Y JD 8/6 06:48
10 SOUTH #1
8 <Unassigned>
$
2 UNIT 2
Shift
Staff
OT/CT Start End
10 SOUTH #1
$
OT
UNIT 2
$
[Removed]
JD 8/6 06:48
[Sick / Annual]
$
(sp)ESCORT OFF #2
8
$
[Sick / Annual]
<Unassigned>
JD 8/6 06:48
(sp)ESCORT OFF #2
8 <Unassigned>
$
Annual Leave
JD 8/6 06:50
8 PHONE MONITOR
JD 8/6 07:07
3 SALLY OFF
8 <Unassigned>
3 <Unassigned>
10 LOBBY
RW 8/6 10:07
CONTROL #2
3 <Unassigned>
8 SHU #2
RW 8/6 11:40
SHU #3
ACT LT
3
Sick Leave
<Unassigned>
KS 8/6 14:12
[Inserted]
[Sick/Annual]
KS 8/6 14:29
[Sick/Annual]
KS 8/6 14:29
[Inserted]
[Inserted]
[Sick/Annual]
KS 8/6 14:29
[Sick/Annual]
KS 8/6 14:29
[Inserted]
IF TRAINING
KS 8/6 14:32
[Sick / Annual]
[Sick / Annual]
IF TRAINING
KS 8/6 14:32
[Sick / Annual]
IF TRAINING
KS 8/6 14:32
IF TRAINING
KS 8/6 14:33
[Sick / Annual]
[Sick/Annual]
SJ 8/6 20:12
[Inserted NCS]
7 SOUTH
[Sick / Annual]
SJ 8/6 20:12
8 <Unassigned>
SANITATION OFF
2
Annual Leave
<Unassigned>
RW 8/7 07:52
7 SOUTH
2
[Sick / Annual]
<Unassigned>
RW 8/7 08:27
[Sick / Annual]
[Removed]
RW 8/7 08:27
7 SOUTH
2 <Unassigned>
27 NORTH
RW 8/7 08:27
7 NORTH
2 <Unassigned>
12 OSP #1
Y
RW 8/7 08:27
Shift
Staff
OT/CT Start End
7 NORTH
oT
OSP #1
8 <Unassigned>
2 INTERNAL
Y
RW 8/7 10:06
9 NORTH
Shift
Staff
OT/CT Start End
9 NORTH
$
oT
INTERNAL
$
10 <Unassigned>
$
Annual Leave
Y
RW 8/7 10:24
LOBBY
Shift
Staff
OT/CT Start End
LOBBY
$
oT
Annual Leave
$
1/10/2019 7:19:01 PM
EFTA00025409

=== Page 5 ===
Friday August 09, 2019
Page 5
Relieved Officer's
Relieving Officer's
Ret
Post
New Status
Relieving Officer
Previous Status
Shft Changed By
Spit Shft Officer
6 CAPTAIN SEC
Y RW 8/7 10:27
VISIT #2
9 <Unassigned>
Shift
Staff
OT/CT Start End
VISIT #2
oT
14:00
20:00
CAPTAIN SEC
CAPTAIN SEC
[Time Change]
RW 8/7 10:28
6
Shift
Staff
OT/CT Start End
CAPTAIN SEC
06:00 14:00
8 EPO OFFICE(sp)
Y
RW 8/7 10:29
(sp)TNWDVR
10 <Unassigned>
Shift
Staff
OT/CT Start End
TNWDVR
OT
14:00
EPO OFFICE
06:00
(sp)EPO OFFICE
3 <Unassigned>
8 EPO OFFICE(sp)
RW 8/7 10:29
2 11 NORTH
Y RW 8/7 11:37
11 NORTH
12 <Unassigned>
Shift
Staff
OT/CT Start End
11 NORTH
OT
11 NORTH
ACT LT
Day Off
Y
JD 8/7 13:36
3 <Unassigned>
Shift
Staff
OT/CT Start End
ACT LT
OT
Day Off
2 OSP #1
Y RW 8/8 07:12
SHU #1
12 <Unassigned>
Shift
Staff
OT/CT Start End
SHU #1
OT
OSP #1
8 <Unassigned>
8 UNIT 2
JD 8/8 08:56
11 SOUTH
[Inserted NCS]
[Sick/Annual]
JD 8/8 08:56
8 <Unassigned>
[Sick / Annual]
JD 8/8 08:56
UNIT 2
CONTROL #1
2
Sick Leave
<Unassigned>
RW 8/8 12:33
2 <Unassigned>
C
Annual Leave
Y RW 8/8 12:37
CONTROL #1
Shift
Staff
OT/CT Start End
CONTROL #1
C
OT
Annual Leave
C
[Sick / Annual]
$
[Removed]
JD 8/8 13:36
SHU #4
12
$
[Sick / Annual]
<Unassigned>
JD 8/8 13:36
[Inserted NCS]
$
[Sick/Annual]
JD 8/8 13:41
SHU #4
12 <Unassigned>
$
[Sick / Annual]
ID 8/8 13:41
[Inserted NCS]
[Sick/Annual]
DM 8/8 15:34
5 SOUTH
2 <Unassigned>
[Sick / Annual]
DM 8/8 15:34
5 SOUTH
8
<Unassigned>
27 SOUTH
MC 8/8 15:50
2 <Unassigned>
8 11 NORTH
Y
DM 8/8 15:54
7 SOUTH
Shift
Staff
OT/CT Start End
7 SOUTH
OT
11 NORTH
8 <Unassigned>
12 11 SOUTH #2
Y
DM 8/8 17:59
SHU #2
Shift
Staff
OT/CT Start End
SHU #2
OT
11 SOUTH #2
[Removed]
MC 8/8 18:06
[Sick / Annual]
INTERNAL #2
2
[Sick / Annual]
<Unassigned>
MC 8/8 18:06
2 SALLY OFF
8
Sick Leave
<Unassigned>
MC 8/8 18:23
1/10/2019 7:19:01 PM
EFTA00025410

=== Page 6 ===
Friday August 09, 2019
Page 6
Relieved Officer's
Relieving Officer's
Ret
Post
Splt Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
SHU #1
2
[Sick / Annual]
<Unassigned>
DM 8/8 19:02
[Sick / Annual]
[Removed]
DM 8/8 19:02
[Inserted NCS]
[Sick/Annual]
DM 8/8 19:02
INTERNAL #2
2
<Unassigned>
[Sick / Annual]
DM 8/8 19:02
SHU #1
2 <Unassigned>
12 9 NORTH
Y
DM 8/8 19:04
Shift
Staff
OT/CT Start End
SHU #1
OT
9 NORTH
SHU #2
8
[Sick / Annual]
<Unassigned>
CP 8/9 06:53
[Sick / Annual]
[Removed]
CP 8/9 06:53
SHU #2
8
<Unassigned>
8 11 NORTH
CP 8/9 06:54
11 NORTH
8 <Unassigned>
12 11 SOUTH #2
Y CP 8/9 06:55
Shift
Staff
OT/CT Start End
11 NORTH
oT
11 SOUTH #2
SHU #4
8
<Unassigned>
3 REC OFFICER #2
CP 8/9 06:55
SHU #4
8
[Time Change]
CP 8/9 06:55
Shift
Staff
OT/CT Start End
SHU #4
06:00 14:00
5 NORTH
8
Sick Leave
<Unassigned>
CP 8/9 07:15
(sp)ESCORT OFF #1
8
[Time Change]
JD 8/9 07:15
Shift
Staff
OT/CT Start End
ESCORT OFF #1
06:30 14:30
(sp)ESCORT OFF #2
8
$
[Time Change]
JD 8/9 07:15
Shift
Staff
OT/CT Start End
ESCORT OFF #2
$
06:30 14:30
(sp)ESCORT OFF #3
8
<Unassigned>
3 CONTROL #2
JD 8/9 07:16
CONTROL #2
3 <Unassigned>
8 PHONE RM 2(sp)
JD 8/9 07:16
[Inserted NCS]
[Sick/Annual]
CP 8/9 07:46
5 NORTH
8 <Unassigned>
[Sick / Annual]
CP 8/9 07:46
SHU LT
3
$
Sick Leave
<Unassigned>
CP 8/9 07:50
(sp)TNWDVR
10
[Sick / Annual]
<Unassigned>
RW 8/9 08:03
[Sick / Annual]
[Removed]
RW 8/9 08:03
(sp)TNWDVR
10 <Unassigned>
3 SHU #3
Y
RW 8/9 08:03
Shift
Staff
OT/CT Start End
TNWDVR
OT
14:00
SHU #3
SIS LT
6
$
Annual Leave
<Unassigned>
JD 8/9 08:53
OPS LT
12
Sick Leave
<Unassigned>
CP 8/9 08:58
OPS LT
12 <Unassigned>
10 ACT LT
CP 8/9 08:58
ACT LT
10 <Unassigned>
$
8 ATTY CONF
Y
CP 8/9 08:59
Shift
Staff
OT/CT Start End
ACT LT
$
OT
ATTY CONF
$
7 NORTH
12
Sick Leave
<Unassigned>
RW 8/9 09:05
[Inserted NCS]
[Sick/Annual]
RW 8/9 09:08
ACT LT
10
$
[Time Change]
CP 8/9 09:09
Shift
Staff
OT/CT Start End
ACT LT
$
OT
16:00 22:00
3/10/2019 7:19:01 PM
EFTA00025411

=== Page 7 ===
Friday August 09, 2019
Page 7
Relieved Officer's
Relieving Officer's
Ret
Post
Splt Shft Officer
New Status
Relieving Officer
Previous Status
Shft Changed By
7 NORTH
12 <Unassigned>
[Sick / Annual]
RW 8/9 09:09
10 <Unassigned>
3 EPO OFFICE(sp)
Y
RW 8/9 09:47
(sp)TREATY LT
Shift
Staff
OT/CT Start End
TREATY LT
oT
15:00
EPO OFFICE
07:00 15:00
(sp)TREATY 1
10 <Unassigned>
8 3 SALLY OFF
Y
RW 8/9 09:47
Shift
Staff
QT/CT Start End
TREATY 1
OT
3 SALLY OFF
(sp)TREATY 1
10
[Time Change]
RW 8/9 09:48
Shift
Staff
OT/CT Start End
TREATY 1
OT
16:00
[Inserted NCS]
[Sick/Annual]
RW 8/9 09:57
(sp)TREATY 2
10 <Unassigned>
[Sick / Annual]
RW 8/9 09:57
SHU #1
12
[Sick / Annual]
<Unassigned>
CP 8/9 10:59
[Sick / Annual]
[Removed]
CP 8/9 10:59
[Inserted NCS]
[Sick/Annual]
CP 8/9 11:12
SHU #1
12 <Unassigned>
[Sick / Annual]
CP 8/9 11:13
[Inserted NCS]
[Sick/Annual]
CP 8/9 11:32
11 SOUTH
12
Sick Leave
[Sick / Annual]
CP 8/9 11:32
SHU #4
12
$
[Sick / Annual]
<Unassigned>
CP 8/9 13:40
[Sick / Annual]
$
[Removed]
CP 8/9 13:40
(sp)DRY CELL
12 <Unassigned>
8 11 SOUTH
Y
MC 8/9 14:41
Shift
Staff
OT/CT Start End
DRY CELL
OT
16:00 00:00
11 SOUTH
(sp)TREATY LT
10
[Time Change]
RW 8/9 22:45
Shift
Staff
OT/CT Start End
TREATY LT
OT 15:00 22:30
(sp)TREATY 1
10
[Time Change]
RW 8/9 22:45
Shift
Staff
OT/CT Start End
TREATY 1
oT 16:00 22:30
(sp)TREATY 2
10
[Time Change]
RW 8/9 22:45
Shift
Staff
OT/CT Start End
TREATY 2
oT
07:30
22:30
**Recapitulation****
Morning Watch
8
AM Watch
4
Day Watch
21
PM Watch
6
Evening Watch
14
**Back Page Categories**
Day Off
23
Sick Leave
9
Annual Leave
8
LWOP(M)
2
AWOL
11
SUSPENSION 1
OFFICIAL TIME
1
COP
4
IF TRAINING
4
Total Correctional Svcs. Staff: 116
3/10/2019 7:19:01 PM
EFTA00025412

=== Page 8 ===
Friday August 09, 2019
Page 8
Non Correctional Svcs. Staff: 8
Overtime Occurrences: 28
Comptime Occurrences: 0
Ops Lt. Evening Watch Signature:
Captain's Signature:
3/10/2019 7:19:02 PM
EFTA00025413


c1: EFTA00024627
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024627.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
Page:
1 of 9
FedEx Tax ID: 71-0427007
JEFFREY E EPSTEIN
Billing Account Shipping Address:
Invoice Questions?
IFFEREY E EPSTEIN
Contact FedEx Revenue Services
Phone:
M-F 7-6 (CST)
Fax:
Internet: www.fedex.com
Invoice Summary Oct 27, 2003
FedEx Express Services
Transportation Charges
602.65
Base Discount
-63.90
Special Handling Charges
56.24
Total Charges
USD.$
594.99
TOTAL THIS INVOICE
USD $
594.99
You saved $63.90 in discounts this period!
The FedEx Ground accounts referenced in this invoice have been transferred and assigned to, are owned by, and are payable to FedEx Express.
To ensure proper credit, please return this portion with your payment to FedEx
Please do not staple or foid. Please make your check payable to FedEx
For change of address, check here and complete form on reverse side.
Invoice
Account
Amount
Number
Number
Due
Remittance Advice
Your payment is due by Nov 11, 2003
4-923-30001
USD $594.99
114420814923300018300005949948
SP 01 000001 97702 A 1 ASNGLP
FEEREY E ERSTEIN
FedEx
P.O. Box 1140
Memphis TN 38101-1140
EFTA00024627

=== Page 2 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
Page:
2 of 9
Adjustment Request
FAX TO (800) 548-3020
Tracking No./Airbill No.
Reason Code
Explanation
BEFORE YOU FAX
REASON CODE KEY
Reason
Please include detailed explanation for each adjustment request.
Code
Description
DUP
Duplicate Billing
Remember to include recipient's account number or third party's
PND
Shipment Never Sent
account number if applicable.
RATE
Incorrect Rates or Pieces
RRA
Rebill Recipient Include
From:
Recipient's Account No.
RSA
Rebill Sender
RTA
Rebill Third Party - Include
Third Party's Account No.
Name
Date
SUR
Incorrect Surcharge
Please Explain
(
)
(
)
OTHR
Other Please Explain
Business Phone
Business Fax
This form cannot be used to request Invoice Adjustments due to Service Failures or lack of a POD.
To request adjustments for Service Failures or lack of a POD, please call 1-800-622-1147,
visit our internet site at www.fedex.com or register for FIO.
FedEx
Federal Express
Please Indicate change in address for the account # listed below:
Physical Address
Billing Address
Mailing Address
Account Number: 1144-2081-6
Name:
Address:
Apt. Suite:
City:
State:
Zip:
Phone: (
)
Fax: (
}
Authorizing Signature:
EFTA00024628

=== Page 3 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
Page:
3 of 9
FedEx Express Shipment Summary by Payor Type
Original
Shipper
Number of Shipments
11
Transportation Charges
458.15
Base Discount
-49.45
Special Handling Charges
50.39
TOTAL
USD $
459.09
Number of Shipments
11
Total Charges
USD $
459.09
Third Party
Number of Shipments
1
Transportation Charges
144.50
Base Discount
-14.45
Special Handling Charges
5.85
TOTAL
USD $
135.90
Number of Shipments
1
Total Charges
USD $
135.90
TOTAL SHIPMENTS
12
TOTAL CHARGES
USD $
594.99
EFTA00024629

=== Page 4 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
Page:
4 of 9
Picked up: Oct 16, 2003
Payor: Shipper
Reference: NO REFERENCE INFORMATION
Fuel Surcharge - FedEx has applied a fuel surcharge of 4.50% to this shipment.
Distance Based Pricing. Zone 8
1st attempt Oct 17. 2003 at 12:44 PM.
Weather delay Thunderstorm.
Tracking ID 838295056769
Sender
Recipient
Service Type FedEx Standard Overnight
JEFFREY EPSTEIN
Package Type FedEx Envelope
JEFFREY E EPSTEIN
Zone
8
Packages
1
Weight
1.0 lbs, 0.5 kgs
Delivered
Oct 20, 2003 12:36
Transportation Charge
16.00
Svc Area
A2
Discount
-2.56
Signed by
Fuel Surcharge
0.60
FedEx Use
289210380/00266/
Residential Delivery
1.40
Total Charge
USD $
15.44
EFTA00024630

=== Page 5 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
Page:
5 of 9
EFTA00024631

=== Page 6 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
Page:
6 of 9
EFTA00024632

=== Page 7 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
Page:
7 of 9
EFTA00024633

=== Page 8 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
Page:
8 of 9
EFTA00024634

=== Page 9 ===
FedEx.
Invoice Number: 4-923-30001
Invoice Date:
Oct 27, 2003
Account Number:
Page:
9 of 9
FedEx Ground Reference Chart
SERVICE CODES
FEDEX HOME DELIVERY SERVICE CODES
ZONE DEFINITIONS
FedEx Ground
800
AutoPOD. Prepaid
0-1
Ground Service Intra-Canada
804
Prepaid
2-6
Ground Service 48 contiguous states and Intra-Canada
808
Signature, Prepaid
7-8
Ground Service 48 contiguous states
015
AutoPOD Prepaid, Domestic
810
Evening, AutoPOD, Prepaid
9
Service to Hawaii
016
COO. Prepaid, Domestic
814
Evening, Prepaid
10
Service to Puerto Rico
017
ECOD, Prepaid Domestic
818
Evening, Signature Prepaid
14
Service to Oahu
018
FedEx Ground PRP, Prepaid, Domestic
820
Date Certain, AutoPOD. Prepaid
17
Service to Alaska
019
Prepaid, Domestic
824
Date Certain, Prepaid
22
Service within Alaska
020
AutoPOO Collect, Domestic
828
Date Certain, Signature, Prepaid
23
Service from Alaska
021
Collect Domestic
830
Appointment AutoPOD, Prepaid
25
Service from Alaska
131
Ground 3rd Party, Returns Manager
834
Appointment Prepaid
51 Service to Canada
136
Ground Prepaid Net Return
836
Home Delivery, 3rd Party, Returns Manager
92 & Service from Hawaii (Deferred)
137
Ground Prepaid Returns Manager
842
Home Delivery, Prepaid, Returns Manager
408
Guaranteed Funds COD. Prepaid Domestic
850
Bill 3rd Party
409
Cash COD. Prepaid, Domestic
851
Bill 3rd Party, Auto POD
410
AutoPOD. COO, Prepaid Domestic
852
Bill 3rd Party, Signature
412
AutoPOD. ECOD, Prepaid, Domestic
853
Evening Bill 3rd Party
415
AutoPOD. Guaranteed Funds COD, Ppd. Dom.
854
Evening, Bill 3rd Party, AutoPOD
OTHER CHARGE CODE DEFINITIONS
416
AutoPOD. Cash COD. Prepaid, Domestic
855
Evening Bill 3rd Party, Signature
417
Bill 3rd Party, Domestic
856
Date Certain, Bill 3rd Party
418
Bill 3rd Party, AutoPOD Domestic
857
Date Certain, Bill 3rd Party, AutoPOO
419
Bill 3rd Party, COD. Domestic
(1)
C.O.D. (Collect on Delivery)
858
Date Certain, Bill 3rd Party, Signature
420
Bill 3rd Party, Guaranteed Funds COO, Dom
(2)
A.O.D. (Acknowledgement of Delivery)
859
Appointment Bill 3rd Party
421
Bill 3rd Party, Cash COD, Domestic
(3)
Cal Tag
860
Appointment Bill 3rd Party, AutoPOD
422
Bill Recipient, Domestic
(4)
Oversize > 84" Combined Length and Girth
869
Bill Recipient
423
(5)
Declared Value
Bill Recipient, AutoPOD Domestic
870
Bill Recipient, AutoPOD
429
ECOD, Bill 3rd Party, Domestic
(6)
Address Correction
871
Bill Recipient, Signature
AutoPOD, COO. Bill 3rd Party, Domestic
(7)
Hazardous Material
430
872
Evening, Bill Recipient
431
AutoPOD. ECOD, Bill 3rd Party, Domestic
(8)
Automatic Proof of Delivery
873
Evening, Bill Recipient, AutoPOD
432
AutoPOD. Cash COD. Bill 3rd Party, Domestic
(9)
Additional Handing
874
Evening, Bill Recipient, Signature
433
AutoPOD. Guaranteed Funds COD, Bill 3rd Party, Dom
(10)
Oversize Extra Service Fee
875
Date Certain, Bill Recipient
434
ECOD. Bill Recipient, Domestic
(11)
Overweight 150 bs
876
Date Certain Bill Recipient, AutoPOD
435
(12)
Electronic C.O.D. 24 hours
AutoPOD COO, Bill Recipient, Domestic
877
Date Certain, Bill Recipient, Signature
436
AutoPOD ECOD, Bill Recipient Domestic
(13)
Electronic C.O.D. 48 hours
878
Appointment, Bill Recipient
437
AutoPOO. Cash COD. Bill Recipient Domestic
(14)
FedEx Ground Residential
879
Appointment, Bill Recipient, AutoPOD
438
AutoPOD. Guaranteed Funds COD, Bill Recipient, Dom
(15)
FedEx Ground Residential Rural
439
Ground Prepaid, Guaranteed Funds, ECOD
(16)
Returns Manager Transmission Fee
(20)
FedEx Signature Home Delivery
(21)
FedEx Date Certain Home Delivery
FedEx International Ground
(22)
FedEx Appointment Home Delivery
(23)
FedEx Evening Home Delivery
(24)
FedEx Home Delivery Residential
022
AutoPOD, Prepaid
(25)
FedEx Home Delivery Residential Rural
023
COO, Prepaid
(26)
Cash C.O.D. Charge
026
Prepaid
(27)
Cash C.O.D. High Density Charge
027
AutoPOD. Collect
(28)
Cash C.O.D. Extra Difference Charge
028
Collect
(29)
Proof of Delivery Advantage Charge
135
International Ground 3rd Party, Returns Manager
(30)
FedEx Home Delivery Forced Appointment
478
Guaranteed Funds COD. Prepaid
(35)
Fuel Surcharge
479
Cash COD. Prepaid
(36)
Oversize > 108" Combined Length and Girth
480
AutoPOD. COO. Prepaid
(37)
Oversize > 108" in Length
485
AutoPOD. Guaranteed Funds COD, Prepaid
(38)
Oversize > 130" Combined Length and Girth
486
AutoPOO. Cash COD. Prepaid
(39)
Supplemental Oversize Package Charge
487
Bill 3rd Party
(40)
Canada Goods & Services Tax GST
488
Bill 3rd Party, AutoPOD
(41)
Canada Harmonized Sales Tax HST
489
Bill 3rd Party, COD
(42)
Canada Quebec Sales Tax QST
490
Bill 3rd Party, Guaranteed Funds COO
(44)
Net Return
491
Bill 3rd Party, Cash COD
(45)
Credit Card Decline Surcharge
492
Bill Recipient
(46)
Consolidated Returns Polybag
493
Bill Recipient, AutoPOD
(47)
Consolidated Returns Package 2x2x4 2x6x8
(48)
Consolidated Returns Package 4x4x6 4x8x12
(49)
Consolidated Returns Package 6x6x10 6x10x16
(50)
Consolidated Returns Package 8x10x12 10x12x16
(51)
Consolidated Returns Package Fill Charge
(52)
Consolidated Returns Oversize Package Charge
(53)
Returns Manager
(54)
Canadian Dropship Linehaul Charge
EFTA00024635


c1: EFTA00026604
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026604.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To
Subject: Accepted: Epstein Call
Date: Thu, 21 May 2020 13:35:11 +0000
Importance: Normal
Attachments: unnamed
EFTA00026604


c1: EFTA00027044
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00027044.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
Cc:
(USANYS)"
Subject:
Date: Fri, 16 Aug 2019 18:14:25 +0000
Shift:
Today - -- 8/16/19 - works until 8 pm or 10pm
OFF DAYS - Monday & Tuesday
WEEKEND = VARIED - 8/17 & 8/18
8 am - 12 am
Wednesday - - 12 pm - 8 pm
Phones:
Control room -
Cell - -
EFTA00027044


c1: EFTA00024297
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024297.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Epstein estate
Start Date: 2019-10-23 18:30:00 +0000
End Date: 2019-10-23 19:00:00 +0000
Organizer: Weinstein, Marc A.
Location: Skype Meeting; Conference ID: 803 102 52;
Class: X-PERSONAL
Date Created: 2019-10-23 13:15:32 +0000
Date Modified: 2019-10-23 13:15:32 +0000
Priority: 5
DTSTAMP: 2019-10-23 13:06:08 +0000
Attendee:
i
i
>; Tomback, Andrew
Alarm: Display the following message 15m before start
Reminder
Dial-In Information (for meetings with no presentations or video)
Dial-In Number:
Conference ID:
One touch dial-in from mobile phone (via cellular service)
Additional Dial-In Numbers
Brazil
Canada
China
France
Germany
India
Ireland
Israel
Japan
Singapore
United Kingdom
United States
EFTA00024297

=== Page 2 ===
Full list of dial-in numbers
Meetings with a presentation or video
Connect from computer or mobile device (via network/internet connection)
Help
Try Skype Web App if you are having trouble joining
Joining from a computer using the "Connect from computer or mobile device" link provides
additional capabilities, however you can simply call in from your telephone using the number
provided above if your meeting will not include video or a presentation. Click the "Help" link for
additional information if you are a guest joining a Skype for Business meeting from your
computer or mobile device for the first time.
For meeting organizers: Reset your dial-in PIN?
+12016300824
[!OC([CUSTOMINVITE]):)
EFTA00024298


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=== Page 1 ===
From: Jean James
To: geoffrey berman
Subject: JEFFREY EPSTEIN
Date: Wed, 07 Aug 2019 22:53:15 +0000
https://www.whatdotheyknow.com/request/emails_leaked_to_the_daily_mali
Emails leaked to the Daily Mail, relayed to
Parliament, Alleging Blackmail by Jeffrey
Epstein
Mark Taylor made this Freedom of Information request to House of Commons
2 followers
Currently waiting for a response from House of Commons, they should respond promptly and
normally no later than 5 September 2019 (details).
Mark Taylor 7 August 2019
Unknown
Dear House of Commons,
This may have to be directed to the Treasury Select Committee, or the information could be found in
the email archive of John Mann or Mark Garnier held by Parliament.
On 2nd Nov 2015, The Times reported that the Daily Mail had been leaked emails from Jeffrey Epstein
to Parliament or some connected source to blackmail Parliament into accepting Jes Staley as CEO for
Barclays. Subsequently in August 2019 it was reported by Bloomberg that Staley had visited Epstein in
prison and also on his island, travelling to the latter on Epstein's yacht.
URL for the Times article is here:
https://www.thetimes.co.uk/article/mps-e..
In the Daily Mail article John Mann MP and Mark Garnier MP were reported to have told the Daily Mail
that Staley ought to face a grilling session as a result of the threats Epstein was alleged to have made
to blackmail Parliament to accept his friend Staley as CEO of Barclays.
1. I would like a copy of any email disclosed to Parliament by the Daily Mail that forms the basis of
these allegations
2. The recipient list of the emails, and any other meta data in the original copies sent to Parliament or
the Treasury Select Committee or its members.
Yours faithfully,
EFTA00024009

=== Page 2 ===
Mark Anthony Taylor
EFTA00024010


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=== Page 1 ===
From:
Subject: FW: Voice Message Attached from
- US GOVT
Date: Thu, 26 Sep 2019 17:09:07 +0000
From:
Sent: Thursday, September 26, 2019 1:09:06 PM (UTC-05:00) Eastern Time (US & Canada)
To:
Subject: RE: Voice Message Attached from
- US GOVT
It is happening again.
Original Message
From
Sent: Thursday, September 26, 2019 1:06 PM
To:
Subject: FW: Voice Message Attached from
- US GOVT
From:
Sent: Thursday, September 26, 2019 1:06:23 PM (UTC-05:00) Eastern Time (US & Canada)
To:
Subject: RE: Voice Message Attached from
- US GOVT
H
I think I might be receiving this in error, along with the Epstein team.
Original Message
From:
Sent: Thursday, September 26, 2019 1:05 PM
To:
Subject: FW: Voice Message Attached fro
- US GOVT
EFTA00025228

=== Page 2 ===
From:
Sent: Thursday, September 26, 2019 1:05:18 PM (UTC-05:00) Eastern Time (US & Canada)
To:
Subject: RE: Voice Message Attached fro
- US GOVT
Are you free at 1:30pm for a call?
Original Message
From: postmaster@voip.usa.doj.gov <postmaster@voip.usa.doj.gov>
Sent: Thursday, September 26, 2019 11:50 AM
To:
Subject: Voice Message Attached from
- US GOVT
Time: Sep 26, 2019 11:50:27 AM
Click attachment to listen to Voice Message
EFTA00025229


c1: EFTA00026839
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026839.pdf
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c0:
=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Subject: letter
Date: Mon, 19 Apr 2021 22:58:06 +0000
Attachments: 2021-04-19_Gov't_response_to_April_19_Order.docx
Here's a really quick draft. It doesn't really strike the right tone, but I wanted to get something to you quickly, and am
hoping you can do some editing magic. Thanks, team.
Assistant United States Attorney
Southern District of New York
EFTA00026839


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=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
(USANYS)"
Cc:
)"
Subject: RE: Epstein search warrant documents
Date: Wed, 04 Mar 2020 21:35:41 +0000
Attachments: EpsteinLoadFilesProgress.xlsx
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
From:
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
is
(USANYS)
>;
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)
i
is
(USANYS)
Cc:
is
is
i
is
Subject: RE: Epstein search warrant documents
EFTA00023774

=== Page 2 ===
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
Sent: Monday, February 24, 2020 17:38
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
>;
i
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
>;
is
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
EFTA00023775

=== Page 3 ===
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
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:
Cc:
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.
EFTA00023776

=== Page 4 ===
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
EFTA00023777


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=== Page 1 ===
From:
)"
To: Paul Cassell
Cc: Stan Pottinger
Brad Edwards
"Brittany Henderson"
)"
)"
Subject: RE: Victims asserting right to reasonable protection and other rights
Date: Thu, 11 Jul 2019 01:16:47 +0000
Importance: Normal
Paul,
Thank you very much for being in touch, and I write to confirm receipt of your email and to acknowledge your
clients' right to be heard in connection with certain public proceedings in the district court, including proceedings
involving release, pursuant to the Crime Victims' Rights Act, specifically 18 U.S.C. 3771(a)(4).
We will convey to the Court your clients' concerns and views, including in particular with respect to their
interests in reasonable protection and fair treatment, and we very much appreciate you communicating with us
consistent with the rights of your clients.
thank you again,
Original Message
From: Paul Cassell
Sent: Wednesday, July 10, 2019 18:12
To:
)
Cc: Stan Pottinger
Brad Edwards
; Brittany Henderson
Subject: RE: Victims asserting right to reasonable protection and other rights
Hi
Along with Mr. Pottinger (admitted in the Southern District of New York) and Mr. Edwards (admitted in
Florida), I represent various victims of federal sex crimes committed by Jeffrey Epstein. It is my understanding
that you will be speaking to the court shortly about conditions of his release. My clients request that he be
detained, as otherwise they will be fearful for their safety. They believe that his continued detention is necessary
under the CVRA's right to "reasonable protection." They request that you communicate that concern to the judge
in whatever way you think best, as part of their CVRA right to be heard on a defendant's release.
My clients are also concerned that Epstein might try to create some sort of "private jail" to secure his release. My
clients believe that this would violate their CVRA right to be treated with fairness and to be free from harassment
and abuse. It is unfair to victims of a wealthy defendant, like Epstein, if he is given great freedoms than others
would in similar circumstances.
Thank you in advance for communicating these concerns to the judge. My clients very much appreciate your
efforts to bring Epstein to justice.
Paul Cassell for Jane Does
EFTA00026678

=== Page 2 ===
Paul G. Cassell
Ronald N. Boyce Presidential Professor of Criminal Law and University Distinguished Professor of Law S.J.
Quinney College of Law at the University of Utah
(phone)
(fax)
You can access my publications on
http://ssrn.com/author=30160
CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is
intended only for the use of the addressee. If you are not the intended recipient, you may not use, disseminate,
distribute or copy this communication. If you have received this message in error, please immediately notify the
sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State
Bar, but not the bars of other states. Any views he expresses in this email are his own.D
EFTA00026679


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=== Page 1 ===
Event: Accepted:
Start Date: 2019-11-04 21:00:00 +0000
End Date: 2019-11-04 21:30:00 +0000
Location: Epstein / Victim Fund Meet
Class: X-PERSONAL
Comment:
Date Created: 2019-11-04 16:36:38 +0000
Date Modified: 2019-11-04 16:36:38 +0000
Priority: 5
DTSTAMP: 2019-11-04 15:17:15 +0000
Attendee:
EFTA00023935


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=== Page 1 ===
From:
"
To:
Cc:
Subject: Scanning Project Index
Date: Mon, 21 Sep 2020 22:27:25 +0000
Attachments: Maxwell_Project_Inventory_List.xlsx
Hi,
sent over a preliminary index of the materials. I've attached it here.
Paralegal Specialist
U.S. Attorney's Office I SDNY
EFTA00023547


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=== Page 1 ===
From:
To:
)"
Subject: Epstein Relativity Questions
Date: Tue, 20 Apr 2021 20:27:05 +0000
Hi
I just had a quick question about how to mark a couple of these documents. For some reason USPV00341820-26 were
blank. I tried clicking image and extracted text and those didn't help. Also, for the documents USVP00341831-51, skipping
some here and there, they said "Browser does not support this multimedia format". I marked all of these "For further
review", is this how you want them marked or do you want me to change that to something else?
Thank you,
EFTA00025192


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: revised search warrant
Date: Sun, 11 Aug 2019 00:13:48 +0000
Attachments: Exhibit A.pdf; Exhibit B.pdf; Exhibit_C.pdf; Exhibit_D.pdf;
USVI_SW.v6_(highlighted).docx; USVI_SW.v6.docx
We talked about the agent's timing, so I wanted to let you know that the plane that will fly the agents down (48 agents in
total) will take off at 9 a.m. tomorrow. If it is at all possible to know from Judge Miller before then whether she is
prepared to sign the application, our team would be very grateful.
As we just discussed, I'm attaching a copy of the application that highlights the paragraphs that were revised. I've also
attached a slightly updated clean version of the draft, which fixes a small typo I saw (which is also fixed in the highlighted
version).
Thanks,
From:
Sent: Saturday, August 10, 2019 7:53 PM
To:
Cc:
Subject: revised search warrant
Thanks again for your help today, and for being flexible while we evaluated how to proceed today. Attached is the revised
application. The exhibits are the same as before, but I'm attaching them again just so you have the complete package. l'll
call you in a moment to discuss logistics.
Special Agent
is copied here. The FBI would greatly appreciate it if we could swear out the warrant first thing in the
morning, if at all possible
Thanks very much--
EFTA00024362


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=== Page 1 ===
From:
]"
To:
)"
Subject: RE: bank records
Date: Mon, 01 Jun 2020 18:08:04 +0000
Are we planning to leave just these FirstBank Puerto Rico records or are there other bank records that we want to leave?
From:
Sent: Monday, June 1, 2020 11:12 AM
To:
Subject: bank records
Hi
For the Epstein case, are you able to assist with getting a copy of some recent bank subpoena returns to our case agent,
? We were hoping to leave a copy for her downstairs at 1 Saint Andrews sometime this week. I'm not sure
who might be in the office to handle this, but if you could possibly coordinate that, it would be extremely helpful.
Thanks!
The returns are saved here:
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY investigation\Subpoena
Returns\ FirstBank Puerto Rico
Much appreciated-
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00026568


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=== Page 1 ===
From:
To:
Subject: RE: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
Date: Mon, 14 Sep 2020 20:07:55 +0000
Terrific, thanks so much.
From:
Sent: Monday, September 14, 2020 4:07 PM
To:
Subject: RE: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
Yep I got it. It's downloading now but will take a little while. It's about 11 GB.
From:
Sent: Monday, September 14, 2020 4:06 PM
To:
Subject: RE: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
Forwarded it. All good?
From:
Sent: Monday, September 14, 2020 3:51 PM
To:
Subject: RE: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
Will you forward the confirmation link once it comes in?
From:
Sent: Monday, September 14, 2020 3:33 PM
To:
Subject: FW: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
PBSA is giving us their entire Epstein file.
Will, when I get the email with the info about how to download the file, I'll forward it to you. Would you please download
everything and save it on the share? You can put it here
USvEpstein-
2018R01618\Investigation\PBSA Epstein File
Original Message
From:
Sent: Monday, September 14, 2020 3:23 PM
To:
Subject: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
The attached document is in regard to the above referenced case, to which you are a party of or have an interest in. If
you have any questions, please contact our office at
EFTA00023540


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Cc:
(USANYS)"
Subject: FW: U.S. V. Maxwell 20 Cr. 330 (AJN)
Date: Tue, 23 Feb 2021 20:06:44 +0000
Attachments: MAXWELL_BAIL_APPLICATION_with_EXHIBIT_2-23-17.pdf
FYI. Apparently they think third time's the charm.
From:
)
Sent: Tuesday, February 23, 2021 2:54 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
(USANYS)
Subject: FW: U.S. V. Maxwell 20 Cr. 330 (AJN)
FYI
From: BOBBI C STERNHEIM
Sent: Tuesday, February 23, 2021 2:44 PM
To:
)
is
)
is
(USANYS)
Cc: Christian Everdell
>; Laura Menninger
>; Jeff Pagliuca
Subject: U.S. V. Maxwell 20 Cr. 330 (AJN)
Good afternoon-
Attached is a courtesy copy of today's ECF filing.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
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.
EFTA00025195


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=== Page 1 ===
From:
)"
To: Joe Nascimento
Cc:
)"
)"
Subject: Re:
)
- Epstein
Date: Sat, 13 Jul 2019 16:52:10 +0000
Importance: Normal
Joe,
It was nice to meet you yesterday, and thanks very much for following up. We appreciate the clarification, and if
you have any specific concerns about this topic please let us know, we are happy to discuss, and we appreciate
keeping the lines of communication open.
I expect we will reach out later this week to set up a time for a call to discuss next steps, but of course please
reach out to us at any time if there's anything you'd like to discuss.
Thanks,
Sent from my iPhone
On Jul 13, 2019, at 12:39 PM, Joe Nascimento
wrote:
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
EFTA00026727

=== Page 2 ===
From:
)"
Date: Thursday, July 11, 2019 at 9:07 PM
To: Joe Nascimento
Cc:
)"
N
)"
Subject: RE:
)
- Epstein
Hi Joe,
We will be at the Hilton in West Palm Beach, at 600 Okeechobee Blvd. Please call me when you are here, and we will
meet you in the lobby.
Thanks,
From: Joe Nascimento
Sent: Thursday, July 11, 2019 9:02 PM
To:
Cc:
is
Subject: Re:
- Epstein
Good evening,
Have you set a location for our meeting tomorrow?
Thanks,
Joe
Sent from my iPhone
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,
EFTA00026728

=== Page 3 ===
Sent from my iPhone
On Jul 10, 2019, at 11:39 AM, Joe Nascimento
<mailto:
wrote:
Of course
Sent from my iPhone
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
<x-apple-data-detectors://2/0>2250 S.W. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors./2/0><x-
apple-data-detectors://2/0> Avenue<x-apple-data-detectors://2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
e.
<mailto:
www.crimlawfirm.com<http://www.crimlawfirm.com/>
On Jul 10, 2019, at 11:34 AM,
<mailto:
wrote:
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. 3<x-apple-data-detectors://2/0>rd<x-apple-data-detectors://2/0><x-
apple-data-detectors://2/0> Avenue<x-apple-data-detectors.//2/0>
<x-apple-data-detectors://2/0>Miami Florida 33129<x-apple-data-detectors://2/0>
t.
<tel:
f.
<tel:
EFTA00026729

=== Page 4 ===
e.
<mailto:
<mailto:
www.crimlawfirm.com http://www.crimlawfirm.com--http://www.crimlawfirm.com/
On Jul 9, 2019, at 4:56 PM,
<mailto:
<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. 3<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 4th Floor
2250 S.W. 3rd Avenue
EFTA00026730

=== Page 5 ===
Miami, FL 33129
p.
f.
e.
<mailto:
<mailto:
www.crimlawfirm.com http://www.crimlawfirm.com-http://www.crimlawfirm.com
From:
)"
<mailto:
<mailto:
Date: Sunday, July 7, 2019 at 10:19 PM
To: Joe Nascimento
<mailto:
<mailto:
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
Lawyer's Plaza I 4th Floor
EFTA00026731

=== Page 6 ===
2250 S.W. B<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 passing in
2018. Agent
served
with a grand jury subpoena earlier today, and as Alan's former
partner and FL Bar appointed inventory attorney, she has contacted me. Unfortunately, I am unable to meet
with her until Tuesday, but I would appreciate a few minutes of your time at your convenience as I am getting
up to speed. Please let me know what day/time is best for you.
Look forward to speaking with you.
EFTA00026732

=== Page 7 ===
Best,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza I 4th Floor
2250 S.W. 3<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/
EFTA00026733


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=== Page 1 ===
7/20/2021
FD-1087
31E-MM-108062 - 1B9
Evidence
31E-MM-108062 - 1B9
Item:
Evidence
General
Type:
Description:
(U//FOUO) One red rope containing: 1) BOOK AN INVITATION TO POETRY 2) VICTORIA'S SECRET WHITE
BRA AND PANTIES SET
Location:
E03707388 - ECR8
E616844 - ECR8, VS33
E5448596 - ECR8, VS33 A
Barcode:
E6516732
Details
Collected On: 04/30/2007 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: Missing
Legal Caveats
None
Chain of Custody
Shipping Log
History
Acquisition Event
Acquisition Event: (U//FOUO) Items migrated on 2007-04-30
Collected From:
(U//FOUO)
700 25TH STREET
WEST PALM BEACH, FL,
Receipt Given:
No
Holding Office:
MM MIAMI
Evidence Log:
Missing
Missing
https://sentinel.fbinet.fbi/lavender/#/Cases/2383628
1/1
EFTA00024861

=== Page 2 ===
FD-1004
FEDERAL BUREAU OF INVESTIGATION
Revised
9-25-2006
EVIDENCE CHAIN-OF-CUSTODY
Evidence Type:
.
General
Drug
Valuable
Firearms
CART
Special Handling Instructions
Initial Receipt
Date and
Time
Batteries
Biohazard
FGJ
Signature:
HAZMAT
Latents
Refrigerate
04/30/2007
Req. Charging
None
Printed Name: SA Jason R. Richards
Other
12:00 pm
Reason: Collected
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
02/08/2018
Signature:
02/08/2008
Printed Name: SA
10:00am
Printed Name
Reason:
TRANSPORT
Reason: Transport
1
10:00am
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature
02/08/2008
Signature: ged
Printed Name
Printed Name:
2/8/02
Reason: Relinguished Custody
3:30 pm
Reason:
STORAGE
3:30PM
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature: gol-
Signature:
Printed Name:
4-10-08
Printed Name
04/10/2008
Reason: RELEASED TO SA.
1100AM AM
Reason: Review
11:01am
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Signature:
Signature: IR
Time
01/13/2008
01-13-09
Printed Nam
Printed Name:
Reason: Retumdall10s
3:14pm
Reason: STORAGE.
314pm
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name:
06/14/19
Printed Name:
Reason:
Reason:
Firearms Certification:
Printed Name:
Signature:
Date:
Case ID: 316-MM-108062
1B:
9
Barcode: 54229236
E6516732
EFTA00024862

=== Page 3 ===
EVIDENCE CHAIN OF CUSTODY
Relinquished Custody Fedel#:4 78344676382
Date and
Accepted Custody
Date and
Time
Signature
6/17/19
Signature: CaD
Time
Printed N
FBI
9:35AM
Printed Name/Agency:
6/20/19
Reason: Transferred to NY
Reason:
3:00PM
Relinquished Custody M
Date and
Accepted Custody
Date and
Time
Time
Reason:
Printed Signature: Name/Agency: Co
6/29/19
Signature:
6/24/19
Printed Name/Agency
2:59
Reason: Evidence Review
2:10p
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature
9/26/19
Signature: all
Printed Name/Agency:-
TBI
9/26/19
Reason: To ECU
2:20p
Date and
Reason Accepted Printed Chips Name/Agercy Custody
220p
Relinquished Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody.
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
Relinquished Custody
Date and
Accepted Custody
Date and
Time
Time
Signature:
Signature:
Printed Name/Agency:
Printed Name/Agency:
Reason:
Reason:
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: 9
Barcode:
E6516732
This form is incomplete without reference to the FD-1087.
EFTA00024863


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c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024413.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: "Moyne, Parvin"
Cc: "Moyer, Thomas"
)"
)"
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Date: Wed, 21 Aug 2019 03:58:21 +0000
Parvin,
That makes good sense, thanks. Because of the scheduling issues I mentioned, we'd like to set it for a time in early
September, if we can - is there a time during the afternoon of September 5 or the morning of September 6 that would
work for you? We should be able to do either of those dates and times. Or if not, we can propose possible times the
following week.
thank you,
From: Moyne, Parvin
Sent: Tuesday, August 20, 2019 14:03
To:
)
is
)
>;
)
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Initially, we propose that the lawyers (myself, my colleagues at Akin Gump, and someone from DB Legal) deliver a
presentation that provides an overview of Epstein's relationship with the bank, the different accounts affiliated with
Epstein and the types of transactions found in the accounts. We would also highlight various transactions that we have
noted in our internal investigation. Our aim is that the attorney proffer would help you in sifting through the records we
have provided so you can more readily identify whatever information you are most interested in. Following the proffer, if
there are particular accounts or transactions of interest, we can identify the person within DB who can best answer
questions on those areas and that person would then meet with you.
In terms of timing, I estimate 2-3 hours for the attorney proffer. (I think closer to 2 hours but I hate to underestimate.)
Best,
Parvin
From:
Sent: Monday, August 19, 2019 8:14 PM
To: Moyne, Parvin
is
is
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
EFTA00024413

=== Page 2 ===
Parvin,
Could you please let us know what format we should expect in terms of the proffer? That will help us with figuring out
scheduling. I.e., do you expect to make an attorney proffer in the first instance, or should be expect to be meeting with
Deutsche Bank personnel, etc? And approximately how long should we be planning to block out?
thanks,
From: Moyne, Parvin
Sent: Monday, August 19, 2019 12:04
To:
is
)
V.
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
Hi
-
The proffer may be helpful in guiding you through the production. That said, we can be available whenever makes most
sense on your ends.
We have time this week (Thursday or Friday afternoon) and next week (Monday - Wednesday), and we have time in
September. If you give us a few options in terms of dates/times, we will sort out schedules on our ends.
Best
Parvin
From:
Sent: Saturday, August 17, 2019 1:59 PM
To: Moyne, Parvin
is
is
)
Cc: Moyer, Thomas
Subject: RE: 2019.8.15 - SDNY Production Index.xlsx
EXTERNAL Email
Parvin,
We received the index, thank you. In terms of a proffer, what generally did you have in mind regarding timing? I think
we'd like to have some time with the subpoena returns to get familiarized, and our team has a combination of travel and
trials in the next couple weeks, but we could do early September if that works on your end. Thoughts?
thanks,
From: Moyne, Parvin
Sent: Thursday, August 15, 2019 09:48
To:
is
)
is
EFTA00024414

=== Page 3 ===
Cc: Moyer, Thomas
Subject: 2019.8.15 - SDNY Production Index.xlsx
&
Please find attached an index to our productions to date. This is a work in progress - we will update it as we gather and
produce additional documents.
Would you like to touch base later today about scheduling a proffer? We are free after 4 p.m.
Best,
Parvin
Parvin Daphne Moyne
AKIN GUMP STRAUSS HAUER & FELD LLP
New York, NY 10036-6745
USA
Direct: +1
I
Internal:
Fax: +1
akingump.com
Bio
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
EFTA00024415


c1: EFTA00025253
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025253.pdf
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c7: images
c0:
=== Page 1 ===
Subject: RE: Final Voucher 10810414(1) prepared by a travel arranger is pending your review
Date: Wed, 20 Nov 2019 17:40:03 +0000
Hi Darlene, Please advise the AUSA re: if the hotel will refund the tax. Thanks
Subject: RE: Final Voucher 10810414(1) prepared by a travel arranger is pending your review
Unfortunately this is still incorrect. First, it has the nightly lodging costs listed as $248 when in fact it was $247 - see the
invoice, which is attached again. (Or please let me know if I'm supposed to be reimbursed for the maximum daily
allowance rather than the actual cost.) Also it still does not include the tax.
Please let me know when it is corrected and I will review it again.
From
Sent: Wednesday November 20 2019 10:06
Subject: Final voucher 10810414(1) prepared by a travel arranger IS pending your review
Dea
Final voucher 10810414(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 10810414
Voucher ID: 1
Voucher type: Final
Traveler name
Purpose: R20NYS13179 - U.S. V. Epstein - Witness Interview
Destination: Santa Monica, CA, United States
Dates: 2019-11-13 - 2019-11-15
Current status: Pending Voucher Approval
Voucher total expenses: 1517.64
Estimated trip cost: 1583.95
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
EFTA00025253

=== Page 2 ===
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.
EFTA00025254


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00026842.pdf
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c0:
=== Page 1 ===
From:
)"
To:
)"
)"
Subject: RE: https://www.nbcnewyork.com/news/local/epstein-accuser-appeals-to-prince-andrew-to-talk-to-
fbi/2279339/
Date: Wed, 05 Feb 2020 18:19:31 +0000
Thanks
From:
Sent: Wednesday, February 5, 2020 1:18 PM
To:
is
V.
;
Subject: https://www.nbcnewyork.com/news/local/epstein-accuser-appeals-to-prince-andrew-to-talk-to-fbi/227939/
Just in case you haven't seen this by now...
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I
Mobile:
I
Press Office:
EFTA00026842


c1: EFTA00025282
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00025282.pdf
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c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: [EXTERNAL] Re: Ghislaine Maxwell 02879-509
Date: Sun, 10 Oct 2021 23:45:00 +0000
Thanks for letting us know. And sorry you have to receive these emails. I think this is certainly better handled by
the court than us as we have no control over theses issues. Since
was copied I'm sure she is
handling up her chain. Does anyone have any other thoughts? Happy to discuss if you'd like.
Sent from my iPhone
On Oct 10, 2021, at 7:17 PM,
(USANYS)
wrote:
Chiefs, FYI.
From: BOBBI C STERNHEIM
Sent: Sunday, October 10, 2021 7:03 PM
To:
Cc:
>; Christian Everdell
is
Subject: [EXTERNAL] Re: Ghislaine Maxwell 02879-509
Good evening-
You failed to provide any update concerning the whereabouts of Ms. Maxwell's legal mail that I had placed in the legal
mailbox on 10/2.
However, on Friday afternoon, I was informed by Ms. Maxwell and Unit Manager
that the envelope had
been located and affixed to it
was a bar-code type sticker, not generated by the MDC, but of the type issued by the U.S. Post Office.
I had placed the envelope in the legal mailbox. It did not have postage. If, for some questionable reason, it had been
handled by the U.S. Postal Service
(which is highly unlikely and, if so, deliberately caused by the MDC), the Post Office would have returned it to my office
address (at the return address on the envelope),
not deliver it to the MDC without postage.
This suggests some type of foul play on the part of the MDC, or at least some type of cover-up.
I am informed that the Warden is aware of this. Today, I received the envelope from Unit Manager
Today, Christian Everdell, Esq. and I had a scheduled legal visit with Ms. Maxwell.
Rather than permitting us to use a somewhat larger room, we were required to use a room for two.
This completely defeated the purpose of COVID protective measures. The plastic partition did not shield
Mr. Everdell and there was little or no table surface for him to use. The room was unnecessarily cramped
when a larger room was available. My request to use a larger room was denied. The officer claimed the team could not
position the camera
to focus on the larger room. This response was bogus. I requested to see the Warden, but that request was never
honored.
EFTA00025282

=== Page 2 ===
Further, defense counsel at large have heard about the current electricity issues affecting water, toilet flushing, and
meals.
Ms. Maxwell received a bologna sandwich despite being on no-flesh (vegetarian) diet.
This is yet another blunder on the part of the MDC which needs to be immediately corrected.
I will not waste my energy requesting a response because even if forthcoming it will likely be insufficient.
These matters will be brought to the Court's attention, so you can start preparing excuses for consideration by Judge
Nathan.
Enjoy your holiday.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be
confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
On Oct 7, 2021, at 7:45 AM, BOBBI C STERNHEIM
wrote:
Good morning-
If by 9:30 this morning (10/7) Ms. Maxwell does not receive the legal mail deposited in the MDC legal mailbox on
Saturday (10/2), an order to show cause will be filed with the Court.
I urge you to respond and comply immediately.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
EFTA00025283

=== Page 3 ===
On Oct 6, 2021, at 7:00 PM, BOBBI C STERNHEIM
wrote:
Good afternoon-
Ms. Maxwell still has not received the legal mail (a properly addressed manila envelope)
that I deposited in the East Building legal mailbox on Saturday 10/2 shortly after 3 pm
while I was escorted to the lobby by a male guard.
Please contact me immediately.
Thank you-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may
be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete
this message. Thank you.
On Oct 6, 2021, at 4:53 AM,
wrote:
I will follow up with the appropriate departments.
BOBBI C STERNHEIM
10/5/2021 7:12 PM
Good evening-
As of this writing, Ms. Maxwell has not received legal mail which I
personally placed in the
East Building legal mailbox on Saturday, October 2. On that same day,
in that same mailbox,
I deposited legal mail for a client housed in the west building. That
client confirmed that he received his legal mail.
Ms. Maxwell has not.
Please explain why delivery of Ms. Maxwell's mail has been delayed.
Time is of the essence. Her trial begins on November 29th.
EFTA00025284

=== Page 4 ===
Every delay caused by the MDC interferes with her ability to prepare
for trial.
Your prompt response is requested.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
This message and any attached documents contain information from the
Law Offices of Bobbi C. Sternheim that may be confidential and/or
privileged.
If you are not the intended recipient, you may not read, copy,
distribute, or use this information.
If you have received this transmission in error, please notify the
sender immediately by reply e-mail and then delete this message. Thank
you.
EFTA00025285


c1: EFTA00024365
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0005/EFTA00024365.pdf
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c0:
=== Page 1 ===
From:
To:
Subject: Part 2
Date: Mon, 12 Aug 2019 11:43:51 +0000
Attachments: attachment_1.pdf; Count_Slips_for_8-10-19.pdf; Psychology Notes_7-9-19.pdf;
Additional_Psychology_Notes.pdf; Psychology_Notes_7-8-19.pdf;
PHOTOGRAPHS_OF_EPSTEIN_8-10-2019.pdf
Embedded: Fwd:_Staff_Assignments.msg; 18_U.S.C._1519_Elements.msg
Assistant United States Attorney
Southern District of New York
EFTA00024365


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c3: VOL00008
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=== Page 1 ===
PROFFER AGREEMENT
With respect to the meeting of
("Client") and her attorney, Joseph
Nascimento, Esq., with Assistant United States Attorneys
and
to be
held on July 12, 2019 ("the meeting"), the following understandings exist:
(1) THIS IS NOT A COOPERATION AGREEMENT. The Client has agreed to
provide the Government with information, and to respond to questions, so that the Government
may evaluate Client's information and responses in making prosecutive decisions. By receiving
Client's proffer, the Government does not agree to make a motion on the Client's behalf or to enter
into a cooperation agreement, plea agreement, immunity or non-prosecution agreement. The
Government makes no representation about the likelihood that any such agreement will be reached
in connection with this proffer.
(2) In any prosecution brought against Client by this Office, except as provided below the
Government will not offer in evidence on its case-in-chief, or in connection with any sentencing
proceeding for the purpose of determining an appropriate sentence, any statements made by Client
at the meeting, except (a) in a prosecution for false statements, obstruction of justice or perjury
with respect to any acts committed or statements made during or after the meeting or testimony
given after the meeting; or (b) if, at any time following the meeting, Client becomes a fugitive
from justice.
(3) Notwithstanding item (2) above: (a) the Government may use information derived
directly or indirectly from the meeting for the purpose of obtaining leads to other evidence, which
evidence may be used in any prosecution of Client by the Government; (b) in any prosecution
brought against Client, the Government may use statements made by Client at the meeting and all
evidence obtained directly or indirectly therefrom for the purpose of cross-examination should
Client testify; and (c) the Government may also use statements made by Client at the meeting to
rebut any evidence or arguments offered by or on behalf of Client (including arguments made or
issues raised sua sponte by the District Court) at any stage of the criminal prosecution (including
bail, all phases of trial, and sentencing) in any prosecution brought against Client.
(4) The Client understands and agrees that in the event the Client seeks to qualify for a
reduction in sentence under Title 18, United States Code, Section 3553(f), United States
Sentencing Guidelines, Sections 2D1.1(b)(18) or 5C1.2, or Fed. R. Crim. P. 35(b), the Office may
offer or use at any stage of the criminal proceeding any statement made by Client during the
meeting, and all evidence obtained directly or indirectly therefrom, to the extent such use is
consistent with Section 402 of the First Step Act of 2018.
(5) To the extent that the Government is entitled under this Agreement to offer in evidence
any statements made by Client or leads obtained therefrom, Client shall assert no claim under the
United States Constitution, any statute, Rule 410 of the Federal Rules of Evidence, or any other
federal rule that such statements or any leads therefrom should be suppressed. It is the intent of
this Agreement to waive all rights in the foregoing respects.
01.14.2019
EFTA00024704

=== Page 2 ===
(6) If this Office receives a request from another prosecutor's office for access to
information obtained pursuant to this Proffer Agreement, this Office may furnish such information
but will do so only on the condition that the requesting office honor the provisions of this
Agreement.
(7) It is further understood that this Agreement is limited to the statements made by Client
at the meeting and does not apply to any oral, written or recorded statements made by Client at
any other time. No understandings, promises, agreements and/or conditions have been entered
into with respect to the meeting other than those set forth in this Agreement and none will be
entered into unless in writing and signed by all parties.
(8) The understandings set forth in paragraphs 1 through 7 above extend to the continuation
of this meeting on the dates that appear below.
(9) Client and Attorney acknowledge that they have fully discussed and understand every
paragraph and clause in this Agreement and the consequences thereof.
Dated: West Palm Beach, Florida
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
by:
Client
Assistant United States Attorney
MA Attorney for Client
Dates of Continuation
Initials of counsel, Client, AUSA, witness
9/10/19
01.14.2019
EFTA00024705


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=== Page 1 ===
From: BOBBI C STERNHEIM <bcsternheim@mac.com>
To:
Cc: Christian Everdell <CEverdell@CohenGresser.com>, Laura Menninger
<lmenninger@hmflaw.com>, Jeff Pagliuca <jpagliuca@hmflaw.com>
Subject: [EXTERNAL] Re: US V. Maxwell S2 20 Cr 330 (AJN)
Date: Wed, 27 Oct 2021 14:18:11 +0000
Attachments: 10-27_ltr_to_Court.pdf; ATT00001.htm
Courtesy copy of today's ECF filing.
EFTA00025144


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=== Page 1 ===
From:
(NY) (FBI)"
To:
(USANYS)"
N
,
(USANYS)"
,
(USANYS)"
(USANYS) [Contractor]"
Subject:
Date: Thu, 23 Jul 2020 16:26:21 +0000
Attachments: Part_4.zip
Special Agent
FBI New York Field Office
Violent Crimes Task Force
EFTA00025401


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=== Page 1 ===
From:
)"
To:
)"
Cc:
(
)"
Subject: Re: [EXTERNAL] information
Date: Tue, 26 Oct 2021 14:22:56 +0000
Will do, thank you.
On Oct 26, 2021, at 10:15 AM,
)
wrote:
Hi
I think for now please just pass along any request that comes in to me. I've let BOP know about this, and can pass along
any request to our contacts there.
Thanks,
From:
Sent: Monday, October 25, 2021 9:14 PM
To:
Cc:
Subject: Re: [EXTERNAL] information
Thanks,
!
I'll figure out where it should go and let you know.
Sent from my iPhone
On Oct 25, 2021, at 8:36 PM,
wrote:
FYI- we discussed this over the summer but I guess he never submitted the request. I know you're no longer on the
case but let me know who I should forward this to in the event I receive a copy of his request. Copying
for his
awareness.
Begin forwarded message:
From:
II
Date: October 25, 2021 at 8:33:40 PM EDT
To:
Cc:
i
)"
Subject: Re: [EXTERNAL] information
Hi Mr.
EFTA00025060

=== Page 2 ===
As I discussed with Ms.
over the summer, you would need to submit a FOIA request to the BOP and note
that you are specifically requesting what they released to the NYT. You can send me copy of that request once it has
been submitted to the BOP and as a courtesy I will ensure that the correct recipient in the Civil Division of our Office
has received it. We do not handle FOIA requests in our division.
Best,
On Oct 25, 2021, at 12:40 PM,
wrote:
Hi,
Hope this finds you well.
I would like to get a copy of ALL of the records that were released to the New York Times on their FOI request
regarding my brother's case (Jeffrey Epstein).
Please advise the quickest way to accomplish this.
Thanks,
Scanned by McAfee and confirmed virus-free.
EFTA00025061


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=== Page 1 ===
Event: Accepted: Epstein Call
Start Date: 2020-05-22 17:00:00 +0000
End Date: 2020-05-22 18:00:00 +0000
Location: 877-720-9282 - 8146826
Class: X-PERSONAL
Comment:
Date Created: 2020-05-21 13:52:01 +0000
Date Modified: 2020-05-21 13:52:01 +0000
Priority: 5
DTSTAMP: 2020-05-21 13:34:35 +0000
Attendee
EFTA00026603


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=== Page 1 ===
Event: Accepted: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to
Start Date: 2019-11-07 18:00:00 +0000
End Date: 2019-11-07 18:30:00 +0000
Location: 866-384-6555 / Code: 1212-294-6734#
Class: X-PERSONAL
Comment:
Date Created: 2019-11-07 09:46:32 +0000
Date Modified: 2019-11-07 09:46:32 +0000
Priority: 5
DTSTAMP: 2019-11-06 18:13:32 +0000
Attendee: Hudgens, Johanna Rae
EFTA00025377


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=== Page 1 ===
From
To
Co
Subject: RE: Joint letter
Date: Fri, 21 May 2021 22:51:45 +0000
Attachments: 2021-05-21_Joint_letter_re_proposed_GM_pretrial_schedule_sent_to_defense.docx
Thanks for sending. Attached is our section added at the end. I did add a heading to make clear where the "Government
Position" starts.
If you want to make any changes to your section as a result of what we wrote, just shoot me a copy before you file so I can
see if that changes any of our positions.
Thanks,
From:
Sent: Fridav. May 21. 2021 2:54 PM
To
Cc
Subject: RE: Joint letter
Hi
Attached is the draft of the joint letter.
Best,
From
Sent: Friday, May 21, 2021 3:18 PM
To:
Cc:
Subject: Joint letter
H
Checking in to see if you guys have your scheduling position statement ready for the joint letter. If you do, can you please
shoot it to us, and we can insert our segment to return to you. You can then let us know if you change anything for us to
review before we agree to sign off on filing.
EFTA00025138

=== Page 2 ===
Thanks so much.
EFTA00025139


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=== Page 1 ===
From:
"
(USANYS)"
To: "Berman, Geoffrey (USANYS)"
Subject: Barr confirms DOJ wants Prince Andrew to 'provide some evidence' in Epstein investigation
Date: Mon, 08 Jun 2020 20:23:47 +0000
https://www.foxnews.com/politics/barr-confirms-doj-wants-prince-andrew-to-provide-some-evidence-in-epstein-
investigation
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New
EFTA00023773


c1: EFTA00038771
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c3: VOL00008
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=== Page 1 ===
Re: Video Interview
From:
To:
Date:
Fri, 05 Feb 2021 15:31:37 -0500
Great,
I'm glad you were able to connect.
Safe travels!
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
Sent: Friday, February 5, 2021 3:23 PM
To:
Subject: Re: Video Interview
Thanks
- I'm traveling today (that's why I was trying to do yesterday). I asked him ifvwe
could talk Monday. Thanks!
From:
Sent: Friday, February 5, 2021 11:25:06 AM
To:
Subject: Re: Video Interview
Hi
,
I'm writing to inform you that attorney Don Duboulay is currently trying to reach out to you in
order to start the process of court appointment. He is looking to do that today if possible.
Please call him at
-
His email address is dondubesq@aol.com.
Thank you,
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
Sent: Monday, February 1, 2021 9:11 AM
To:
Subject: Re: Video Interview
Yes and I Rsvp'd. Hopefully the snow won't knock out our power here
EFTA00038771

=== Page 2 ===
From:
Sent: Sunday, January 31, 2021 3:52:22 PM
To:
Subject: Re: Video Interview
Hey
I'm just double checking to see that you received the invitation for tomorrow's 3:30 interview.
Please let me know thanks,
On Jan 28, 2021, at 10:37,
wrote:
That makes it easy! Anytime tomorrow or Monday, but just Thursday morning. I'll look
for the invitation. Thanks
From:
Sent: Thursday, January 28, 2021 10:32:40 AM
To:
Subject: Re: Video Interview
Hi
Glad things have calmed down a bit for you.
In general I think it's best for everyone to do this over video conference. It's the fastest and
safest way for us to connect in these times.
You will not require any special technology or apps to connect. If you have a smart phone or any
computer with a camera/ webcam that will work. We will send you a secure email link which will
open right up in your web browser. There is an option to download an app on your phone but it's
not necessary.
I will check with the rest of the team on connecting with you either tomorrow, Monday or
Thursday. Mornings work best for you? How's 10 am work on any of those days?
On Jan 28, 2021, at 10:01,
wrote:
Good morning
,
Things have calmed down a bit here and I have time to get back to you.
A couple of questions:
The email says we can have a video conference for a few hours. What type of
video/computer capability would I need?
Would you rather I speak with Grand Jury in NYC? Do to Covid, I'd rather not come
up.
EFTA00038772

=== Page 3 ===
Can I meet with the FBI in DC instead?
And, if it's possible to do a zoom meeting, I'll be at my computer tomorrow, Monday
and Thursday morning. Please let me know ASAP as I have to arrange my
schedule.
Thanks,
From:
Sent: Tuesday, January 19, 2021 3:33:25 PM
To:
Cc:
Subject: Re: Video Interview
Hi
Again I'm sorry to hear about your family issues. We also totally understand the need to
want to do this interview in the safest possible way.
Unfortunately you still remain an important witness to this investigation and it is becoming
time sensitive. That being said we are issuing you the attached Grand Jury Subpoena to
speak with us. In lieu of appearing in a Grand Jury in New York on the listed time and date
we are still ok with you blocking off a few hours to speak with us over video conference
sometime in near future.
Please see attached to the subpoena your Advice of Rights.
Thanks again,
EFTA00038773


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=== Page 1 ===
From:
Subject: Fwd: FW: FBI Victim Services Briefing
Date: Tue, 08 Oct 2019 18:51:57 +0000
Importance: Normal
Attachments: DM_Signed_Form.pdf; MW_Signed_Form.pdf
Inline-Images: image001.png
See below should we allow this?
-
Forwarded message
From: Diane Aldrich <daldrich@amglaw.com>
Date: Oct 8, 2019 2:49 PM
Subject: FW: FBI Victim Services Briefing
To: VictimServices <victimservices@fbi.gov>
Cc:
Hello, all -
Enclosed are questionnaires for
co-counsel to Gloria and our related
Epstein clients.
They are both based in New York, and one of them will attend the meeting on October 23rd but aren't sure
which one yet.
Many thanks,
Diane
ALLRED MAROKO GOLDBERG
JUSTICE I INTEGRITY REPUTATION
Diane Aldrich
Executive Assistant to Gloria Allred
6300 Wilshire Boulevard, Suite 1500
Los Angeles, CA 90048
(323) 653-6530
(323) 653-1660, Facsimile
www.amglaw.com
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT 323-653-6530. Thank you.
EFTA00038310


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=== Page 1 ===
Re: Interview
From:
To:
Cc:
Date:
Mon, 11 Jan 2021 17:06:59 -0500
I'm sorry about the back and forth with this but unfortunately some of the members of our
team are not going to be able to make it on tonight's call. Are you available at all tomorrow
afternoon?
Again I'm sorry about having to cancel tonight.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
Sent: Monday, January 11, 2021 3:39 PM
To:
Cc:
Subject: Re: Interview
Cool
Sent from my iPad
On 11 Jan 2021, at 15:38,
wrote:
Ok sounds good,
I will have a calendar sent out with instructions for 5:30.
Thanks,
On Jan 11, 2021, at 15:33,
wrote:
Hi
There is no need for
to attend.
I am good for 5.30 today.
Yours
Sent from my iPad
EFTA00038814

=== Page 2 ===
On 11 Jan 2021, at 10:43,
wrote:
Good morning
I apologize for the delayed response on this. By all means your attorney is welcome on
this call. In fact if this your preference we will reschedule until he is available to be a
part of it. We can do a call today anytime from 3PM on into the evening if that works for
him. Also most anytime tomorrow works for us. If you or he has any questions feel free
to have him call me directly by cell.
On Jan 10, 2021, at 14:49,
wrote:
Hi
I am now in your fair city. I can do the 5.30pm tomorrow as
Lancaster wont
be on the call.
I should mention that
has been a friend of mine and the
family for 25 years. She said that if either you or
needed a character
reference on me, she would be happy to give one. I spoke to her in LA just now.
Have a great rest of the weekend.
Regards
Sent from my iPad
On 7 Jan 2021, at 17:08,
wrote:
Hello
I've spoken with the team they are going to available on Monday
afternoon at 5:30 for a meeting with you. I know you had mentioned
being in New York that day and meeting with us in person but as of
now it will work best for our team to conduct a virtual interview. If you
are comfortable with that we can schedule you for 5:30 PM on
Monday 1/11. You would receive email instructions on how to log into
the secure video line from either your cell phone of computer.
Please let me know and thanks again,
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
EFTA00038815


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=== Page 1 ===
PRIVILEGED AND CONFIDENTIAL
EDWARDS POTTINGER EPSTEIN CLIENTS
#
Claimant First
Claimant Last
Name
Name
EFTA00038299

=== Page 2 ===
2 I Page
EFTA00038300


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=== Page 1 ===
From:
To:
Subject: Re: Masseuse List, black book, flight logs
Date: Wed, 19 Feb 2025 00:04:32 +0000
Importance: Normal
Thank you, this is extremely helpful!
From:
Sent: Tuesday, February 18, 2025 6:19:50 PM
To:
Subject: Masseuse List, black book, flight logs
The attached item titled "Masseuses" was going to initially be a trial exhibit but was not used at the Maxwell
trial. It was located on one of Epstein's digital devices seized from his Manhattan residence. The names listed are
believed to be women and girls, some of which were identified minors, who were contacted by Epstein,
Maxwell, and his staff to massage Epstein.
Separately, the black book was seized by Miami -Palm Beach during the course of their 72 investigation. It is an
address book that included identified minors under "massage". Sections of this book were a trial exhibit.
The flight logs were kept and provided by Epstein's pilot
This was a trial exhibit.
At trial, the black book and the flight logs had minor victims redacted from the public.
Let me know if you have any questions or need anything further.
Special Agent
FBI Baltimore/Delaware
Violent Crime Safe Streets Task Force
EFTA00038629


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=== Page 1 ===
Event: [EXTERNAL EMAIL] - Maxwell Juror Questionnaire Administration
Start Date: 2021-11-12 05:00:00 +0000
End Date: 2021-11-13 05:00:00 +0000
Organizer:
Location: 40 Foley Courthouse
Class: X-PERSONAL
Date Created: 2021-08-27 23:05:59 +0000
Date Modified: 2021-08-27 23:05:59 +0000
Priority: 5
DTSTAMP: 2021-08-27 23:03:49 +0000
Attendee:
Alarm: Display the following message 18h before start
Reminder
EFTA00038684


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=== Page 1 ===
Event: [EXTERNAL EMAIL] - Call w/ SDNY re: discovery, Epstein investigation
Start Date: 2020-10-23 15:00:00 +0000
End Date: 2020-10-23 15:30:00 +0000
Organize
Location
Class: X-PERSONAL
Date Created: 2020-10-22 16:37:24 +0000
Date Modified: 2020-10-22 23:35:24 +0000
Priority: 5
DTSTAMP: 2020-10-22 16:34:21 +0000
Alarm: Display the following message 15m before start
Reminder
EFTA00038234


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=== Page 1 ===
From:
"
To:
Cc:
"
Subject: [EXTERNAL EMAIL] - scheduling info
Date: Wed, 20 Oct 2021 18:26:14 +0000
Importance: Normal
Attachments: 2021.10.19_Order_re_October_21_Teleconference.pdf
Hi
Attached is the scheduling order with dial-in information for tomorrow's court conference, in case you want to call in. It's
a telephone conference - we're not appearing in court. Our final pretrial conference is on November 1st at 11 a.m., in
person.
EFTA00038937


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: [EXTERNAL EMAIL] - Epstein again
Date: Mon, 05 Oct 2020 14:05:09 +0000
Importance: Normal
Good morning
My name is
I recently transferred from NY to Boston. In NY I was on CD-10, and spoke with
on one occasion. He sent me this email Saturday. I didn't want to cold call you, but I'm available pretty much all day
today if you'd like to speak about him.
My desk
Cell is
,
but I'm in the scif, so desk is best.
Thanks,
Special Agent
FBI - Boston
From:
Sent: Saturday, October 3, 2020 9:24 PM
To:
Subject: [EXTERNAL EMAIL] - Epstein again
Yesterday Capucci reposted the Epstein interview I did from May:
In May, Prof Alan Dershowitz told me that he was calling on Harvard to further investigate him, so that he would be
exonerated completely of any wrongdoing in connection with Epstein. In a follow-up to the letter to President Bacow at
Harvard, I asked his office recently whether they have any status update on that investigation Prof Dershowitz mentioned
to me. It's a good question.
You may have seen that Scott Bergerson (Ghislaine Maxwell's reputed husband) resigned from his tech startup. That leads
me to believe the Maxwell deposition is likely to be unsealed. It will be interesting to see what's in there--among other
things, perhaps more insight into the activities of various faculty members and administrators at MIT and Harvard. We'll
see.
If you wouldn't mind, do tell any of your colleagues who may be interested in the interview about it.
EFTA00038124

=== Page 2 ===
Thanks,
Old Member, Christ Church, Oxford
In the Spirit (John Hunt Publishing, in preparation)
Before God: Exercises in Subjectivity (Rowman & Littlefield, 2020)
Phenomenology in France (Routledge, 2019)
3:16 Interview with
"Being Oneself: Husserl and Henry on Self-Consciousness" in Sabah Ülkesi
EFTA00038125


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=== Page 1 ===
From:
To:
Subject: [EXTERNAL EMAIL] - Maxwell Juror Questionnaire Administration
Date: Fri, 27 Aug 2021 23:03:51 +0000
Importance: Normal
Attachments: unnamed
EFTA00038683


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=== Page 1 ===
Case 1:17-cv-03956-PGG Document 64 Filed 06/25/24 Page 1 of 20
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
RADAR ONLINE LLC and JAMES
ROBERTSON,
Plaintiffs,
ORDER
- against -
17 Civ. 3956 (PGG)
FEDERAL BUREAU OF
INVESTIGATION,
Defendant.
PAUL G. GARDEPHE, U.S.D.J.:
Plaintiffs Radar Online LLC and James Robertson bring this action under the
Freedom of Information Act ("FOIA"), seeking records related to the FBI's investigation and
prosecution of financier Jeffrey Epstein for child sex trafficking crimes. (See Am. Cmplt. (Dkt.
No. 12)) Plaintiff Radar Online is an online investigative news outlet and Plaintiff Robertson is
one of its senior editors. (Id. 11 2-3)
Plaintiffs submitted their FOIA request to the Federal Bureau of Investigation
("FBI") on April 20, 2017. (Id.1 10) Plaintiffs received no response, and filed this action on
May 25, 2017. (Cmplt. (Dkt. No. 1)) The Amended Complaint was filed on August 28, 2017.
(Am. Cmplt. (Dkt. No. 12)) After an initial case management conference on September 7, 2017,
the FBI agreed to begin producing documents at a rate of 500 pages per month. The FBI has
now processed 11,571 responsive pages, most of which were redacted in part or withheld in full
based on certain exemptions to disclosure under FOIA. (Second Seidel Decl. (Dkt. No. 58) (3)
In July 2019, Jeffrey Epstein was arrested and charged with new Federal offenses,
at which point the FBI asserted Exemption 7(A) to FOIA - the exemption for "records or
information compiled for law enforcement purposes[,] [the disclosure of which] could
EFTA00038652

=== Page 2 ===
Case 1:17-cv-03956-PGG Document 64 Filed 06/25/24 Page 2 of 20
reasonably be expected to interfere with enforcement proceedings" 5 U.S.C. § 552(b)(7)(A) - -
over pages that were previously processed and withheld and over all "remaining responsive
records." (Id. 1 7)
On December 10, 2020, this Court directed the parties to file cross-motions for
summary judgment. (Dkt. No. 26) In a September 19, 2023 order (the "Summary Judgment
Order"), this Court granted in part and denied in part each side's cross-motion. (Summary
Judgment Order (Dkt. No. 51)) In its Order, this Court directed the parties to file a joint letter
addressing next steps, including a proposed schedule for the FBI's revised declarations and any
renewed motions for summary judgment. (Id. at 54) 1 On October 3, 2023, this Court set a
briefing schedule for the parties' renewed cross-motions for summary judgment. (Dkt. No. 53)
For the reasons stated below, the FBI's motion for summary judgment will be
granted, and Plaintiffs' motion for summary judgment will be denied.
BACKGROUND²
I.
FACTS
In support of its renewed summary judgment motion, the FBI submitted a revised
declaration from Maureen Comey, an Assistant United States Attorney ("AUSA") in the United
States Attorney's Office for the Southern District of New York. (Third Comey Decl. (Dkt. No.
59) "I 1), and a revised declaration from Michael G. Seidel, the Section Chief of the
Record/Information Dissemination Section ("RIDS") of the FBI's Information Management
Division ("IMD"). (Second Seidel Decl. (Dkt. No. 58) 1 1)
1 The page numbers referenced in this opinion correspond to the page numbers designated by
this District's Electronic Case Files ("ECF") system.
2 The relevant facts and procedural history are set forth in greater detail in the Summary
Judgment Order and are only summarized below. (Summary Judgment Order (Dkt. No. 51))
Familiarity with the Summary Judgment Order is assumed.
2
EFTA00038653

=== Page 3 ===
Case 1:17-cv-03956-PGG Document 64 Filed 06/25/24 Page 3 of 20
A.
Plaintiffs' FOIA Request and the Instant Action
Epstein was a financier who in June 2008 pleaded guilty to "a criminal charge of
procuring prostitution of a minor," and served thirteen months of an eighteen-month sentence.
(Second Seidel Decl. (Dkt. No. 58) 6) On April 20, 2017, Plaintiff Robertson submitted a
FOIA request to the FBI seeking "all documents relating to the FBI's investigation and
prosecution" of Epstein. (First Seidel Decl., Ex. A. (FOIA Request) (Dkt. No. 50-1) at 4)
On July 2, 2019, Epstein was indicted by a federal grand jury in this District on
"one count of conspiracy to commit sex trafficking
[and] one count of sex trafficking."
(Second Seidel Decl. (Dkt. No. 58) 1 6 (citing United States V. Epstein, 19 Cr. 490 (RMB)
(S.D.N.Y.), Indictment (Dkt. No. 2))) After the July 2, 2019 indictment, the FBI "began to
categorically assert Exemption 7(A) with respect to information in the remaining documents it
was processing
on the basis that release could negatively impact the then-pending
prosecution of Jeffrey Epstein and any related investigations." (Id. I 7) The FBI further
"asserted Exemption 7(A) over all information that had been withheld under other exemptions
prior to that date." (Id.)
Epstein committed suicide at the Metropolitan Correction Center in Manhattan on
August 10, 2019, while the charges against him were pending. (Id. (citing United States V.
Epstein, 19 Cr. 490 (RMB), Nolle Prosequi (Dkt. No. 52)))
B.
The Prosecution of Ghislaine Maxwell
On June 29, 2020, Ghislaine Maxwell was indicted by a grand jury in this District
on "one count of conspiracy to entice minors to travel to engage in illegal sex acts"; "one count
of enticement of a minor to travel to engage in illegal sex acts"; "one count of conspiracy to
transport minors with intent to engage in criminal sexual activity"; "one count of transportation
3
EFTA00038654

=== Page 4 ===
Case 1:17-cv-03956-PGG Document 64 Filed 06/25/24 Page 4 of 20
of a minor with intent to engage in criminal sexual activity"; "and two counts of perjury." (Third
Comey Decl. (Dkt. No. 59) 6)
On December 29, 2021, a jury found Maxwell guilty of enticing a minor to travel
to engage in illegal sex acts, transporting minors with the intent to engage in criminal sexual
activity, and three related conspiracy counts. (Third Comey Decl. (Dkt. No. 59) 1 8; 20 Cr. 330,
Dkt. Sheet at Dec. 29, 2021) On June 28, 2022, Maxwell was sentenced to 20 years'
imprisonment. (Third Comey Decl. (Dkt. No. 59) 1 8; 20 Cr. 330, Judgment (Dkt. No. 696))
On July 7, 2022, Maxwell appealed her conviction to the Second Circuit. (Third
Comey Decl. (Dkt. No. 59) 9) Maxwell seeks, inter alia, "a new trial based on alleged juror
misconduct and alleged evidentiary issues." (Id.) Her appeal remains pending. (Id. "I 8)
II.
THE SEPTEMBER 19, 2023 SUMMARY JUDGMENT ORDER
In its September 19, 2023 Order, this Court granted the FBI summary judgment as
to records withheld under Exemption 3 pursuant to the Child Victims' Act (Summary Judgment
Order (Dkt. No. 51) at 26); Exemption 5 for attorney work-product privilege (id. at 31-33);
Exemptions 6 and 7(C) to protect persons from an unwarranted invasion of personal privacy (id.
at 33-42); Exemption 7(D) to protect confidential information provided by local law enforcement
agencies (id. at 47-48); and Exemption 7(E) to protect against disclosure of law enforcement
techniques, procedures, and guidelines. (Id. at 48-51)
As to Exemption 7(A), this Court found that the FBI's invocation of this
Exemption was timely and that the requested records were compiled for law enforcement
purposes and related to a pending or prospective law enforcement proceeding. (Id. at 11-18)
The FBI, however, "ha[d] not explicitly linked any of the document categories - whether
Seidel's or Comey's - to the four types of potential harm cited in the 2021 Comey declaration."
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(Id. at 21) As a result, this Court denied the FBI's motion for summary judgment without
prejudice as to Exemption 7(A) because the FBI had not demonstrated that the disclosure of the
requested records would interfere with pending or prospective law enforcement proceedings.
(Id. at 18-25)
This Court also denied without prejudice the FBI's motion for summary judgment
as to records withheld under Exemption 3 pursuant to the Juvenile Justice and Delinquency Act,
18 U.S.C. $ 5038, which shields the arrest information and criminal history of third-party
juveniles, and Fed. R. Crim. P. 6(e), which shields matters occurring before the grand jury. (Id.
at 26-31)
Finally, this Court denied without prejudice the FBI's motion for summary
judgment as to records withheld under Exemption 7(D) for the protection of information
provided under an explicit or implicit assurance of confidentiality, and for information provided
by foreign agencies. (Id. at 42-47)
As noted above, in the Summary Judgment Order, this Court directed the parties
to submit a joint letter as to next steps, and to propose a "schedule for the FBI's submission of
revised declarations, as well as any renewed motions for summary judgment." (Id. at 54) After
the parties submitted a joint letter (Dkt. No. 52), this Court issued an October 3, 2023 order
setting a briefing schedule for the parties' renewed cross-motions for summary judgment. (Dkt.
No. 53)
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On January 30, 2024, the parties filed their renewed cross-motions for summary
judgment. (Dkt. Nos. 56, 61)
DISCUSSION
I.
LEGAL STANDARDS
A.
Rule 56 Standard
Summary judgment is warranted where the moving party shows that "there is no
genuine dispute as to any material fact" and that it "is entitled to judgment as a matter of law."
Fed. R. Civ. P. 56(a). "A dispute about a "genuine issue' exists for summary judgment purposes
where the evidence is such that a reasonable jury could decide in the non-movant's favor."
Beyer V. County of Nassau, 524 F.3d 160, 163 (2d Cir. 2008). "When no rational jury could find
in favor of the nonmoving party because the evidence to support its case is so slight, there is no
genuine issue of material fact and a grant of summary judgment is proper." Gallo V. Prudential
Residential Servs., Ltd. P'ship, 22 F.3d 1219, 1224 (2d Cir. 1994) (citing Dister V. Cont'l Grp.,
Inc., 859 F.2d 1108, 1114 (2d Cir. 1988)).
In deciding a summary judgment motion, the Court "resolve[s] all ambiguities,
and credit[s] all factual inferences that could rationally be drawn, in favor of the party opposing
summary judgment." Spinelli V. City of New York, 579 F.3d 160, 166 (2d Cir. 2009) (quoting
Brown V. Henderson, 257 F.3d 246, 251 (2d Cir. 2001) (internal quotation marks and citation
omitted)). However, a "party may not rely on mere speculation or conjecture as to the true
nature of the facts to overcome a motion for summary judgment.
[M]ere conclusory
allegations or denials
cannot by themselves create a genuine issue of material fact where
none would otherwise exist." Hicks V. Baines, 593 F.3d 159, 166 (2d Cir. 2010) (alterations in
original) (quoting Fletcher V. Atex, Inc., 68 F.3d 1451, 1456 (2d Cir. 1995)).
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"The same standard[s] appl[y] where, as here, the parties file[] cross-motions for
summary judgment. Morales V. Quintel Entm't, Inc., 249 F.3d 115, 121 (2d Cir. 2001).
"[W]hen both parties move for summary judgment, asserting the absence of any genuine issues
of material fact, a court need not enter judgment for either party. Rather, each party's motion
must be examined on its own merits, and in each case all reasonable inferences must be drawn
against the party whose motion is under consideration." Id. (internal citations omitted).
B.
Summary Judgment in FOIA Cases
"Summary judgment is the procedural vehicle by which most FOIA actions are
resolved." Jones-Edwards V. Appeal Bd. of Nat. Sec. Agency Cent. Sec. Agency, 352 F. Supp.
2d 420, 423 (S.D.N.Y. 2005). "In order to prevail on a motion for summary judgment in a FOIA
case, the defending agency has the burden of showing that [1] its search was adequate[,] and [2]
any withheld documents fall within an exemption to the FOIA." Carney V. U.S. Dept. of Justice,
19 F.3d 807, 812 (2d Cir. 1994).
A government agency may sustain its burden through "[a]ffidavits or
declarations [that] supply[] facts indicating that the agency has conducted a thorough search and
[that] giv[e] reasonably detailed explanations why any withheld documents fall within an
exemption." Associated Press V. U.S. Dept. of Justice, 2007 WL 737476, at *3 (S.D.N.Y. Mar.
7, 2007) (quoting Carney, 19 F.3d at 812); accord Garcia V. U.S. Dept. of Justice, Office of Info.
& Privacy, 181 F. Supp. 2d 356, 366 (S.D.N.Y. 2002). "[T]he general rule in this Circuit is that
in FOIA actions, agency affidavits alone will support a grant of summary judgment,' and Local
Civil Rule 56.1 statements are not required." N.Y. Times Co. V. U.S. Dept. of Justice, 872 F.
Supp. 2d 309, 314 (S.D.N.Y. 2012) (quoting Ferguson V. FBI, 1995 WL 329307, at *2 (S.D.N.Y.
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June 1, 1995), aff'd, 83 F.3d 41 (2d Cir. 1996)). "Affidavits submitted by an agency are
presumed to have been made in good faith." Garcia, 181 F. Supp. 2d at 366.
"[D]iscovery relating to the agency's search and the exemptions it claims for
withholding records generally is unnecessary if the agency's submissions are adequate on their
face." Carney, 19 F.3d at 812. "A district court
may grant summary judgment in favor of an
agency 'on the basis of agency affidavits if they contain reasonable specificity of detail rather
than merely conclusory statements, and if they are not called into question by contradictory
evidence in the record or by evidence of agency bad faith." Grand Cent. P'ship, Inc. V. Cuomo,
166 F.3d 473, 478 (2d Cir. 1999) (emphasis in original) (quoting Gallant V. N.L.R.B., 26 F.3d
168, 171 (D.C. Cir. 1994)). A plaintiff may avoid summary judgment and obtain discovery
where, "once the agency has satisfied its burden, the plaintiff
make[s] a showing of bad faith
on the part of the agency or provide[s] some tangible evidence that an exemption claimed by
the agency should not apply." Conti V. U.S. Dept. of Homeland Sec., 2014 WL 1274517, at *10
(S.D.N.Y. Mar. 24, 2014).
II.
FOIA EXEMPTION 7(A)
The FBI again argues that all of the withheld records responsive to Plaintiffs'
FOIA request were properly withheld under Exemption 7(A) to FOIA. (See Def. Br. (Dkt. No.
57) at 10-21; Second Comey Decl. (Dkt. No. 47); Third Comey Decl. (Dkt. No. 59)) Plaintiff
responds that the FBI's declarations do not link any of the document categories to potential
harms. (Pltf. Br. (Dkt. No. 62) at 3-4) According to Plaintiffs, "[w]hile [the FBI declarations]
now divide[] the material at issue into a greater number of categories, [they] offer[] nothing to
substantiate how releasing records within that category will likely result in harm." (Id. at 3
(emphasis in original))
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A.
Applicable Law
Exemption 7(A) to FOIA permits government agencies to withhold "records or
information compiled for law enforcement purposes" where "the production of such law
enforcement records or information
could reasonably be expected to interfere with
enforcement proceedings." 5 U.S.C. § 552(b)(7)(A). "This exemption 'prevent[s] harm to the
government's case in court by not allowing litigants earlier or greater access to agency
investigatory files than they would otherwise have." N.Y. Times Co. V. United States Dept. of
Justice, 2016 WL 5946711, at *7 (S.D.N.Y. Aug. 18, 2016) (quoting Conti, 2014 WL 1274517,
at *22). "[I]f the exemption applies, it 'will justify denial of release, not only to the objects of
the investigation and any pending or prospective enforcement actions, but to third parties as
well." Stein V. U.S. Sec. & Exch. Comm'n, 2017 WL 3141903, at *11 (D.D.C. July 24, 2017)
(quoting Kanter V. IRS, 433 F. Supp. 812, 817 (N.D. III. 1977)).
In order to demonstrate that Exemption 7(A) applies, the government must show
that (1) "the requested records were compiled for law enforcement purposes," Local 32B-32J,
Serv. Employees Int'l Union, AFL-CIO V. Gen. Servs. Admin., 1998 WL 726000, at *7
(S.D.N.Y. Oct. 15, 1998) (internal quotation marks omitted); (2) "a law enforcement proceeding
is pending or prospective," Amnesty Int'l USA V. C.I.A., 728 F. Supp. 2d 479, 525 (S.D.N.Y.
2010); and (3) "release of the information could reasonably be expected to cause some
articulable harm." Id.
"[A]lthough [courts] give deference to an agency's predictive judgment of the
harm that will result from disclosure of information, it is not sufficient for the agency to simply
assert that disclosure will interfere with enforcement proceedings; it must rather demonstrate
how disclosure will do so." Stein, 2017 WL 3141903, at *9 (quoting Citizens for Responsibility
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& Ethics in Wash. V. U.S. Dept. of Justice ("CREW I"), 746 F.3d 1082, 1096 (D.C. Cir. 2014))
(emphasis in CREW "Ultimately, the government must "allow[] the court to trace a rational
link between the nature of the document and the alleged likely interference." N.Y. Times Co.,
2016 WL 5946711, at *7 (quoting Ctr. for Nat'l Sec. Studies V. U.S. Dept. of Justice, 331 F.3d
918, 940 (D.C. Cir. 2003)).
B.
Interference with Law Enforcement Proceedings
and the Applicability of Exemption 7(A)
The FBI contends that "the records responsive to the FOIA requests withheld in
full or in part
[a]ll
fall within the scope of Exemption 7(A)" (Third Comey Decl. (Dkt.
No. 59) 11), because their "public disclosure
could reasonably be expected to interfere with
the pending prosecution of [Ghislaine] Maxwell." (Id. 1 12)
In previously denying the FBI summary judgment as to the applicability of
Exemption 7(A), this Court noted that (1) the Seidel and Comey Declarations submitted in
support of this request categorized the documents at issue inconsistently; and (2) "the FBI has
not explicitly linked any of the document categories to the four types of potential harm cited
in the [First] Comey declaration." (Summary Judgment Order (Dkt. No. 51) at 21)
The First Comey Declaration grouped the responsive records sought by Plaintiffs
and withheld by the FBI into three categories: (1) "[i]nterview forms, reports and notes
of
interviews with individuals, including victims"; (2) "Federal Grand Jury Subpoenas and
Subpoenaed information"; and (3) "documents provided by state and local law enforcement
agencies,
background information for witnesses
and subjects for the investigation[,]
communications within the FBI [and between the FBI and other agencies] regarding the
investigation[,] organizational documents,
the sources from and techniques through which
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such information and evidence was gathered[,] the methods used to analyze the information
and evidence, and the focus of the investigation." (First Comey Decl. (Dkt. No. 39) 11)
The First Seidel Declaration - on the other hand - speaks of nine "types of
responsive records"3 and three "functional categories of information":
(1) "Evidentiary/Investigative Materials," including "confidential witness statements" and
"information exchanged between the FBI and its local law enforcement partners";
(2) "Administrative [M]aterials," including internal agency "reporting communications"
pertaining to an investigation, and other "standardized forms used for a variety of purposes"; and
(3) "public source material," including news articles and court transcripts which have already
been "released to Plaintiffs." (First Seidel Decl. (Dkt. No. 50) " 58-68 (capitalization
altered)) This Court pointed out that "[t]he document categories in the [First] Seidel
[D]eclaration and in the [First] Comey Declaration do not match, and documents falling within
each of the Comey categories likely span multiple categories described by Seidel." (Summary
Judgment Order (Dkt. No. 51) at 21)
The FBI now relies on the First Seidel Declaration's three "functional categories
of information" - (1) Evidentiary/Investigative materials, (2) Administrative Materials, and (3)
Public Source/Non-Investigative Harm. (First Seidel Decl. (Dkt. No. 50) 1 59) - and the Third
Comey Declaration submitted in support of the FBI's instant motion adopts the same
categorization. (See Third Comey Decl. (Dkt. No. 59) 13) With the Government's
3 (1) "FD-1057 - Electronic Communication"; (2) "Interview Forms (FD-302)"; (3)
"Handwritten Interview Notes"; (4) "State and Local Law Enforcement Documents";
(5) "Documents Implementing Sensitive Investigative Techniques"; (6) "Federal Grand
Jury Subpoenas/Subpoenaed Information"; (7) "FD-340, IA Envelopes"; (8) "Other
Investigative Documents"; and (9) "Internet Printouts." (First Seidel Decl. (Dkt. No. 50)
" 58-68 (formatting altered))
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categorization of responsive documents now consistent, this Court can move on to consider
whether the FBI has linked these document categories to potential harms and explained how
those harms could "reasonably be expected to interfere with enforcement proceedings." 5 U.S.C.
$ 552(b)(7)(A).
As to the harm that would result from disclosure, the FBI notes that "the Maxwell
criminal prosecution is still pending on appeal," and "[i]f the Second Circuit grants Maxwell the
relief she seeks, there could be a new trial." (Third Comey Decl. (Dkt. No. 59) 1 12)
Accordingly, "public disclosure of the FBI's records relating to the investigation and prosecution
of Epstein that were withheld in full or in part under Exemption 7(A) could reasonably be
expected to interfere with the pending prosecution of Maxwell." (Id.)
As discussed below, in the FBI's revised declarations filed in support of the
instant motion, the Bureau now lists the potential harms that may arise from public disclosure,
and does so as to each category of documents.
The first category of documents - Evidentiary/Investigative Materials - "includes
copies of records or evidence, analysis of that evidence, and derivative communications
summarizing or otherwise referencing evidence." (Third Comey Decl. (Dkt. No. 59) 14) This
category includes business records and "documents and evidence provided by witnesses to law
enforcement," as well as information regarding those witnesses. (Id.)
The second category of documents - Administrative Materials - consists of
internal communications among investigators within the FBI providing updates
regarding the status of the investigation, including witness interviews and
discussion of evidence gathered during the investigation; communications
between the FBI and other government agencies regarding the investigation;
grand jury subpoenas identifying the names of witnesses and documents sought
during the investigation; and organizational documents such as envelopes used to
organize and store documents and other evidentiary documents, bulky exhibit
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cover sheets, transmittal forms, and letter routing slips, some of which contain the
names of witnesses, including victim-witnesses, and subjects of the investigation.
(Id. 1 15)
As for the harm that would result from disclosure of the Evidentiary/Investigative
Materials and the Administrative Materials, the FBI states that disclosure would (1) impact
witness testimony, (2) impact witnesses' willingness to testify, (3) prejudice the jury pool "so as
to hinder the Government's ability to present its case in court,"4 (4) provide Maxwell with
greater access "to the investigatory files than she would otherwise have during the criminal
4
In connection with its previous summary judgment motion, the FBI described the harm that
would result from disclosure as "impair[ing] the Government's (and the defendant's) ability to
seat a fair and impartial jury in Maxwell." (First Comey Decl. (Dkt. No. 39) " 17-19) In
denying the FBI's motion as to Exemption 7(A), this Court noted that "the FBI's concerns
regarding the effects of disclosure on jury impartiality are properly raised under Exemption 7(B),
and not under Exemption 7(A)." (Summary Judgment Order (Dkt. No. 51) at 22 n.10)
"Exemption 7(B) applies when the disclosure of law enforcement records would deprive a
person of the right to 'a fair trial or an impartial adjudication[,]' [and] the word 'trial' means
the ultimate determination of factual and legal claims by judge or jury in a judicial proceeding."
Chiquita Brands Int'l Inc. V. S.E.C., 805 F.3d 289, 295 (D.C. Cir. 2015) (quoting 5 U.S.C. $
552(b)(7)(B)); see also Washington Post Co. V. U.S. Dep't of Just., 863 F.2d 96, 101 (D.C. Cir.
1988) ("The exemption[] was meant to prevent disclosures from conferring an unfair
advantage upon one party to an adversary proceeding or leading to prejudicial publicity in
pending cases that might inflame jurors or distort administrative judgment.").
In connection with its current motion, the FBI states that "the harm the government is
articulating through a risk of prejudicing the jury pool is the harm of prejudicing the
government's ability to present its criminal case in court." (Def. Br. (Dkt. No. 57) at 17-18
(emphasis in original)) In this regard, the Government states that because the "majority of
records in this category
were not admitted into evidence at Maxwell's first trial[,]
the jury
may wonder why those materials were absent from the trial and may suspect the government of
trying to hide evidence from the jury, causing jurors to draw an unwarranted adverse inference
against the government." (Id. at 16 (citing Third Comey Decl. (Dkt. No. 59) 14(c)))
Accordingly, the harm now identified by the FBI is not prejudice to the parties' right to a fair and
impartial jury, but instead unfair prejudice to the Government in presenting its case. This type of
potential harm is properly raised under Exemption 7(A).
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discovery process," and (5) violate the Protective Order entered in the underlying case. (Id. "
14(a)-(e), 15(a)-(d))
In response, Plaintiffs renew their argument that the FBI has not linked the
document categories to any potential harm. (Pltf. Br. (Dkt. No. 62) at 3) According to Plaintiffs,
"the FBI insists that these are simply the kinds of documents that would tend to cause harm if
released, without engaging the reality on the ground that the target of the investigation has seen
millions of records and was convicted in one of the most high-profile trials in U.S. history." (Id.)
Plaintiffs also point out that "there is no new substantive factual information offered" in the
revised declarations or the FBI's current motion for summary judgment. (Id.)
The standard for application of Exemption 7(A) is not whether the "target of the
investigation has seen millions of records," however, or whether an agency has proffered
"substantive factual information" in support of a claimed exemption. Instead, an agency "must
explain to the court how the release of each category would interfere with enforcement
proceedings." Tipograph V. Dep't of Just., 83 F. Supp. 3d 234, 239 (D.D.C. 2015) (quoting
Bevis V. Dep't of State, 801 F.2d 1386, 1389-90 (D.C.Cir. 1986)). "The agency need not justify
the withholding of each document with specific facts," however. Robbins Geller Rudman &
Dowd LLP V. United States Sec. & Exch. Comm'n, 419 F. Supp. 3d 523, 530 (E.D.N.Y. 2019).
Instead, the agency need only make a showing that "allow[s] the court to be able to 'trace a
rational link between the nature of the document and the alleged likely interference." Id.
(quoting N.Y. Times Co., 2016 WL 5946711, at *7).
The FBI has met that burden here. Unlike in its previous motion (see Summary
Judgment Order (Dkt. No. 51) at 22-23), the FBI has described the contents of each category and
linked specific harms that would result from the public disclosure of the documents in each
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category. For example, the FBI has explained that public disclosure of the
Evidentiary/Investigative Materials "could influence the testimony of witnesses by providing the
opportunity for witnesses to shape their testimony to conform with other evidence gathered
during the investigation, including both records and witness statements." (Third Comey Decl.
(Dkt. No. 59) 1 14(a)) Disclosure of the Evidentiary/Investigative Materials could also have a
chilling effect on witnesses because "[t]he public release of this information could lead to the
identification and intimidation of witnesses, who may decline to cooperate with the parties and
be disinclined to testify if their personal information is released to the public." (Id. 1 14(b))
Public disclosure could also cause unfair prejudice to the Government at a retrial, based on the
fact that certain documents were available to the Government but not offered at the first trial.
Finally, public disclosure would provide Maxwell with greater access to investigatory materials
than she would otherwise have. (Id. " 14(c)-(e), 15(a)-(d))
"Ultimately, an agency's justification for invoking a FOIA exemption is sufficient
if it appears logical or plausible." Larson V. Dep't of State, 565 F.3d 857, 862 (D.C. Cir. 2009)
(internal citation and quotations omitted). Given the information contained within each category,
and the potential harm that could result from public disclosure - as described in the Second
Seidel Declaration and the Third Comey Declaration - the FBI has adequately demonstrated the
necessary logical and plausible connection between disclosure and harm.
Plaintiffs argue, however, that
(1) much of the evidence is already the subject of public record from the prior
trial and other civil proceedings; (2) much of the evidence is otherwise in the
public domain; and (3) the government makes no effort to segregate this material
or particularize how the exposure of this material would influence witness
testimony.
(Pltf. Br. (Dkt. No. 62) at 3)
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The FBI has explained, however, that the exhibits admitted at trial "represent a
small fraction of the documents contained in [the Evidentiary/Investigative Materials] category."
The Government further represents that it "has made available to the press upon request copies
of all publicly admitted exhibits from the trial" and is willing to "provide a copy of those
publicly filed exhibits to the Plaintiffs upon request." (Third Comey Decl. (Dkt. No. 59) 1 14(f))
In connection with the instant FOIA application, the FBI has also reviewed responsive records
"on a document-by-document basis" (Second Seidel Decl. (Dkt. No. 58) at 2) and has separated
"publicly available news reporting and other open source materials that are already accessible
online through public sources" into a third category that "ha[s] already been produced to
Plaintiffs." (Third Comey Decl. (Dkt. No. 59) I 16) Finally, "an agency may satisfy its burden
of proof 'by grouping documents in categories and offering generic reasons for withholding the
documents in each category." CREW I, 746 F.3d at 1098 (quoting Maydak, 218 F.3d at 765).
Where an agency
wishes to adopt the generic approach, [it] has a three-fold task. First, it must
define its categories functionally. Second, it must conduct a document-by-
document review in order to assign documents to the proper category. Finally, it
must explain to the court how the release of each category would interfere with
enforcement proceedings.
Id., 746 F.3d at 1098 (quoting Bevis, 801 F.2d at 1389-90). As discussed above, the FBI has
"defined its categories functionally"; it has performed "a document-by-document review in order
to assign documents to the proper category"; and it has explained how the disclosure of each
category would interfere with enforcement proceedings.
In connection with the harm element, the FBI has explained that the public
disclosure of the materials at issue could influence witness testimony by "providing the
opportunity for witnesses to shape their testimony to conform with [what is set forth in the non-
public records]." (Third Comey Decl. (Dkt. No. 59) " 14(a), 15(a)) "Courts allow withholding
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under Exemption 7(A) [where] '[p]ublic disclosure of information could result in destruction
of evidence, chilling and intimidation of witnesses, and revelation of the scope and nature of the
Government's investigation." Tipograph, 83 F. Supp. 3d at 239 (quoting Solar Sources, Inc. V.
United States, 142 F.3d 1033, 1039 (7th Cir. 1998)). Indeed, "Exemption 7 was designed to
prevent harm to the government's case in court by not allowing litigants earlier or greater access
to agency investigatory files than they would otherwise have." Conti, 2014 WL 1274517, at *22
(citing Robbins Tire & Rubber Co., 437 U.S. at 224-25); see also New York Times, 2016 WL
5946711, at *13 ("Such explanations are sufficient to establish that the withholdings conceal
records compiled for law enforcement purposes that disclose techniques and procedures for law
enforcement investigations, and, therefore, justify nondisclosure.").
These paradigmatic harms are among the harms that the FBI now alleges would
result from disclosure of the Evidentiary/Investigative Materials and the Administrative
Materials. While the FBI previously failed to link these potential harms to each document
category, it has now done so. There is no need for the FBI to further "particularize how the
exposure of this material would influence witness testimony." (Pltf. Br. (Dkt. No. 62) at 3)
"[T]he record establishes that the release of the requested information could reasonably be
expected to cause articulable harm." Cui V. Fed. Bureau of Investigation, 551 F. Supp. 3d 4, 24
(E.D.N.Y. 2021)
This Court concludes that "[t]he [revised] declarations provide[] sufficient detail
for the Court to trace a rational link between the information contained in the records and the
potential interference with law enforcement proceedings," id. at 24, and the FBI has thus met its
burden for withholding disclosure of the records under Exemption 7(A). Because "Exemption
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7(A) continues to be asserted to protect all redacted information," (Second Seidel Decl. (Dkt. No.
58) 8), this Court need not evaluate the applicability of the other Exemptions.
III.
SEGREGABILITY
"FOIA provides that '[a]ny reasonably segregable portion of a record shall be
provided to any person requesting such record after deletion of the portions which are exempt."
Conti, 2014 WL 1274517, at *25 (quoting 5 U.S.C. $ 552(b)). "[T]he agency must provide a
detailed justification for its decision that non-exempt material is not segregable," but "is entitled
to a presumption that it complied with its obligation to disclose reasonably segregable material."
Id. (citing Mead Data Cent., Inc. V. U.S. Dept. of Air Force, 566 F.2d 242, 261 (D.C. Cir. 1977)).
"[T]o justify withholding an entire document[,] the DOJ ... must demonstrate that [it] cannot
delineate between exempt and non-exempt information therein." Ayyad V. U.S. Dept. of Justice,
2002 WL 654133, at *2 (S.D.N.Y. Apr. 18, 2002).
Here, the FBI states that it has reviewed responsive records on a "document-by-
document basis" and conducted a segregability review concerning 11,571 responsive pages.
(Second Seidel Decl. (Dkt. No. 58) at 2, 20-21). The FBI further represents that "to the extent
there is non-exempt information contained in the records withheld under Exemption 7(A), that
information is intertwined with exempt information and cannot reasonably be segregated without
risking interference with the Maxwell prosecution, referencing the harms described
[previously]." (Def. Br. (Dkt. No. 57) at 30; Third Comey Decl. (Dkt. No. 59) T 17) According
to the FBI, "[t]he media coverage of speculation and theories about Maxwell's association with
Epstein makes the segregation of any possibly non-exempt information particularly difficult
because providing information pertaining to Epstein without complete context can reasonably be
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expected to contribute to the dissemination of speculation and theories about the Maxwell case."
(Third Comey Decl. (Dkt. No. 59) [17)
"An agency's explanation that records are exempt in their entirety is sufficient to
satisfy its segregability obligations with respect to the documents withheld under Exemption
7(A)." New York Times Co. V. United States Dep't of Just., 390 F. Supp. 3d 499, 519 (S.D.N.Y.
2019); Stein V. U.S. Sec. & Exch. Comm'n, 266 F. Supp. 3d 326, 353 (D.D.C. 2017) ("[T]he
SEC has sufficiently described two categories of documents that it has withheld under
Exemption 7(A) in their entirety, and explained that it is not possible to segregate non-exempt
information from these documents, except as the Court has described above. This is sufficient to
satisfy the agency's segregability obligations with respect to the documents withheld under
Exemption 7(A)."); Dillon V. Dep't of Just., 102 F. Supp. 3d 272, 298 (D.D.C. 2015) (concluding
that the FBI satisfied its segregability obligation under FOIA by stating that it had "carefully
reviewed the material withheld" and explained that "segregability is not possible because [the
records] are exempt from disclosure [in their entirety] pursuant to Exemption 7(A)" (second
alteration in original)). This Court concludes that the FBI has satisfied its segregability burden
with respect to the documents withheld in full under Exemption 7(A).
19
EFTA00038670

=== Page 20 ===
Case 1:17-cv-03956-PGG Document 64 Filed 06/25/24 Page 20 of 20
CONCLUSION
For the reasons stated above, Defendant's motion for summary judgment (Dkt.
No. 56) is granted, and Plaintiffs' cross-motion for summary judgment (Dkt. No. 61) is denied.
The Clerk of Court is directed to terminate the motions (Dkt. Nos. 56, 61) and to
close this case.
Dated: New York, New York
June 25, 2024
SO ORDERED.
Pauls Landate Pauls sandgshe
Paul G. Gardephe
United States District Judge
20
EFTA00038671


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=== Page 1 ===
From:
To:
Cc:
Subject: Draft Analysis Of 2019 2018 2017 Tx Returns
Date: Sun, 13 Dec 2020 16:49:55 +0000
Importance: Normal
Attachments: 2019_2018_2017_Tax_Return_Analysis_V1_12-13-20.pdf;
Cohen_and_Gresser_Page_9_Schedule_V2.pdf
The attached analyses are for discussion purposes only.
Forensic Accountant
FBI New York Field Office
26 Federal Placa
NYC, NY 10278
Office:
EFTA00038594


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=== Page 1 ===
From:
To:
Subject: [EXTERNAL EMAIL] - Call w/ SDNY re: discovery, Epstein investigation
Date: Thu, 22 Oct 2020 16:34:24 +0000
Importance: Normal
Attachments: unnamed
EFTA00038233


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c7: images
c0:
=== Page 1 ===
From:
"
To:
"
Cc:
Subject: Maxwell Triggerfish
Date: Tue, 30 Jun 2020 17:30:41 +0000
Importance: Normal
Attachments: Maxwell_Triggerfish_v2.docx
Attached.
Assistant United States Attorney
Southern District of New York
EFTA00037961


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=== Page 1 ===
From: "dropbox@ic.fbi.gov" <dropbox@ic.fbi.gov>
To:
Subject: FBINET to UNET Uploaded Files
Date: Fri, 31 Jan 2020 14:52:39 +0000
Importance: Normal
Attachments: Phone_conversation_with
.pdf
EFTA00038461


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=== Page 1 ===
From:
To:
Subject: FW: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your
review
Date: Tue, 27 Oct 2020 20:21:48 +0000
Importance: High
From:
Sent: Tuesday, September 15, 2020 5:12 AM
To:
Cc:
Subject: FW: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
Importance: High
Good Morning SA
I am going to follow up this email with 4 attachments of an upcoming OPR report re: 2006-08
Epstein Investigation. OPR forwarded to us for review to make sure our 7A stance is not impacted.
I am going to begin to review this today, but I wanted to forward for you, as well. If you have not reviewed this yet, please
let us know if anything within the report could impact any ongoing investigations.
We have until this Friday to respond.
Feel free to email or call with any questions.
Thanks,
From:
Sent: Monday, September 14, 2020 8:21 PM
To:
Subject: Fw: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
Hey
Please take a look at the attached docs and let me know if release of info in this report will impact our 7A
position.
Thanks,
From:
Sent: Thursday, September 10, 2020 1:55 PM
To:
Cc:
Subject: RE: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
EFTA00038158

=== Page 2 ===
I just had a conversation with SC Seiler about this. We have until next Friday to respond. l'll look into it tomorrow, as I
have a few other deadlines I'm dealing with today. Just keeping you posted.
Thanks,
Unit Chief
Litigation Support Unit/RIDS
From:
Sent: Thursday, September 10, 2020 9:18 AM
To:
Cc:
Subject: FW: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
#4
From:
Sent: Wednesday, September 9, 2020 2:55 PM
To:
Subject: FW: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
From:
Sent: Thursday, September 3, 2020 5:43 PM
To:
Subject: FW: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
4 of 4
Forwarded message
From:
Date: Sep 2, 2020 1:19 PM
Subject: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
To:
Assistant Director and General Counsel
Office of General Counsel
FBI Headquarters
Washington, D.C.
Mr.
-
EFTA00038159

=== Page 3 ===
Attached is a letter from Department of Justice Office of Professional Responsibility (OPR) Director
transmitting to you, for a sensitivity review, OPR's draft report in the Southern District of Florida's handling of the Jeffrey
Epstein matter during 2006-2008. We've found that the draft report is too large to email, so will set it separately in two
parts. We ask that it be treated with confidentiality. The letter is self-explanatory, but please do not hesitate to let us
know if you have any questions.
With regards,
Counsel
Office of Professional Responsibility
U.S. Department of Justice
950 Pennsylvania Avenue, N.W. - Room 3266
Washington, D.C. 20530
EFTA00038160


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=== Page 1 ===
Attached is the Form I-918B, which needs to be completed and signed by the law enforcement
agency. I have completed the parts I need to complete, but please make sure that the FBI
completes the following:
1. Part 2. Agency Information:
a. (questions 1-3) Please complete the full name and title of the FBI agent signing
the Form.
b. (questions 4.2.-5.h.) include the name of the Head of the FBI and the address
for the FBI Office
C. (question 9.) include the court case number for defendant Ghislaine Maxwell
2. Part 3. Criminal Acts:
a. (question 1.-3) I listed sexual exploitation and trafficking as the criminal
activity for parts 2.a.-2.d. please list the dates the criminal activity occurred as
alleged in the Indictment and the section of the USC code she is charged with
b. (question 4.b.) list the city and state where the violations occurred
C. (question 6.) Please describe the criminal activity being investigated according
to the charges and allegations in the indictment
d. (question 7) describe the injury to Ms.
3. Part 6. Certification
a. Have the FBI agent sign, date and include his telephone and fax number
EFTA00038704

=== Page 2 ===
U.S. DEPARTMENT OF
Supplement B, U Nonimmigrant Status Certification
USCIS
Form I-918
HOMELAND SECURITY
Department of Homeland Security
OMB No. 1615-0104
U.S. Citizenship and Immigration Services
Expires 04/30/202
Remarks
For
USCIS
Use
Only
START HERE- Type or print in black or blue ink.
Part 1. Victim Information
Name of Head of Certifying Agency
1. Alien Registration Number (A-Number) (if any)
4.a. Family Name
(Last Name)
A-
4.b. Given Name
(First Name)
2.a. Family Name
(Last Name)
4.c. Middle Name
2.b. Given Name
(First Name)
Agency Address
2.c. Middle Name
5.a. Street Number
Other Names Used (Include maiden names, nicknames, and
and Name
aliases, if applicable.)
5.b.
Apt.
Ste.
Flr.
If you need extra space to provide additional names, use the
space provided in Part 7. Additional Information.
5.c. City or Town
3.a. Family Name
5.d. State
4.f. ZIP Code
(Last Name)
3.b. Given Name
5.f. Province
(First Name)
3.c. Middle Name
5.g. Postal Code
4. Date of Birth (mm/dd/yyyy)
5.h. Country
5. Gender
Male
X
Female
Other Agency Information
Part 2. Agency Information
6. Agency Type
1. Name of Certifying Agency
X
Federal
State
Local
Federal Bureau of Investigations
7. Case Status
A
Name of Certifying Official
X
On-going
Completed
2.a. Family Name
Other
(Last Name)
2.b. Given Name
8. Certifying Agency Category
(First Name)
Judge
X
Law Enforcement
Prosecutor
2.c. Middle Name
Other
3. Title and Division/Office of Certifying Official
9. Case Number
10. FBI Number or SID Number (if applicable)
Form I-918 Supplement B 04/24/2019
Page 1
5
&
EFTA00038705

=== Page 3 ===
Part 3. Criminal Acts
4.a. Did the criminal activity occur in the United States
(including Indian country and military installations) or the
If you need extra space to complete this section, use the space
territories or possessions of the United States?
provided in Part 7. Additional Information.
Yes
No
1. The petitioner is a victim of criminal activity involving a
violation of one of the following Federal, state, or local
4.b. If you answered "Yes," where did the criminal activity
occur?
criminal offenses (or any similar activity). (Select all
applicable boxes)
Abduction
Manslaughter
Abusive Sexual Contact
Murder
5.a. Did the criminal activity violate a Federal extraterritorial
jurisdiction statute?
Attempt to Commit
Obstruction of Justice
Yes
No
Any of the Named
Crimes
Peonage
5.b. If you answered "Yes," provide the statutory citation
providing the authority for extraterritorial jurisdiction.
Being Held Hostage
Perjury
Prostitution
Blackmail
Conspiracy to Commit
Rape
Any of the Named
6. Briefly describe the criminal activity being investigated
Sexual Assault
and/or prosecuted and the involvement of the petitioner
Crimes
X
Domestic Violence
Sexual Exploitation
named in Part 1. Attach copies of all relevant reports and
findings.
Slave Trade
Extortion
Solicitation to
False Imprisonment
Commit Any of the
Felonious Assault
Named Crimes
Female Genital
Stalking
Mutilation
Torture
Fraud in Foreign Labor
X
Contracting
Trafficking
Unlawful Criminal
Incest
Restraint
Involuntary Servitude
Witness Tampering
Kidnapping
Provide the dates on which the criminal activity occurred.
2.a. Date (mm/dd/yyyy)
2.b. Date (mm/dd/yyyy)
7. Provide a description of any known or documented injury
to the victim. Attach copies of all relevant reports and
2.c. Date (mm/dd/yyyy)
findings.
2.d. Date (mm/dd/yyyy)
3. List the statutory citations for the criminal activity being
investigated or prosecuted, or that was investigated or
prosecuted.
&
Form I-918 Supplement B 04/24/2019
Page 2 055
EFTA00038706

=== Page 4 ===
Part 4. Helpfulness Of The Victim
4. Other. Include any additional information you would like
to provide.
For the following questions, if the victim is under 16 years of
age, incompetent or incapacitated, then a parent, guardian, or
next friend may act on behalf of the victim.
1. Does the victim possess information concerning the
criminal activity listed in Part 3.?
X
Yes
No
2. Has the victim been helpful, is the victim being helpful, or
is the victim likely to be helpful in the investigation or
prosecution of the criminal activity detailed above?
X
Yes
No
3. Since the initiation of cooperation, has the victim refused
or failed to provide assistance reasonably requested in the
investigation or prosecution of the criminal activity
detailed above?
Yes
X
No
If you answer "Yes" to Item Numbers 1.-3., provide an
explanation in the space below. If you need extra space to
complete this section, use the space provided in Part 7.
Additional Information.
Form I-918 Supplement B 04/24/2019
Page 3 of 5
EFTA00038707

=== Page 5 ===
Part 5. Family Members Culpable In Criminal
Part 6. Certification
Activity
I am the head of the agency listed in Part 2. or I am the person
1. Are any of the victim's family members culpable or
in the agency who was specifically designated by the head of
believed to be culpable in the criminal activity of which
the agency to issue a U Nonimmigrant Status Certification on
the petitioner is a victim?
Yes
x
No
behalf of the agency. Based upon investigation of the facts, If
certify, under penalty of perjury, that the individual identifiedan
If you answered "Yes," list the family members and their
Part 1. is or was a victim of one or more of the crimes listed
criminal involvement. (If you need extra space to
Part 3. I certify that the above information is complete, true,
complete this section, use the space provided in Part 7.
and correct to the best of my knowledge, and that I have made
Additional Information.)
and will make no promises regarding the above victim's ability
2.a. Family Name
to obtain a visa from U.S. Citizenship and Immigration Services
(Last Name)
(USCIS), based upon this certification. I further certify that if
2.b. Given Name
the victim unreasonably refuses to assist in the investigation or
(First Name)
prosecution of the qualifying criminal activity of which he or
she is a victim, I will notify USCIS.
2.c. Middle Name
1.
Signature of Certifying Official (sign in ink)
2.d. Relationship
2. Date of Signature (mm/dd/yyyy)
2.e. Involvement
3. Daytime Telephone Number
3.a. Family Name
(Last Name)
4. Fax Number
3.b. Given Name
(First Name)
3.c. Middle Name
3.d. Relationship
3.e. Involvement
4.a. Family Name
(Last Name)
4.b. Given Name
(First Name)
4.c. Middle Name
4.d. Relationship
4.e. Involvement
Form I-918 Supplement B 04/24/2019
Page 4 of 5
EFTA00038708

=== Page 6 ===
Part 7. Additional Information
5.a. Page Number 5.b. Part Number 5.c. Item Number
If you need extra space to complete any item within this
supplement, use the space below or attach a separate sheet of
5.d.
paper; type or print the agency's name, petitioner's name, and
the Alien Registration Number (A-Number) (if any) at the top
of each sheet; indicate the Page Number, Part Number, and
Item Number to which your answer refers; and sign and date
each sheet. If you need more space than what is provided, you
may also make copies of this page to complete and file with this
supplement.
1. Agency Name
Federal Bureau of Investigations
Petitioner's Name
2.a. Family Name
(Last Name)
2.b. Given Name
(First Name)
2.c. Middle Name
3.
A-Number (if any)
A-
6.a. Page Number 6.b. Part Number 6.c. Item Number
4.a. Page Number 4.b. Part Number 4.c. Item Number
6.d.
4.d.
Form I-918 Supplement B 04/24/2019
Page 5
of
5
EFTA00038709


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=== Page 1 ===
From:
Subject: Re: JE CART evidence
Date: Tue, 23 Jun 2020 17:59:26 +0000
Importance: Normal
Attachments: EpsteinNYEvidence.xlsx
I have this sheet that I gave to
,
maybe this helps? It's tough to help as I don't have access to look at the
items till tomorrow AM. Just remember, some items had multiple hard drives in them, so some items might
map back to the same 1B.
FBI NY CART Coordinator
Senior Examiner
From:
Sent: Tuesday, June 23, 2020 1:21 PM
To:
Subject: JE CART evidence
Hey
I attached the sheet that
went over with you with CART numbers. I can't match up all the numbers with 1B numbers-
some of the cart numbers for the island I don't even have so I'm not sure where the mix up is. Are you able to identify what
items these are? Any info would be helpful.
Thanks,
EFTA00037913


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: New Victim for treatment
Date: Fri, 08 May 2020 14:31:26 +0000
Importance: Normal
Yes I will forward you
email.
On May 8, 2020 7:45 AM,
wrote:
Hi
If
has confirmed she is a known victim in this case and does not have access to crime victims comp due
to
regulations, she is approved.
I'll add her to SP.
,
EFTA00038413

=== Page 2 ===


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c0:
=== Page 1 ===
PALM BEACH POLICE DEPARTMENT
PROPERTY RECEIPT
CONTRIBUTOR'S COPY
PBPD Form #52
PROPERTY
FOUND
DECEASED (Probated)
PERSONAL
CONFISCATED
DESTROY
EVIDENCE
TRIAL
LABORATORY
STOLEN/RECOVERED
OTHER
INCIDENT/CITATION NUMBER
DATE/TIME RECOVERED
PROPERTY NUMBER (Leave Blank)
BIN NUMBER (Leave Blank)
05-368
10/8/21
ADDRESS WHERE PROPERTY IMPOUNDED
WEST Pain BRAZA Fl 33101
DISCOVERED BY / D.O.B.
ADDRESS
Street
City
Zip
PHONE NUMBER
OWNER'S NAME / D.O.B.
ADDRESS
Street
City
Zip
PHONE NUMBER
Palm Beach Police Dep
PalmBroin 33481
SUSPECT'S NAME / D.O.B.
ADDRESS
Street
City
Zip
PHONE NUMBER
ADDT'NL SUSPECT / D.O.B.
ADDRESS
Street
City
Zip
PHONE NUMBER
SPECIAL INSTRUCTIONS
FOUND PROPERTY
CLAIM
90 DAYS
NOT CLAIM
ITEM #
QUANTITY
VALUE
DESCRIPTION
/
2
Bnawers Box EASE FILES
TOTAL PACKAGE WEIGHT
I hereby acknowledge that the above list represents all property taken
I hereby acknowledge that the above list represents all property impounded
from me and that I have received a copy of this receipt.
by me in the official performance of my duty as a police officer.
10/8/21
V.C
756 CONTA
SIGNATURE
DATE
SIGNATURE
ID#
UNIT
RECEIVED BY
REASON
DATE/TIME RECEIVED
EFTA00038939


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=== Page 1 ===
Re: Epstein investigation
From:
To:
Jill Greenfield <jll.greenfield@fieldfisher.com>
Cc:
)"
(USANYS)"
, Louise Scott
<louise.scott@fieldfisher.com>
Date:
Sat, 01 Feb 2020 14:29:13 -0500
Jill I'm glad that you noted that as the AUSA's sent you two emails this week that we weren't sure or
not if you had received. Must be some issue with the governments servers. Either way no worries,
when are you available for a phone call this week? I can just email with you directly if this thread is
the technical issue.
On Feb 1, 2020, at 12:55, Jill Greenfield <Jill.Greenfield@fieldfisher.com wrote:
Hello
I note that I did not hear.
Shall we try to schedule something next week?
Kind regards,
Jill
Jill Greenfield
Partner
D:
+44 207 861 4557
M:
+44 7739 664765
Personal Injury Team of the Year - Solicitors Journal Awards 2017
From: Jill Greenfield
Sent: Tuesday, January 28, 2020 6:12 PM
To:
Cc:
(USANYS)
Subject: RE: Epstein investigation
Many thanks
EFTA00038778

=== Page 2 ===
I am available until tomorrow from 2.00 at 5.45 GMT and then again on Friday afternoon from
about 3.00.
Please let me know if any of these work.
Best
Jill
From:
Sent: Tuesday, January 28, 2020 5:59 PM
To: Jill Greenfield <Jill.Greenfield@fieldfisher.com>
Cc:
is
(USANYS)
Subject: Re: Epstein investigation
Jill,
Thank you for reaching out to me about your client and we appreciate your assistance in the matter. I've
CC'd some of the members of our team including the prosecutors from the Southern District of New York.
We agree that a call may be a good idea to hash out some of these details and questions you may have. Is
there a particular time that works for you?
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
From: Jill Greenfield <Jill.Greenfield@fieldfisher.com>
Sent: Tuesday, January 28, 2020 12:34 PM
To:
Subject: Epstein investigation
Dear
My client has been in contact regarding the possibility of an interview to take place in London.
Please note that my client is entitled to automatic anonymity under UK Statute as herself a victim
of sexual assault that occurred in the UK and she does not waive her right to that anonymity.
I very much look forward to hearing from you in order that we may set up a convenient time for
you to meet with my client but perhaps before that it would be useful if you could confirm the
parameters of your interest in my client.
A call may be a good idea.
Kind Regards
EFTA00038779

=== Page 3 ===
Jill
Jill Greenfield
Partner
D:
+44 207 861 4557
M:
+44 7739 664765
Personal Injury Team of the Year - Solicitors Journal Awards 2017
Fieldfisher, Riverbank House, 2 Swan Lane, London EC4R 3TT.
www.fieldfisher.com
We do not intend to change our bank details. If you receive any communication that any of our bank details have changed,
telephone us and speak to your contact at our office before transferring any funds. We do not accept responsibility for monies
paid into a wrong bank account in any circumstances.
This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact
the sender immediately, destroy the email and any attachments and do not use, copy, store or disclose this email and any
attachments for any purpose. Fieldfisher does not accept service of documents by electronic means without express prior
agreement.
For details about what personal information we collect and why, please see our Privacy Notice on our website at
www.fieldfisher.com.
Fieldfisher is the trading name of Fieldfisher LLP, a limited liability partnership registered in England and Wales (registered
number OC318472) and is authorised and regulated by the Solicitors' Regulation Authority. A list of its members and their
professional qualifications is available at its registered office, Riverbank House, 2 Swan Lane, London EC4R 3TT. We use the
term partner to refer to a member of Fieldfisher LLP or an employee or consultant with equivalent standing or qualifications.
EFTA00038780


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=== Page 1 ===
From:
To:
Subject: RE: Epstein Image/Video File Review Protocol
Date: Thu, 22 Oct 2020 16:41:09 +0000
Importance: Normal
3:30 works for me.
From:
Sent: Thursday, October 22, 2020 12:39 PM
Subject: Epstein Image/Video File Review Protocol
Hey all,
I wanted to send a follow-up email about the device review. See below on who is covering what device. Happy to talk
through and sit down with those of you I haven't. Everyone should be set up by end of day today to have access to the
case. The AUSAs have asked that you read through the attachments to be familiar with it. They would also like to set up a
call sometime later today to touch base with all of you about the review. Is there a time everyone could get on a call,
maybe around 3:30 or a little later?
Let me know.
Thanks!
From:
Sent: Wednesday, October 21, 2020 1:51 PM
Subject: Epstein Image/ Video File Review Protocol
Hi everyone,
Thank you all for your help! Please see below regarding the Image/video file review. Please note that we need to have
this completed by next Friday. We have ten devices to review at this time. I hope to have each of you set up with access
to CAIR today and you'll be able to review this from your desk. I will sit down with each of you to help you navigate the
system and the devices. I've already bookmarked the folders for the devices so all you will have to do is put the
images/videos into the designated folders. In each of these categories, there are multiple devices; please be sure to only
EFTA00038290

=== Page 2 ===
click on the device you are working on. I have bookmarked folders in different devices to keep the location of items found
organized by device. I've split up the devices below. This is how they are labeled in the system. Let's keep in touch as you
finish each device so we know when each device is complete.
NY-3027571_Safe
NYC024355
NY-3027571_21597
NYC024323
NYC024326
NYC024334
NY-3027571_21940
NYC024368
NYC024394
NYC024390
NYC027908
NYC027910
NY-3027571_MAC
NYC024363
l'll be around to assist/help as needed and answer any questions that may come up. Please feel free to reach out with
questions.
Thanks,
From:
Sent: Monday, October 19, 2020 4:08 PM
mage/
video
All,
Attached please find the review protocol for the image and video files from Epstein's devices. The protocol asks that all
reviewers read the warrant and supporting affidavit, which are both attached here as well. I am also attaching a copy of
the Maxwell indictment, which contains a photograph of Epstein and Maxwell.
Once the USAO and FBI review teams are assembled, please let me know when would be a good time for me to have a
call with them to talk through the review and answer any questions.
EFTA00038291

=== Page 3 ===
In the first instance, we would ask that the FBI team review the following devices:
NYC024363
NYC024394
NYC024326
NYC024368
NYC024390
NYC024334
NYC027910
NYC024323
NYC024355
NYC027908
Depending on how quickly the FBI and USAO teams move through the review, we may reassign some devices between the
teams.
EFTA00038292


c1: EFTA00038945
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038945.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: [EXTERNAL EMAIL] - RE: Hotline tracking spreadsheets?
Date: Tue, 05 Oct 2021 02:12:59 +0000
Importance: Normal
Thanks,
I have a few questions about these, can I give you a call tomorrow (Tuesday) morning?
From:
Sent: Monday, October 4, 2021 2:29 PM
To:
Subject: RE: Hotline tracking spreadsheets?
The two are attached.
From:
Sent: Sunday, October 3, 2021 6:53 PM
To:
Subject: [EXTERNAL EMAIL] - Hotline tracking spreadsheets?
Hi
Hope you're doing well. Do you have up-to-date copies of the tracking spreadsheets for the tipline/hotlines for Maxwell
and Epstein that you could please send to me as soon as possible? I think the last ones we have from FBI are from last
summer (one of which is attached) so just want to do extra due diligence on my end to make sure we have what we need
to produce in 3500. If you could send those spreadsheets as soon as possible, that would be great.
Thank you,
EFTA00038945


c1: EFTA00038620
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038620.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(BA) (FBI)"
To:
(NY) (FBI)"
Subject: Masseuse List, black book, flight logs
Date: Tue, 18 Feb 2025 23:19:50 +0000
Importance: Normal
Attachments: USGME01088970_(masseuse_list).doc
The attached item titled "Masseuses" was going to initially be a trial exhibit but was not used at the Maxwell
trial. It was located on one of Epstein's digital devices seized from his Manhattan residence. The names listed are
believed to be women and girls, some of which were identified minors, who were contacted by Epstein,
Maxwell, and his staff to massage Epstein.
Separately, the black book was seized by Miami -Palm Beach during the course of their 72 investigation. It is an
address book that included identified minors under "massage". Sections of this book were a trial exhibit.
The flight logs were kept and provided by Epstein's pilot
This was a trial exhibit.
At trial, the black book and the flight logs had minor victims redacted from the public.
Let me know if you have any questions or need anything further.
Special Agent
FBI Baltimore/Delaware
Violent Crime Safe Streets Task Force
EFTA00038620


c1: EFTA00038187
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038187.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Epstein Victim Briefings
Start Date: 2019-10-02 17:00:00 +0000
End Date: 2019-10-02 18:00:00 +0000
Organizer
Location: 290 9th Floor Conference Room
Class: X-PERSONAL
Date Created: 2019-09-26 15:49:56 +0000
Date Modified: 2019-09-26 17:15:23 +0000
Priority: 5
DTSTAMP: 2019-09-26 15:50:30 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
Sorry it is 1pm not 1:30
EFTA00038187


c1: EFTA00038994
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038994.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "Ruzumna, Daniel (x
)"
To:
"Doxey, Lauren (x
"
Subject: [EXTERNAL EMAIL] - In re Epstein: FBI (
Video Review
Date: Tue, 16 May 2023 21:27:59 +0000
Importance: Normal
Attachments: unnamed
Privileged/Confidential Information may be contained in this message. If you are not
the addressee indicated in this message (or responsible for delivery of the message to
such person), you may not copy or deliver this message to anyone. In such case, you
should destroy this message and kindly notify the sender by reply email. Please advise
immediately if you or your employer do not consent to receiving email messages of this
kind.
EFTA00038994


c1: EFTA00037968
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00037968.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Subject: RE: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your
review
Date: Tue, 15 Sep 2020 18:03:24 +0000
Importance: Normal
Absolutely will do.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
From:
Sent: Tuesday, September 15, 2020 2:01 PM
To:
;
Subject: RE: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
Hello
Given the sensitivity, please treat with confidentiality.
Thanks,
Unit Chief
Litigation Support Unit/RIDS
From:
Sent: Tuesday, September 15, 2020 1:15 PM
To:
Cc:
Subject: RE: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
This is the first I've seen this. l'll read through this and let you know.
Thanks for sending,
Special Agent
FBI New York Field Office
EFTA00037968

=== Page 2 ===
Child Exploitation/Human Trafficking
From:
Sent: Tuesday, September 15, 2020 5:12 AM
To:
,
Cc:
Subject: FW: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
Importance: High
Good Morning SA
I am going to follow up this email with 4 attachments of an upcoming OPR report re: 2006-08
Epstein Investigation. OPR forwarded to us for review to make sure our 7A stance is not impacted.
I am going to begin to review this today, but I wanted to forward for you, as well. If you have not reviewed this yet, please
let us know if anything within the report could impact any ongoing investigations.
We have until this Friday to respond.
Feel free to email or call with any questions.
Thanks,
From:
Sent: Monday, September 14, 2020 8:21 PM
To:
Subject: Fw: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
Hey
Please take a look at the attached docs and let me know if release of info in this report will impact our 7A
position.
Thanks,
From:
Sent: Thursday, September 10, 2020 1:55 PM
To:
Cc:
Subject: RE: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
I just had a conversation with SC
about this. We have until next Friday to respond. l'll look into it tomorrow, as I
have a few other deadlines I'm dealing with today. Just keeping you posted.
Thanks,
EFTA00037969

=== Page 3 ===
Unit Chief
Litigation Support Unit/RIDS
From:
Sent: Thursday, September 10, 2020 9:18 AM
To:
Subject: FW: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
#4
From:
Sent: Wednesday, September 9, 2020 2:55 PM
To:
Subject: FW: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
From:
Sent: Thursday, September 3, 2020 5:43 PM
To:
Cc:
Subject: FW: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
4 of 4
Forwarded message
From:
Date: Sep 2, 2020 1:19 PM
Subject: [EXTERNAL EMAIL] - USDOJ Office of Professional Responsibility Matter for your review
To:
Cc:
Assistant Director and General Counsel
Office of General Counsel
FBI Headquarters
Washington, D.C.
Mr.
-
Attached is a letter from Department of Justice Office of Professional Responsibility (OPR) Director
transmitting to you, for a sensitivity review, OPR's draft report in the Southern District of Florida's handling of the Jeffrey
Epstein matter during 2006-2008. We've found that the draft report is too large to email, so will set it separately in two
parts. We ask that it be treated with confidentiality. The letter is self-explanatory, but please do not hesitate to let us
know if you have any questions.
With regards,
EFTA00037970

=== Page 4 ===
Counsel
Office of Professional Responsibility
U.S. Department of Justice
950 Pennsylvania Avenue, N.W. — Room 3266
Washington, D.C. 20530
EFTA00037971


c1: EFTA00038530
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038530.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(DN) (FBI)"
To:
(NY) (FBI)"
Subject: RE: Epstein victim
Date: Wed, 24 Feb 2021 15:16:32 +0000
Importance: Normal
O.k., we should probably test to make sure we can use Webex before the meeting. I would hate to have technical
difficulties when she arrives.
From:
(NY) (FBI)
Sent: Wednesday, February 24, 2021 8:11 AM
To:
(DN) (FBI)
Subject: RE: Epstein victim
Hey
We are going to be using Webex. I'm going to send the link to you as soon as I get it from the AUSA. Completely up to
you if you want to sit in; you're helping us out. You do not need to sit in though, so don't feel you have to.
I should have the link shortly.
From:
(DN) (FBI)
Sent: Wednesday, February 24, 2021 10:07 AM
To:
(NY) (FBI)
Subject: RE: Epstein victim
What system are you planning to use for the video conference? Do you want me to sit in with
on this end? If you
do that is fine, and if you don't that is fine, just let me know.
Thanks,
From:
(NY) (FBI)
Sent: Tuesday, February 23, 2021 4:48 PM
To:
(DN) (FBI)
is
(NY) (FBI)
Cc:
(DN) (FBI)
Subject: Re: Epstein victim
Great news! Thanks so much for coordinating. I'll send out a video link
Special Agent
FBI New York Field Office
On Feb 23, 2021 6:33 PM,
(DN) (FBI)"
wrote:
After a few attempts we finally made contact with
She will be here at 1030 tomorrow morning.
EFTA00038530

=== Page 2 ===
-
On Feb 18, 2021 7:31 PM,
(NY) (FBI)"
wrote:
Hi
yes I can be available. That shouldn't be a problem. What time works best?
Special Agent
FBI New York Field Office
On Feb 18, 2021 8:44 PM,
(DN) (FBI)"
wrote:
Would you be available next Tuesday (preferably) or Wednesday morning to do this interview?
-
On Feb 3, 2021 1:02 PM,
(NY) (FBI)"
wrote:
Thanks
-
, do you mind if I give you a call to discuss?
Thanks,
Special Agent
New York Field Office
Child Exploitation/Human Trafficking
C:
From:
(DN) (FBI)
Sent: Wednesday, February 3, 2021 12:42 PM
To:
(NY) (FBI)
is
(NY) (FBI)
Cc:
(DN) (FBI)
Subject: Epstein victim
I'm in forensic interviews all day. SA
(ccd on this) is an agent in the
office. He's actually met
Mayne
touch base with him to detail what yall need.?
Thanks
On Feb 3, 2021 9:58 AM,
(NY) (FBI)"
wrote:
EFTA00038531

=== Page 3 ===
I can chat anytime. When is a good time to call?
Special Agent
FBI New York Field Office
On Feb 2, 2021 5:38 PM,
(DN) (FBI)"
wrote:
Give me a call on this. I'm actually on my way to
We have an fbi office there. But it's 7 hours from where I'm
stationed. Would love to address if we can while I'm there.
On Feb 2, 2021 2:40 PM,
(NY) (FBI)"
wrote:
happy new year! I hope you are doing ok! I am reaching out regarding
who you assisted us with last year. She
has resurfaced and is asking for a trauma focused therapist. I told her I would reach back out to you since I know you had
given this information to her before.
We are hoping to try to interview her sooner than later and wanted to ask if you know of any office locations close to her
in
? Any suggestions would be greatly appreciated!
Thanks again for all of your help! We really appreciate it!
EFTA00038532


c1: EFTA00038297
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038297.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Fwd: [EXTERNAL EMAIL] - Follow-up call re Epstein
Date: Tue, 27 Oct 2020 19:35:18 +0000
Importance: Normal
Attachments: Scan.pdf
Forwarded message
From:
Date: Oct 25, 2020 1:42 PM
Subject: [EXTERNAL EMAIL] - Follow-up call re Epstein
Thanks very much for sending along your papers regarding the Epstein case. I've reviewed all of them, and just had a
couple questions about the attached. Is there a time this week when we could have a call to discuss, please?
Thanks,
EFTA00038297


c1: EFTA00038151
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038151.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: [EXTERNAL EMAIL] - RE: Confirmation of devices and responsive files
Date: Tue, 03 Nov 2020 18:44:25 +0000
Importance: Normal
Great, thank you!
From:
Sent: Tuesday, November 3, 2020 1:43 PM
To:
Cc:
>;
Subject: [EXTERNAL EMAIL] - RE: Confirmation of devices and responsive files
I was out yesterday. I will get this information to you later today when I am able to be at my computer so I can
make sure you get the most accurate info.
-
On Nov 3, 2020 10:13 AM,
wrote:
In addition to the information requested below, I have questions regarding a few particular files that I was unable to open
on the drive of responsive materials from the FBI (I received an error message saying that the file was either too large,
damaged, or corrupted to view). There were six files in total that I was unable to open, listed below with the device they
were on.
NYC024326
f_003a1d, f_003a1f, f_0039eb, f_00394b, f_003994
NYC024355
2b2cf6a7acb1a26fa73bc8d0e28a25119968507e
Please let us know at your earliest convenience about these files as well as my questions in my email yesterday (i.e., the
number of highly confidential files and how we can get the responsive materials from the remaining devices that the FBI
was assigned to review-- NYC024334, NYC027908, NYC024394, NYC024363).
Thanks so much,
From:
Sent: Monday, November 2, 2020 1:11 PM
To:
Cc:
is
Subject: Confirmation of devices and responsive files
EFTA00038151

=== Page 2 ===
Hope you're well and had a nice weekend! I am writing to confirm which devices had responsive materials (and how many
responsive materials were on each device) for the Maxwell photo/video responsiveness review.
The drive which you gave me on Friday contains five folders, one for each of the following devices (NYC024323,
NYC024326, NYC024355, NYC024368, NYC027910), each of which contains confidential material. Can you please let us
know how many highly confidential images and video files were identified for these devices?
Additionally, can you please let us know whether the following devices (NYC024334, NYC027908, NYC024394) had any
responsive material on them or not? These are devices that were initially assigned to the FBI to review but were not
included on the hard drive given to us on Friday. If these devices do have responsive confidential material on them, we
need to get that material from you ASAP, please.
Finally, the device highlighted below (NYC024363) is the one we spoke about last week which you said would not be ready
on Friday to provide us with the responsive materials. Please let us know when this is done and how we can best get
these materials from you.
In sum, we need you to please confirm the contents of all of the cells below marked with an "x" at your earliest
convenience. Let us know if you have any questions.
Thanks,
Device
CONFIDENTIAL-
CONFIDENTIAL-
HIGHLY
HIGHLY
images
videos
CONFIDENTIAL-
CONFIDENTIAL-
images
videos
NYC024323
398
0
X
X
NYC024326
97
3
X
X
NYC024355
5,222
15
X
X
NYC024368
24
1
X
X
NYC027910
28
0
X
X
NYC024363
X
X
X
X
NYC024334
X
X
X
X
NYC027908
X
X
X
X
NYC024394
X
X
X
X
EFTA00038152


c1: EFTA00038180
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038180.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(NY) (FBI)"
To:
(NY) (FBI)"
Cc:
(SI) (FBI)"
Subject: Fwd: C-20 request for assistance 11/13
Date: Thu, 12 Nov 2020 00:54:36 +0000
Importance: Normal
Great! Thanks so much
for helping again.
I also heard from
so we are now good.
Thanks for sending this out.
-
On Nov 11, 2020 7:52 PM,
(NY) (FBI)"
wrote:
Hi
SA
is able to assist on Friday.
Forwarded message
From:
(NY) (FBI)"
Date: Nov 11, 2020 3:50 PM
Subject: C-20 request for assistance 11/13
To: NY-NADP
Cc:
(NY) (FBI)"
All
Squad C-20 is requesting the assistance of two agents for the Maxwell investigation. They are looking for 2
volunteers to help out on Friday 11/13 from 9:00 am - 3:00 pm. You would have to show some discovery to
Maxwell and her defense team at MDC. It is digital evidence so a laptop and hard drive would be shown to
them.
If you are able to assist, please reach out to SA
(she is cc'd)
EFTA00038180


c1: EFTA00038703
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038703.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FBINET to UNET Uploaded Files
Date: Fri, 10 Sep 2021 23:23:20 +0000
Importance: Normal
Attachments: ADG_immigration_form192707.pdf
EFTA00038703


c1: EFTA00037914
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00037914.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
Subject: JE CART evidence
Date: Tue, 23 Jun 2020 17:21:08 +0000
Importance: Normal
Attachments: JE_EVIDENCE_CART.docx
Hey
,
I attached the sheet that
went over with you with CART numbers. I can't match up all the numbers with 1B
numbers- some of the cart numbers for the island I don't even have so I'm not sure where the mix up is. Are you
able to identify what items these are? Any info would be helpful.
Thanks,
EFTA00037914


c1: EFTA00038040
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038040.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
=
To:
Subject: GM conference
Date: Tue, 14 Jul 2020 15:43:35 +0000
Importance: Normal
Attachments: 2020.07.09_Scheduling_Order.pdf.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
C:
EFTA00038040


c1: EFTA00037921
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00037921.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Epstein message pad scans
Date: Wed, 04 Sep 2019 18:30:59 +0000
Importance: Normal
Hey
,
Are you in the office today? I wanted to check in about the message pad scans; I know that they are rather large.
I want to get them down drafted and on a disc or hard drive to get over to the AUSA's office before we proffer a
witness next week.
Also, do you have an estimate of the entire size of all that you scanned so I have a better idea of what device
SDNY will need to store everything?
Can you email me or give me a call
when you have a chance.
Thanks,
EFTA00037921


c1: EFTA00038386
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038386.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Maxwell Facebook subpoena
Date: Tue, 26 Nov 2019 15:28:04 +0000
Importance: Normal
Attachments: 2019-11-26,_subpoena_and_NDO_to_Facebook,_re_Maxwell_identifierspdf
Could you please serve the attached subpoena & NDO? Thanks!
EFTA00038386

=== Page 2 ===


c1: EFTA00038882
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038882.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(NY) (FBI)"
To:
(USANYS)"
Cc:
Subject: Re: Good news (and time sensitive request)
Date: Mon, 11 Apr 2022 12:39:51 +0000
Importance: Normal
Oh wow thank you! That's a really nice honor.
Sorry just seeing this.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
From:
(USANYS)
Sent: Sunday, April 10, 2022 11:17:35 PM
To:
(NY) (FBI)
Cc:
Subject: [EXTERNAL EMAIL] - Good news (and time sensitive request)
I hope you had a great weekend! We are writing to let you know that our Office is nominating you for the WIFLE (Women
in Federal Law Enforcement) award in recognition of your outstanding work on Maxwell and various other cases. Can you
please send us your DOB and the last 4 digits of your social security number before 9 am tomorrow? We need to forward
that information along to our supervisors before 9 am. Congratulations-this is so well deserved!!
EFTA00038882


c1: EFTA00038579
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038579.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Request for assistance C-20
Date: Thu, 08 Apr 2021 14:03:02 +0000
Importance: Normal
I definitely understand that. That would work. Thanks for canvassing.
Special Agent
FBI New York Field Office
On Apr 8, 2021 9:50 AM,
wrote:
Hi
Since it might be tough for agents to assist for three days, I can send this out to see if anyone can give a day for it if that
works for you guys? You might get two different people helping each day.
Let me know and I can resend the request.
From:
Sent: Wednesday, April 07, 2021 3:54 PM
To:
Subject: Request for assistance C-20
Hey Tracy,
Could you canvas for at least two agents, possibly three to assist with Maxwell and her defense team reviewing evidence
at 500 Pearl Street from Tuesday April 13 through Thursday April 15. This will be from 9:00am and continue for the entire
day for all three days. AUSA
will be present as well for the review. Please see below for additional info.
Maxwell and her defense team will all be present in the proffer room area on the 5th floor of the 500 Pearl Street
courthouse for the primary review. This review will begin on April 13, 2021 and will continue every day thereafter
until the review is complete. The logistics for this review are as follows:
The Marshals will produce Maxwell to 500 Pearl Street each morning by approximately 9:30am. Defense
counsel are expected to arrive each morning at approximately 9:30am. We will need at least one FBI
agent with a handcuff key who is responsible for pulling Maxwell from the Marshal cellblock and
monitoring her (the same way an agent would monitor any proffering inmate at 500 Pearl) throughout
the day. Please note that an agent will likely need to escort Maxwell to the bathroom during the day as
well.
AUSA
has reserved three proffer rooms for this review: The largest will be where the FBI can put
the evidence for review. The second largest will be where the defense can meet privately, without any of
the evidence items, to confer among themselves. The smallest will be a break area available for any
agents and/or AUSAs who are not currently monitoring the evidence review or maintaining custody of
Maxwell.
Thanks!
Special Agent
EFTA00038579

=== Page 2 ===
FBI New York Field Office
Child Exploitation/Human Trafficking
Des
Cell:
EFTA00038580


c1: EFTA00038047
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038047.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Fw: FBINET to UNET Uploaded Files
Date: Mon, 15 Jul 2019 19:55:26 +0000
Importance: Normal
Attachments: HOTLINE_TRACKER.xlsx
Inline-Images: Outlook-1510171437.png; Outlook-1510171974.jpg
NYPD Detective Bureau Child Exploitation/ Human Trafficking Task Force
N.Y. FBI Squad C20
Office
Desk
Fax
Cell
DEPARTMENT OF JUSTICE
*
D3
TOTAL BUREAU OF BURE INTERNATIONAL
From:
Sent: Monday, July 15, 2019 12:39 PM
To:
Subject: FW: FBINET to UNET Uploaded Files
Here is the updated spreadsheet.
Original Message
From: dropbox@ic.fbi.gov [mailto:dropbox@ic.fbi.gov]
Sent: Monday, July 15, 2019 12:37 PM
To:
Subject: FBINET to UNET Uploaded Files
EFTA00038047


c1: EFTA00037926
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00037926.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Amended GPS warrant
Date: Wed, 01 Jul 2020 13:12:29 +0000
Importance: Normal
Attachments: Amended_GPS_warrant.pdf
Hi
See attached.
EFTA00037926


c1: EFTA00038381
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038381.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: assistance with victim in
Date: Fri, 06 Dec 2019 15:32:15 +0000
Importance: Normal
Hi
- I am reaching out again to see how to proceed with the below? The victim has just reached out again
looking for assistance. She lives outside
-
If there is someone else I should teach out please let me
know.
Thank you again for your assistance!
-
On Nov 26, 2019 2:35 PM,
wrote:
Hi
- I am a Victim Specialist in New York and am reaching out in hopes that you can assist or guide me in the right
direction. As you may have seen we have an open case regarding Jeffrey Epstein for trafficking charges. There is an
identified victim who lives in
and she is asking for counseling assistance. How would I connect her to appropriate
referrals? I have asked her where she lives and am waiting to hear back. Any assistance is greatly appreciated. I have
copied the Case Agent
if you have any questions.
Thanks in advance! And Happy Thanksgiving!
FBI Victim Specialist
New York Field Office
EFTA00038381


c1: EFTA00038854
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038854.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
Cc:
Subject: RE: photo project
Date: Thu, 30 Sep 2021 20:30:59 +0000
Importance: Normal
Attachments: Photos_for_Trial_Prep_with_Location_Info.xlsx
Hi
The photo sourcing project is completed and attached.
I added 3 columns: Evidence Item #, Name of CD and Location of Item.
Thanks,
From:
Sent: Monday, September 27, 2021 6:26 PM
To:
Cc:
Subject: [EXTERNAL EMAIL] - photo project
Hi
Just checking in on the photo sourcing project. Do you think you'll be able to send us that spreadsheet in the next few
days?
Thanks so much for helping with this.
Assistant United States Attorney
Southern District of New York
EFTA00038854


c1: EFTA00038885
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038885.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: [EXTERNAL EMAIL] - victim notification
Date: Tue, 15 Feb 2022 20:47:40 +0000
Importance: Normal
From:
Sent: Wednesday, April 7, 2021 4:16 PM
To:
Cc:
Subject: RE: [EXTERNAL EMAIL] - victim notification
Hi
and
I hope that you are doing well.
is speaking with an immigration lawyer and wants to go forward with the T visa
application. I will give you more information about the status of that as I get more info from the immigration lawyer.
Also,
filed a claim W the Epstein Victims Compensation Fund. She had her interview W the fund managers yesterday.
I believe it went well. I am not sure how the process works but just wanted to give you a heads up in case they contact
you for confirmation or information regarding her victimization.
I also wanted to thank both of you again for all of your kindness toward
Please feel free to contact me if you have any questions.
Thanks!
Very truly yours,
Erica
Erica T. Dubno, Esq.
Fahringer & Dubno
43 West 43rd Street, Suite 261
New York, New York 10036
www.fahringerlaw.com
(fax)
IMPORTANT: This email (and any attachment) is exclusively for the intended recipient and likely contains information that is
proprietary, privileged, confidential or exempt from disclosure under law. If you are not the intended recipient, viewing, copying, use,
disclosure or distribution of this information may be subject to legal restriction or sanction, and is not intended to waive any privilege.
Please notify the sender of any unintended recipients and immediately delete the original message and any copies.
From:
Sent: Wednesday, September 2, 2020 4:06 PM
To: Erica T. Dubno, Esq.
Cc:
Subject: Re: [EXTERNAL EMAIL] - victim notification
EFTA00038885

=== Page 2 ===
Hi Erica - since these are all handled through USCIS we really are unable to speak on the best route. I would speak to an
Immigration Attorney who routinely works these types of cases; they would have a better idea the number of visas
approved each year and the timeframe.
I could connect you someone at Legal Aid who works on these all of the time- would you like me to connect you to her?
-
On Sep 2, 2020 3:42 PM, "Erica T. Dubno, Esq."
wrote:
We are trying to figure out whether you think she has a chance to get the T. Thanks!
Very truly yours,
Erica
Erica T. Dubno, Esq.
Fahringer & Dubno
43 West 43rd Street, Suite 261
New York, New York 10036
www.fahringerlaw.com
(fax)
IMPORTANT: This email (and any attachment) is exclusively for the intended recipient and likely contains information that
is proprietary, privileged, confidential or exempt from disclosure under law. If you are not the intended recipient, viewing,
copying, use, disclosure or distribution of this information may be subject to legal restriction or sanction, and is not
intended to waive any privilege. Please notify the sender of any unintended recipients and immediately delete the original
message and any copies.
On Sep 2, 2020, at 1:55 PM,
wrote:
Hi Erica - hope you are doing well too! I believe you said that your office has an Immigration attorney who will assist
her; is that still the case or do you need Immigration referrals? I know we discussed both options previously the last time
the three of us spoke; but wanted to see if you have any additional questions and would like to talk again?
Let me know what works best-
From: Erica T. Dubno, Esq. [mailto:
Sent: Tuesday, September 01, 2020 1:58 PM
To:
Cc:
Subject: Re: [EXTERNAL EMAIL] - victim notification
Hi
and
I hope you guys are doing well and managed to relax a little this summer.
would like to start the process for the U
(preferred) or T visa. Please let me know if you have any suggestions on this. Thanks so much.
Very truly yours,
Erica
EFTA00038886

=== Page 3 ===
Erica T. Dubno, Esq.
Fahringer & Dubno
43 West 43rd Street, Suite 261
New York, New York 10036
www.fahringerlaw.com
(fax)
IMPORTANT: This email (and any attachment) is exclusively for the intended recipient and likely contains information
that is proprietary, privileged, confidential or exempt from disclosure under law. If you are not the intended recipient,
viewing, copying, use, disclosure or distribution of this information may be subject to legal restriction or sanction, and is
not intended to waive any privilege. Please notify the sender of any unintended recipients and immediately delete the
original message and any copies.
On Aug 10, 2020, at 2:40 PM,
wrote:
Hi Erica,
Glad to hear that it worked out. I'm copying
on this as well.
Is the form you're referring to for OVS or immigration?
Thanks,
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
0
From:
Sent: Friday, August 7, 2020 6:53 PM
To:
Subject: [EXTERNAL EMAIL] - victim notification
Hi
managed to get the stamp. We are going to start the visa application process.
We are also filling out the victim forms.
How can we obtain a notification of identified victim letter for
?
Thank you and
again for everything. We really appreciate your dedication and compassion.
Very truly yours,
Erica
Erica T. Dubno, Esq.
Fahringer & Dubno
43 West 43ʳᵈ Street, Suite 261
EFTA00038887

=== Page 4 ===
New York, New York 10036
www.fahringerlaw.com
(fax)
IMPORTANT: This email (and any attachment) is exclusively for the intended recipient and likely contains information that is
proprietary, privileged, confidential or exempt from disclosure under law. If you are not the intended recipient, viewing, copying,
use, disclosure or distribution of this information may be subject to legal restriction or sanction, and is not intended to waive any
privilege. Please notify the sender of any unintended recipients and immediately delete the original message and any copies.
From:
Sent: Monday, August 3, 2020 3:01 PM
To: Erica T. Dubno, Esq.
Subject: Forms
Hi Erica,
Attached are the forms that were filled out when
came to the office. We can talk more in depth
tomorrow about the deferred action process.
EFTA00038888


c1: EFTA00038731
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038731.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Fw: Itinerary
From:
To:
Date:
Tue, 24 Aug 2021 14:22:18 -0400
Attachments:
KMTUFY. pdf (40.87 kB)
This is itinerary for
and the 3 kids.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
From:
Sent: Tuesday, August 24, 2021 11:47 AM
To:
Subject: Itinerary
EFTA00038731


c1: EFTA00038828
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038828.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Re: Video Conference
From:
To:
Date:
Fri, 21 Aug 2020 13:14:40 -0400
Hi
:
I am fairly certain Monday afternoon will work unless there is a change with
Do you have a
specific time in mind?
Best,
Sent from my iPhone
On Aug 20, 2020, at 7:28 PM,
wrote:
Hope all is well. Just checking in to see how next week is looking and if you are going to
be available for the 24th. No pressure if you're not able to swing it for that date, just
wanted to check in.
Thanks,
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
Sent: Wednesday, August 12, 2020 6:13 PM
To:
Subject: Re: Video Conference
Not a problem at all. We're wishing you guys the best. Let us know as we get closer if
anything changes with that date and your schedule.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
Sent: Wednesday, August 12, 2020 4:53 PM
To:
Subject: Re: Video Conference
EFTA00038828

=== Page 2 ===
Hello
At this time I have the 24th available. However,
starts radiation next Wednesday and I will
not have the upcoming schedule until then. I will stay in touch.
Best,
Sent from my iPhone
On Aug 12, 2020, at 10:37 AM,
wrote:
Hello
,
Hope you are feeling well. How does the afternoon of Monday 8/24 work for you
for a video conference? I've spoken with our team and that seems to be the best
date for us right now. If that doesn't work please let us know any other dates that
may be better for you.
Thanks again,
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
Sent: Monday, August 10, 2020 5:50 PM
To:
Cc:
Subject: Video Conference
Hello
,
Was nice speaking with you earlier and wishing you a speedy recovery from your
oral surgery. I will contact the prosecutors on the case and see what everyone's
availability is for the next couple of weeks and we will go from there. If you decide
that you prefer to have Sigrid involved that is fine just have her reach out to either
myself or the prosecutors.
Thanks again,
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
EFTA00038829


c1: EFTA00038615
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038615.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Trial gov exhibits
Date: Tue, 25 Feb 2025 16:21:45 +0000
Importance: Normal
Attachments: 2021.11.16_US_v_Maxwell_Government_Exhibit_Index.pdf
Special Agent
FBI Baltimore/Delaware
Violent Crime Safe Streets Task Force
EFTA00038615


c1: EFTA00038163
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038163.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(CRT)"
To:
(ODAG)"
(DO) (FBI)"
,
(ODAG)"
i
,
(DO) (FBI)"
(DO) (FBI)"
(NY) (FBI)"
Cc:
(NY) (FBI)"
,
(DO) (FBI)"
Subject: [EXTERNAL EMAIL] - RE: ODAG/FBI Briefing Conference Call
Date: Mon, 02 Nov 2020 19:54:54 +0000
Importance: Normal
Attachments: Survivor_Briefing_Invitees_ODAG_Master_List.xlsx
Hi all,
Thanks again for the call. Here attached is the updated Survivor Master list, with green and yellow highlighting in Column
H ("Other Notes") assigning issuing of invitations by telephone, and the outstanding victims for whom we still don't have
contact info still red-highlighted.
FBI folks, thank you also for following up with Sigrid re her victim list; and the Dubai request.
Thank you,
Mobile:
From:
(ODAG)
Sent: Monday, November 2, 2020 1:44 PM
To:
(DO) (FBI)
is
(ODAG)
is
(CRT)
is
(DO) (FBI)
is
(DO) (FBI)
is
(NY) (FBI)
Cc:
(NY) (FBI)
is
(DO) (FBI)
Subject: RE: ODAG/FBI Briefing Conference Call
Hi all,
Attached is a copy of the RSVP tracking spreadsheet for this afternoon's call. This includes RSVP and travel information for
responses received to date.
Thank you,
Original Appointment
From:
(DO) (FBI)
Sent: Monday, November 2, 2020 9:28 AM
To:
(DO) (FBI);
(ODAG);
(CRT);
(ODAG);
EFTA00038163

=== Page 2 ===
(DO) (FBI);
(DO) (FBI);
(NY) (FBI)
Cc:
(NY) (FBI);
(DO) (FBI)
Subject: ODAG/FBI Briefing Conference Call
When: Monday, November 2, 2020 2:00 PM-3:00 PM (UTC-05:00) Eastern Time (US & Canada).
Where:
Please use the line below to dial-in:
CALL
OR
Guest Passcode:
EFTA00038164


c1: EFTA00038502
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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0011/EFTA00038502.pdf
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=== Page 1 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 1 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
P
06/11/2019
215
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
21:42
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
P
06/02/2019
212
O
APIS
ON BOARD
LHR
BOS
NOELLE
00:00
MARION
MAXWELL
GHISLAINE
P
12/27/2018
8
I
A041
APC
APIS
ON BOARD
BOS
NRT
NOELLE
17:08
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
P
12/17/2018
7
O
APIS
ON BOARD
NRT
BOS
00:00
MAXWELL
GHISLAINE
P
08/29/2018
743
I
APIS
NOT ON
BOS
DOH
NOELLE
00:00
BOARD
MARION
MAXWELL
GHISLAINE
P
08/15/2018
59
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
12:05
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
P
08/01/2018
58
O
APIS
ON BOARD
LHR
BOS
NOELLE
00:00
MAXWELL
GHISLAINE
P
05/30/2018
213
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
13:20
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
P
05/21/2018
744
O
APIS
ON BOARD
DOH
BOS
NOELLE
00:00
MARION
MAXWELL
GHISLAINE
P
11/28/2017
59
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
11:46
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
P
11/21/2017
12
O
APIS
ON BOARD
LHR
BOS
NOELLE
00:00
MAXWELL
GHISLAINE
P
09/09/2017
59
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
12:32
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
P
08/22/2017
58
O
Name No
APIS
ON BOARD
LHR
BOS
NOELLE MAR
00:00
Name, No
MAXWELL
GHISLAINE
P
01/08/2017
11
I
A041
APC
APIS
ON BOARD
BOS
LHR
21:32
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
P
01/02/2017
12
O
APIS
ON BOARD
LHR
BOS
00:00
For Official Use Only / Law Enforcement Sensitive
EFTA00038502

=== Page 2 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY DISTON
TECS Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 2 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
P
11/20/2016
213
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
13:42
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
P
11/13/2016
212
O
Name No
APIS
ON BOARD
LHR
BOS
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
08/18/2016
11
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
15:57
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
P
07/25/2016
12
O
Name No
APIS
ON BOARD
LHR
BOS
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
11/27/2015
I
L382
VEHICLE
NOELLE
15:30
MAXWELL
GHISLAINE
P
08/28/2015
213
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
13:26
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
P
08/18/2015
112
O
Name No
APIS
ON BOARD
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
07/02/2015
9
I
A471
APC
APIS
ON BOARD
JFK
LHR
NOELLE
19:07
AUTOMATED
PASSPORT
CONTROL, JFK
MAXWELL
GHISLAINE
P
06/15/2015
474
O
Name No
APIS
ON BOARD
VCE
JFK
00:00
Name, No
MAXWELL
GHISLAINE
P
03/29/2015
4363
I
A741
APC
APIS
ON BOARD
MIA
NAS
11:15
AUTOMATED
PASSPORT
CONTROL, NAS
MAXWELL
GHISLAINE
P
03/27/2015
4270
O
Name No
APIS
NOT ON
NAS
MIA
00:00
Name, No
BOARD
MAXWELL
GHISLAINE
P
11/19/2014
1048
I
A471
APIS
PASSENGER
JFK
LTN
04:57
MAXWELL
GHISLAINE
P
11/19/2014
193
I
Name No
APIS
NOT ON
DFW
LHR
00:00
Name, No
BOARD
MAXWELL
GHISLAINE
P
11/15/2014
214
O
Name No
APIS
ON BOARD
LHR
BOS
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
11/09/2014
7462
I
A792
APC
APIS
ON BOARD
LGA
YUL
NOELLE
17:35
AUTOMATED
PASSPORT
CONTROL, YUL
MAXWELL
GHISLAINE
P
11/07/2014
5089
O
Name No
APIS
ON BOARD
YUL
LGA
00:00
Name, No
MAXWELL
GHISLAINE
P
11/02/2014
615
I
A472
APIS
ON BOARD
JFK
KEF
NOELLE
18:22
MAXWELL
GHISLAINE
P
10/29/2014
630
O
Name No
APIS
ON BOARD
KEF
BOS
NOELLE
00:00
Name, No
For Official Use Only / Law Enforcement Sensitive
EFTA00038503

=== Page 3 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY DISTON
TECS Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 3 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
P
09/01/2014
215
I
A041
APC
APIS
ON BOARD
BOS
LHR
NOELLE
20:22
AUTOMATED
PASSPORT
CONTROL, BOS
MAXWELL
GHISLAINE
P
07/30/2014
292
O
Name No
APIS
ON BOARD
LHR
IAD
NOELLE MAR
00:00
Name, No
MAXWELL
GHISLAINE
P
01/04/2014
45
I
A471
APC
APIS
ON BOARD
JFK
LHR
NOELLE
16:37
AUTOMATED
PASSPORT
CONTROL, JFK
MAXWELL
GHISLAINE
P
12/27/2013
5
I
Name No
APIS
NOT ON
MIA
LHR
NOELLE
00:00
Name, No
BOARD
MAXWELL
GHISLAINE
P
12/27/2013
1487
O
Name No
APIS
NOT ON
SXM
JFK
00:00
Name, No
BOARD
MAXWELL
GHISLAINE
P
12/26/2013
175
I
Name No
APIS
NOT ON
JFK
LHR
NOELLE
00:00
Name, No
BOARD
MAXWELL
GHISLAINE
P
12/09/2013
208
o
Name No
APIS
ON BOARD
LHR
MIA
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
11/09/2013
45
I
A471
APC
APIS
ON BOARD
JFK
LHR
NOELLE
16:00
AUTOMATED
PASSPORT
CONTROL, JFK
MAXWELL
GHISLAINE
P
10/30/2013
10
O
Name No
APIS
REQUEST
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
10/29/2013
22
O
Name No
APIS
NOT ON
LHR
IAD
00:00
Name, No
BOARD
MAXWELL
GHISLAINE
P
10/14/2013
617
I
A472
APIS
ON BOARD
JFK
KEF
NOELLE
19:30
MAXWELL
GHISLAINE
P
10/09/2013
614
O
Name No
APIS
ON BOARD
KEF
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
09/02/2013
3
I
A471
APIS
ON BOARD
JFK
LHR
NOELLE
12:16
MAXWELL
GHISLAINE
P
07/18/2013
46
O
Name No
APIS
ON BOARD
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
06/22/2013
7732
I
A795
APIS
ON BOARD
LGA
YOW
NOELLE
12:33
MAXWELL
GHISLAINE
P
06/21/2013
7733
O
Name No
APIS
ON BOARD
YOW
LGA
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
06/19/2013
25
I
A471
APIS
NOT ON
JFK
LHR
NOELLE
12:36
BOARD
MAXWELL
GHISLAINE
P
06/19/2013
3
I
Name No
APIS
ON BOARD
JFK
LHR
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
06/03/2013
10
O
Name No
APIS
ON BOARD
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
06/01/2013
10
O
Name No
APIS
NOT ON
LHR
JFK
NOELLE
00:00
Name, No
BOARD
For Official Use Only / Law Enforcement Sensitive
EFTA00038504

=== Page 4 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 4 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
P
04/05/2013
183
I
A472
APIS
JFK
LHR
NOELLE
22:51
MAXWELL
GHISLAINE
P
03/22/2013
22
O
Name No
APIS
LHR
IAD
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
03/14/2013
177
I
Name No
APIS
JFK
LHR
NOELLE MAR
00:00
Name, No
MAXWELL
GHISLAINE
P
02/08/2013
687
O
Name No
APIS
SXM
MIA
00:00
Name, No
MAXWELL
GHISLAINE
P
01/07/2013
9103
I
A151
APIS
ILM
SXM
14:52
MAXWELL
GHISLAINE
P
01/02/2013
2144
I
A52B
Name No
APIS
MIA
SXM
00:00
Name, No
MAXWELL
GHISLAINE
P
12/22/2012
177
I
AB52
Name No
APIS
JFK
LHR
NOELLE MAR
00:00
Name, No
MAXWELL
GHISLAINE
P
11/16/2012
845
O
Name No
APIS
HKG
JFK
00:00
Name, No
MAXWELL
GHISLAINE
P
11/15/2012
841
O
Name No
APIS
HKG
JFK
00:00
Name, No
MAXWELL
GHISLAINE
P
11/14/2012
10
O
Name No
APIS
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
10/03/2012
1031
I
A27G
APIS
LAX
LTN
NOELLE
03:52
MAXWELL
GHISLAINE
P
10/03/2012
1031
I
A27F
Name No
APIS
LAX
LTN
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
10/03/2012
17
I
AB5J
Name No
APIS
EWR
LHR
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
10/02/2012
1031
I
A27F
Name No
APIS
LAX
LTN
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
09/28/2012
78
O
Name No
APIS
LHR
DFW
00:00
Name, No
MAXWELL
GHISLAINE
P
09/28/2012
738
O
Name No
APIS
YYZ
SFO
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
09/03/2012
83
I
AB52
Name No
APIS
JFK
NCE
00:00
Name, No
MAXWELL
GHISLAINE
P
08/30/2012
MFALC
I
APIS
BGR
XXX
13:22
MAXWELL
GHISLAINE
P
08/30/2012
MFALC
I
Name No
APIS
TEB
XXX
00:00
Name, No
MAXWELL
GHISLAINE
P
06/15/2012
8057
O
Name No
APIS
GIG
MIA
00:00
Name, No
MAXWELL
GHISLAINE
P
05/29/2012
45
I
A471
APIS
JFK
LHR
16:35
MAXWELL
GHISLAINE
P
05/21/2012
172
O
Name No
APIS
LHR
JFK
00:00
Name, No
MAXWELL
GHISLAINE
P
04/12/2012
7
O
Name No
APIS
CDG
JFK
00:00
Name, No
For Official Use Only / Law Enforcement Sensitive
EFTA00038505

=== Page 5 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY DISTON
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 5 of 14
Last Name
First Name
DOB
Doc
Document
Date Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
P
04/05/2012
651
O
Name No
APIS
BGI
MIA
00:00
Name, No
MAXWELL
GHISLAINE
P
01/05/2012
5239
I
A461
APIS
TEB
DAV
NOELLE
18:26
MAXWELL
GHISLAINE
P
01/05/2012
2192
I
ABFT
Name No
APIS
MIA
PTY
00:00
Name, No
MAXWELL
GHISLAINE
P
12/28/2011
687
O
Name No
APIS
SXM
MIA
00:00
Name, No
MAXWELL
GHISLAINE
P
12/21/2011
219
I
A337
APIS
DEN
LHR
NOELLE
18:06
MAXWELL
GHISLAINE
P
12/09/2011
286
O
Name No
APIS
LHR
SFO
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
10/29/2011
268
O
Name No
APIS
TLV
JFK
00:00
Name, No
MAXWELL
GHISLAINE
P
08/28/2011
1078
I
A524
APIS
MIA
BGI
18:55
MAXWELL
GHISLAINE
P
07/27/2011
182
O
Name No
APIS
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
05/08/2011
N2767
I
Name No
APIS
BGR
XXX
00:00
Name, No
MAXWELL
GHISLAINE
P
05/07/2011
N2767
I
Name No
APIS
BGR
XXX
00:00
Name, No
MAXWELL
GHISLAINE
P
04/29/2011
N2767
O
Name No
APIS
XXX
NUQ
00:00
Name, No
MAXWELL
GHISLAINE
P
04/26/2011
1078
I
A524
APIS
MIA
BGI
19:04
MAXWELL
GHISLAINE
P
04/20/2011
871
O
Name No
APIS
BGI
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
03/28/2011
3
I
A471
APIS
JFK
LHR
13:10
MAXWELL
GHISLAINE
P
02/14/2011
45
I
A471
SUCARI-MUTT,
APIS
JFK
LHR
NOELLE
16:14
KARENA
MAXWELL
GHISLAINE
P
02/14/2011
3
I
AB52
Name No
APIS
JFK
LHR
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
02/09/2011
46
O
Name No
APIS
LHR
JFK
NOELLE
00:00
Name, No
MAXWELL
GHISLAINE
P
11/06/2010
179
I
A472
APIS
JFK
LHR
NOELLE
21:29
MAXWELL
GHISLAINE
P
10/29/2010
262
O
Name No
APIS
AMM
JFK
00:00
Name, No
MAXWELL
GHISLAINE
P
10/01/2010
N923CL
I
APIS
TEB
XXX
15:43
MAXWELL
GHISLAINE
P
10/01/2010
923CL
I
A10D
AIRLINE
TEB
NOELLE
14:09
(NOT
API)
For Official Use Only / Law Enforcement Sensitive
EFTA00038506

=== Page 6 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 6 of 14
Last Name
First Name
DOB
Doc
Document
Date Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
P
10/01/2010
N923CL
I
Name No
APIS
TEB
XXX
00:00
Name, No
MAXWELL
GHISLAINE
P
09/28/2010
N923CL
O
Name No
APIS
XXX
TEB
00:00
Name, No
MAXWELL
GHISLAINE
P
08/29/2010
183
I
A472
APIS
JFK
LHR
NOELLE
20:11
MAXWELL
GHISLAINE
P
08/29/2010
115
I
AB52
Name No Name
APIS
JFK
LHR
NOELLE
00:00
N
MAXWELL
GHISLAINE
P
08/01/2010
N17ND
O
Name No Name
APIS
XXX
TEB
00:00
N
MAXWELL
GHISLAINE
P
07/26/2010
N17ND
I
APIS
APA
XXX
01:29
MAXWELL
GHISLAINE
P
07/12/2010
N17ND
O
Name No Name
APIS
XXX
TEB
00:00
N
MAXWELL
GHISLAINE
P
07/11/2010
N17ND
O
Name No Name
APIS
XXX
TEB
00:00
N
MAXWELL
GHISLAINE
P
07/10/2010
N17ND
I
Name No Name
APIS
FRG
XXX
00:00
N
MAXWELL
GHISLAINE
P
06/21/2010
N17ND
O
Name No Name
APIS
XXX
TEB
00:00
N
MAXWELL
GHISLAINE
P
06/12/2010
N17ND
I
APIS
IAD
XXX
11:54
MAXWELL
GHISLAINE
P
06/11/2010
N17ND
O
Name No Name
APIS
XXX
IAD
00:00
N
MAXWELL
GHISLAINE
P
04/16/2010
N17ND
I
A276
AIRLINE
PSP
22:06
(NOT
API)
MAXWELL
GHISLAINE
P
04/16/2010
N17ND
I
Name No Name
APIS
PSP
XXX
00:00
N
MAXWELL
GHISLAINE
P
04/05/2010
N17ND
O
Name No Name
APIS
XXX
SAN
00:00
N
MAXWELL
GHISLAINE
P
03/21/2010
N17ND
I
APIS
SAN
XXX
18:46
MAXWELL
GHISLAINE
P
03/20/2010
N17ND
I
Name No Name
APIS
SAN
XXX
00:00
N
MAXWELL
GHISLAINE
P
03/16/2010
N17ND
O
Name No Name
APIS
XXX
OPF
00:00
N
MAXWELL
GHISLAINE
P
03/03/2010
N17ND
I
APIS
TEB
XXX
17:24
MAXWELL
GHISLAINE
P
03/03/2010
17ND
I
A10D
AIRLINE
TEB
17:13
(NOT
API)
MAXWELL
GHISLAINE
P
03/03/2010
N17ND
I
Name No Name
APIS
HPN
XXX
00:00
N
MAXWELL
GHISLAINE
P
03/01/2010
N17ND
O
Name No Name
APIS
XXX
SAN
00:00
N
For Official Use Only / Law Enforcement Sensitive
EFTA00038507

=== Page 7 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 7 of 14
Last Name
First Name
DOB
Doc
Document
Date Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
P
01/22/2010
N1 7ND
I
APIS
TEB
XXX
23:48
MAXWELL
GHISLAINE
P
01/22/2010
N1 7ND
I
A10D
AIRLINE
TEB
NOELLE
23:43
(NOT
API)
MAXWELL
GHISLAINE
P
01/22/2010
N1 7ND
I
Name No Name
APIS
HPN
XXX
00:00
N
MAXWELL
GHISLAINE
P
01/19/2010
N1 7ND
O
Name No Name
APIS
XXX
KSA
00:00
N
MAXWELL
GHISLAINE
P
01/07/2010
N17ND
I
APIS
HPN
XXX
21:23
MAXWELL
GHISLAINE
P
01/06/2010
N1 7ND
I
Name No Name
APIS
HPN
XXX
00:00
N
MAXWELL
GHISLAINE
P
12/27/2009
N1 7ND
O
Name No Name
APIS
XXX
KSA
00:00
N
MAXWELL
GHISLAINE
P
11/14/2009
N17ND
I
APIS
SAN
XXX
17:20
MAXWELL
GHISLAINE
P
11/08/2009
N17ND
o
Name No Name
APIS
XXX
PAN
00:00
N
MAXWELL
GHISLAINE
P
10/31/2009
N1 7ND
I
APIS
HPN
XXX
10:12
MAXWELL
GHISLAINE
P
10/30/2009
N17ND
I
Name No Name
APIS
HPN
XXX
00:00
N
MAXWELL
GHISLAINE
P
10/28/2009
N1 7ND
O
Name No Name
APIS
XXX
KIA
00:00
N
MAXWELL
GHISLAINE
P
08/13/2009
N1 7ND
I
Name No Name
APIS
SAN
XXX
00:00
N
MAXWELL
GHISLAINE
P
07/30/2009
N1 7ND
I
Name No Name
APIS
SAN
XXX
00:00
N
MAXWELL
GHISLAINE
P
07/19/2009
N1 7ND
O
Name No Name
APIS
XXX
KSA
00:00
N
MAXWELL
GHISLAINE
P
07/18/2009
269
I
A273
APIS
LAX
LHR
NOELLE
22:07
MAXWELL
GHISLAINE
P
07/11/2009
278
O
Name No Name
APIS
LHR
LAX
NOELLE
00:00
N
MAXWELL
GHISLAINE
P
07/08/2009
N1 7ND
O
Name No Name
APIS
XXX
KOM
00:00
N
MAXWELL
GHISLAINE
P
07/05/2009
N17ND
O
Name No Name
APIS
XXX
KDS
00:00
N
MAXWELL
GHISLAINE
P
06/28/2009
N17ND
I
Name No Name
APIS
SAN
XXX
00:00
N
MAXWELL
GHISLAINE
P
06/15/2009
N1 7ND
O
Name No Name
APIS
XXX
KSA
00:00
N
MAXWELL
GHISLAINE
P
05/03/2009
N1 7ND
I
A262
AIRLINE
TUS
NOELLE
12:37
(NOT
API)
For Official Use Only / Law Enforcement Sensitive
EFTA00038508

=== Page 8 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 8 of 14
Last Name
First Name
DOB
Doc
Document
Date Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINENOE
P
06/12/2008
10
I
A477
APIS
JFK
CDG
LLE
19:02
MAXWELL
GHISLAINE
P
06/06/2008
112
O
Name No Name
APIS
LHR
JFK
NOELLE MAR
00:00
N
MAXWELL
GHISLAINE
000
06/02/2008
17
I
A10D
AIRLINE
TEB
21:35
(NOT
API)
MAXWELL
GHISLAINE
P
04/30/2008
428WT
I
A10D
AIRLINE
TEB
10:26
(NOT
API)
MAXWELL
GHISLAINE
P
01/24/2008
428WT
I
A10D
AIRLINE
TEB
18:31
(NOT
API)
MAXWELL
GHISLAINE
P
11/17/2007
614RD
I
A523
AIRLINE
PBI
09:53
(NOT
API)
MAXWELL
GHISLAINE
P
08/22/2007
208
O
Name No Name
APIS
LHR
MIA
NOELLE
00:00
N
MAXWELL
GHISLAINE
P
04/21/2007
1
I
A471
APIS
JFK
STN
13:23
MAXWELL
GHISLAINE
P
01/01/2007
UNKN
I
A511
AIRLINE
16:41
(NOT
API)
MAXWELL
GHISLAINE
P
12/23/2006
N908
I
A511
AIRLINE
STT
10:19
(NOT
API)
MAXWELL
GHISLAINE
C
09/26/2006
2
I
A52B
AIRLINE
MIA
14:21
(NOT
API)
MAXWELL
GHISLAINE
P
06/28/2006
4
I
A52B
AIRLINE
MIA
22:51
(NOT
API)
MAXWELL
GHISLAINE
P
05/28/2006
279
I
A273
APIS
LAX
LHR
NOELLE
16:39
MAXWELL
GHISLAINE
P
01/02/2006
401WJ
I
A511
AIRLINE
STT
11:57
(NOT
API)
MAXWELL
GHISLAINE
P
12/22/2005
491GM
I
A511
AIRLINE
STT
14:22
(NOT
API)
MAXWELL
GHISLAINE
P
11/20/2005
268
O
Name No Name
APIS
LHR
LAX
NOELLE MAR
00:00
N
MAXWELL
GHISLAINE
P
10/17/2005
312P
I
A311
AIRLINE
ANC
09:18
(NOT
API)
MAXWELL
GHISLAINE
P
07/04/2005
182
O
Name No Name
APIS
LHR
JFK
NOELLE
00:00
N
For Official Use Only / Law Enforcement Sensitive
EFTA00038509

=== Page 9 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 9 of 14
Last Name
First Name
DOB
Doc
Document
Date Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
P
06/29/2005
401WJ
I
A523
AIRLINE
PBI
11:56
(NOT
API)
MAXWELL
GHISLAINE
P
06/04/2005
1
I
A492
AIRLINE
SJU
16:51
(NOT
API)
MAXWELL
GHISLAINE
P
05/29/2005
909JE
I
A523
AIRLINE
PBI
18:17
(NOT
API)
MAXWELL
GHISLAINE
P
02/19/2005
909JE
I
A523
AIRLINE
PBI
20:13
(NOT
API)
MAXWELL
GHISLAINE
P
02/12/2005
I
A52B
AIRLINE
20:48
(NOT
API)
MAXWELL
GHISLAINE
P
01/02/2005
401WJ
I
A523
AIRLINE
PBI
13:19
(NOT
API)
MAXWELL
GHISLAINE
P
08/25/2004
908JE
I
A523
AIRLINE
PBI
17:42
(NOT
API)
MAXWELL
GHISLAINE
P
07/18/2004
9
I
A471
APIS
JFK
LHR
22:03
MAXWELL
GHISLAINE
P
07/11/2004
46
O
Name No Name
APIS
LHR
JFK
00:00
N
MAXWELL
GHISLAINE
P
06/04/2004
174
O
Name No Name
APIS
LHR
JFK
NOELLE MAR
00:00
N
MAXWELL
GHISLAINE
P
05/12/2004
8
I
A477
AIRLINE
JFK
CDG
21:10
(NOT
API)
MAXWELL
GHISLAINE
P
02/07/2004
207
I
A520
APIS
MIA
LHR
14:43
MAXWELL
GHISLAINE
P
01/02/2004
1
I
A523
AIRLINE
PBI
18:03
(NOT
API)
MAXWELL
GHISLAINE
P
12/24/2003
909JE
I
A523
AIRLINE
PBI
17:52
(NOT
API)
MAXWELL
GHISLAINE
P
11/02/2003
23
O
Name No Name
APIS
CDG
JFK
00:00
N
MAXWELL
GHISLAINE
P
10/08/2003
115
I
A472
APIS
JFK
LHR
19:09
MAXWELL
GHISLAINE
P
09/30/2003
2
O
Name No Name
APIS
LHR
JFK
00:00
N
MAXWELL
GHISLAINE
P
06/14/2003
909JE
I
A523
APIS
PBI
20:29
MAXWELL
GHISLAINE
P
05/29/2003
1
I
A472
APIS
JFK
LHR
17:43
For Official Use Only / Law Enforcement Sensitive
EFTA00038510

=== Page 10 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 10 of 14
Last Name
First Name
DOB
Doc
Document
Date Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
P
04/11/2003
1
I
A523
APIS
PBI
00:45
MAXWELL
GHISLAINE
P
04/01/2003
491GM
I
A511
APIS
STT
14:38
MAXWELL
GHISLAINE
P
03/23/2003
909JE
I
A523
APIS
PBI
21:43
MAXWELL
GHISLAINE
P
02/21/2003
1
I
A471
APIS
JFK
LHR
09:33
MAXWELL
GHISLAINE
P
01/02/2003
615A
T
A491
Name No Name
APIS
STT
EIS
00:00
N
MAXWELL
GHISLAINE
P
12/31/2002
222
T
A491
Name No Name
APIS
SBH
STT
00:00
N
MAXWELL
GHISLAINE
A
08/30/2002
672
I
A512
AIRLINE
12:50
(NOT
API)
MAXWELL
GHISLAINE
P
08/04/2002
283
I
2720
APIS
LAX
LHR
19:00
MAXWELL
GHISLAINE
A
04/18/2002
908JE
I
A523
AIRLINE
17:57
(NOT
API)
MAXWELL
GHISLAINE
A
03/18/2002
5
I
A511
AIRLINE
09:45
(NOT
API)
MAXWELL
GHISLAINE
A
01/13/2002
1
I
A523
AIRLINE
20:59
(NOT
API)
MAXWELL
GHISLAINE
A
12/23/2001
I
A511
AIRLINE
16:21
(NOT
API)
MAXWELL
GHISLAINE
P
10/01/2001
209
I
5206
APIS
MIA
LHR
18:20
MAXWELL
GHISLAINE
P
08/01/2001
6
I
4701
APIS
JFK
CDG
18:31
MAXWELL
GHISLAINE
A
07/01/2001
1
I
A511
AIRLINE
15:04
(NOT
API)
MAXWELL
GHISLAINE
A
06/29/2001
909
I
A511
AIRLINE
00:36
(NOT
API)
MAXWELL
GHISLAINE
A
02/21/2001
672
I
A511
AIRLINE
14:02
(NOT
API)
MAXWELL
GHISLAINE
A
09/05/2000
115
I
A472
AIRLINE
18:15
(NOT
API)
MAXWELL
GHISLAINE
P
07/17/2000
115
I
4701
APIS
JFK
LHR
17:59
For Official Use Only / Law Enforcement Sensitive
EFTA00038511

=== Page 11 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 11 of 14
Last Name
First Name
DOB
Doc
Document
Date - Time
Carrier
Carrier
I/O
Site
Insp
Type
Status
Ref
Arr
Dep
Type
Number
Code
Num.
Loc
Loc
MAXWELL
GHISLAINE
P
06/23/2000
1
I
4701
APIS
JFK
LHR
09:22
MAXWELL
GHISLAINE
A
04/16/2000
733TA
I
A523
AIRLINE
20:59
(NOT
API)
MAXWELL
GHISLAINE
P
03/09/2000
175
I
4701
APIS
JFK
LHR
13:28
MAXWELL
GHISLAINE
A
02/05/2000
20700
I
A511
AIRLINE
15:34
(NOT
API)
MAXWELL
GHISLAINE
A
01/21/2000
505LS
I
A523
AIRLINE
23:35
(NOT
API)
Total Number of Records: 203
Legend
Loc
For Official Use Only / Law Enforcement Sensitive
EFTA00038512

=== Page 12 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS - - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 12 of 14
Codes
Value
YOW
OTTAWA
NAS
NASSAU INTL
LAX
LOS ANGELES, CA INTL
OPF
OPA LOCKA
CDG
PARIS, CH. DE GAULLE
SXM
ST MAARTEN, PRINCE JULIANA
ILM
NEW HANOVER COUNTY
STN
LONDON, STANSTED
JFK
JOHN F KENNEDY INTL
NRT
NARITA, TOKYO
STT
C.E. KING
DFW
DALLAS/FT WORTH INTL
PBI
WEST PALM BEACH
KDS
KDS
DOH
DOHA#INTERNATIONAL, QATAR
AMM
QUEEN ALIA INTL
KIA
KIA
MIA
MIAMI INTL, FL
GIG
RIO DE JANEIRO
HKG
HONG KONG
BGI
BARBADOS, GRANTLEY ADAMS INTL
BOS
BOSTON / LOGAN INTL
LGA
LA GUARDIA
BGR
BANGOR
PSP
PALM SPRINGS
KEF
REYKJAVIK / KEFLAVIK INTL
IAD
DULLES INTL
EIS
BEEF ISLAND, VIRGIN ISLAND (BRITISH)
YUL
DORVAL, MONTREAL
NCE
COTE D'AZUR
ANC
ANCHORAGE
VCE
MARCO POLO
YYZ
TORONTO, PEARSON INTERNATIONAL
SAN
LINDBERG FLD S.DIEGO
LTN
LUTON INTERNATIONAL
HPN
WESTCHESTER
PTY
PANAMA, OMAR TORRIJOS H
LHR
LONDON / HEATHROW INTL
KSA
KOSRAE, CAROLINE IS. #ARPT, P. OCEAN
For Official Use Only / Law Enforcement Sensitive
EFTA00038513

=== Page 13 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
HOMELAND SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 13 of 14
Codes
Value
SBH
ST. BARTHELEMY#ARPT, GUADELOUPE
XXX
UNKNOWN AIRPORT (USED ONLY WHEN THE AIRPORT CODE IS UNKNOWN)
SFO
SAN FRANCISCO INTL AIRPORT
TLV
BEN GURION INTL
SJU
SAN JUAN, LUIS MUNOZ MARIN INTL
EWR
NEWARK INTERNATIONAL
KOM
KOM
NUQ
MOFFETT FIELD
DEN
DENVER INTERNATIONAL AIRPORT
TEB
TETERBORO
APA
ARAPAHOE CO
TUS
TUCSON
DAV
ENRIQUE MALEK
FRG
REPUBLIC FIELD
PAN
PAN
Doc Type
Codes
Value
P
P - PASSPORT
000
000
A
A - U.S. ALIEN REGISTRATION CARD
C
C - PERMANENT RESIDENT CARD
Site Code
For Official Use Only / Law Enforcement Sensitive
EFTA00038514

=== Page 14 ===
U.S. DEPARTMENT OF
U.S. Customs and Border Protection
U.S. Department of Homeland Security
DISTON SECURITY
TECS - Person Encounter List
09/23/2019 14:20 EDT
Generated By:
Page 14 of 14
Codes
Value
L382
L382 - CBP-DETROIT, WINDSOR TUNNEL
AB5J
AB5J - INS-NEWARK ASYLUM *HIST*
A524
A524 - CBP-MIAMI, AIRPORT CNTRL TERML
A523
A523 - CBP-PALM BEACH, INTERNATIONAL
A520
A520 - CBP-MIAMI, AIRPORT N TERMINAL
A741
A741 - CBP-NASSAU, BAHAMAS PRECLEAR
A461
A461 - CBP-TETERBORO, AIRPT HANGER 2
A041
A041 - CBP-BOSTON, LOGAN AIRPORT
A262
A262 - CBP-TUCSON, IAP ARRIVALS
2720
2720 - 2720
4701
4701 - 4701
A27F
A27F - CBP-LOS ANGELES, ATLANTIC AVN
A27G
A27G - CBP-LOS ANGELES, LANDMARK GAF
AB52
AB52 - INS-JFK AIRPORT
A337
A337 - CBP-DENVER, INTL AIRPORT
A511
A511 - CBP-CYRIL E KING, INTL AIRPORT
A512
A512 - CBP-ST THOMAS, VI PREDEPARTURE
A795
A795 - OTTAWA, MCDONALD-CARTIER INTL
A311
A311 - CBP-ANCHORAGE, INTL AIRPORT
A477
A477 - NEW YORK, JFK AIRPORT, TERM 1
A276
A276 - CBP-PALM SPRINGS, REGIONAL APT
A472
A472 - NEW YORK, JFK AIRPORT, TERM 7
A792
A792 - MONTREAL CD, DORVAL, PRECLEAR
ABFT
ABFT - INS-MIAMI OGC *HIST*
A151
A151 - CBP-WILMINGTON, INT'L AIRPORT
A492
A492 - CBP-SAN JUAN, MUNOZ MARIN IAP
A471
A471 - NEW YORK, JFK AIRPORT, TERM 4
A273
A273 - LOS ANGELES, BRADLEY AP LAX
A491
A491 - SAN JUAN, PASSENGER BRANCH
A52B
A52B - MIAMI, AIRPORT, GEN AVIATION
A10D
A10D - CBP-TETERBORO, JET AVIATION
5206
5206 - 5206
For Official Use Only / Law Enforcement Sensitive
EFTA00038515


