# docs_fts_content

c1: EFTA00027430
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027430.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
Subject: RE: New drive for Maxwell
Date: Fri, 04 Dec 2020 20:21:52 +0000
In particular, there appears to be a track change that is included in the second page, which we are hoping you
could fix before we submit this to Judge Nathan.
We also were hoping to chat about some other issues, but even if that's not possible, we're hoping we can provide
the court with a clean copy without the track change.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
Original Message
From:
Sent: Friday, December 4, 2020 2:20 PM
To:
Cc:
Subject: RE: New drive for Maxwell
Thank you very much. Would you have time for a quick call to discuss, please?
Best,
Assistant United States Attorney
Southern District of New York
EFTA00027430

=== Page 2 ===
New York, NY 10007
Original Message
From:
Sent: Friday, December 4, 2020 2:04 PM
To:
Cc:
Subject: RE: New drive for Maxwell
Attached please find the letter to Hon. Nathan.
Best,
Staff Attorney
Department of Justice
Federal Bureau of Prisons
Metropolitan Detention Center Brooklyn
Brooklyn, New York 11232
P:
E:
SENSITIVE/PRIVILEGED COMMUNICATION
The information contained in this electronic message and any and all accompanying documents constitutes
sensitive information. This information is the property of the U.S. Department of Justice. If you are not the
intended recipient of this information, any disclosures, copying, distribution, or the taking of any action in
reliance on this information is strictly prohibited. If you received this message in error, please notify us
immediately to make arrangements for its return to us.
)"
12/4/2020 9:39
AM
Thank you very much.
Original Message
From:
Sent: Friday, December 4, 2020 7:41 AM
To:
i
Cc:
)
(
EFTA00027431

=== Page 3 ===
Subject: Re: New drive for Maxwell
Not a problem.
Best,
)"
12/3/2020 5:24
PM
Hi all,
Today our office is sending via FedEx a replacement drive for Ghislaine Maxwell, which should arrive at the
MDC tomorrow. This drive will replace the drive that Maxwell recently dropped and broke, and the
accompanying cover letters are attached. Would you please make sure Maxwell is given access to this drive?
Would you please mail the broken drive back to our office? It can be mailed to the below address:
Paralegal Specialist
U.S. Attorney's Office, SDNY
New York, NY 10007
Thanks very much, as always, for your help.
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
<mailto:
EFTA00027432


c1: EFTA00027842
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027842.pdf
c6: pdf
c7: images
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=== Page 1 ===
From:
To:
Subject: RE: Epstein -- travel approval form
Date: Fri, 31 Jan 2020 18:47:05 +0000
& thanks for helping with this.
From:
Sent: Friday, January 31, 2020 1:47 PM
To:
Subject: RE: Epstein -- travel approval form
Any updates on the signed memo?
said I need to email it to EOUSA this afternoon.
From:
Sent: Friday, January 31, 2020 12:53 PM
To:
Cc:
Subject: RE: Epstein -- travel approval form
Already signed and sent upstairs
I will do my best to ensure signature immediately.
Re: this afternoon: it may be best to kick it to next week. If some time develops before 3, I'll let you know, but right now
it is iffy.
From:
Sent: Friday, January 31, 2020 12:21 PM
To:
Cc:
Subject: Epstein -- travel approval form
We dropped off the Sweden travel memo for you - we were unexpectedly significantly delayed in getting OIA approval,
but it finally came this morning, so with apologies for the short turnaround, hoping to get Office and final DOJ approval
this afternoon. Thank you!
And separately, if you still wanted to meet up today, l'll be around until about 3:00, but I'm also flexible next week if that's
easier.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00027842


c1: EFTA00027397
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027397.pdf
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=== Page 1 ===
From:
To:
)"
Subject: Automatic reply: Epstein SW database
Date: Wed, 28 Apr 2021 13:53:20 +0000
I will be out of the office Starting on April 28, 2021 - April 30, 2021. I will be back in the office on May 3, 2021
If there are any questions please contact either
Thank you.
EFTA00027397


c1: EFTA00028123
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028123.pdf
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=== Page 1 ===
Event: Accepted: Epstein estate
Start Date: 2019-10-23 18:30:00 +0000
End Date: 2019-10-23 19:00:00 +0000
Location: Skype Meeting; Conference ID: 803 102 52;
Class: X-PERSONAL
Comment:
Date Created: 2019-10-23 13:34:28 +0000
Date Modified: 2019-10-23 13:34:28 +0000
Priority: 5
DTSTAMP: 2019-10-23 13:20:20 +0000
Attendee: Weinstein, Marc A.
EFTA00028123


c1: EFTA00027109
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027109.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
Cc:
Subject: Tova Noel
Date: Wed, 14 Aug 2019 15:32:20 +0000
Attachments: 2019.08.14_Tova_Noel_Subpoena.pdf
Mr. Foy,
Based on our phone conversation, I understand that you represent Ms. Noel and are authorized to accept service of this
subpoena on her behalf. Please see attached.
Thanks,
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00027109


c1: EFTA00027341
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027341.pdf
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=== Page 1 ===
From:
"
)"
To:
"
(USANYS) [Contractor]"
Cc:
"
)"
,
(USANYS)"
Subject:
3500
Date: Thu, 08 Apr 2021 18:08:33 +0000
Embedded: RE:
; Re: Epstein.msg; RE: Updated vic list.msg;
; Re:
; RE:
;
Re:
(1).msg; FW:
; Re:
(2).msg;
Re:
(3).msg
Hi
The attached emails should all go into
witness folder and should also be saved as potential 3500 for
her, please.
we should discuss later on what should be redacted from these.
,
Thanks,
EFTA00027341


c1: EFTA00028594
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028594.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Bill Richardson
Date: Thu, 13 May 2021 16:08:11 +0000
Embedded: FW:_Richardson.msg
Hi
Can we find some time next week to discuss the WebEx
and I had today with former Governor Bill
Richardson's new attorneys, please? Not urgent.
For context, attached is email correspondence from 2019 regarding
interactions with Richardson's prior
counsel.
Thanks,
EFTA00028594


c1: EFTA00029305
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00029305.pdf
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c7: images
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=== Page 1 ===
Event: Accepted: Epstein Team Meeting
Start Date: 2019-12-09 20:30:00 +0000
End Date: 2019-12-09 21:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-12-08 21:21:03 +0000
Date Modified: 2019-12-08 21:21:03 +0000
Priority: 5
DTSTAMP: 2019-12-08 21:09:57 +0000
Attendee:
(USANYS)
EFTA00029305


c1: EFTA00028545
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028545.pdf
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=== Page 1 ===
Event: Declined: Epstein discovery deadline
Start Date: 2019-10-31 21:00:00 +0000
End Date: 2019-10-31 21:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-08-15 22:01:05 +0000
Date Modified: 2019-08-15 22:01:05 +0000
Priority: 5
DTSTAMP: 2019-08-15 17:27:30 +0000
Attendee:
EFTA00028545


c1: EFTA00027390
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027390.pdf
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=== Page 1 ===
From:
Subject: Maxwell scheduling updates
Date: Fri, 27 Aug 2021 23:09:57 +0000
Attachments: 2021.08.27_Order_re_Maxwell_trial_schedule.pdf
Hi
Judge Nathan just issued the attached order setting out a number of dates for the Maxwell trial. Would you be able to
update the victim website with these dates, please?
Thanks very much,
EFTA00027390


c1: EFTA00027845
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027845.pdf
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=== Page 1 ===
From:
To:
Subject: Accepted: FW: GHISLAINE MAXWELL Removal Hearing 20mj132-01
Date: Thu, 02 Jul 2020 16:26:33 +0000
Importance: Normal
Attachments: unnamed
EFTA00027845


c1: EFTA00027437
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027437.pdf
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=== Page 1 ===
From:
To:
'Chiefs'
Bee:
Subject: SDNY NEWS CLIPS, MONDAY, DECEMBER 7, 2020
Date: Mon, 07 Dec 2020 20:11:33 +0000
Inline-Images: image001.png
SDNY PRESS CLIPPINGS
DISCOUNT
JUSTITIA
MAXWELL
REUTERS: https://www.reuters.com/article/us-people-ghislaine-maxwell-idUSKBN28H2/9
NY POST: https://nypost.com/2020/12/07/bureau-of-prisons-defends-ghislaine-moxwells-jail-conditions/
CNN: https://www.cnn.com/2020/12/06/us/ghislaine-maxwell-motion-bail/index.html
GRANDISON
WWhttps://wwwwwp.com/news/bonx-resident-charged-with-sheitering-massochusets-fugitive-and-making-false-claims-in-shooting-of-wo-us-marshals/
MSN: https://www.msn.com/en-us/news/crime/bronx-man-charged-with-lying-to-us-marshals-before-deadly-shooting/ar-BB1bl21-
MATTERS OF INTEREST
WAPO:https://www.washingtonpost.com/national-security/william-bar-may-resign/2020/12/06/bbc5f7e-382a-11eb-9276-ae0ca72729be_storyhtml
CNN: https://www.cnn.com/2020/12/06/politics/william-bar-considering-leaving-office/index.htm
CNN: https://www.cnn.com/2020/12/06/politics/rudy-giulian-coronavirus-positive/index.html
FOX: https://www.foxnews.com/politics/gop-rep-ken-buck-hunter-biden-special-counsel
USATODAY: https://www.usatodoy.com/story/news/politics/2020/12/07/politics-updates-joe-biden-donaldtrump-presidential-transition/3854979001/
YAHOO: https://news.yahoo.com/people-able-apply-daca-again-144905135.html
CNBC: https://www.con.com/2020/12/06/politics/william-borr-considering-leaving-ofice/index.html
BUSINESS INSDER: htps://www.businessinsider.com/georgia-republican-kely-loeffler-dodges-question-about-stock-troding-2020-12
PROPUBLICA: htps://www.propublica.org/article/nypd-cops-cash-in-on-sex-trade-arrests-with-litevidence-while-black-and-brown-new-yorkers-pay-the-price
NYDN: ttps://www.nydailynews.com/news/politis/nw-york-elections-government/ny-brion-benjamin-nypd-settements-20201207-zb2toeanz5bujf34e5tpnktgystory.hml
EFTA00027437


c1: EFTA00028124
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028124.pdf
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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher
approved by
,
now awaiting further
approval
Date: Thu, 24 Oct 2019 16:41:30 +0000
Importance: Normal
Dear
Final voucher
has been approved by
now awaiting further approval.
Trip ID:
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R19NYS13842 - U.S. V. Epstein - Witness Interviews
Destination:
Dates: 2019-09-17 - 2019-09-20
Current status: Pending Voucher Approval
Voucher total expenses: 2152.79
Estimated trip cost: 2489.21
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#
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.
EFTA00028124


c1: EFTA00027219
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00027219.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
Bank of America, N.A.
Legal Order Processing
P.O. Box 15047
Wilmington, DE 19850-5047
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before
the GRAND JURY of the people of the United States for the Southern District of New York, at the United States
Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the
Southern District of New York, at the following date, time and place:
Appearance Date:
August 30, 2019
Appearance Time: 10:00 a.m.
to testify and give evidence in regard to an alleged violation of :
18 U.S.C. §§ 201, 371, 1001, 1346, 1519, 2
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
Please see attached rider. Personal appearance is not required if the requested records are (1) produced on or
before the return date to Assistant U.S. Attorney
of the United States Attorney's Office, 1 St.
Andrew's Plaza, New York, NY 10007. Tel:
, email:
, and (2)
accompanied by an executed copy of the attached Declaration of Custodian of Records. Ref No. 2019R01059.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
August 17, 2019
Geoffey
S.
with
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
DEPARTMENT IIIIII UNITED COURT
Assistant United States Attorney
FOR
One St. Andrew's Plaza
THE
RICT
YORK
New York, New York 10007
or
NEW
Telephone:
Email:
rev. 02.01.12
EFTA00027219

=== Page 2 ===
RIDER
(Grand Jury Subpoena to Bank of America, dated August 17, 2019)
Ref. No. 2019R01059
REQUEST:
For the following account, and any other account controlled by the account holder of one of the below
accounts:
Please provide any and all documents, to include, but not limited to those identified below, for the period
January 1, 2019 until the present:
a. Account opening documents, including applications and signature cards;
b. Records of account holders for debit and credit cards liked to the accounts;
c. Account statements and ledgers;
d. Images of checks (both front and back) deposited in account;
e. Images of canceled checks (both front and back) drawn on account;
f. Images of cashier's checks (both front and back) and depositing bank account information;
g. Account deposit slips, withdrawal slips, debit & credit memos, and cash tickets;
h. Detailed wire transfer records, ACH transfer records (including routing/account numbers funds
transferred to/from), money orders, and traveler's check records;
i. All credit card and line of credit records, including, but not limited to: applications, monthly
statements, billing slips, and records evidencing the source of payment (copies of checks, ACH
records (including routing/account numbers funds transferred to/from), or cash received slips);
j. Customer information associated with the account, including name(s), address(es), telephone
number(s), e-mail address(es), and any other identifying or contact information.
INSTRUCTIONS FOR PRODUCTION OF DOCUMENTS:
1. All transactions-based information, include wire and ACH transfers, withdrawals/deposits,
charges/payments, and bank account activity should be provided in electronic spreadsheet
format (either Microsoft Excel or similarly compatible format). Specifically:
a. For wires and other types of transfers, the account holder name, account number, and bank
name of both the originator and beneficiary of the transaction should be clearly stated in
separate fields.
b. Cash and check transactions should be indicated within a transaction type field.
i. Check transactions should include the name of the payee in the recipient
field. Additionally, check images should be attached in graphic data files in a commonly
readable, non-proprietary format with the highest image quality maintained, and named in
a manner that uniquely associates them with the relevant transaction record(s).
EFTA00027220

=== Page 3 ===
ii. Cash withdrawals should be indicated with CASH written in the recipient field.
iii. Cash deposits should be indicated with CASH written in the sender/originator field.
c. Field headers should be included for each column of data, and a data dictionary or other
explanation of the contents of each column provided.
2. Where more than one account is being requested, each account's transaction records should be
returned in a separate file.
3. All document images are to be produced in electronic PDF format. Where images of checks,
deposit slips, withdrawal slips, or cash tickets are being produced, they should be produced no
more than two per page.
4. In lieu of an appearance you may comply with this subpoena by providing the requested
information, along with a business records certification pursuant to Fed. R. Evid. 803(6) to
Assistant U.S. Attorney
of the United States Attorney's Office, 1 St. Andrew's
Plaza, New York, NY 10007. Tel:
, email:
EFTA00027221

=== Page 4 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the
business named below, or I am otherwise qualified as a result of my position with the business named below to
make this declaration.
I am in receipt of a Grand Jury Subpoena, dated August 17, 2019, and signed by Assistant United States
Attorney
,
requesting specified records of the business named below. Pursuant to Rules 902(11) and
803(6) of the Federal Rules of Evidence, I hereby certify that the records provided herewith and in response to the
Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from
information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
-
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any form, of acts,
events, conditions, opinions, or diagnoses. The term "business" as used in Fed. R. Evid. 803(6) and the above declaration
includes business, institution, association, profession, occupation, and calling of every kind, whether or not conducted for
profit.
EFTA00027222

=== Page 5 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 17, 2019
Re:
Grand Jury Subpoena
This letter describes the procedure for requesting reimbursement for subpoenaed records.
12 CFR part 219 (subpart A), issued by the Board of Governors of Federal Reserve System under section
1115 of the Right to Financial Privacy Act (12 U.S.C. $ 3415), sets the rates and conditions for reimbursement of
costs directly incurred by financial institutions in assembling or providing customer financial records to a
government authority pursuant to the Act. No costs are reimbursable if the records are those of a corporation or a
partnership comprised of more than five individuals.
If reimbursement is authorized, and the estimated billing to the government will exceed $500, advance
permission is necessary from
at
If the subpoenaed records indicated on the rider are eligible for reimbursement, please complete section B
of the enclosed form OBD-211, which will serve as your invoice, and return it with a copy of the subpoena to the
following address:
U.S. Attorney's Office - SDNY
Accounts Payable
86 Chambers Street, 3rd floor
New York, NY 10007
Please send your invoice to the above address within 60 days of the submission of the subpoenaed records.
If no invoice is received within 120 days, funds will not be available to pay the invoice.
Thank you for your cooperation in this matter.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
By:
/s/
Assistant United States Attorney
Enclosure: OBD- 211
EFTA00027223


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10982122 approved by
,
, now awaiting further
approval
Date: Tue, 28 Jan 2020 16:12:08 +0000
Importance: Normal
Dear
Travel authorization 10982122 has been approved by
,
, now awaiting further approval.
Trip ID: 10982122
Traveler name:
Purpose: R20NYS13340 - Epstein investigation (2018R01618) - Witness Interviews
Destination: Stockholm, Sweden
Dates: 2020-02-03 - 2020-02-06
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.
EFTA00027839


c1: EFTA00028158
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028158.pdf
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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: VW Update draft
Date: Mon, 22 Jul 2019 19:51:51 +0000
Perfect, thanks
From:
(USANYS)
Sent: Monday, July 22, 2019 15:51
To:
Subject: RE: VW Update draft
Ah, I totally spaced this time, thanks for putting on top. It's done: https://www.justice.gov/usao-
sdny/programs/victim-witness-services/united-states-v-jeffrey-epstein-19-cr-490-rmb
From:
Sent: Monday, July 22, 2019 3:45 PM
To:
(USANYS)
Subject: RE: VW Update draft
Wanted to just quickly bump this - no emergency or anything but it's ready to go up when you have a chance - thanks!
From:
)
Sent: Friday, July 19, 2019 17:24
To:
(USANYS)
Subject: RE: VW Update draft
Hey thanks very much - let's do:
July 19, 2019 update:
On July 18, 2019, a status conference was held in the case of United States V. Jeffrey Epstein, 19 Cr. 490 (RMB).
The court announced its ruling that the defendant will be incarcerated pending trial. The next conference, which
is expected to address scheduling and administrative matters, is scheduled for Wednesday, July 31, 2019, at
11:30 a.m. before the Honorable Richard M. Berman, United States District Judge for the Southern District of
New York, Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, New York, in
Courtroom 17B.
thanks again, and have a great weekend!
From:
(USANYS)
Sent: Friday, July 19, 2019 09:01
To:
Subject: VW Update draft
July 18, 2019 update:
EFTA00028158

=== Page 2 ===
On July 18, 2019, the court announced its ruling that Jeffrey Epstein must remain in custody pending trial.
The first pretrial conference in United States V. Jeffrey Epstein, 19 Cr. 490 (RMB) is scheduled for Wednesday,
July 31, 2019, at 11:30 a.m. before the Honorable Richard M. Berman, United States District Judge for the
Southern District of New York, Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York,
New York, in Courtroom 17B.
Sent from my iPhone
EFTA00028159


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=== Page 1 ===
Sent:
Mon, 14 Jan 2013 16:06:26 +0000
From:
"Amazon.com" <ship-confirm@amazon.com>
To:
"jeeproject@yahoo.com" <jeeproject@yahoo.com>
Subject:
Your Amazon.com order of 2x "USB lightning cable for..." has shipped!
Kindle Store
Your Orders
Amazon.com
Shipping Confirmation
Order #109-6782579-8474625
Hello Jeffrey Epstein,
Thank you for shopping with us. We thought you'd like to know that LWZTech shipped your items, and that this completes your order. Your
order is on its way, and can no longer be changed. If you need to return an item from this shipment or manage other orders, please visit Your
Orders on Amazon.com.
Your estimated delivery date is:
Your order was sent to:
Thursday, February 7, 2013 -
jeffrey epstein
Tuesday, February 26, 2013
NEW YORK, NEW YORK 10021-4102
United States
Your package is being shipped by ec-firstclass and the tracking number is UEE130113OKK000413. Depending on the ship speed
you chose, it may take 24 hours for your tracking number to return any information.
Shipment Details
2x USB lightning cable for iphone 5
$5.10
Sold by LWZTech
Condition: new
Item Subtotal:
$5.10
Shipping & Handling:
$0.00
Total Before Tax:
$5.10
Shipment Total:
$5.10
Paid by Amex:
$5.10
Returns are easy. Visit our Online Return Center.
If you need further assistance with your order, please contact the seller.
We hope to see you again soon!
Amazon.com
http://www.amazon.com:80/gp/redirect.htm/ref=pe_175190_21431760_M3T1_LM_DVD/175-5776878-
EFTA00029221

=== Page 2 ===
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EFTA00029222


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=== Page 1 ===
From: Gloria Allred
To:
)"
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of
Epstein. She is willing to fly to New York for the victim meeting on Oct. 23. May I call you
at 5:45 P.M. to discuss ?
Date: Wed, 23 Oct 2019 13:32:52 +0000
Inline-Images: image001.jpg; image002.png
Meeting at my office whenever the victim's meeting concludes will be fine. Thank you.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
ALLRED. MAROKO & GOLDBERG
2019
Best Lawyers
Martindale-Hubbell'
PREEMINENT
AV
Peer Rated for Highest Level
of Professional Excellence
2019
From:
Sent: Wednesday, October 23, 2019 6:06 AM
To: Gloria Allred
Cc:
is
Subject: Re: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly to
New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria,
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?
EFTA00028461

=== Page 2 ===
Gloria Allred
Allred, Maroko & Goldberg
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:
y
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>
From:
Sent: Tuesday, October 22, 2019 1:08 PM
To: Gloria Allred
Cc:
is
)
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00028462

=== Page 3 ===
From: Gloria Allred
Sent: Tuesday, October 22, 2019 4:03 PM
To:
)
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
I have asked her when we can reschedule, but I do not have an answer yet.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image009.jpg>
<image010.png>
From:
Sent: Tuesday, October 22, 2019 11:54 AM
To: Gloria Allred
Cc:
is
Subject: Re: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria,
Is
still available for our 4pm call, or do we need to reschedule?
Thanks,
On Oct 22, 2019, at 12:26 PM,
wrote:
Ok thanks, please keep us posted. We are happy to accommodate
schedule.
And yes, we can speak with
at your office from noon to 1pm tomorrow.
will be the AUSA
handling that meeting.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00028463

=== Page 4 ===
From: Gloria Allred
Sent: Tuesday, October 22, 2019 12:24 PM
To:
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to
fly to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Just a heads up. I think she is needing to reschedule and is cancelling for today. I will let you know a.s.a.p. or by 2P.M.
at the latest. Sorry. Also, re
for tomorrow.can you speak to her from noon to 1 P.M. at my office at 305
Broadway? I need to leave at 1P.M. to catch the train to D.C.
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image003.jpg>
<image004.png>
From:
Sent: Tuesday, October 22, 2019 8:19 AM
To: Gloria Allred
Cc:
is
is
(NY) (FBI)
Subject: Re: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to
fly to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Hi Gloria,
We are find with a conference call this afternoon if that is ok with your client. We can use the below dial-in:
Passcode
And your proposed time for
interview works on our end.
Thanks,
On Oct 21, 2019, at 8:11 PM, Gloria Allred
wrote:
I have 2 questions. First, would it be o.k. with all of you if we did the call with
tomorrow at 4P.M. e.s.t as a
conference call rather than as a Skype call? We will be in at least 4 different locations and I think it will be easier if we
did it that way. If so, please send us the number to dial. Daniel from my CO counsel Marianne Wang's office will also
be joining us on the call. Also ,re
my client who is flying in for victim services will be happy to speak with you,
but I have a very tight schedule on Wednesday, because I need to be on a 1 or at the latest 2 P.M. train to D.C. that
day. Could we have the meeting from noon to 1P.M.? My office is only one block away from the FBI meeting.
Gloria Allred
Allred, Maroko & Goldberg
EFTA00028464

=== Page 5 ===
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
www.gloriaallred.com
<image001.jpg>
<image002.png>
From:
Sent: Monday, October 21, 2019 6:40 AM
To: Gloria Allred
>;
Cc:
is
(NY) (FBI)
Subject: RE: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to
fly to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria,
We will make ourselves available to meet with your new client on 10/23. Because the victim meeting is being run by
the FBI, their victim services folks are handling travel logistics. I'm cc'ing
who should be able to
hopefully help coordinate travel. Would you please provide
with your new client's name as it appears on her
ID, date of birth, email address, and phone number?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Gloria Allred
Sent: Friday, October 18, 2019 5:02 PM
To:
Cc:
Subject: Urgent. I have a new alleged victim of E I have a new client who was a victim of Epstein. She is willing to fly
to New York for the victim meeting on Oct. 23. May I call you at 5:45 P.M. to discuss ?
Gloria Allred
Allred, Maroko & Goldberg
6300 Wilshire Blvd., Suite 1500
Los Angeles, CA 90048
www.amglaw.com
EFTA00028465

=== Page 6 ===
www.gloriaallred.com
<image003.jpg>
<image004.png>
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED
THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED
THIS COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER
NAMED ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
This message is CONFIDENTIAL and may contain legally privileged information intended only for the addressee. If you are not the
addressee you may not use, forward, copy or disclose to anyone any information contained in this message. IF YOU RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE NOTIFY ALLRED, MAROKO & GOLDBERG IMMEDIATELY BY TELEPHONING THE SENDER NAMED
ABOVE AT
Thank you.
EFTA00028466


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Draft OCME Letter
Date: Wed, 28 Aug 2019 01:11:44 +0000
Attachments: 2019.08.28_Letter_to_OCME.ebd.docx
Thanks. I'm operating on the assumption this letter, too, may someday be made public, so I think the less we say about
specifics, the better. I would also ask tomorrow morning what exactly they need, since they may not need more than a
high level request (and I would make the request about returning the 302 by phone only unless they push for it in
writing). Happy to discuss though if you disagree.
From:
Sent: Tuesday, August 27, 2019 7:27 PM
To:
Cc:
Subject: Draft OCME Letter
Please see attached for your review. We tried to keep this as brief as possible while still accurately describing the contents
of their file that we do not want disclosed, and the circumstances under which they were disclosed. Let us know if you
have any thoughts. Our call is at 10 tomorrow morning and we'd like to send this after the fact. I also spoke with the GC
by phone tonight to give her a head's up that this was coming, and she did not have any issues with it.
Thanks,
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00028000


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=== Page 1 ===
From:
(USANYS)"
To:
Cc:
)"
)"
)"
Subject: RE: FW: U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Thu, 29 Apr 2021 20:50:25 +0000
Attachments: 2021.04.29_AJN_Order_re_GM_Sleeping_Conditions.pdf
All,
Judge Nathan directed us to confer with you per the attached order. Do you have time to speak tomorrow? Please
let us know some times that work for you.
Thanks,
Original Message
From:
Sent: Thursday, April 29, 2021 4:12 PM
To:
(USANYS)
Cc:
)
Subject: Re: FW: U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Confirming receipt.
(USANYS)"
4/29/2021
3:27 PM
Hi all,
Attached please find a letter just filed by Maxwell's counsel regarding sleep deprivation. She asks "the Court to
address Ms. Maxwell's sleeping conditions by directing the MDC to cease 15-minute light surveillance of Ms.
Maxwell or justify the need for the disruptive flashlight surveillance." Judge Nathan has not yet ordered any
response but we wanted to send this along to you. Please let us know if a call would be useful.
Thanks,
From:
C STERNHEIM
Sent: Thursday, April 29, 2021 3:01 PM
To:
(USANYS)
Cc: Christian Everdell
>; Laura Menninger
>; ; Jeff
Pagliuca
Subject: U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Good afternoon-
Attached is a courtesy copy of today's ECF fling.
EFTA00029136

=== Page 2 ===
Regards-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
<mailto:
**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.
EFTA00029137


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=== Page 1 ===
From:
To:
Subject: Fwd: Autopsy
Date: Sun, 11 Aug 2019 19:43:56 +0000
Prelim results below
Forwarded message
From:
Date: Aug 11, 2019 2:55 PM
Subject: Autopsy
To:
Cc:
Gents,
The following is a brief update as it relates to the Epstein Autopsy.
Ligature marks around the neck, petechia hemorrhage in the eyes, fractured hyoid bone-All the injuries
noted are consistent with the circumstances surrounding the death.
Deep tissue bleeding to left shoulder/scapula area, which is believed to be caused from the position he hung
himself.
Dr. Roman would not provide a Cause & Manner of Death at this time and will be pending this case for
additional studies (histology, neuropathology, toxicology)
In addition, the family hired private pathologist, Dr. Baden Michael, who was present for the autopsy. We
will continue to track this case and advise of any new or significant developments.
Lieutenant
Commanding Officer
NYPD/FBI JointBank Robbery
Violent Crimes Task Force
Cell
FBI NA 267
EFTA00027265


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=== Page 1 ===
From:
Subject: RE: Requests
Date: Thu, 25 Jun 2020 16:30:23 +0000
/Dave,
Some follow up questions related to these materials:
1. We received unsigned Word versions of Program Statements 5511.08 and 5500.13. Are there finalized versions?
2. Why were we given the BOP Correctional Services Procedures Manual? Which of our requests is this responsive
to?
3. Why were we given the BOP Suicide Prevention Program Statement? Which of our requests is this responsive to?
4. We were also given a Powerpoint entitled Suicide Prevention for Inmates. Which of our requests is this
responsive to? When is this document from?
5. We were provided a document titled Introduction to Correctional Techniques from January 2020. Which of our
requests is this responsive to? Is it the MCC institutional familiarization training outline? If so, we would request
one from a time when the defendants were actively employed at MCC (so before August 2019).
6. We were provided with an undated slide presentation about the MCC SHU. Which of our requests is this
responsive to? When is this document from?
7. The BOP Code of Ethics is highlighted below. Which document is this?
8. We received digital lieutenant's logs. Is there also a hard copy book?
9. We were provided with a document called "SHU Logs MW" and a document called "SHU Logs." Can we confirm
what these are? Our requests were for SHU Watch Call Logs and SHU Control Center Logs.
10. Which document contains the BOP and MCC policy on SHU quarterly training, which is highlighted below as
having been provided?
11. We asked for P.S. 5270.10, but got P.S. 5270.11. Was P.S. 5270.10 provided to us in error? Or was our request
incorrect?
12. Which document contains the BOP and MCC policy on cellmates?
13. In the second email, there is a document called "Hot Lists" dated August 30, 2019. Which of our requests is this
responsive to?
14. In the second email,
mentioned that most of the control center paperwork was seized by FBI and/or OIG.
Do you or FBI have that paperwork? Has it been provided to us?
15. Finally, what is the status of the remaining requests?
Please work on this as quickly as you can. Thanks!
From:
Sent: Tuesday, June 23, 2020 3:59 PM
To:
Subject: FW: Requests
fyi
From:
Sent: Tuesday, June 23, 2020 3:53 PM
EFTA00028317

=== Page 2 ===
To:
Cc:
Subject: Re: Requests
I've attached all the documentation I have pertaining to the below request. I am waiting for a few things from HR and
Psychology but wanted to send you what I have right now. I highlighted the items below that are attached in this email.
Let me know if you have any questions.
Kizzier
Special Investigative Agent
MCC New York
150 Park Row
New York, NY 10007
646-836-6300 ext. 6485
06/12/20 1:54 PM >>>
Hi
Hope you and fam have been well, as well as MCC staff.
Can you please provide the following information concerning the Epstein suicide investigation:
The BOP and MCC Employee Code of Conduct, Code of Ethics, and corresponding employee acknowledgement
forms for Defendant Noel.
The MCC institutional familiarization training outline.
The BOP and MCC policy on cellmates and local Institutional Supplement on Special Housing Unit Regulations,
including Institutional Supplement/Program Statement Number P.S. NYM 5270.10.
The BOP and MCC policy on SHU quarterly training.
The Inmate Accountability Institutional Supplement/Program Statement, Number I.S. NYM 5511.08.
The Security Inspections Institutional Supplement/Program Statement, Number I.S. NYM 5500.13.
SHU Watch Call Logs from August 9, 2019 and August 10, 2019.
All SHU Watch Call Logs completed during Defendant
assignment to the SHU post which began on June 26,
2019.
All SHU Control Center Logs completed during Defendant
assignment to the SHU post which began on
June 26, 2019.
All SHU Operations Lieutenant Log Books completed during Defendant
assignment to the SHU post which
began on June 26, 2019.
All High Risk Lists reviewed during weekly SHU meetings during Defendant
assignment to the SHU post
which began on June 26, 2019.
All SHU reports and SRO reviews completed by the SHU Lieutenant during Defendant
assignment to the SHU
post which began on June 26, 2019.
Many thx!
EFTA00028318


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: RE: Epstein Documents from BOP without Green Watermark
Date: Tue, 13 Apr 2021 20:35:13 +0000
Thanks again for this,
and we can talk some more about it tomorrow. In the meantime, can I ask how BOP
provided the docs to you? Do you have JEFS access? Or did they email them?
Thanks,
From:
(USANYS)
Sent: Monday, April 12, 2021 11:36 AM
To:
(USANYS)
>;
(USANYS)
Subject: RE: Epstein Documents from BOP without Green Watermark
Hi
We requested these from the BOP, and they provided a set of documents, which we then produced to defense counsel.
We did not do a page by page comparison between the redacted set and the unredacted set, so we can't guarantee that
they are "comprehensive." But we can provide you with what we have, assuming that there aren't any issues with us
sharing in that way.
Best,
From:
(USANYS)
Sent: Sunday, April 11, 2021 12:27 PM
To:
(USANYS)
is
(USANYS)
Subject: Epstein Documents from BOP without Green Watermark
and
I recall that at some point you requested a version of the Epstein FOIA documents from BOP without the translucent
green watermark they put on the withheld documents. Do you have those saved down somewhere? Although the Court
has not put in a specific order yet, I think it's likely that we'll need to produce documents without the translucent green
marking to the Court. I have versions without the watermark for some of the docs, but it looks like not all. Do you have a
comprehensive set somewhere?
Thanks,
Assistant United States Attorney
300 Quarropas Street
White Plains, NY 10601
Telephone:
EFTA00027381


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=== Page 1 ===
From:
To:
Subject: Object of the conspiracy was to meet Epstein.docx
Date: Thu, 02 Jan 2020 22:11:47 +0000
Attachments: Object_of_the_conspiracy_was_to_meet_Epstein.docx
EFTA00029314


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=== Page 1 ===
SECOND AMENDMENT TO RESTATED TRUST
THE JEFFREY E. EPSTEIN 2001 TRUST TWO
I am the Grantor of THE JEFFREY E. EPSTEIN 2001 TRUST
TWO ("the trust").
Pursuant to Article TWELFTH of the trust, I have the power to
amend the trust.
The trust was amended and restated on March 8, 2002 and was
further amended on January 13, 2004.
I hereby make this SECOND AMENDMENT to the Restated
Trust as follows:
FIRST
I hereby delete Article FIRST of the trust and substitute in its
place the following new Article FIRST:
"FIRST
The Trustees shall retain such property, IN TRUST, for the
following purposes:
(a) During the life of the Grantor, to pay any part or all of
the income from such property and such sums from any part or all of the
principal of the trust as the Trustees, in their discretion, from time to time
determine for any reason whatsoever to, for, or on behalf of the Grantor.
Any income not so paid shall annually be added to the principal.
358398.1
GJ_000283
EFTA00028554

=== Page 2 ===
(b)
On the death of the Grantor, the remaining income and
principal of the trust, including any property received by this trust as a result
of the Grantor's death pursuant to his will or otherwise shall be distributed
as follows:
(i)
Two Million Dollars ($2,000,000) to
,
if she is then living.
(ii)
Two Million Dollars ($2,000,000) to
, if she is then living.
(iii)
Two Million Dollars ($2,000,000) to
,
if he is then living.
(iv)
One Million Dollars ($1,000,000) to
, if she is then living.
(v)
One Million Dollars ($1,000,000) to
if she is then living.
(vi)
One Million Dollars ($1,000,000) to
, if she is then living.
(vii)
One Million Dollars ($1,000,000) to
, if she is then
living.
(viii) One Million Dollars ($1,000,000) in equal shares
to
if they are both then living or all
to the survivor if only one of them is then living.
(ix) Any remaining balance shall be distributed to the
Grantor's estate.
358398.1
2
GJ_000284
EFTA00028555

=== Page 3 ===
IN WITNESS WHEREOF, the undersigned has executed this
SECOND AMENDMENT on the 3rd day of December , 2004.
Jeffrey E. Epstein, Grantor
358398.1
3
GJ_000285
EFTA00028556

=== Page 4 ===
New York
)
) SS.:
NewYork New York
)
On the 3rd day of December in the year 2004, before me, the
undersigned, personally appeared JEFFREY E. EPSTEIN, personally known
to me or proved to me on the basis of satisfactory evidence to be the
individual whose name is subscribed to the within instrument and
acknowledged to me that he executed the same in his capacity, and that by
his signature on the instrument, the individual or the person upon behalf of
which the individual acted, executed the instrument.
S
Sep Notary/Public
LAUREN J. KWINTNER
Notary Public, State of New York
No. 02KW6016686
Qualified in New York County
Commission Expires November 30, 20 06 06
358398.1
GJ_000286
EFTA00028557


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=== Page 1 ===
From:
To:
Subject: Double Jeopardy
Date: Sat, 15 May 2021 21:38:56 +0000
Attachments: Double_Jeopardy_v1.docx
Hi team,
I hope you're enjoying the beautiful weekend! Attached is a draft of the double jeopardy section.
Thanks!
Assistant United States Attorney
Southern District of New York
EFTA00028643


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=== Page 1 ===
From:
(USANYS)"
To:
E.(OIG)"
Subject: Re: Draft letter to Congress on Epstein
Date: Mon, 12 Aug 2019 20:11:57 +0000
I just tried you.
On Aug 12, 2019, at 3:55 PM,
E.(OIG)
wrote:
Begin forwarded message:
From:
"
(ODAG)"
Date: August 12, 2019 at 2:07:27 PM EDT
To:
E.(OIG)"
(DO) (FBI)"
Subject: Draft letter to Congress on Epstein
This is the letter that we intend to send to the congressional leaders. Please review and let me know if you have
concerns about any of the specific statements. This attempts to take into consideration your comments from last
night. Apologies for the tight turnaround, but if you can review and revert with any issues in the next hour, that would
be appreciated.
Principal Associate Deputy Attorney General
Epstein ltr.pdf>
EFTA00027096


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c3: VOL00008
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c0:
=== Page 1 ===
From:
(USANYS)"
To: Jason Foy
Cc:
(USANYS)"
(USANYS)"
(USANYS) [Contractor]"
Subject: RE: U.S. V. Noel, No. 19 Cr. 830 - Discovery Production
Date: Tue, 31 Dec 2019 17:30:35 +0000
Attachments: SDNY_00008123_(AEO).pdf; 2019.12.31_Noel_Discovery_Letter_-_Production_1.pdf
Hi Jason,
Apologies, please use the attached version of SDNY_00008123 and destroy the version that I previously sent you. Thanks
and happy New Years.
Best,
From:
(USANYS)
Sent: Tuesday, December 31, 2019 12:23 PM
To: 'Jason Foy'
Cc:
(USANYS)
is
(USANYS)
>;
(USANYS) [Contractor]
Subject: U.S. V. Noel, No. 19 Cr. 830 - Discovery Production
Counsel:
Please find attached a letter regarding the Government's discovery production in this case. We are sending a hard drive
containing the discovery materials to you. The password on the drive is
Additionally, please find
attached one additional page of discovery, which has been marked attorney's eyes only. Please contact us with any
questions. Thank you.
Regards,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
Tel:
EFTA00027731


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=== Page 1 ===
From:
)"
To:
(USANYS)"
)"
Subject: FW: Discovery Issues
Date: Wed, 12 May 2021 13:55:32 +0000
Inline-Images: image001.jpg; image002.jpg
You two are welcome to join, but no pressure. I'm happy to handle.
From:
(USANYS) [Contractor]
Sent: Wednesday, May 12, 2021 9:43 AM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS) [Contractor]
>;
is
(USANYS)
Subject: Re: Discovery Issues
As am I.
On May 12, 2021, at 9:36 AM,
(USANYS) [Contractor]
wrote:
and I are both available anytime today.
From:
Sent: Tuesday, May 11, 2021 10:41 PM
To:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: FW: Discovery Issues
Hi team,
Maxwell's attorneys have asked for the below-listed information from the SUPP production that went out on November
9, 2021. Is there a time tomorrow when we can have a call to discuss, please?
Thanks,
From: Laura Menninger
Sent: Friday, May 7, 2021 4:53 PM
To:
)
>; Christian Everdell
is
is
(USANYS)
Cc: Jeff Pagliuca
>; ; Bobbi Sternheim
(
Subject: RE: Discovery Issues
Also following up on your response to Chris. We have had a chance to take a look at these files again.
EFTA00028585

=== Page 2 ===
For the SUPP production, many of the files were produced as PDFs, which seems as though they were converted prior to
production. As I understand it (which is admittedly limited), carved or deleted files can still contain application
metadata.
We request that as to the SUPP production, you:
a. Provide a list of all files that were carved or deleted;
b. Confirm if all those files were produced in native format or if any were converted to PDF;
C. If any were converted, provide additional information including the MIME type (for all), and if available from
application metadata original file name, file dates, etc. This would amount to the equivalent of the index you provided
for SDNY011.
d. In the absence of (b), confirm that no application metadata was recovered from those files which might indicate file
creation/modified dates
Please let me know if you have any questions.
Thanks,
Laura
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
(Office)
From:
Sent: Friday, April 23, 2021 10:30 AM
To: Christian Everdell
is
is
(USANYS)
Cc: Jeff Pagliuca
>; Laura Menninger
>; Bobbi Sternheim
Subject: RE: Discovery Issues
Chris,
Following up on these issues:
For #3, the attachments were not recovered from the searched devices. We do not have them, which is why they
were not produced.
For #4, the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was
available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so
none is viewable, except for data showing when a particular file was saved to a drive by the investigative team or
prepared for production. I am not aware of any additional metadata in our possession that you do not have for
these files.
For #5, those photographs were not processed by CART, which is why they do not have a CART number. They
came from the CDs that your team reviewed last week. The available metadata for those photographs was
produced in two excel spreadsheets with the same production - one with metadata for nude images (which were
contained on one of the hard drives you reviewed last week), and one with metadata for non-nude images (which
were produced in the November 9, 2020 discovery production). As I mentioned in my email to Laura earlier
today, I am working with our vendor to figure out how to best convey to you which Bates numbers correspond
with which rows in the spreadsheet.
For #6:
EFTA00028586

=== Page 3 ===
The SDNY_GM_SUPP contain electronic files recovered from Epstein's devices. As noted above, those files
have the same metadata on the hard drive that was available when the FBI seized each file. For files that
were carved or deleted, no metadata was recovered, so none is viewable.
The videos from SDNY005 (October 20, 2020 production) were converted by a vendor from VHS and
cassette tapes, so there is no metadata to provide. The Sept-Octo 2020 dates reflect when these
recordings were converted by our vendor.
The SDNY011 (November 9, 2020 production) consists of images from the CDs seized from Epstein's
residences, which you reviewed last week. As referenced above, those photographs were not processed
by CART, which is why they do not have a CART number. As referenced above, the available metadata for
those photographs was produced in two excel spreadsheets with the same production - one with
metadata for nude images (which were contained on one of the hard drives you reviewed last week), and
one with metadata for non-nude images (which were produced in the November 9, 2020 discovery
production). As I mentioned in my email to Laura earlier today, I am working with our vendor to figure out
how to best convey to you which Bates numbers correspond with which rows in the spreadsheet.
Best,
Assistant United States Attorney
Southern District of New York
From:
Sent: Tuesday, March 30, 2021 11:10 PM
To: Christian Everdell
i
i
(USANYS)
Cc: 'Jeff Pagliuca'
>; Laura Menninger
>; Bobbi Sternheim
Subject: RE: Discovery Issues
Chris,
That all makes sense, thanks very much. I will reach back out once I have conferred with our vendor and have answers
for you on #3-#6.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00028587

=== Page 4 ===
From: Christian Everdell
Sent: Tuesday, March 30, 2021 10:58 PM
To:
is
is
(USANYS)
Cc: 'Jeff Pagliuca'
>; Laura Menninger
>; Bobbi Sternheim
Subject: RE: Discovery Issues
Apologies for the late response on this. It seems like it would be better to confer after you have heard back from your
vendor, since the answers to #3-#6 will depend on what the vendor says. And I believe we have now resolved #7.
As for #1 and #2, I will call
at MDC and represent to her that we have your concurrence to send the
drive directly to Ms. Maxwell. If she agrees, we can add the additional productions to our drive before we send it. If she
refuses, we will take it up with Judge Nathan.
Thanks,
Chris
From:
) [mailto:
Sent: Monday, March 29, 2021 3:36 PM
To: Christian Everdell;
);
(USANYS)
Cc: 'Jeff Pagliuca'; Laura Menninger; Bobbi Sternheim
(
)
Subject: RE: Discovery Issues
Chris,
We are available for a call to discuss tomorrow between 1pm and 2pm, between 3pm and 5pm, or after 5:30pm. Please
let us know if there is a time in those windows that would work on your end. In the meantime, below are some initial
responses:
1. Our supervisors have indicated that we are not permitted to send a drive that our IT department did not load to
the MDC. As a result, we cannot provide the drive directly to the MDC. That said, I am happy to join you in
asking the MDC to accept the drive from you. If the MDC still refuses, then my office would not object to an
application to Judge Nathan for an order directing the MDC to accept the drive from you, though we would need
to allow MDC legal counsel the opportunity to note their objections to Judge Nathan.
2. The MDC recently alerted us to this issue, and our paralegal converted the excel files at issue to pdfs and sent a
new CD with those pdfs to the MDC. If you client still cannot view them, then we are happy to load them to a
drive if you would like to provide one for us.
3. I have asked our vendor to look into this issue and will get back to you when I have spoken with them.
4. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said,
similar to the note I sent in my email regarding highly confidential images on March 16, 2021, the electronic files
recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI
seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except
for data showing when a particular file was saved to a drive by the investigative team or prepared for production.
EFTA00028588

=== Page 5 ===
5. As indicated in our November 9, 2020 discovery letter, all images within Bates range SDNY_GM_00467566 though
SDNY_GM_00514100 were seized during the 2019 searches of Epstein residences. These are the images from the
CDs that were recovered during those searches, so they did not come from any of the electronic devices that
were the subject of extractions by CART. As a result, these images would not have CART numbers. As for the
metadata, I have asked our vendor to look into this issue and will get back to you when I have spoken with them.
6. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, I
note again that the electronic files recovered from Epstein's devices have the same metadata on the hard drive
that was available when the FBI seized each file. For files that were carved or deleted, no metadata was
recovered, so none is viewable. Additionally, as indicated in our November 9, 2020 discovery letter, all images
within the SDNY011 load file (Bates range SDNY_GM_00467566 though SDNY_GM_00514100) were seized during
the 2019 searches of Epstein residences. These are the images from the CDs that were recovered during those
searches, so they did not come from any of the electronic devices that were the subject of extractions by CART.
As a result, these images would not have CART numbers.
7. I have asked our paralegals and vendor to look into the Bates gap and will get back to you when I have spoken to
them.
Best,
Assistant United States Attorney
Southern District of New York
From: Christian Everdell
Sent: Monday, March 29, 2021 2:40 PM
To:
is
)
V.
(USANYS)
Cc: 'Jeff Pagliuca'
>; Laura Menninger
>; Bobbi Sternheim
Subject: Discovery Issues
and
-
We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for
a call to discuss.
1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had
created (without the highly confidential items). You had said you would check to see if you could facilitate this.
We have not heard back from you. Are you able to send Ms. Maxwell the hard drive?
2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and
must use the prison computer. But the prison computer cannot read some of the files. We can include these files
on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please
advise which way you would like to proceed.
EFTA00028589

=== Page 6 ===
3. A number of the emails in the discovery - over 109,000 - were produced without their attachments (see tab 1 of
the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide
the missing attachments, if they exist.
4. A number of electronic documents - over 110,000 - that were extracted from one of Epstein's devices, as
identified by a CART number, have metadata that indicates a "date created" or "date last modified" date in July
2020 or afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with
the original metadata for these files.
5. A number of photographs - over 6500 - were produced in native format, but do not have a CART number and
have "date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please
provide the CART number for these photographs or specify which device they came from. Also, we request that
you produce a metadata overlay with the original metadata for these files.
6. A number of the audio/visual files - over 460 - have similar metadata issues (see tab 4 of the attached Excel file).
These fall into the following buckets:
a. SDNY_GM_SUPP: these have CART numbers, but were produced without metadata load files and have
"date created" and "date last modified" dates in September-November 2020, after the date the device was
seized. We request that you produce a metadata overlay with the original metadata for these files.
b. SDNY005 (October 20, 2020 production): these are a few videos from the SDFL or PBPD investigations that
were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request
that you produce a metadata overlay with the original metadata for these files.
C. SDNY011 (November 9, 2020 production): these were produced in native form with load files, but do not
reference a CART number and have Sept 2020 dates. We request that you provide a CART number for
these files or indicate their source. Also, we request that you produce a metadata overlay with the original
metadata for these files.
7. There is a gap between 11/18 and 12/18 production numbers (SDNY_GM_02742044 to 2742183). Was that
intentional or are we missing those documents?
Please let us know your responses as soon as possible.
Thanks,
Chris
Christian
Everdell
<image001.jpg>
view bio
www.cohengresser.com
New York
Paris
Washington DC
London
<image002.jpg>
CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
EFTA00028590

=== Page 7 ===
the sender by telephone and permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy.
COHEN & GRESSER LLP
C&G
EFTA00028591


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=== Page 1 ===
Event: Epstein meeting
Start Date: 2019-01-22 18:30:00 +0000
End Date: 2019-01-22 19:30:00 +0000
Organizer:
Location: conf room 333
Class: X-PERSONAL
Date Created: 2019-01-22 01:26:44 +0000
Date Modified: 2019-01-22 01:26:44 +0000
Priority: 5
DTSTAMP: 2019-01-22 01:11:25 +0000
Attendee:
Alarm: Display the following message 15m before start
I
Reminder
EFTA00029462


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=== Page 1 ===
From: Jack Scarola
To:
)"
Cc:
)"
(USANYS)"
"
,
"Chris R. Rodgers"
Subject: Re:
Date: Thu, 28 Jan 2021 18:19:14 +0000
Thank you,
This is very good news. You can count on us to provide whatever support may be
reasonably necessary.
On Jan 28, 2021, at 1:16 PM,
) wrote:
Jack,
I was just able to confer with our office's Victim-Witness Coordinator. She informed me that our office will be able to pay
for
husband, and
three minor children to travel with her to New York for her testimony and
then back to Florida. She also confirmed that our office will be able to pay for a hotel suite that is large enough to
accommodate
her husband, and her children.
We will reach out to coordinate the logistics closer to the trial date. For now, the trial is scheduled to begin on July 12,
2021. l'll plan to reach back out in March or April to provide you with an update on timing and to potentially schedule a
time for me to meet with
for trial prep.
As always, please do not hesitate to contact me with any questions or concerns.
Best,
From:
Sent: Thursday, January 28, 2021 1:06 PM
To: Jack Scarola
Cc:
;
(USANYS)
Subject: RE:
Jack,
Thank you very much for letting us know. That's great to hear, and I completely understand
desire to have her
family with her as support when she testifies. I will work with our Victim-Witness Coordinator and with the FBI's Victim
Services folks to figure out what we can do about funding for
family to join her in New York. I'll get back to you
as soon as I have information about those logistics.
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
From: Jack Scarola
Sent: Wednesday, January 27, 2021 3:59 PM
To:
Cc:
(USANYS)
Subject: Re:
EFTA00027350

=== Page 2 ===
My apologies for not getting back to you following my meeting with
yesterday, but it took until today to get a final
response from
She is willing to commit to testify but she definitely wants her husband and children with her when in NY for trial in July.
While she does not presently have the ability to finance her family's travel at this time, she might be willing and able to
set aside funds she might receive from the Epstein Victims' Compensation Fund to at least partially defray related
expenses.
Please let us know what commitment the government is able to make in this regard.
I hope your trip home went smoothly.
On Jan 27, 2021, at 3:10 PM,
wrote:
Hi Jack,
Any word from
? Apologies for pestering, but there are a number of steps we'll need to take in the near term if we
are going to expand our case to include
testimony.
Thanks very much,
From:
Sent: Monday, January 25, 2021 4:11 PM
To: Jack Scarola
Cc:
is
(USANYS)
Subject: RE:
Thank you.
From: Jack Scarola
Sent: Monday, January 25, 2021 4:10 PM
To:
)
Cc:
(USANYS)
Subject: Re:
I am scheduled to conference with
tomorrow afternoon and should have an answer for you then.
Sent from my iPad
On Jan 25, 2021, at 3:32 PM,
wrote:
Jack,
It was a pleasure to see you in person last week. Thank you for being so accommodating and kind during my trip down
to Florida.
I'm just checking in to see whether
has made a decision about whether she would be willing to testify at our
trial. And, of course, I am happy to have a call to discuss or answer any questions if that would be useful.
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 1
12-637-2324
|
Privileged and Confidential | 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-
EFTA00027351

=== Page 3 ===
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
and destroy all copies of the original message. Thank you.
EFTA00027352


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=== Page 1 ===
90A-NY-3151227 Serial 42
FD-1087 (Rev. 5-8-10)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Collected Item Log
Event Title:
(U) Submission of CART Derivative
Date: 08/16/2019
Evidence NYC027715
Approved By: SSA
Drafted By:
Case ID #: 90A-NY-3151227
(U) UNSUB (S);
JEFFREY EPSTEIN - VICTIM;
DEATH INVESTIGATION
Collected From:
(U) CART-NY
Receipt Given?: No
Holding Office: NEW YORK
Details:
Submission of CART Derivative Evidence NYC027715: One (1) Seagate
Barracuda 1000GB HDD, ST1000DM003, S/N W1D06T5L, containing the Clone
Copy of 1B18 hard drive (Seagate Barracuda 500GB HDD, ST3500320NS, S/N
9QM8MSRR), collected via Tableau TD3-B, S/N 01D3B07E-1331. Derivative
Copy.
Item Type
Description
1B Digital
(U) NYC027715: One (1) Seagate Barracuda 1000GB HDD,
ST1000DM003, S/N W1D06T5L, containing the Clone Copy of
1B18 hard drive (Seagate Barracuda 500GB HDD,
ST3500320NS, S/N 9QM8MSRR), collected via Tableau TD3-B,
S/N 01D3B07E-1331. Derivative Copy.
Collected On: 08/12/2019 07:00 PM EDT
Seizing Individual:
Collected By:
Device Type: Hard Drive
Designation: Derivative
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.
EFTA00027970

=== Page 2 ===
90A-NY-3151227 Serial 42
UNCLASSIFIED
Title: (U) Submission of CART Derivative Evidence NYC027715
Re: 90A-NY-3151227, 08/16/2019
UNCLASSIFIED
2
EFTA00027971


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=== Page 1 ===
From:
)"
To:
(USANYS)
[Contractor]"
Subject: CD with Maxwell files
Date: Mon, 05 Apr 2021 17:55:13 +0000
H
an
e,
On Friday, the FBI brought me a CD containing additional files that I need to review for Maxwell. It should be sitting in my
office on the 4th floor on my keyboard at my desk. Would one of you (or another paralegal who is in the office) be able to
please grab the CD and load its contents onto the Epstein share? You can save everything from the CD here:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Iinvestigation\FBINY CaseFile as of August
2020\1B items not included in
box
Thanks so much,
EFTA00029230


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 226 Filed 04/21/21 Page 1 of 2
USDC SDNY
DOCUMENT
UNITED STATES DISTRICT COURT
ELECTRONICALLY FILED
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 4/21/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
The Court is in receipt of the Defendant's and Boies Schiller Flexner LLP's April 19,
2021 joint letter responding to the Court's April 19, 2021 Order, Dkt. No. 215. The letter
proposes limited redactions on the basis that some of the information is covered by the terms of
the protective order in this case.
In light of this, by April 22, 2021, the Defendant and BSF are hereby ORDERED to
confer with the Government regarding whether the Government requests redaction of any
information contained in the Defendant's response to BSF's objections to the Defendant's
proposed Rule 17(c) subpoena, BSF's reply, and the April 19, 2021 joint letter addressing the
redactions to these documents.
The Government may submit any redaction requests by April 23, 2021; in doing so, the
Government shall justify any proposed redactions by reference to the test articulated in Lugosch
V. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006).
The Defendant, BSF, and the Government are further ORDERED to notify the Court
whether any party seeks redactions to the April 19, 2021 joint letter. If not, the Defendant shall
file the letter on the public docket by April 23, 2021.
SO ORDERED.
EFTA00027163

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 226 Filed 04/21/21 Page 2 of 2
Alim D. Nitts
Dated: April 21, 2021
New York, New York
ALISON J. NATHAN
United States District Judge
EFTA00027164


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=== Page 1 ===
From:
To:
)"
Subject: RE: Head over?
Date: Tue, 30 Jul 2019 17:48:04 +0000
Oh. Ok.
From:
Sent: Tuesday, July 30, 2019 1:48 PM
To:
)
is
Subject: RE: Head over?
Ok if I catch up? I may need to sneak in late and sit in the back, very sorry. Issue came up with Epstein.
From:
Sent: Tuesday, July 30, 2019 1:46 PM
To:
is
Subject: Head over?
Assistant U.S. Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Phone:
Fax:
EFTA00028528


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 11063042(1) approved by
, now awaiting further approval
Date: Fri, 21 Feb 2020 18:48:32 +0000
Importance: Normal
Dear
Final voucher 11063042(1) has been approved by
, now awaiting further approval.
Trip ID: 11063042
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R20NYS13403 - Epstein Investigation - Witness interview
Destination: Pensacola, FL, United States
Dates: 2020-02-19 - 2020-02-20
Current status: Pending Voucher Approval
Voucher total expenses: 628.07
Estimated trip cost: 973.89
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# V0010
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.
EFTA00027828


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=== Page 1 ===
From: Martin Weinberg
To:
)"
Subject: Re: Epstein - Legal Issues and Requests
Date: Thu, 18 Jul 2019 11:41:15 +0000
,
maybe we can find a few minutes after today's hearing to discuss further
Thanks
Marty
Sent from my iPhone
On Jul 17, 2019, at 10:56 PM,
)
wrote:
Marty,
I stand corrected regarding the timing of the recusal of SDFL from potential prosecution; I hadn't realized that (which
may further show that any speculation about the genesis of our investigation being with SDFL is misguided). In any
event, as we have represented to the Court, our investigation was initiated internally, and beyond that we're not
prepared to make representations about internal communications or to otherwise characterize the investigation. With
respect to the preservation of communications, my understanding is that the Department generally retains
communications for some period of years, so while we don't believe there is any formal obligation to retain (or produce)
such materials, I don't believe there would be any issue with retrieving communications should that be necessary.
Regarding the privilege review, I expect that we will utilize a wall / taint individual or team to screen for privileged
materials, as we do in the ordinary course where there are privilege concerns. If in addition to attorney names and law
firms there are search terms, phrases, etc., that you want to identify for the review team, you should certainly feel free
to do so and we can facilitate that. In the first instance I expect it will take some time to process the drives and devices
to make their content reviewable on a web-based platform, so I don't believe anyone is yet reviewing those items (with
the possible exception of a required preliminary screen of images for possible child pornography). In terms of the
attorney and firm names, my thought was that it would be helpful for the case team to have them in case somehow
some material wasn't screened, for easy recognition should we come across those names-and I've had those types of
identifying information in other cases-but that certainly isn't a requirement if you prefer otherwise.
Once the materials are in a position to be reviewed by a taint team, we will let you know right away to facilitate the
easiest and most straightforward process for screening, review, and eventual production. The lag in setting that up is
not to interpose any delay, but rather because there are intermediate technological steps before a review team will have
access to those materials.
I hope that's helpful, and keeps the gears turning, and please let us know if additional information would be useful.
thanks,
From: Martin G. Weinberg
Sent: Tuesday, July 16, 2019 18:46
To:
>; 'Marc Fernich'
Cc: 'Marty Weinberg'
i
is
>; 'Martin Weinberg'
Subject: Epstein - Legal Issues and Requests
EFTA00028149

=== Page 2 ===
Hi
the SD Fla was ordered recused by the DOJ from criminal matters concerning Mr Epstein at a much earlier date,
see Dkt 205-2 of the CVRA, at pg 12, fn 13 which was filed in our case as Doc 6- Exh 2 ( our bail submission of last
week). You are correct that the ND Ga did not enter the CVRA proceedings until much later.
I will await further communication on the communications-related request.
I think its more consistent with a taint review - if that is indeed the search protocol that you will use or (if there is a
challenge) attempt to use to review the seized Epstein phones/electroncs - for the attorney list to go to the taint
prosecutor to guard against any risk that identifying an attorney may in combination with other evidence in your
possession disclose a privilege. If there is a particular concern with the case team accessing privileged materials absent
the list of attorneys, please let me know so we can address it without delay. We have enough legal issues
Thanks
Best, Marty
Martin G. Weinberg, Esq.
This Electronic Message contains information from the Law
Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the
addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of
the contents of this message is prohibited.
From:
) [mailto:
Sent: Tuesday, July 16, 2019 11:42 AM
To: Martin G. Weinberg
>; 'Marc Fernich'
Cc: 'Marty Weinberg'
is
is
Subject: RE: Epstein Arrest Seizure Items
Hi Marty,
In reverse order, we're not prepared to make any generalized representations regarding any communications within the
Department in its entirety, but I note for your reference that the Southern District of Florida apparently recused itself in
or about March 2019, and it was only at that point, to my knowledge, that the Northern District of Georgia became
involved in the CVRA case. As we have noted, our investigation had been active for several months at that time. And we
will further discuss your other communications-related questions and get back to you.
Regarding the review of electronic devices, we'll discuss internally whether we're in a position to specifically describe
our review and screening process, but certainly it would be helpful in the first instance for you to provide the list of
attorneys and/or firms that could implicate privilege. You can simply send that list to us-unless you have concerns that
even the identities of those attorneys and firms would disclose privileged information, though I think ideally the case
team would benefit from having that information as further protection against any taint.
thanks,
From: Martin G. Weinberg
Sent: Tuesday, July 16, 2019 08:31
To:
>; 'Marc Fernich'
>; 'Martin
Weinberg'
Cc: 'Marty Weinberg'
V.
EFTA00028150

=== Page 3 ===
is
)
Subject: RE: Epstein Arrest Seizure Items
Good morning
The purpose of this email is to address two issues separate from the ongoing bail/detention hearings.
First, the seizure of various phones and computer-type devices from Mr Epstein and his residence. I would like to discuss
the protocol for any search of the devices with the purpose of protecting the confidentiality of a vast amount of
attorney-client and work product privileged communications that are within these devices. Can we schedule a call? I
have assembled a preliminary list of attorneys. If the matter has been delegated to a taint prosecutor, and without
waiving rights to contest the process, I would like to send the list of attorneys to that taint prosecutor.
Second, yesterday
stated that there had been no communications with the SD Fla. That is not surprising since they
are recused. Would you inform the defense whether there has been a similar absence of any contact with the ND Ga
prosecutors (in particular Ms
and/or Mr
)
or with Main Justice (eg CEOS or others)? I would also
want to explore with you an agreement on preserving emails, texts, voicemessages, documents that would be relevant
to the genesis of the SDNY investigation given the issues that we have raised regarding the NPA. I am not by this email
seeking their discovery (a future issue), only an agreement on their preservation.
Thanks
Marty
Martin G. Weinberg, Esq.
This Electronic Message contains information from the Law
Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the
addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of
the contents of this message is prohibited.
From:
) [mailto:
Sent: Monday, July 15, 2019 8:35 PM
To: Marc Fernich
Cc: Marty Weinberg
>; Martin Weinberg
is
)
is
Subject: RE: Epstein Arrest Seizure Items
Marc,
Circling back on this, I'll ask the agents to bring the cash and other personal effects seized from Mr. Epstein to the
hearing on Thursday, unless it is important to receive them before then, in which case please let me know and l'll try to
arrange that. With respect to the electronic devices, we've obtained a warrant to search them and so will be retaining
them as evidence.
thanks,
From: Marc Fernich
Sent: Thursday, July 11, 2019 15:54
To:
Cc: Marty Weinberg
>; Martin Weinberg
is
Subject: Epstein Arrest Seizure Items
EFTA00028151

=== Page 4 ===
Hi
Sorry to bug you while you may be working on a bail reply.
I'm having trouble reaching Agent
to coordinate pickup of the cellphone and other items seized upon Epstein's
arrest. She said she'd be out in the field, but I don't hear from the intermediary agent - identity unknown - who was
supposed to handle it in her absence. Can you step in and try to move this along?
Thanks a lot.
Marc Fernich, Esq.
Sent from my iPhone
On Jul 9, 2019, at 3:26 PM,
wrote:
Marc,
It is the right number, so feel free to follow up later, but I can also give you her cell number which is
thanks,
From: Marc Fernich
Sent: Tuesday, July 09, 2019 14:56
To:
Cc: Marty Weinberg
>; Martin Weinberg
>;
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
Sorry to trouble again. No answer or VM pickup at that number. I'll try again later so long as it's the right number. Can
you confirm? Many thanks.
Marc Fernich, Esq.
Sent from my iPhone
EFTA00028152

=== Page 5 ===
On Jul 9, 2019, at 2:45 PM,
wrote:
Marc,
Apologies for the delay on this, and thanks for following up. The best way to coordinate this is to contact the case
agent directly - I just spoke to her so she'll be expecting your call. They're running around, so if you reach out and
aren't able to connect today please let me know, but hopefully we can get it coordinated. The contact is Special
Agent
and she can be reached at
thanks,
From: Marc Fernich
Sent: Monday, July 08, 2019 15:40
To:
Subject: Re: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
One of your agents told Marty the case agent would return Epstein's phone, the cash and other items taken from his
person upon arrest. Marty's returning to Boston shortly. Can you arrange for me to take possession of those items?
Thanks,
Marc
Marc Fernich, Esq.
Sent from my iPhone
On Jul 8, 2019, at 10:53 AM,
)
wrote:
Marc,
Wanted to send this to you as well in case your co-counsel can't receive it in the Court. Please let me know if it
would be helpful to get a hard copy - I'm copying two of our paralegals who can bring you (or co-counsel) a copy;
l'll be unreachable for the next hour or so.
thank you,
From:
Sent: Monday, July 08, 2019 10:43
EFTA00028153

=== Page 6 ===
To:
Cc:
is
'Martin Weinberg'
is
is
is
Subject: RE: U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum
To the Chambers of Judge Pitman:
In advance of the expected bail argument in the above-captioned case, in connection with the presentment and
arraignment referred by Judge Berman, attached please find a memorandum from the government on the issue of
detention. Defense counsel is copied, as is the chambers of Judge Berman at their request.
Thank you,
Assistant U.S. Attorney
Southern District of New York
<U.S. V. Epstein, 19 Cr. 490 (RMB), Government bail memorandum.pdf>
EFTA00028154


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=== Page 1 ===
From:
To:
Bec: "USAHUB-USAJournal111"
Subject: RE: Recirculating surplusage draft
Date: Wed, 17 Feb 2021 01:32:42 +0000
Embedded: RE:_Recirculating_surplusage_draft.msg
Sender:
Subject: RE: Recirculating surplusage draft
Message-Id:
<BN3P110MB025744EB120DCDE7411E6A3D8A869@BN3P110MB0257.NAMP110.PROD.OUTLOOK.CO
M>
To:
EFTA00028198


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=== Page 1 ===
From:
)"
To:
Subject: RE: Prince Andrew
Date: Fri, 03 Jul 2020 14:42:01 +0000
Thanks very much. Have a wonderful holiday weekend!
From:
Sent: Friday, July 3, 2020 5:24 AM
To:
Subject: Fwd: Prince Andrew
I'll probably get a complete round up of the U.K. news a little later. I think it more than a little weird that
reached out again right before this arrest. (I don't have
email on this system, so please forward
to him and others.)
Hope you have a a great 4th of July. I'll be back on EDT starting Tuesday morning.
Best,
US DOJ Attaché - London
Subject: Prince Andrew
The Daily Mirror, Daily Telegraph, The Guardian, Daily Mail, Metro, and Daily Express all lead with articles on the
arrest of Ghislaine Maxwell and the implications of this case for Prince Andrew. i and FT have smaller stories.
Daily Mail:
Prince Andrew is 'bewildered' over lack of response from US justice officials as he and Royal Family brace for
new revelations after arrest of Jeffrey Epstein 'pimp' Maxwell
Ghislaine Maxwell, 58, arrested in US for allegedly helping to lure underage girls
Girls were allegedly abused by paedophile Jeffrey Epstein, who died last August
Arrest will now intensify calls for Andrew to be questioned over any involvement
Andrew has previously claimed he has offered three times to be a witness in case
But US prosecutors say he has declined their request to schedule an interview
Full story:
https://www.dailymail.co.uk/news/article-8483875/Prince-Andrews-six-month-standoff-FBl-deepens.html
Best,
EFTA00028760

=== Page 2 ===
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=== Page 1 ===
From:
(USANYS)"
To: "Martin G. Weinberg"
(USANYS)"
Cc: "Miller, Michael"
, Reid Weingarten
Subject: RE: Confidential - Epstein
Date: Fri, 16 Aug 2019 21:15:45 +0000
Thank you for reaching out. We are not able to share that information at this time. If there is anything that you believe
would be useful for us to know as we continue our investigation, please let us know.
From: Martin G. Weinberg
Sent: Thursday, August 15, 2019 4:53 PM
To:
(USANYS)
is
(USANYS)
Cc: 'Miller, Michael'
>; 'Martin G. Weinberg'
>; Reid Weingarten
Subject: Confidential - Epstein
provided us with your contact info. As the prior criminal defense attorneys for Mr
Epstein, and with the approval of the attorney for his Estate, we would ask for you to consider allowing one or more of us
to view any videos showing his jail cell at the MCC or the hallway leading to the entry to his jail cell from midnight-7 AM
on Aug 10, 2019. We would appreciate your consideration of this request.
If we can otherwise help, let us know.
Thanks
Marty
Martin G. Weinberg, Esq.
This Electronic Message contains information from the Law Office
of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee
only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents
of this message is prohibited.
EFTA00027977


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=== Page 1 ===
From:
"
To:
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: RE: Epstein investigation -- discovery
Date: Mon, 26 Oct 2020 23:58:10 +0000
Embedded: RE:_Epstein_investigation__discovery.msg
Sender:
Subject: RE: Epstein investigation -- discovery
Message-Id:
<SN5P110MB054263A5AFC730C49A057FC192190@SN5P110MB0542.NAMP110.PROD.OUTLOOK.COM
>
To:
Cc:
Cc:
EFTA00028477


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=== Page 1 ===
From:
To:
Subject: RE: travel approval request
Date: Tue, 22 Oct 2019 19:04:45 +0000
Thanks
I'm planning to fly down on the morning of 11/4 and fly back that same day. Would it be possible to
please book me on the 7:30am JetBlue flight from LGA to PBI, and the 7:12pm JetBlue flight from PBI to LGA, both on
11/4?
From:
Sent: Tuesday, October 22, 2019 2:03 PM
To:
is
Cc:
is
is
Subject: RE: travel approval request
Good afternoon all,
Please let me know your preferred schedules for your trip to West Palm Beach, FL, and I'll get started on making the
reservations for airfare and hotel ASAP. Thanks.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Tuesday, October 22, 2019 2:00 PM
To:
Cc:
is
V.
is
Subject: RE: travel approval request
Approved for both and the conference room.
From:
Sent: Tuesday, October 22, 2019 1:55 PM
To:
>
Cc:
is
is
is
Subject: RE: travel approval request
Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and
and
we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel on that Monday for the interview, please.
thanks very much,
EFTA00028805

=== Page 2 ===
From:
Sent: Wednesday, June 12, 2019 14:51
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next
week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return no later
than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination of me,
and/or
as previously. And also same as last time, we'd like to ask permission to reserve a conference room at
the hotel on Thursday for the interview, please.
thanks very much,
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
Subject: RE: travel approval request
Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly
down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling allows).
Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will either
be me and
or
and
but we wanted to ask for permission now either way so we weren't doing it
super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to reserve a
conference room at the hotel for the interviews, please.
thanks very much,
From:
Sent: Wednesday, April 03, 2019 20:57
To:
Subject: RE: travel approval request
Thank you
From:
Sent: Wednesday, April 03, 2019 20:46
To:
Cc:
is
Subject: Re: travel approval request
EFTA00028806

=== Page 3 ===
Approved
Sent from my iPad
On Apr 3, 2019, at 8:02 PM,
wrote:
For the same case as below, United States V. Epstein, 2018R01618, an investigation relating to enticement of minors for
sexual activity,
and I would like to please request permission to travel for approximately three days next week for
meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and
return on Friday, though we will shorten the timeframe if scheduling allows.
Please let us know if any other information would be helpful, and thanks very much.
From:
-
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00028807


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=== Page 1 ===
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
33 West 19th Street - 4th Floor
New York, NY 10011
Main
Cell:
Fax:
**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.
EFTA00029237


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=== Page 1 ===
Case 1:20-cr-00330-AJN Document 331 Filed 08/30/21 Page 1 of 5
Haddon, Morgan and Foreman, P.C.
Jeffrey Pagliuca
HADDON
MORGAN
FOREMAN
www.hmflaw.com
jpagliuca@hmflaw.com
August 30, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: Response to Government Letter dated August 18, 2021, Dkt. 320, United States V.
Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
I write in response to the government's letter dated August 18, 2021, Dkt. 320, which
raises two issues.¹
Identities of Co-Conspirators
The government first attempts to walk back its multiple concessions regarding disclosure
of the identities of the unnamed co-conspirators alleged in the S2 indictment.
As this Court noted, Ms. Maxwell has on at least two occasions requested such
disclosure. Dkt. 317 at 12 n.1 (citing Dkt. 291 and Dkt. 293). Only after this Court ordered
disclosure of the identities of the unnamed co-conspirators alleged in the S2 indictment did the
government finally object. The government's objection comes too late.
1 As directed by the Court, on August 24 the parties conferred about the government's
letter, but they were unable to reach an agreement on the government's requests for
reconsideration.
EFTA00029590

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 331 Filed 08/30/21 Page 2 of 5
The Honorable Alison J. Nathan
August 30, 2021
Page 2
The government's objection is, in substance, a motion to reconsider. "There is 'no
specific rule, either in the Federal Rules of Criminal Procedure or in this district's local criminal
rules that provide for reconsideration of a ruling in a criminal matter." United States V.
Okparaeke, No. 17-CR-225 (NSR), 2019 WL 4233427, at *2 (S.D.N.Y. Sept. 6, 2019) (quoting
United States V. Cartagena, No. 10 Cr. 222-2, 2012 WL 2958175, at *1 (S.D.N.Y. July 20,
2012)). Even so, courts have discretion to reconsider prior rulings in criminal cases when the
moving party can point to "controlling law or factual matters which it believes the court
overlooked and that might reasonably be expected to alter the court's decision." United States V.
Berger, 188 F. Supp. 2d 307, 328-39 (S.D.N.Y. 2002).
But "[t]he standard for granting a motion for reconsideration 'is strict." Farmer V.
United States, No. 12-CR-758/15-cv-6287 (AJN), 2017 WL 3448014, at *2 (S.D.N.Y. Aug. 10,
2017) (quoting Analytical Surveys, Inc. V. Tonga Partners, L.P., 684 F.3d 36, 52 (2d Cir. 2012)).
That's because "[r]econsideration of a court's previous order is an "extraordinary remedy to be
employed in the interests of finality and conservation of scarce judicial resources. Montanile V.
Nat'l Broad. Co., 216 F. Supp. 2d 341, 342 (S.D.N.Y. 2002).
The government cannot show extraordinary circumstances here. The government twice
had notice of Ms. Maxwell's request for disclosure, and the government twice chose not to
object. The government cannot use a motion to reconsider to save itself from the consequences
of its deliberate decisions. "[A] losing party" is not permitted to "examin[e] a decision and then
plug[] in the gaps of a lost motion with additional matters." Berger, 188 F. Supp. 2d at 339.
Because that is exactly what the government is attempting to do, this Court should deny the
government's request. Ms. Maxwell is entitled to the disclosure this Court ordered.
EFTA00029591

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 331 Filed 08/30/21 Page 3 of 5
The Honorable Alison J. Nathan
August 30, 2021
Page 3
Co-Conspirator Statements
The government's letter raises a second issue-disclosure of the purported co-conspirator
statements it intends to offer at trial. The government says that, at least as of August 18, it
intends to seek admission of co-conspirator statements from only two individuals: Jeffrey
Epstein and the employee of Epstein's referenced in paragraph 25(d) of the S2 Indictment. Dkt.
320 at 2. But the government also hedges, allowing for the possibility that it might identify
"statements for use at trial from additional co-conspirators." Id.
Both in its August 18 letter and during an August 24 conferral call, the government took
the position that it has no obligation to identify the specific statements it intends to offer under
Federal Rule of Evidence 801(d)(2)(E). The government told defense counsel that Ms. Maxwell
could glean what statements might be offered from the government's witness list and exhibit list,
once those lists are disclosed on October 11.
This Court has already resolved this matter, and the government's position is another
improper attempt to obtain reconsideration.
After conferral, the parties spelled out their positions with respect to the disclosure of co-
conspirator statements and the identities of co-conspirators. Dkt. 291 at 5, 8-9. On June 2, this
Court ordered the government to disclose "co-conspirator statements" no later than October 11.
Dkt. 297 at 1. In the same order, the Court additionally ordered the government to disclose its
witness list and proposed exhibit list, also by October 11. Id. The Court then ordered the parties
to file their motions in limine by October 18 and responses by November 1.²
2 The in limine response date since has been advanced to October 25, 2021. Dkt. 330.
EFTA00029592

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 331 Filed 08/30/21 Page 4 of 5
The Honorable Alison J. Nathan
August 30, 2021
Page 4
If disclosure of the witness and exhibit lists were by themselves sufficient to give Ms.
Maxwell notice of the specific co-conspirator statements the government intends to admit at trial,
this Court would not have separately ordered the government to disclose "co-conspirator
statements." Id. But that's not what the Court did.
There are very good reasons for this. This Court serves as a gatekeeper to the admission
of alleged co-conspirator statements. The Supreme Court's decision in Bourjaily V. United States
requires the Court to determine, by a preponderance of the evidence, whether statements of a co-
conspirator are admissible under Rule 801(d)(2)(E). 483 U.S. 171, 175-76 (1987). In making this
determination, the Court must find that a conspiracy existed, that its members included the
declarant and the party against whom the statement is offered, and that the statement was made
during the course of and in furtherance of the conspiracy. Bourjaily, 483 U.S. at 175.
If the government does not disclose what co-conspirator statements it intends to offer, as
this Court already ordered the government to do by October 11, then Ms. Maxwell will be unable
to file a motion in limine by October 18 challenging the admissibility of the co-conspirator
statements and thereby put the government to its burden of proof and ensure this Court is able to
discharge its gatekeeping function. See Bourjaily, 483 U.S. at 175-76. Although the government
may not wish to give Ms. Maxwell the required notice, this Court has already entered its order.
The government's letter offers no reason, much less a compelling reason, for this Court to
reconsider its order. The government has not even attempted to identify "controlling law or
factual matters which it believes the court overlooked and that might reasonably be expected to
alter the court's decision." Berger, 188 F. Supp. 2d at 328-39. And that's because the Court
didn't overlook anything. The parties briefed this issue in their joint letter regarding pretrial
EFTA00029593

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 331 Filed 08/30/21 Page 5 of 5
The Honorable Alison J. Nathan
August 30, 2021
Page 5
scheduling deadlines, this Court considered the parties' positions, and it made a decision. Dkt.
297 at 1. The government has offered nothing to justify reconsideration.
Conclusion
Ms. Maxwell asks this Court to confirm what it already ordered: (1) that the government
disclose the identities of the unnamed co-conspirators charged in the S2 indictment at the same
time it discloses Jenks Act material; and (2) that, no later than October 11, the government
disclose the specific co-conspirator statements it intends to admit at trial.
Respectfully Submitted,
Jeffrey S. Pagliuca
CC: Counsel of Record (via ECF)
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From:
To:
Cc:
Subject: Re: Mark Epstein
Date: Thu, 24 Oct 2019 15:12:27 +0000
Thank you so very very much
Sent from my iPhone
On Oct 24, 2019, at 10:56 AM,
wrote:
We are confirmed for a meeting at 3:00 p.m. on Monday at
See you then. Thanks.
Assistant United States Attorney
Southern District of New York
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=== Page 1 ===
From:
To: Nathan NYSD Chambers
Cc:
Christian Everdell
'BOBBI C STERNHEIM'
Jeff Pagliuca
, Laura Menninger
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Pseudonym logistics
Date: Thu, 11 Nov 2021 04:43:44 +0000
Attachments: 2021-11-10_GM_letter_re_pseudonyms_and_sealing_final_proposed_redactions].pdf;
2021-11-10_GM_letter_re_pseudonyms_and_sealing_final_[unredacted]pdf,2021-11-
10,_pseudonym_Exhibit_A.pdf
Chambers,
Attached please find a joint letter regarding the parties' proposals for logistics related to the use of pseudonyms.
Attached also is a version highlighting the Government's proposed redactions. A version implementing those redactions
has been filed on ECF.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00028259


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=== Page 1 ===
From:
,
(USANYS) [Contractor]"
To:
)"
Subject: RE: binder
Date: Mon, 27 Sep 2021 18:02:03 +0000
Not a problem! Just printed it and left it on
desk. Let me know if you need anything else.
Best,
From:
Sent: Monday, September 27, 2021 1:33 PM
To:
(USANYS) [Contractor]
Subject: RE: binder
Blue sheets are fine, thanks. No need for tabs or labels or an index. Thanks for putting this together!
From:
(USANYS) [Contractor]
Sent: Monday, September 27, 2021 12:36 PM
To:
Subject: RE: binder
Hi
I just wanted to check with you and see whether you wanted tabs separating the different 302s or if blue sheets were fine,
and also whether you wanted a table of contents at the beginning or not.
Thanks,
From:
Sent: Monday, September 27, 2021 9:26 AM
To:
(USANYS) [Contractor]
Subject: binder
Hi
Thanks again for all your help getting the team ready for the focus group exercise this weekend. For this case, we have a
witness coming in for trial prep this week.
is going to conduct a mock cross examination of her. In order to help him
prep for that, could you please put together a binder of the 302s of her interviews?
can point you to the
folder on the shared where all of that lives (things have been moving around a bit as we prep to produce 3500). The
witness is
(that's her married name- she used to be
, so some documents are titled that
way).
If you're able to get that to
by tomorrow morning, that would be great. Thanks!
Thanks!
Assistant United States Attorney
Southern District of New York
EFTA00027579

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From:
(USANYS) [Contractor]"
To:
(USANYS)"
(USANYS)"
Subject: RE: Scanning
Date: Wed, 28 Aug 2019 17:20:31 +0000
The subpoena log is now updated. For the outstanding requests log would you like me to mark that something has been
received or just to delete it entirely from the spreadsheet?
From:
(USANYS)
Sent: Tuesday, August 27, 2019 6:45 PM
To:
(USANYS) [Contractor]
>;
(USANYS)
Subject: RE: Scanning
Hey
Could you please update the outstanding requests log and the subpoena log tomorrow? Thank you!
From:
(USANYS)
Sent: Tuesday, August 27, 2019 5:00 PM
To:
(USANYS) [Contractor]
>;
(USANYS)
Subject: RE: Scanning
Awesome, thank you!
From:
(USANYS) [Contractor]
Sent: Tuesday, August 27, 2019 4:51 PM
To:
(USANYS)
is
(USANYS)
Subject: Scanning
The beast has been slayed.
I organized the files out of the jumble that they were brought to us in. A few things that
probably be helpful to know:
1. There were some commissary receipts/finance documents pertaining to Epstein's activity inside of prison. I didn't
know where to put this so I left it outside of the folders but still inside MCC Recs
2. In the MCC Regs folder, I put a few things:
a. One file had inventory and then at the end some documents pertaining to daily key counts. I wasn't sure
if these were different so I created a separate file for the key counts just in case (while also keeping them
in the inventory file)
b. The MCC training 06-06-19 & information file was confusing to me. It was massive and I couldn't tell
whether or not I needed to separate anything out.
Everything else should be pretty straightforward as to where it is located. Let me know if you need me to clarify anything
or help any further.
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=== Page 1 ===
From
To
Subject: RE: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:52:49 +0000
Inline-Images: image001.png
Why am I just hearing about this case now?
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 JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
EFTA00027853

=== Page 2 ===
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment [1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
EFTA00027854

=== Page 3 ===
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
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=== Page 1 ===
From:
(USANYS)"
To: Christian Everdell
"Mark S. Cohen"
, Bobbi Sternheim
, "Laura
Menninger"
Jeff Pagliuca
Cc:
)"
)"
)"
(USANYS) [Contractor]"
(USANYS) [Contractor]"
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - discovery production
Date: Mon, 13 Sep 2021 20:12:32 +0000
Attachments: 2021.09.13_Maxwell_Discovery_Letter.pdf
Counsel,
We have an additional discovery production ready to send to you today. Attached please find the accompanying cover
letter. The production will be made via USAfx.
We will send a CD with the new production to the MDC for Ms. Maxwell. As always, if you would prefer that she receive
the production on a drive, we can either request that the MDC send us one of the drives back to load with the production,
or we can load a new drive if you would like to provide us with one.
Chris, we reached out to MDC about your question from Thursday afternoon regarding the photo viewer program. We
will get back to you once we have more information.
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
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=== Page 1 ===
From:
To:
Subject: other epstein trust issue
Date: Mon, 27 Jan 2020 20:15:08 +0000
Attachments: GJ_000283_-_Second_Amendment_to_the_Restated_IEE_2001_Trust_Two.pdf
This one makes reference to a 1/13/2004 amendment to the 2001 Trust Two. Unless I'm missing something. I do not think
we have that amendment.
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=== Page 1 ===
From:
To:
Subject: RE: Epstein Related
Date: Sat, 14 Sep 2019 23:09:28 +0000
Hey I stopped by your office a couple times Thursday and Friday but didn't catch you, sorry about that -- I'm happy to chat
on Monday if you're around. My guess is that some combination of the press office and brass would make the call, but
I'm totally happy to touch base with you if that's useful in the first instance.
From:
Sent: Thursday, September 12, 2019 10:51
To:
Subject: Epstein Related
Do you have a few minutes today or tomorrow to discuss something? Specifically, a good friend of mine is the executive
producer on a 4-part Netflix series that will come out in a few months on Epstein (they had been working on the story for
18 months before we charged). He had spoken to
at one point (not sure how that worked!) and wants to see
if anyone from the office would give an interview, all backward looking. I imagine the answer is no but they are going with
this regardless, so thought I would at least make you and potentially chiefs aware of it. Wanted to start with you. I'm free
between now and noon or after 6pm tonight, or tomorrow morning or after lunch. Thanks!
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=== Page 1 ===
From:
To:
Subject: RE:
)
- Epstein
Date: Tue, 18 May 2021 14:25:46 +0000
Attachments:
.pdf
I apologize. Sent the wrong attachment. The correct one is now attached.
From:
Sent: Monday, May 17, 2021 8:36 PM
To:
(NY) (FBI)
Subject: [EXTERNAL EMAIL] - RE:
)
- Epstein
I think these are the notes for the 302?
From:
Sent: Monday, May 17, 2021 7:26 PM
To:
Subject: RE:
)
- Epstein
Signed.
From:
Sent: Friday, May 14, 2021 3:27 PM
To:
(NY) (FBI)
Subject: [EXTERNAL EMAIL] - FW:
- Epstein
Hi
When you have a chance, could you please initial the proffer agreement and send it back to me? Thanks!
From: Joe Nascimento
Sent: Friday, May 14, 2021 2:56 PM
To:
Cc:
(USANYS)
i
)
Subject: Re:
)
- Epstein
Hi
Thanks again for your time today. Attached, please find a copy of the proffer agreement with updated initials.
Have a nice weekend,
Joe
Joseph E. Nascimento, Esq.
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza 4th Floor
EFTA00028695

=== Page 2 ===
Miami, FL 33129
p.
f.
e.
www.crimlawfirm.com
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=== Page 1 ===
From:
To:
Bcc:
Subject: FW: 21-770 United States of America V. Maxwell "Motion FILED for bail"
Date: Tue, 18 May 2021 05:14:20 +0000
Attachments: Maxwell_renewed_bail_motion.pdf
After the Circuit rejected her prior bail appeal, Maxwell filed the attached "renewed motion" in the Circuit in the same
docket. Can anyone think of a reason she can't do that? Even if it's not procedurally proper, it probably doesn't get us
much, as she could just file a new notice of appeal from AJN's latest order and then file the same motion in the Circuit..
From: cmecf@ca2.uscourts.gov <cmecf@ca2.uscourts.gov>
Sent: Monday, May 17, 2021 4:50 PM
To
Subject: 21-770 United States of America V. Maxwell "Motion FILED for bail"
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of
record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents
filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other
users. To avoid later charges, download a copy of each document during this first viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 05/17/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-770
Document(s): Document(s)
Docket Text:
MOTION, for bail, on behalf of Appellant Ghislaine Maxwell in 21-770, 21-58, FILED. Service date 05/17/2021
by CM/ECF. [3102450] [21-770, 21-58]
Notice will be electronically mailed to:
EFTA00028644

=== Page 2 ===
Notice will be stored in the notice cart for:
Ms. Khadijah Y Young, Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Motion FILED
Original Filename: Motion for Reconsideration4.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=05/17/2021] [FileNumber=3102450-0]
[af9aab28891e80a21dee810d54129a886570637c738ee09dc616f56110a0f1aef0897141dbcec842505547dc49999
11dd5d8fc8da383fbe04f509071ec0dad8]]
Document Description: Supporting Document
Original Filename: Appendix to the Renewed Motion for Reconsideration4.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=05/17/2021] [FileNumber=3102450-1]
[bfd5d5123fc8fc9fca32aecd0dbde6bcfb337f880c0f0bde611f6521f7e4147a1afa4cae33bb83a940a70a8bc2c59239
2b151424f9d6cadb6b194593aaaa12ee]]
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=== Page 1 ===
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 8, 2019
VIA ECF
The Honorable Henry Pitman
United States District Court
Southern District of New York
United States Courthouse
500 Pearl Street
New York, New York 10007
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Pitman:
The Government respectfully submits this letter in advance of the bail hearing scheduled
for July 8, 2019, in the above-captioned case. For the reasons set forth herein, the Court should
order that the defendant be detained pending trial; he cannot meet his burden of overcoming the
presumption that there is no combination of conditions that would reasonably assure his continued
appearance in this case or protect the safety of the community were he to be released.
As set forth below, the charges in this case are exceptionally serious: the defendant is
alleged to be a serial sexual predator who preyed on dozens of minor girls over a period of years,
and he now faces a potentially massive prison sentence predicated on substantial and multifaceted
evidence of his guilt. In light of the strength of the Government's evidence and the substantial
incarceratory term the defendant would face upon conviction, there is an extraordinary risk of
flight, particularly given the defendant's exorbitant wealth, his ownership of and access to private
planes capable of international travel, and his significant international ties. Indeed, the arrest of
the defendant occurred when he arrived in the United States on his private jet after having returned
from a multi-week stay abroad.
Finally, and as detailed herein, the Government has real concerns-grounded in past
experience with this defendant-that if allowed to remain out on bail, the defendant could attempt
to pressure and intimidate witnesses and potential witnesses in this case, including victims and
their families, and otherwise attempt to obstruct justice. As a result, he poses both an acute danger
to the community, including some of its most vulnerable members, and a significant risk of flight.
The defendant thus cannot overcome the statutory presumption that detention is appropriate in this
case, and the Court should order that he be detained pending trial.
EFTA00029004

=== Page 2 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 2
BACKGROUND
A. Overview
On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed
indictment (the "Indictment") charging the defendant with one count of sex trafficking of minors,
in violation of 18 U.S.C. $ 1591, and one count of conspiracy to commit sex trafficking of minors,
in violation of 18 U.S.C. $ 371.
As charged by the grand jury, the facts underlying the charges in the Indictment arise from
a years-long scheme to sexually abuse underage girls. In particular, beginning in at least 2002, the
defendant enticed and recruited dozens of minor girls to engage in sex acts with him, for which he
paid the victims hundreds of dollars in cash.
He undertook this activity in at least two different locations, including his mansion in
Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the
"Palm Beach Residence"). In both New York and Florida, the defendant perpetuated this abuse in
similar ways. Victims were initially recruited to provide "massages" to the defendant, which
would be performed nude or partially nude, would become increasingly sexual in nature, and
would typically include one or more sex acts, including groping and direct or indirect contact with
victims' genitals. The defendant paid his victims hundreds of dollars in cash for each separate
encounter.
Moreover, the defendant actively encouraged certain of his victims to recruit additional
girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying
these victim-recruiters hundreds of dollars for each additional girl they brought to him. In this
fashion, the defendant created a vast network of underage victims for him to exploit, in locations
including New York and Palm Beach.
The defendant's victims were as young as 14 years old when he abused them. Many of his
victims were, for various reasons, often particularly vulnerable to exploitation. The defendant
intentionally sought out-and knew that he was abusing-minors. Indeed, in some instances, his
victims expressly told him they were underage before or during the period in which he abused
them.
In creating and maintaining a network of minor victims whom he abused, the defendant
worked with others, including employees and associates who facilitated his exploitation of minors
by, among other things, contacting victims and scheduling their sexual encounters with the
defendant, both in New York and in Florida.
B. The Defendant
Jeffrey Epstein designed, financed, and perpetrated this scheme, both as its main participant
and through his direction of others, including certain of his employees, to further facilitate his
rampant abuse of underage girls.
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Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 3
As has been widely reported, the defendant is extraordinarily wealthy, and he owns and
maintains luxury properties and residences around the world, including in Manhattan, New York;
Palm Beach, Florida; Stanley, New Mexico; and Paris, France. Additionally, Epstein owns a
private island in the U.S. Virgin Islands which, as noted above, is believed to be his primary
residence in the United States. His mansion in Manhattan alone-a multi-story townhouse
reported to be one of the largest single residences in all of Manhattan, which previously housed a
school and which he owns through an LLC-has been valued at approximately $77 million.
Entities controlled by the defendant also own at least two private jets in active service, at least one
of which is capable of intercontinental travel.
As described further below, the defendant possesses three active United States passports,
and his international connections and travels are extensive. For example, in addition to
maintaining a residence in Paris, France, as described above, in the past 18 months alone, the
defendant has traveled abroad, via private jet, either into or out of the country on approximately
more than 20 occasions.
C. The Prior Florida Investigation
In or about 2005, the defendant was investigated by local police in Palm Beach, Florida, in
connection with allegations that he had committed similar sex offenses against minor girls. The
investigation ultimately also involved federal authorities, namely the U.S. Attorney's Office for
the Southern District of Florida ("SDFL") and the FBI's Miami Office, and included interviews
with victims based in the Palm Beach area, including some of the alleged victims relevant to Count
One of the instant Indictment.
In fall 2007, the defendant entered into a non-prosecution agreement with the SDFL in
connection with the conduct at issue in that investigation, which the non-prosecution agreement
identified as including investigations into the defendant's abuse of minor girls in the Palm Beach
area. The Southern District of New York was not a signatory to that agreement, and the defendant
was never charged federally.² In June 2008, the defendant pled guilty in state court to one count
of procuring a person under the age of 18 for prostitution, a felony, and one count of solicitation
of prostitution, a felony. As a result, the defendant was designated as a sex offender with
registration requirements under the national Sex Offender Registration and Notification Act.
1 The non-prosecution agreement, further discussed below, was entered into at the conclusion of
the SDFL investigation and did not purport to cover any victims outside of the State of Florida.
As noted above, the instant Indictment expressly alleges the existence of dozens of victims who
were abused in this District in addition to dozens of victims who were abused in Florida.
2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the
Second Circuit that absent an express provision to the contrary in the agreement, one District is
not bound by the terms of an agreement entered into between a defendant and a U.S. Attorney's
Office in another district. See page 6, infra.
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=== Page 4 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 4
ARGUMENT
I.
Applicable Law
Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to
order a defendant's detention pending trial upon a determination that the defendant is either a
danger to the community or a risk of flight. 18 U.S.C. $ 3142(e) ("no condition or combination of
conditions would reasonably assure the appearance of the person as required and the safety of any
other person and the community"). A finding of risk of flight must be supported by a
preponderance of the evidence. See, e.g., United States V. Jackson, 823 F.2d 4, 5 (2d Cir. 1987);
United States V. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must
be supported by clear and convincing evidence. See, e.g., United States V. Ferranti, 66 F.3d 540,
542 (2d Cir. 1995); Chimurenga, 760 F.2d at 405. In addition, a court may also order detention if
there is "a serious risk that the [defendant] will attempt to obstruct justice, or to threaten,
injure, or intimidate, a prospective witness or juror." 18 U.S.C. $ 3142(f)(2)(B); see also United
States V. Friedman, 837 F.2d 48 (2d Cir. 1988).
The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the
nature and circumstances of the crimes charged; (2) the weight of the evidence against the person;
(3) the history and characteristics of the defendant, including the person's "character
[and]
financial resources"; and (4) the seriousness of the danger posed by the defendant's release. See
18 U.S.C. $ 3142(g). Evidentiary rules do not apply at detention hearings and the government is
entitled to present evidence by way of proffer, among other means. See 18 U.S.C. $ 3142(f)(2);
see also United States V. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (government entitled
to proceed by proffer in detention hearings); Ferranti, 66 F.3d at 542 (same); United States V.
Martir, 782 F.2d 1141, 1145 (2d Cir. 1986) (same).
Where a judicial officer concludes after a hearing that "no condition or combination of
conditions will reasonably assure the appearance of the person as required and the safety of any
other person and the community, such judicial officer shall order the detention of the person before
trial." 18 U.S.C. $ 3142(e)(1). Additionally, where, as here, a defendant is charged with
committing an offense involving a minor victim under 18 U.S.C. $ 1591, it shall be presumed,
subject to rebuttal, that no condition or combination of conditions will reasonably assure the
appearance of the defendant as required and the safety of the community. 18 U.S.C.
$ 3142(e)(3)(E).
II.
Discussion
The defendant should be detained pending trial. For the reasons set forth below, it is
difficult to overstate the risk of flight and danger to the community if the defendant is released,
and for those reasons, the defendant cannot overcome the statutory presumption in favor of
detention in this case.
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Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 5
A. The Defendant Poses an Extreme Flight Risk
Each of the relevant factors to be considered as to flight risk - the nature and circumstances
of the offense, the strength of the evidence, and the history and characteristics of the defendant -
counsel strongly in favor of detention.
1. The Nature and Circumstances of the Offense and the Strength of the Evidence
The "nature and circumstances" of this offense plainly favor detention. 18 U.S.C.
$
3142(g)(1) (specifically enumerating "whether the offense. involves a
minor
victim"
as
a
factor in bail applications). Indeed, the crime of sex trafficking of a minor is so serious that for a
defendant charged with that offense, there is a presumption that no condition or combination of
conditions will reasonably assure the appearance of the defendant as required and the safety of the
community. 18 U.S.C. $ 3142 (e)(3)(E). Here, as specified in the Indictment, the defendant's
conduct was committed serially, over a period of years, and affected dozens of victims.
The seriousness of the charge is also reflected in the penalties the defendant faces, which
include up to 45 years of incarceration for Counts One and Two of the Indictment. As the Second
Circuit has noted, the possibility of a severe sentence is a significant factor in assessing the risk of
flight. See Jackson, 823 F.2d at 7; see also United States V. Cisneros, 328 F.3d 610, 618 (10th Cir.
2003) (defendant was a flight risk because her knowledge of the seriousness of the charges against her
gave her a strong incentive to abscond); United States V. Townsend, 897 F.2d 989, 995 (9th Cir. 1990)
("Facing the much graver penalties possible under the present indictment, the defendants have an even
greater incentive to consider flight."). Here, the defendant is facing a statutory maximum of decades
in prison. Even in the absence of means-which, as discussed in detail below, the defendant has
in abundance-this fact alone would provide a compelling incentive for anyone to fail to appear.
It is particularly compelling for a defendant who is 66 years old and therefore faces the very real
prospect of spending the rest of his life in prison if convicted.
The likelihood of a substantial period of incarceration is buttressed by the strength of the
evidence. As set forth in the Indictment, the evidence in this case is strong. The Indictment alleges
that the defendant sexually abused dozens of minor victims, and the conspiracy count lists
numerous overt acts committed in furtherance of the defendant's crimes.4
3 The current penalties for violations of 18 U.S.C. $ 1591 include a 10 year mandatory minimum
sentence. However, that punishment was created through an amendment to the statute in 2006.
The penalty for a violation of Section 1591 during the period charged in the Indictment, and
therefore relevant here, was a maximum of 40 years' imprisonment.
4 With respect to the evidence in this case, the Court should start its analysis by accepting that the
Indictment is sufficient, on its own, to establish probable cause that the defendant committed the
crimes of sex trafficking and sex trafficking conspiracy. Contreras, 776 F.2d at 54. ("Were an
evidentiary hearing addressing the existence of probable cause required in every $ 3142(e) case in
which an indictment had been filed, the court would spend scarce judicial resources considering
that which a grand jury had already determined, and have less time to focus on the application of
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=== Page 6 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 6
Multiple victims, including several specified in the Indictment, have provided information
against the defendant. That information is detailed, credible, and corroborated, in many instances,
by other witnesses and contemporaneous documents, records and other evidence-including, as
further detailed below, evidence from a search of the New York Residence on the night of the
defendant's arrest that reflects an extraordinary volume of photographs of nude and partially-nude
young women or girls. Such corroborating evidence also includes documents and other materials,
such as contemporaneous notes, messages recovered from the defendant's residence that include
names and contact information for certain victims, and call records that confirm the defendant and
his agents were repeatedly in contact with various victims during the charged period. Put simply,
all of this evidence - the voluminous and credible testimony of individuals who were sexually
abused by the defendant as minors, each of whom are backed up by other evidence - will be
devastating evidence of guilt at any trial in this case and weighs heavily in favor of detention.
Finally, it bears noting that neither the age of the conduct nor the defendant's previous non-
prosecution agreement ("NPA") with a different federal district pose any impediment to his
conviction. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283,
which was amended in 2003 to extend the limitations period for conduct that was timely as of the
date of the amendment, to any time during the lifetime of the minor victim. See United States V.
Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because Congress extended the statute
of limitations for sex offenses involving minors during the time the previous statute was still
running, the extension was permissible); United States V. Pierre-Louis, No. 16 Cr. 541 (CM), 2018
WL 4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same).
Moreover, with respect to the NPA, that agreement, to which the Southern District of New
York was not a party, which by its express language pertained exclusively to the SDFL
investigation, and which did not purport to bind any other Office or District, does not preclude
prosecution in this District for at least two reasons. First, it is well settled in the Second Circuit
that "a plea agreement in one U.S. Attorney's office does not, unless otherwise stated, bind
another." United States V. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) ("A plea agreement binds
only the office of the United States Attorney for the district in which the plea is entered unless it
affirmatively appears that the agreement contemplates a broader restriction.") (citing United States
V. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). This is true even if the text of the
agreement purports to bind "the Government." See Annabi, 771 F.2d at 672. This analysis
similarly extends to a non-prosecution agreement. See United States V. Laskow, 688 F. Supp. 851,
854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is an explicit statement
to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States
Attorney that are not parties to the agreement. This position is at odds with the law in this Circuit,
which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can
affirmatively establish that a more expansive interpretation was contemplated.") (citing Annabi,
771 F.2d at 672). Second, the Indictment charges conduct not covered by the NPA, namely
the presumptions and the $ 3142(g) factors in deciding whether the defendant should be
detained.").
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Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 7
conduct that occurred in New York. The prior NPA included a list of several dozen victims
identified in the prior investigation, all of whom were abused in the State of Florida, and none of
whom are a part of the conduct charged in Count Two of the instant Indictment.
Each of these factors-the seriousness of the allegations, the strength of the evidence, and
the possibility of lengthy incarceration-creates an extraordinary incentive to flee. And as further
described below, the defendant has the means and money to do so.
2. The Characteristics of the Defendant
The history and characteristics of the defendant also strongly support detention. The
defendant is extraordinarily wealthy and has access to vast financial resources to fund any attempt
to flee. Indeed, his potential avenues of flight from justice are practically limitless.
As the defendant acknowledged in his most recent New York State sex offender
registration, he has six residences, including two in the U.S. Virgin Islands (including his own
private island), and one each in Palm Beach, Florida; Paris, France; New York, New York; and
Stanley, New Mexico. The most recent estimated value of the defendant's New York City mansion
alone is more than $77 million. The most recent tax-assessed value of the defendant's Palm Beach
estate is more than $12 million. The defendant's primary residence is a private island in the U.S.
Virgin Islands, a place where any sort of meaningful supervision would be all but impossible.
Moreover, the defendant has access to innumerable means to flee. His sex registration
documentation of "current vehicles" lists no fewer than 15 motor vehicles, including seven
Chevrolet Suburbans, a cargo van, a Range Rover, a Mercedez-Benz sedan, a Cadillac Escalade,
and a Hummer II. These cars are registered in various states and territories including the Virgin
Islands, New York, Florida, and New Mexico. The defendant also has access to two private jets,
giving him the ability to leave the country secretly and on a moment's notice and to go virtually
anywhere he wants to travel. He is a very frequent international traveler and regularly travels to
and from the United States by private plane. In particular, between January 1, 2018, and the
present, U.S. Customs and Border Patrol has logged approximately more than 20 flights in which
Epstein was traveling to or from a foreign country. Indeed, he was arrested at Teterboro Airport
arriving on just such a private international flight after having spent approximately three weeks
abroad. Extensive international travel of this nature further demonstrates a significant risk of
flight. See, e.g., United States V. Anderson, 384 F. Supp. 2d 32, 36 (D.D.C. 2005). There can be
no assurance that, upon release, the defendant would suddenly lack access to such means of travel.
Finally, the defendant has no meaningful ties that would keep him in this country. The
defendant has no known immediate family. He is not married and has no children. He has friends
and associates worldwide, as demonstrated by his extensive international travel, and his
professional obligations, if any, can and seemingly are plainly capable of being handled by the
defendant remotely. Simply put, there would be no meaningful reason for the defendant to remain
in the country, while he would have every incentive (and every resource needed) to flee.
Nor would home confinement with electronic monitoring reasonably assure the
defendant's presence as required. At best, home confinement with electronic monitoring would
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Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 8
merely reduce his head start should he decide to flee. See United States V. Zarger, No. 00 Cr. 773,
2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application
for bail in part because home detention with electronic monitoring "at best
limits a fleeing
defendant's head start"); see also United States V. Casteneda, No. 18 Cr. 047, 2018 WL 888744,
at *9 (N.D. Cal. Feb. 2018) (same); United States V. Anderson, 384 F.Supp.2d 32, 41 (D.D.C.
2005) (same); United States V. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y.
Oct. 10, 2002) (same).
Finally, there can be little doubt that the defendant is in a position to abandon millions of
dollars in cash and property securing any potential bond and still live comfortably for the rest of
his life. These resources, and the ease with which the defendant could flee and live outside the
reach of law enforcement-particularly considering his vast wealth and lack of meaningful ties to
this District-make the risk of flight exceptionally high in this case, particularly when considered
in conjunction with the strength of the government's case and the lengthy sentence the defendant
could receive if convicted.
B. The Defendant Poses a Risk of Danger to the Community and of Engaging in
Obstruction of Justice
The release of the defendant, under any conditions, would pose a significant threat to the
community and to the ongoing investigation.
As described above, where there is probable cause to believe that an individual has
committed an offense under 18 U.S.C. $ 1591, it is presumed that no condition or combination of
conditions can reasonably assure the safety of the community. 18 U.S.C. $ 3142(e)(3). Here, not
only is the defendant charged with very serious sex crimes against minors, he has already
previously admitted to-and been convicted of-engaging in related conduct. Specifically, in
June 2008, the defendant pled guilty in state court to one count of procuring a person under the
age of 18 for prostitution, a felony, and he currently is a registered sex offender, under
classification level three in New York-defined as presenting a "high" risk of committing another
sex crime and harm to the community. While the conduct presently alleged does not post-date the
2008 conviction, it nevertheless underscores the risk he poses to the community if released.
Additionally, and in connection with the investigation of the defendant's offense in Florida,
there were credible allegations that the defendant engaged in witness tampering, harassment, or
other obstructive behaviors. In fact, according to publicly-filed court documents, there were
discussions between prosecutors and the defendant's then-counsel about the possibility of the
defendant pleading guilty to counts relating to "obstruction," as well as "harassment," with
reference to 18 U.S.C. $ 1512, which criminalizes "[t]ampering with a witness, victim, or
informant." For example, in a communication from the defendant's then-counsel to prosecutors
in SDFL, his counsel set forth a possible factual proffer that included statements that the defendant
had "attempted to harass both [redacted] delay and hinder their receipt of a [redacted] to attend an
official proceeding" and that the defendant "in particular, changed travel plans and flew with both
[redacted] to the United States Virgin Islands rather than to an airport in New Jersey in order to
attempt to delay their receipt of what Mr. Epstein expected to be a [redacted]" and "further verbally
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=== Page 9 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 9
harassed both [redacted] in connection to this attempt to delay their voluntary receipt of process
all in violation of 18 USC 1512(d)(1)." Doe V. United States, 08 Civ. 80736 (S.D. Fla.), Dkts.
361 at 3-4, 361-7 through 361-11. In addition to 18 U.S.C. $ 1512(d), prosecutors also proposed
that the defendant could plead guilty to 18 U.S.C. $ 403, that is, a knowing or intentional violation
of the privacy protection of child victims and child witnesses, to which the defendant's then-
counsel replied: "Already thinking about the same statutes." Id. Dkt. 361-11. They also discussed
a possible obstruction plea that "could rely on the incident where Mr. Epstein's private
investigators followed [redacted] father, forcing off the road." Id. Dkt. 361-10.
The defendant's apparent previous willingness to obstruct a federal investigation, harass or
tamper with witnesses, and hire private investigators that "forc[ed] off the road" the father of an
individual relevant in the investigation is alarming. It should especially weigh on the Court's
consideration here because the defendant was apparently willing to take those steps before even
being charged and thus facing federal indictment; the incentive to interfere in the Government's
case here, where an Indictment has been returned, is exponentially greater. And as discussed
above, the defendant has nearly limitless means to do so.
Finally, despite having been previously convicted of a sex offense involving an underage
victim, the defendant has continued to maintain a vast trove of lewd photographs of young-looking
women or girls in his Manhattan mansion. In a search of the New York Residence on the night of
his arrest, on July 6-7, 2019, pursuant to judicially-authorized warrants, law enforcement officers
discovered not only specific evidence consistent with victim recollections of the inside of the
mansion, further strengthening the evidence of the conduct charged in the Indictment, but also at
least hundreds-and perhaps thousands-of sexually suggestive photographs of fully- or partially-
nude females. While these items were only seized this weekend and are still being reviewed, some
of the nude or partially-nude photographs appear to be of underage girls, including at least one girl
who, according to her counsel, was underage at the time the relevant photographs were taken.
Additionally, some of the photographs referenced herein were discovered in a locked safe, in which
law enforcement officers also found compact discs with hand-written labels including the
following: "Young [Name] + [Name]," "Misc nudes 1," and "Girl pics nude." The defendant, a
registered sex offender, is not reformed, he is not chastened, he is not repentant;6 rather, he is a
continuing danger to the community and an individual who faces devastating evidence supporting
deeply serious charges.
5 The redactions above are contained in the publicly filed version of the quoted document.
6 See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator,
N.Y. Post (2011) ("I'm not a sexual predator, I'm an "offender," the financier told The Post
yesterday. 'It's the difference between a murderer and a person who steals a bagel."); Philip
Weiss, The Fantasist, New York Magazine (2007) ("It's the Icarus story, someone who flies too
close to the sun,' I said. 'Did Icarus like massages?' Epstein asked.").
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=== Page 10 ===
Honorable Henry Pitman
United States Magistrate Judge
July 8, 2019
Page 10
CONCLUSION
As set forth above, in this case, the risk of flight in this case is extraordinarily real. The
defendant is extremely wealthy, has extensive foreign contacts, and is charged with serious
offenses that carry a potential statutory sentence of up to 45 years' imprisonment-even a fraction
of which could result in the defendant, who is 66 years old, spending the rest of his life in jail. In
sum, the defendant's transient lifestyle, his lack of family or community ties, his extensive
international travel and ties outside the country, and his vast wealth, including his access to and
ownership of private planes, all provide the defendant with the motive and means to become a
successful fugitive. Further, the nature of the offenses he is alleged to have perpetrated-the abuse
dozens of underage, vulnerable girls-along with his demonstrated willingness to harass,
intimidate and otherwise tamper with victims and other potential witnesses against him, render his
dangerousness readily apparent.
Accordingly, the Government respectfully submits that the defendant cannot and will not
be able to meet his burden of overcoming the strong presumption in favor of detention, that there
are no conditions of bail that would assure the defendant's presence in court proceedings in this
case or protect the safety of the community, and that any application for bail should be denied.
Very truly yours,
GEOFFREY S. BERMAN
United A
By:
/
/
Assistant United States Attorney
Southern District of New York
Tel: (212) 637-2415 / 2225 / 2324
Cc:
Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant
Hon. Richard M. Berman, United States District Judge
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: SDFL
Date: Mon, 19 Apr 2021 21:57:42 +0000
Attachments: 2021.04.19_SDFL_Boxes_-_Paralegal_Review_Protocol.pdf
Terrific, thanks! Attached is the memo. I'm around this evening and flexible tomorrow whenever you want to have a call.
From:
Sent: Monday, April 19, 2021 5:26 PM
To:
Subject: SDFL
Hey,
We've gotten four additional people to help out bringing our total to eight. Have you had the chance to write up the
memo? I'd send it out tonight and then schedule a call to answer any questions if need be.
Thanks,
Paralegal Specialist
United States Attorney's Office I SDNY
New York, NY 10007
Office:
Cell:
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From:
To:
Cc:
Subject: RE: Jane Doe 43 V. Epstein, et al., 17 Civ. 616 (JGK)(SN)
Date: Tue, 05 Feb 2019 18:57:47 +0000
-
Importance: Normal
Attachments: 2019-02-05,_JE,_unsealing_application_and_order_17_Civ_616_(SN).pdf
To the Chambers of Judge Netburn:
Please see the attached application and proposed order in connection with the above-captioned case, which the
Government respectfully requests be filed under seal for the reasons explained in the application.
Respectfully,
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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 21, 2021
BY ECF
The Honorable Analisa Torres
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
Re:
United States V. Noel and Thomas, 19 Cr. 830 (AT)
Dear Judge Torres:
The Government submits this letter to inform the Court that the parties have entered into
deferred prosecution agreements (the "Agreements"), which have been approved by Pretrial
Services and are included for the Court's consideration.¹ After a thorough investigation, and based
on the facts of this case and the personal circumstances of the defendants, the Government has
determined that the interests of justice will best be served by deferring prosecution in this District.
The proposed Agreements contemplate an additional six-month term of supervision by Pretrial
Services and, in addition to the standard terms of pretrial supervision, the proposed Agreements
include the additional salient terms:
The defendants will cooperate with a pending Department of Justice Office of Inspector
General review by providing truthful information related to their employment by the
Bureau of Prisons, including about the events and circumstances described in the
Indictment; and
The defendants will complete 100 hours of community service, preferably in an area related
to the criminal justice system.
The defendants have consented to the entry of the Agreements and have also admitted that
they "willfully and knowingly completed materially false count and round slips regarding required
counts and rounds in the Special Housing Unit of the Metropolitan Correctional Center on August
9, 2019 and August 10, 2019."
The Government respectfully requests, with the consent of the defendants, through counsel,
that the Court schedule a hearing date for entry of the Agreements. Having conferred with defense
1 As the deferred prosecution agreements are not final until they are approved by the Court, the
Government has not filed them publicly with this letter.
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=== Page 2 ===
Page 2
counsel, the Government proposes the following dates, should any of them prove convenient for
the Court:
[DATES]
Respectfully submitted,
AUDREY STRAUSS
United States Attorney
By:
/s/
Assistant United States Attorneys
Cc:
Defense Counsel
Pretrial Services
EFTA00028583


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-58 United States of America V. Maxwell "Defective Document FILED"
Date: Thu, 01 Apr 2021 16:15:37 +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 04/01/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Document(s): Document(s)
Docket Text:
DEFECTIVE DOCUMENT, motion for bail, [36], on behalf of Appellant Ghislaine Maxwell in 21-58, 21-770,
FILED.[3068308] [21-58, 21-770]
Notice will be electronically mailed to:
The following document(s) are associated with this transaction:
Document Description: Defective_Document_Notice
Original Filename:
/opt/ACECF/live/forms/
2158_3068308_Defective_Document_Notice_142.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=04/01/2021] [FileNumber=3068308-0]
[22ac24bf9567329b90328b6228eaaa8ca707dc5a039b7084bad2868d7f7c6521ee430394e9c5db35c75a8dc09f721
3ca161f69833cc70aacc5cb62086773ca32]]
Recipients:
EFTA00027357

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=== Page 1 ===
an
SUPERIOR COURT
19
ISLANDS
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN
COPY
IN THE MATTER OF THE ESTATE OF
)
JEFFREY E. EPSTEIN
)
PROBATE NO. ST-19-PB-
)
Deceased.
)
ACTION FOR TESTATE
)
ADMINISTRATION
PETITION FOR PROBATE AND FOR LETTERS TESTAMENTARY
COME NOW Petitioners DARREN K. INDYKE and RICHARD D. KAHN, Executors
of the Estate of Jeffrey E. Epstein, by and through KELLERHALS FERGUSON KROBLIN PLLC, and
petition this Honorable Court to grant the instant petition pursuant to V.I. CODE ANN. tit. 15, $ 161
COURT NISUIA ON
SUPERIOR
and Rule 3 of the Virgin Islands Rules for Probate and Fiduciary Proceedings. In support thereof,
Petitioners state the following:
60
ANDS
1)
That Petitioners Darren K. Indyke and Richard D. Kahn ("Petitioners") are citizens of the
United States of America and residents of Florida and New York, respectively.
2)
The original Last Will and Testament of Decedent, dated August 8, 2019, which is attached
hereto, appoints Petitioners as Executors of the Estate.
3)
The Decedent, Jeffrey E. Epstein, died testate on August 10, 2019 in New York, New
York, and was domiciled in and a resident of St. Thomas, Virgin Islands at the time of his
death, as supported by the copy of Certificate of Death attached hereto.¹
4)
Decedent left certain assets in trust.
5)
The Decedent died possessed of certain property within the Territory of the U.S. Virgin
Islands and within the jurisdiction of the Court as herein described:
1 The original death certificate, or a certified copy thereof, will be filed with the Court upon Counsel's receipt of the same.
EFTA00027979

=== Page 2 ===
Estate of Jeffrey E. Epstein
Probate No. ST-19-PB-
Petition for Probate and Letters Testamentary
Page No. Page 2 of 4
PERSONAL PROPERTY²
VALUE
Cash
$56,547,773.00
Fixed Income Investments
$ 14,304,679.00
Equities
$ 112,679,138.00
Aviation Assets, Automobiles and Boats
$ 18,551,700.00
Fine Arts, Antiques, Collectibles,
Valuables & Other
TBD subject to
Personal Property
appraisal/valuation
Hedge Funds & Private Equity Investments
$194,986,301.00
10,000 shares of Maple, Inc., a U.S. Virgin Islands
corporation which holds title to
$55,931,000.00
10,000 shares of Cypress, Inc., a U.S. Virgin Islands
Corporation, which holds title to
$17,246,208.00
10,000 shares of Laurel, Inc., a U.S. Virgin Islands
Corporation, which holds title to
$ 12,380,209.00
999 shares of SCI JEP, a French Company
which holds title to units 47 with mezzanine, 48 and 81
on the 2nd floor, units 63 and 74 on the 5th floor and
units 5 and 22 (cellars) in the basement
$ 8,672,823.00
10,000 shares of Poplar, Inc., a U.S. Virgin Islands
Corporation, which holds title to
Great St. James Island
$ 22,498,600.00
10,000 shares of Nautilus, Inc., a U.S. Virgin Islands
Corporation, which holds title to
Little St. James Island
$ 63,874,223.00
TOTAL PERSONAL PROPERTY:
$ 577,672,654.00
TOTAL ESTATE PROPERTY:
$ 577,672,654.00
2 Values are subject to appraisal and/or update to their date of death valuation, which will be confirmed in verified
inventory to be filed with the Court.
EFTA00027980

=== Page 3 ===
Estate of Jeffrey E. Epstein
Probate No. ST-19-PB-
Petition for Probate and Letters Testamentary
Page No. Page 3 of 4
6)
Petitioners are investigating potential debts and claims of the Estate and at this time they
are unknown.
7)
That the names and addresses, insofar as known to Petitioners, of the heirs and next of
kin of the deceased, who would be entitled to share the estate if he had left no will; the
relation of each such person to him; the proportion due each such person, and whether
each of them is an adult or an infant are as follows:
NAMES
RELATIONSHIP
CAPACITY
SHARE
Mark Epstein
Brother
Adult
100%
8)
That Petitioners Darren K. Indyke and Richard D. Kahn be appointed Executors. They
are adults of sound mind, are not convicted of any crime involving moral turpitude, and
are not judicial officers of this Honorable Court.
9)
Although Petitioners are not residents of the Virgin Islands, they are qualified to serve as
Executors pursuant to 15 V.I.C. s 235(c) because they otherwise qualify under 15 V.I.C. s
235(a) and they have appointed the law firm of Kellerhals Ferguson Kroblin PLLC, which
has offices on St. Thomas, Virgin Islands, to accept service of all papers for purposes of
the probate of Decedent's estate.
10)
The Decedent's Last Will and Testament provides that "No bond or other security shall
be required of any Executor in any jurisdiction." See original Last Will and Testament
attached hereto at Article THIRD, subsection B on page 2. Accordingly, Petitioners pray
that the bond be waived pursuant to V.I. R. Prob. 3.
EFTA00027981

=== Page 4 ===
Estate of Jeffrey E. Epstein
Probate No. ST-19-PB-
Petition for Probate and Letters Testamentary
Page No. Page 4 of 4
WHEREFORE, Petitioners pray:
A. That the Estate of Jeffrey E. Epstein be entered into Probate;
B. That a citation be issued to any heir or next of kin who has not signed a Waiver;
C. That this Honorable Court order the issuance of a notice to creditors and claims procedure
order in substantial form of that which will be separately proposed to the court forthwith;
D. That the Last Will and Testament of Jeffrey E. Epstein, attached hereto, be admitted to
Probate;
E. That Darren K. Indyke and Richard D. Kahn be appointed Executors and Letters
Testamentary be issued to them;
F. That the bond be waived; and
G. That the Petition be granted.
Respectfully,
DATED: August 15 2019
WILLIAM BLUM, ESQ., Of Counsel
V.I. Bar No. 136
KELLERHALS FERGUSON KROBLIN PLLC
Royal Palms Professional Building
Telephone:
Facsimile:
Email:
EFTA00027982

=== Page 5 ===
Estate of Jeffrey Epstein
Probate No. ST-19-PB-
Petition for Probate and Letters Testamentary
VERIFICATION OF PETITION
I, Darren K. Indyke, Executor of the Last Will and Testament of Jeffrey E. Epstein, hereby
verify I have read and do hereby certify that the statements contained in the Petition for Probate
and for Letters Testamentary are accurate in so far as my knowledge and insofar as my own records
show.
DATED: August 15 , 2019
Darren Darren K. Indyke Indyne
SUBSCRIBED AND SWORN to before me
this 15 day of Avaust 2019.
Eh has
Notary Public State of Florida
Elie Macius
My Commission GG 137817
Expires 08/24/2021
EFTA00027983

=== Page 6 ===
Estate of Jeffrey Epstein
Probate No. ST-19-PB-
Petition for Probate and Letters Testamentary
VERIFICATION OF PETITION
I, Richard D. Kahn, Executor of the Last Will and Testament of Jeffrey E. Epstein, hereby
verify I have read and do hereby certify that the statements contained in the Petition for Probate
and for Letters Testamentary are accurate in so far as my knowledge and insofar as my own records
show.
DATED: August 15th , 2019
aubaid D Kalm
Richard D. Kahn
is
reby
SUBSCRIBED AND SWORN to before me
this 15th day of August , 2019.
mananne Baractt
MARIANNE BARNETT
NOTARY PUBLIC, STATE OF NEW YORK
by
NO. 01BA6276845
Qualified in Suffolk County
the
Term expires February 25, 2021
EFTA00027984

=== Page 7 ===
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN
IN THE MATTER OF THE ESTATE OF
)
JEFFREY E. EPSTEIN
)
PROBATE NO. ST-19-PB-
)
Deceased.
)
ACTION FOR TESTATE
)
ADMINISTRATION
OATH OF WILLINGNESS TO SERVE AS EXECUTOR AND
APPOINTMENT OF LOCAL COUNSEL
I, Darren K. Indyke, hereby declare, certify, verify, and state under penalty of perjury under
the laws of the United States Virgin Islands that:
1. I am an adult of sound mind, have never been convicted of any felony or of a misdemeanor
involving moral turpitude, and I am not a judicial officer.
2. I am a resident of Florida.
3. The Last Will and Testament of Jeffrey E. Epstein nominates and appoints me as an
Executor of the Estate of Jeffrey E. Epstein, deceased.
4. I am willing to act as Executor of the above-captioned Estate according to the law and to
the best of my ability and I will faithfully discharge the duties and obligations of Executor.
5. I will render a true accounting of all monies and property coming into my possession for
which I am responsible.
6. I am willing to act as Executor of the above-captioned Estate and request that the Court act
upon and grant all the prayers of the Petition for Probate.
7. I am a non-resident of the Virgin Islands, and thus, I appoint the law office of KELLERHALS
FERGUSON KROBLIN PLLC, located in the Virgin Islands, specifically at Royal Palms
Professional Building,
as my
attorney upon whom service of all papers may be made.
Darren K. Indyke
SUBSCRIBED AND SWORN to before
me this IS day of Avaust, 2019.
rh had
NOTARY
Notary Public State of Florida
Elie Macius
My Commission GG 137817
Expires 06/24/2021
EFTA00027985

=== Page 8 ===
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN
IN THE MATTER OF THE ESTATE OF
)
JEFFREY E. EPSTEIN
)
PROBATE NO. ST-19-PB-
)
Deceased.
)
ACTION FOR TESTATE
)
ADMINISTRATION
OATH OF WILLINGNESS TO SERVE AS EXECUTOR AND
APPOINTMENT OF LOCAL COUNSEL
I, Richard D. Kahn, hereby declare, certify, verify, and state under penalty of perjury under
the laws of the United States Virgin Islands that:
1. I am an adult of sound mind, have never been convicted of any felony or of a misdemeanor
involving moral turpitude, and I am not a judicial officer.
2. I am a resident of New York, New York.
3. The Last Will and Testament of Jeffrey E. Epstein nominates and appoints me as an
Executor of the Estate of Jeffrey E. Epstein, deceased.
4. I am willing to act as Executor of the above-captioned Estate according to the law and to
the best of my ability and I will faithfully discharge the duties and obligations of Executor.
5. I will render a true accounting of all monies and property coming into my possession for
which I am responsible.
6. I am willing to act as Executor of the above-captioned Estate and request that the Court act
upon and grant all the prayers of the Petition for Probate.
7. I am a non-resident of the Virgin Islands, and thus, I appoint the law office of KELLERHALS
FERGUSON KROBLIN PLLC, located in the Virgin Islands
1
Palms
Professional Building,
attorney upon whom service of all papers may be made
Outiand D. Kalm
as my
Richard D. Kahn
SUBSCRIBED AND SWORN to before
act
me this 15th day of August 2019.
MARIANNE BARNETT
NOTARY PUBLIC, STATE OF NEW YORK
NO. 01BA6276845
NOTARY
Qualified in Suffolk County
Term expires February 25, 2021
EFTA00027986

=== Page 9 ===
THE CITY OF NEW YORK
VITAL RECORDS CERTIFICATE
DEATH TRANSCRIPT
DATE FILED THE CITY OF NEW YORK- DEPARTMENT OF HEALTH AND MENTAL HYGIENE
AUG-11-2019 07:36 PM
CERTIFICATE OF DEATH
Certificate No. 156-19-032838
1. DECEDENT'S
JEFFREY EDWARD EPSTEIN
LEGAL NAME
(First, Middle, Last)
2a. New York City
Place
2c. Type of Place
4
Nursing Home/Long Term Care Facility
2d. Any Hospice care
2e. Name of hospital or other facility (If not facility, street address)
2b. Borough
1
Of
Hospital Inpatient
5
Hospice Facility
in last 30 days
1
Yes
2
Emergency Dept/Outpatient 6
Decedent's Residence
No
New York-Presbyterian-Lower Manhattan Hospital
Death
Manhattan
2
3
Dead on Arrival
7
Other Specify
3
Unknown
Date and Time of Death
3a.
(Month)
(Day)
(Year-yyyy)
3b. Time
a AM
4. Sex
5. OCME Case No.
or Found Dead
August
10
2019
7:36
PM
Male
M19019432
6.C
P
a. Immediate cause
Pending Further Study
A
R
b. Due to or as a
(To be filled in by the OCME)
T
consequence of
I I
CHENT TO DEASH
1
c. Due to or as a
M OF
consequence of
Other significant conditions contributing to death but not resulting in the underlying cause given in Part I. Include operation information.
PART #
7a. Injury Date (mm dd mm)
7b. Time
7c. At Work
7d. Place of Injury At home. factory, street. etc.
AM
1 Yes
***
PM
2
No
7e. Location
NNY
71. How injury Occurred
7g. If Transportation Injury Specify
8. Manner of Death
9. Autopsy
10. On the basis of examination and/or investigation, in my opinion, death occurred due to
Driver/Operator
Pedestrian
Pending further study
W Yes
x the causes and manner as stated
Natural
Homicide
No Autopsy
Certifier Signature
Kristin Roman
M.D. D.O. Date AUG-11-2019
Passenger
Accident
Suicide
Undetermined
Pursuant to Law
Other Specify
No Autopsy
Certifier Name (Print)
KRISTIN
ROMAN
Medical Examiner
(Medical Investigator) (Deputy Chief) (Chief) (Medical Examiner)
11a. Usual Residence State
11b. County
11c. City or Town
11d. Street and Number
Apt. No.
ZIP Code
11a. Inside City Umits
US Virgin Islands
St. Thomas
St. Thomas
Little Saint James Island
00802
1
Yes 2 No
12 Date of Birth (Month) (Day)
(Year YYYY)
13. Age at last birthday
Under 1 Year
Under 1 Day
1
14. Social Security No.
(years)
Months
DAYS
Hours
Minutes
January 20
1953
66
,
4
-3348
15a. Usual Occupation (Type of work done during most of working life.
15b. Kind of business or industry
16. Allases or AKAB
Do not use "retired") Consultant
Finance
(To be filled in by Funeral Director or, in case of City Burlal by OCME)
17. Birthplace (City & State or Foreign Country)
18. Education (Check the box that best describes the highest degree or level of school completed of the time of death)
8th grade or less: none
4
at Some college credit. but no degree
Master's degree (eg. MA, MS MEng MEd. MSW. MBA
Brooklyn, New York
2
9th -12th grade; no diploma
5
Associate degree (e.g., M, AS)
8
Doclorate (e.g., PhD. EdD) or
3
High school graduate or GED
6
Bachelor's degree (e.g., BA, AB, BS)
Professional degree (e.g., MD, DOS. DVM, LLB, JD)
19. Ever in U.S.
20. Marital/Partnership Status at time of death
21: Surviving Spouse's Partner's Name (If wife, name prior to first marriage)(First, Middle, Last)
Armed Forces?
1
Married
Domestic Partnership
3
Divorced
4
Married. but separated
5 at Never Married
6
Widowed
1
Yes
2 or No
7
Other, Specify
Unknown
22. Father's Name (First, Middle, Last)
23. Mother's Maiden Name (Prior to first marriage) (First, Middle, Last)
Seymour Epstein
Paula Stolofsky
24a. Informant's Name
24b. Relationship to Decedent
Address
(Street
ADI.
No.
Civ State
ZIP Code)
Mark Epstein
Brother
33411-9219
25a. Method of Disposition
25b. Place of Disposition (Name of cometery. crematory, other place)
1
Burial
2
Cremation
3
Entombiment
4
City Cemetery
5
Other Specify
25c Location of Disposition (City & State or Foreign Country)
25d. Date of
mm
dd
yyyy
Disposition
08
13
2019
26a. Funeral Establishment
26b. Address (Street and Number
City & State
ZIP Code)
1076 Madison Ave New York, NY 10028-0237
No Correction History."
VR 16 (Rev. 01/03)
EVT201908377726
Gutchen Vantuye
August 11, 2019
Gretchen Van Wye, Ph.D.; City Registrar as of 9/1/18
This is to certify that the foregoing is . true copy of a record on file In the Department of Health
Stown P. Sdwards
The
and Mental Hygiene. The Department of Health and Mental Hygiene does not certify 10 the truth of
Steven P Schwartz, Ph.D., City Registrar
the statements made thereon, 88 no inquiry as to the facts has been provided by law.
City
Do not accept this transcript unless it hears the security features listed on the back Reproduction
or alteration of this transcript is prohibited by $3.19(b) of the New York City Health Code if the
SENUAL HYGENE
New York
purpose is the evasion or violation of any provision of the Health Code or any other law.
Y01383215
THE
YORK
OF
EFTA00027987

=== Page 10 ===
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN
IN THE MATTER OF THE ESTATE OF
)
JEFFREY E. EPSTEIN
)
PROBATE NO. ST-19-PB-
)
Deceased.
)
ACTION FOR TESTATE
)
ADMINISTRATION
AFFIDAVIT
I, Erika A. Kellerhals, hereby depose or otherwise state that I do not know of any will or
codicil of Jeffrey E. Epstein, deceased, other than the instrument in writing dated August 8, 2019;
that I received the Last Will and Testament of Jeffrey E. Epstein from Jeffrey E. Epstein, and the
said Jeffrey E. Epstein died on or about August 10, 2019.
Erika & A. Kellerhals
SUBSCRIBED AND SWORN to before me
This 15th day of August , 2019.
Biott Young
Brett A. Geary
Notary Public: NP-144-15
Commission Expires: December 24, 2019
St. Thomas / St. John, USVI
EFTA00027988

=== Page 11 ===
LAST WILL AND TESTAMENT
OF
JEFFREY E. EPSTEIN
I, JEFFREY E. EPSTEIN, a resident and domiciliary of St. Thomas, United States Virgin Islands,
do make, publish and declare this to be my Will hereby revoking all prior Wills and Codicils made
by me.
1:
I direct my Executor to pay from my estate all expenses of
my last illness, my funeral and burial expenses, the administration expenses of my estate and all of
my debts duly proven and allowed against my estate.
A.
I direct my Executor to pay from my estate, as compensation
to each Executor for serving as Executor hereunder, the sum of Two Hundred Fifty Thousand
Dollars ($250,000) to each Executor upon the completion of probate of my estate. No Executor
shall receive any other compensation for serving as Executor hereunder; provided, however, that
my Executor shall be reimbursed from my estate for all reasonable costs, expenses, charges, and
liabilities incurred or paid in respect thereto, including fees and expenses of counsel or any other
agents hired by my Executor, and my Executor shall not be liable therefor individually.
B.
I direct my Executor to pay from my estate the federal and
state transfer taxes described in Paragraph B(1) of Article SEVENTH.
C.
I direct my Executor to pay from my estate all expenses of
storing, insuring, packing, shipping and delivering my tangible personal property in accordance with
the provisions of Article SECOND.
2:
I give all of my property, real and personal, wherever situated, after
the payments and distributions provided in Article FIRST, to the then acting Trustees of The 1953
Trust ("Trust") created under that certain Trust Agreement of The 1953 Trust (the "Trust
Agreement") dated August 8, 2019, as the same may be amended from time to time, to be held in
accordance with the provisions comprising the Trust Agreement at the time of my death.
3:
I appoint DARREN K. INDYKE and RICHARD D.
KAHN to serve as the Executors of this Will. If any one or more of my Executors fails to qualify, is
unable or unwilling to serve or ceases to act, I appoint BORIS NIKOLIC, as successor Executor. If
any successor Executor fails to qualify, is unable or unwilling to serve or ceases to act, I authorize
the last acting Executor to designate his or her successor. Such designation shall be made by
written instrument delivered to such designated successor Executor.
A.
If my estate must be administered in whole or in part in any
jurisdiction other than the state or territory of my domicile at the date of my death, and if my
Executor is unable or unwilling to serve in such jurisdiction, then I appoint the successor Executor
of my estate designated in Paragraph A of Article THIRD as successor Executor in such
we
EFTA00027989

=== Page 12 ===
Last Will & Testament of Jeffrey E. Epstein
Page 2 of 11
jurisdiction only, provided that he or she is able and willing to serve in such jurisdiction. If no
Executor or successor Executor is able and willing to serve in such jurisdiction, my Executor shall
designate a successor Executor to serve in such jurisdiction. Such designation shall be made by
written instrument delivered to such successor Executor.
B.
No bond or other security shall be required of any Executor
in any jurisdiction.
C.
Any Executor may resign in the manner provided for by the
governing statutes of the state or territory having jurisdiction of the administration of my estate or
in the absence of such statutory guidance, by filing a written notice of resignation with the Court
having jurisdiction of the administration of my estate. Any Executor who resigns shall not be
entitled to any compensation hereunder for any services rendered as Executor prior to his or her
resignation.
D.
My Executor shall not be accountable or responsible to any
person interested in my estate for the manner in which my Executor in good faith exercises or
declines to exercise any discretionary authority or power of my Executor. My Executor shall not be
liable for any loss or depreciation in value occasioned by reason of any negligence, error or mistake
of judgment in entering into any transaction, in making any sale or investment, in continuing to
hold any property or by reason of any action or omission, whether by my Executor or any other
fiduciary, unless my Executor has acted in bad faith. In the absence of proof by affirmative
evidence to the contrary, each Executor shall be deemed to have acted within the scope of my
Executor's authority, to have exercised reasonable care, diligence and prudence and to have acted
impartially as to all interested persons. An Executor shall not be liable for the acts or defaults of
another Executor.
4:
The following provisions shall apply to my estate and to my
Executor, except as is otherwise specifically provided in this Will:
A.
My Executor has the entire care and custody of all assets of
my estate. My Executor has the power to do everything my Executor in good faith deems advisable
without necessity of any judicial authorization or approval, even though but for this power it would
not be authorized or appropriate for fiduciaries under any statutory or other rule of law. My
Executor shall exercise my Executor's best judgment and discretion for what my Executor believes
to be in the best interests of the beneficiaries hereunder. Except as otherwise specifically provided
in this Will, if two Executors are empowered to participate in the decision to exercise or not to
exercise any fiduciary power granted by this Will or by law, such decision shall be made by such
Executors acting unanimously. If more than two Executors are empowered to participate in the
decision to exercise or not exercise any fiduciary power granted by this Will or by law, a majority of
such Executors shall be empowered to make such decision.
B.
Except as otherwise provided herein, my Executor shall have
the power:
(1) to enter upon and take possession of the
assets of my estate and collect the income and profits from such assets, and to invest and reinvest
such assets in real, personal or mixed assets (including the common trust funds of a corporate
2
P
EFTA00027990

=== Page 13 ===
Last Will & Testament of Jeffrey E. Epstein
Page 3 of 11
fiduciary) or in undivided interests therein without being limited by any present or future
investment laws;
(2) to retain all or any part of the assets of my
estate (without regard to the proportion that any one asset or class of assets may bear to the whole)
in the form in which such assets were received or acquired by my Executor;
(3) to sell or dispose of, exchange, transfer,
invest or loan all or any part of the assets of my estate which may, at any time, be held by my
Executor for such sums or upon such terms as to payment, security or otherwise as my Executor
determines, either by public or private transactions;
(4)
to buy and sell options, warrants, puts, calls
or other rights to purchase or sell (collectively "options") relating to any security or securities,
regardless of whether such security or securities are then held by my Executor, and whether such
options are purchased or sold on a national securities exchange, and to exercise with respect to such
options all powers which an individual owner thereof could exercise, including, without limitation,
the right to allow the same to expire;
(5) with respect to oil, natural gas, minerals, and
all other natural resources and rights to and interests therein (together with all equipment pertaining
thereto), including, without limiting the generality of the foregoing, oil and gas royalties, leases, or
other oil and gas interests of any character, whether owned in fee, as lessee, lessor, licensee,
concessionaire or otherwise, or alone or jointly with others as partner, joint tenant, or joint venture
in any other noncorporate manner, (a) to make oil, gas and mineral leases or subleases; (b) to pay
delay rentals, lease bonuses, royalties, overriding royalties, taxes, assessments, and all other charges;
(c) to sell, lease, exchange, mortgage, pledge or otherwise hypothecate any or all of such rights and
interests; (d) to surrender or abandon, with or without consideration, any or all of such rights and
interests; (e) to make farm-out, pooling, and unitization agreements; (f) to make reservations or
impose conditions on the transfer of any such rights or interests; (g) to employ the most
advantageous business form in which properly to exploit such rights and interests, whether as
corporations, partnerships, limited partnerships, mining partnerships, limited liability companies,
joint ventures, co-tenancies, or otherwise exploit any and all such rights and interests; (h) to
produce, process, sell or exchange all products recovered through the exploitation of such rights
and interests, and to enter into contracts and agreements for or in respect of the installation or
operation of absorption, reprocessing or other processing plants; (i) to carry any or all such interests
in the name or names of a nominee or nominees; (j) to delegate, to the extent permitted by law, any
or all of the powers set forth herein to the operator of such property; and (k) to employ personnel,
rent office space, buy or lease office equipment, contract and pay for geological surveys and studies,
procure appraisals, and generally to conduct and engage in any and all activities incident to the
foregoing powers, with full power to borrow and pledge in order to finance such activities; together
with the power to allocate between principal and income any net proceeds received as
consideration, whether as royalties or otherwise, for the permanent severance from lands of oil,
natural gas, minerals, and all other natural resources;
(6) to hold all or any part of the assets of my
estate in cash or in bank accounts without the necessity of investing the same;
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Last Will & Testament of Jeffrey E. Epstein
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(7)
to improve, repair, partition, plat or subdivide
all or any part of the assets of my estate;
(8) to litigate, defend, compromise, settle,
abandon or submit to arbitration on such terms and conditions as my Executor determines any
claims in favor of or against my estate or the assets of my estate;
(9) to loan or borrow money in such amounts
and upon such terms and conditions as my Executor determines, assume such obligations or give
such guarantees as my Executor determines, for the purpose of the acquisition, improvement,
protection, retention or preservation of the assets of my estate, or for the welfare of the
beneficiaries of my estate;
(10) to carry on for as long and in such manner as
my Executor determines any business enterprise in which I owned any interest at my death, either
individually, or as a partner, member, joint venture, stockholder or trust beneficiary; to sell such
business enterprise as an ongoing business; to consolidate, merge, encumber, dissolve, liquidate or
undertake any other extraordinary corporate transaction relating to such business enterprise;
(11) to vote in person or by proxy any and all
stock or securities and to become a party to any voting trusts, reorganization, consolidation or other
capital or debt readjustment of any corporation, association, partnership, limited liability
partnership, limited liability company or individual with respect to stocks, securities or debts held by
my estate;
(12) except as provided for in Sections (20) and
(21) of this Article Fourth, to enter into any good faith transactions with any Executor individually
or with any corporation, partnership or other entity in which any Executor has an ownership
interest;
(13) To purchase from my estate any stocks,
bonds, securities, real or personal property, or other assets, or make loans to my estate even though
the same person or persons occupy the office of my Trustee and the office of the Executor of my
estate;
(14) to lease, mortgage, pledge, grant a security
interest in or otherwise encumber all or any part of the assets of my estate for any term of years
whether or not beyond the duration of my estate (including, without limitation, any such action for
the benefit of any of the beneficiaries of my estate);
(15) to abandon any property of my estate, real or
personal, which my Executor may deem worthless or not of sufficient value to warrant keeping or
protecting; to abstain from the payment of taxes, water rents or assessments and to forego making
repairs, maintaining or keeping up any such property; and to permit such property to be lost by tax
sale or other proceedings or to convey any such property for a nominal consideration or without
consideration so as to prevent the imposition of any liability by reason of the continued ownership
thereof;
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Last Will & Testament of Jeffrey E. Epstein
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(16) to elect the mode of distribution of the
proceeds payable to my estate from any profit-sharing plan, pension plan, employee benefit plan,
individual retirement plan, insurance contract or annuity contract pursuant to the terms of such
plan;
(17) to allocate, in my Executors discretion, any
adjustment to basis provided to my estate under the provisions of Federal and State law with
respect to property comprising my estate, without any obligation to make a compensatory
adjustment among the beneficiaries hereunder on account of such allocation;
(18) to conduct any audit, assessment or
investigation with respect to any asset of my estate regarding compliance with any law or regulation
having as its object protection of public health, natural resources or the environment
("Environmental Laws"); to pay from the assets of my estate to remedy any failure to comply with
any Environmental Law (even to the exhaustion of all of the assets of my estate); and, as may be
required in my Executor's judgment by any Environmental Law, to notify any governmental
authority of any past, present or future non-compliance with any Environmental Law; and
(19) to sell to the Trustee under the Trust
Agreement any stocks, bonds, securities, real or personal property or other assets or borrow from
the Trustee under the Trust Agreement even though the same person or persons occupy the office
of the Executor of my estate and the Trustee under the Trust Agreement.
(20) No executor shall directly or indirectly buy or
sell any property for the estate from or to himself, or from or to his relative, employer, employee,
partner, or other business associate.
(21) No executor shall lend estate funds to himself,
or to his relative, employer, employee, partner, or other business associate.
C.
Except as otherwise provided herein, my Executor shall have
the power:
(1) to employ agents, attorneys-at-law,
consultants, investment advisers (to whom my Executor has discretion to delegate my Executor's
investment authority and responsibility), other executors and other fiduciaries in the administration
of my Executor's duties; to delegate to such persons, or to one or more of my Executors, the
custody, control or management of any part of my estate as my Executor determines and to pay for
such services from the assets of my estate, without obtaining judicial authorization or approval;
(2) to delegate, in whole or in part, to any person
or persons the authority and power to (a) sign checks, drafts or orders for the payment or
withdrawal of funds, securities and other assets from any bank, brokerage, custody or other account
in which funds, securities or other assets of my estate shall be deposited, (b) endorse for sale,
transfer or delivery, or sell, transfer or deliver, or purchase or otherwise acquire, any and all
property, stocks, stock warrants, stock rights, options, bonds or other securities whatsoever, (c) gain
access to any safe deposit box or boxes in which my assets or assets of my estate may be located or
which may be in the name of my Executor and remove part or all of the contents of any such safe
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Last Will & Testament of Jeffrey E. Epstein
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deposit box or boxes and release and surrender the same, and (d) take any other action that my
Executor may have the power to take with respect to my estate and the property thereof; no person
or corporation acting in reliance on any such delegation shall be charged with notice of any
revocation or change of such delegation unless such person or corporation receives actual notice
thereof;
(3) to pay any property distributable to a
beneficiary under a legal disability or who has not attained the age of 21, without liability to my
Executor, by paying such property (a) to such beneficiary, (b) for the use of such beneficiary, (c) to
a legal representative of such beneficiary appointed by a court or if none, to a relative for the use of
such beneficiary, or (d) to a custodian for such beneficiary designated by my Executor, to hold until
age 21 or such earlier age as shall be the maximum permitted under applicable law;
(4)
to distribute to any of the beneficiaries of my
estate in kind or in cash, or partly in kind and partly in cash, and to allocate different kinds or
disproportionate shares of assets or undivided interests in assets among all of such beneficiaries;
(5) to have evidence of ownership of any security
maintained in the records of a Federal Reserve Bank under the Federal Reserve Book Entry
System; to deposit funds in any bank or trust company; to carry in the name of my Executor or
the nominee or nominees of my Executor and with or without designation of fiduciary capacity, or
to hold in bearer form, securities or other property requiring or permitting of registration; and to
cause any securities to be held by a depository corporation of which an Executor is a member or
by an agent under a safekeeping contract; provided, however, that the books and records of my
Executor shall at all times show that such investments are part of my estate;
(6)
to renounce and disclaim, in whole or in part,
and in accordance with applicable law, any assets, interests, rights or powers (including any power
of appointment) which are payable to (or exercisable by) me or my estate, which are includible in
my estate or Gross Estate or over which I have any right, title, interest or power; and
(7)
to make, execute and deliver any and all such
instruments in writing as shall be necessary or proper to carry out any power, right, duty or
obligation of my Executor or any disposition whatsoever of my estate or any asset of my estate and
to exercise any and all other powers incidental or necessary to carry out or to fulfill the terms,
provisions and purposes of my estate.
D.
In connection with any insurance policy or annuity on the
life of an Executor which is included in my estate, such Executor shall not participate in the
decision to exercise or not exercise any fiduciary power in connection with any incidents of
ownership for such policy or annuity, including, without limitation, any decision to continue, assign,
terminate or convert such policy or annuity or to name the beneficiary of such policy or annuity.
E.
An Executor hereunder may by a written notice delivered to
the other Executor decline to participate in the decision to exercise or not exercise any fiduciary
power granted by this Will or by law.
F.
If an Executor is not empowered (because of a conflict of
ng
6
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Last Will & Testament of Jeffrey E. Epstein
Page 7 of 11
interest, declination to act or otherwise) to participate in the decision to exercise or not exercise any
fiduciary power granted by this Will or by law, then the remaining Executor shall be empowered to
make such decision. If no Executor is empowered to participate in such decision, then the
successor Executor of my estate designated in Paragraph A of Article THIRD and able and willing
to act shall be empowered to make such decision. If no Executor or successor Executor is
empowered to participate in such decision, my Executor may designate a successor Executor to
serve as Executor of my estate who shall be empowered to make such decision but shall have no
other power or authority of my Executor. Such designation shall be by written notice delivered to
such successor Executor.
G.
Except as otherwise specifically provided in this
Paragraph G(1) of this Article, and except as provided in Paragraph G(2) of this Article, my
Executor shall allocate receipts and disbursements in accordance with sound trust accounting
principles and shall have discretion to allocate receipts and disbursements when the treatment is
uncertain under applicable laws or generally accepted accounting principles in the judgment of my
Executor.
(1)
Except as otherwise specifically provided in this Will,
my Executor shall not treat any part of the principal amount of the proceeds of sale of any asset of
my estate as income distributable to or for the benefit of any beneficiary entitled to distributions of
income; provided, however, that my Executor shall treat a portion of any proceeds of sale of any
financial instrument originally issued or acquired at a discount equal to the amount which (a) has
previously been characterized as ordinary income for income tax purposes or (b) will be
characterized as ordinary income for income tax purposes in the year of such sale, as income for
trust accounting purposes.
5:
Where a party to any proceeding with respect to my estate has the
same interest as a person under a disability, it shall not be necessary to serve legal process on the
person under a disability.
6:
If any beneficiary under the Trust shall in any way directly or
indirectly (a) contest or object to the probate of my Will or to the validity of any disposition or
provision of my Will or of the Trust or (b) institute or prosecute, or be in any way directly or
indirectly instrumental in the institution or prosecution of, any action, proceeding, contest,
objection or claim for the purpose of setting aside or invalidating my Will or the Trust or any
disposition therein or provision thereof, then I direct that (a) any and all provisions in the Trust for
such beneficiary and his issue in any degree shall be null and void and (b) my estate, whether
passing under my Will or the Trust or pursuant to the laws of intestacy, shall be disposed of as if
such beneficiary and his issue in any degree had all failed to survive me.
7:
A.
As used herein:
(1) The term "Executor" of a person's estate
means all persons or entities who occupy the office of executor, administrator, personal
representative, or ancillary administrator while such persons or entities occupy such office, whether
one or more persons or entities occupy such office at the same time or times, and includes any
7
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Last Will & Testament of Jeffrey E. Epstein
Page 8 of 11
successor or successors to that office. The term "Trustee" means all persons or entities who occupy
the office of Trustee under the Trust Agreement while such persons or entities occupy such office,
whether one or more persons or entities occupy the office of Trustee at the same time or times, and
includes any successor Trustee or Trustees. A reference to a person's estate or probate estate means
that person's estate which is subject to probate administration. A reference to a person's Will means
such person's Last Will and Testament and any Codicil or Codicils thereto.
(2)
The term "IRC section" means a section of
the Internal Revenue Code of 1986, as amended, or the corresponding provision of any successor
Internal Revenue law, as in effect as of the date of my death.
(3) A reference to any tax also includes any
interest or penalties thereon. A reference to a person's "Gross Estate" means such person's gross
estate as finally determined for purposes of computing such person's federal estate tax.
(4) Whenever the singular number is used, the
same shall include the plural, and the masculine gender shall include the feminine and neuter
genders.
B.
The federal and state transfer taxes which my
Executor shall be obligated to pay pursuant to Paragraph B of Article FIRST shall consist of all
federal and state estate, inheritance, succession, and similar taxes (including any federal or state
generation-skipping transfer tax) imposed upon my probate estate or by reason of my death in
respect to all assets which pass under this Will or the Trust Agreement. Subject to Paragraph B(2)
of this Article, all federal estate taxes with respect to assets not passing under this Will or the Trust
Agreement (such assets are referred to as the "Apportionment Assets") and any applicable state
estate taxes with respect to the Apportionment Assets shall be apportioned among all persons
interested in the Apportionment Assets. My Executor shall make reasonable efforts to collect all
federal estate taxes and state estate, inheritance, succession and similar taxes allocable to the
Apportionment Assets from the recipients of the Apportionment Assets. Without changing the
apportionment of taxes in this Paragraph B(1), my Executor has discretion, but is not required, to
pay all or part of such taxes allocable to the Apportionment Assets. To the extent my Executor
pays such taxes allocable to the Apportionment Assets, my Executor shall seek reimbursement for
such taxes from the recipients of the Apportionment Assets. My Executor shall not be personally
liable for any of such taxes if my Executor is unable, with reasonable efforts, to collect payment (or
reimbursement) from any recipient of any Apportionment Assets for any or all of such taxes
allocable to such assets.
(1) My Executor has discretion to direct the
Trustee of the Trust Agreement to pay all or any portion of the taxes which my Executor is directed
or obligated to pay pursuant to Paragraph B of Article FIRST and this Paragraph B pursuant to a
written direction delivered to the Trustee under the Trust Agreement. Any taxes which my
Executor directs the Trustee under the Trust Agreement to pay shall be allocated and paid from the
trusts under the Trust Agreement as provided under the Trust Agreement.
C.
Except as otherwise specifically provided in this Will, a
bequest or devise to an individual who does not survive me shall lapse notwithstanding any law to
the contrary.
A
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Last Will & Testament of Jeffrey E. Epstein
Page 9 of 11
D.
To the extent that the distribution to the Trustee under the
Trust Agreement pursuant to Article SECOND shall not be effective, I give all the rest of my
property, real and personal, wherever situated, after the payments and distributions provided in
Article FIRST, to the person or persons named as Trustee or Trustees under the Trust Agreement,
be to held in trust under this Will in accordance with the provisions comprising the Trust
Agreement at the time of my death, which provisions are incorporated in this Will by reference.
IN WITNESS WHEREOF, I have duly executed this Will this 8th day of August,
2019.
JEFFREY a E. EPSTEIN
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=== Page 20 ===
Last Will & Testament of Jeffrey E. Epstein
Page 10 of 11
The foregoing instrument, consisting of eleven (11) pages, was signed in our presence by Jeffrey E.
Epstein and was declared by him to be his last Will. We, at the request of and in the presence of
Jeffrey E. Epstein and in the presence of each other, have subscribed our names below as
witnesses. We declare that we are of sound mind and of the proper age to witness a will, that to the
best of our knowledge the testator is of the age of majority, or is otherwise legally competent to
make a will, and appears of sound mind and under no undue influence or constraint. Under penalty
of perjury, we declare these statements are true and correct on this 8th day of August, 2019 at New
York, New York.
Marie Colón Miro
residing at
Gulnoia Jah
residing at
GULNORA TALI
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=== Page 21 ===
Last Will & Testament of Jeffrey E. Epstein
Page 11 of 11
AFFIDAVIT
We,
Gulnora Jeffrey Tali
E.
Epstein,
Mariel A. Colón Miro
and
the Testator and the witnesses respectively, whose names are
signed to the attached instrument in those capacities, personally appearing before the undersigned
authority and first being duly sworn, do hereby declare to the undersigned authority under penalty of
perjury that the Testator declared, signed, and executed the instrument as his last will; he signed it
willingly; he/she executed it as his free and voluntary act for the purposes therein expressed; and
each of the witnesses, at the request of the Testator, in his or her hearing and presence, and in the
presence of each other, signed the will as witness and that to the best of his or her knowledge the
testator was at that time eighteen (18) years of age or older, of sound mind and under no constraint
or undue influence.
Mariek
JEFFREY E. EPSTEIN
residing at
60 Duffield Street Apt8A
Gelnora Jali
Brooklyn, NY 11201
residing at
675 Arenue Z apt 1D
Brooklyn, NY 11223
STATE OF NEW YORK
)
)ss:
COUNTY OF NEW YORK
)
Subscribed and sworn to before me by JEFFREY E. EPSTEIN, the Testator, who is personally
known to me or who has produced Personally known as identification, and by MARIEL A Carn MIRD
a witness who is personally known to me or who has produced
as identification,
and GULNORA TALI
, a witness who is personally known to me or who has produced
as identification, on August 8, 2019.
Sworn to before me this 8th day of August, 201.
Make Melaly
Notary Public
MARLANA A. MELENDEZ
Notary Public, State of New York
No. 02MB6371741
Qualified in New York County
Commission Expires March 5th, 2022
11
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=== Page 1 ===
From:
To:
, Susan Necheles
"Kathleen E. Cassidy"
Cc:
Subject: following up
Date: Sun, 13 Dec 2020 23:37:04 +0000
All,
Thanks for speaking with us yesterday. Below is the most current version of the statement of facts we have discussed. We
want to emphasize that this is not a plea offer or a proposal, but we are passing this along since you've asked us to send
you a draft that reflects our must recent discussions. This is not final from our perspective, and this may change following
our conversations with victims during the conferral process.
We recognize and respect that you will need to speak with your client this week. However, we do not want to delay
notifying the victims, and, as we've discussed, we plan to issue a letter to the victims notifying them that we are in plea
negotiations. That letter will need to go out this week. From our conversation, it sounds like you plan to meet with your
client in the next few days, so let's plan to talk mid-week.
Thanks,
EFTA00028140

=== Page 2 ===


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=== Page 1 ===
Event: Epstein FOIA - Noel Team
Start Date: 2021-04-28 14:30:00 +0000
End Date: 2021-04-28 15:00:00 +0000
Organizer:
Location
Class: X-PERSONAL
Date Created: 2021-04-29 06:59:27 +0000
Date Modified: 2021-04-29 06:59:27 +0000
Priority: 5
DTSTAMP: 2021-04-28 02:22:34 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
EFTA00029076


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=== Page 1 ===
From:
To: Alex Conlon
Subject: RE: SDNY investigation / interview
Date: Wed, 22 May 2019 14:59:04 +0000
Importance: Normal
Sounds good, thanks.
From: Alex Conlon
Sent: Tuesday, May 21, 2019 22:35
To:
Subject: Re: SDNY investigation / interview
Thanks so much. I let
know who is planning to attend the meeting from your office and haven't heard anything
back from her about that. I expect that means she's fine with it, but if anything changes l'll let you know.
Thanks again,
Alex
Get Outlook for iOS
From:
Sent: Tuesday, May 21, 2019 7:24:38 PM
To: Alex Conlon
Subject: RE: SDNY investigation / interview
If either or both of the other individuals want to reach out to us, that's totally fine and they can call
in the first
instance -- her cell is
and they can call her literally anytime (and can leave a message with their contact info
if for whatever reason she's not able to pick up when they call).
Separately, we're confirmed for Thursday at 4:30. One heads up, as I mentioned was a possibility, the AUSAs will be me
and my colleague
is also traveling, so
is available, but please let us know if you think it would be
prudent (and/or if
prefers) that we have another female agent join, in case there are topics
would prefer
that
and I step out for. No pressure or obligation either way, just wanted to mention it as a possibility.
Please let me know if I'm forgetting anything, and thanks very much.
Original Message
From: Alex Conlon
Sent: Tuesday, May 21, 2019 17:57
To:
Subject: RE: SDNY investigation / interview
Oh, also --
asked for the contact information she can give in case the people she reaches out to want to
affirmatively reach out to you or one of your colleagues to arrange a meeting with you.
I wasn't sure if I should give her
contact info or yours. Please let me know and I'll pass that on right away.
EFTA00027744

=== Page 2 ===
Thanks,
Alex
Alex Conlon I Kaplan Hecker & Fink LLP
Original Message
From:
Sent: Tuesday, May 21, 2019 4:11 PM
To: Alex Conlon
Subject: Re: SDNY investigation / interview
Just need the day of the week : )
Sent from my iPhone
On May 21, 2019, at 16:07,
Conlon
<mailto:
wrote:
Hi
I just tried to reach you at your desk, but missed you.
is available to meet this week at 4:30 at our office if that works for you. Also, she plans to make the phone calls we
discussed today and tomorrow on her own. She will contact me once she has connected with two individuals she's
reaching out to and I will reach out to you in turn.
Happy to discuss anything, if that's helpful.
Thanks,
Alex
Alex Conlon I Kaplan Hecker & Fink LLP
<mailto:
EFTA00027745

=== Page 3 ===
From:
Sent: Tuesday, May 14, 2019 4:49 PM
To: Alex Conlon
<mailto:
Cc: Alexandra Elenowitz-Hess
Subject: RE: SDNY investigation / interview
Alex,
Just tried calling but missed you - wanted to briefly follow up on our conversation last week to let you know that we
certainly don't have any objection to someone from your firm (whether attorney or staff) taking notes in connection with
Ms.
conversations to tell the individuals we discussed that our office is interested in speaking with them.
I
expect we might request a copy of the notes, and, as discussed, whoever is with her would be a potential, theoretical
witness, but no issue on our end with any of that.
Separately, if it's possible, could you please ask Ms.
if there is a time next week or the following that we could
meet with her? We're hoping to cover all the information we need to in this first set of discussions before June, when I
think it will be even more inconvenient for her to meet. I expect the next meeting will address difficult topics, including
Giglio subjects and some review of Epstein's conduct with Ms.
in particular; but, I also expect that once we get
through those issues, we won't need to meet with her again for at least a little while.
We can generally make ourselves available whenever works on her end, with some combination of our team (e.g., if it's
the latter half of next week, will likely be me and our new team member
,
but let us know if there are any issues
with that), and as always can work around her schedule. And happy to come to your office for the final push.
Don't hesitate to give a call if any other info would be helpful, or if any questions or issues, and thanks very much.
Assistant U.S. Attorney
Southern District of New York
This email and its attachments may contain information that is confidential and/or protected from disclosure by the
attorney-client, work product or other applicable legal privilege. If you are not the intended recipient of the email, please
be aware that any unauthorized review, use, disclosure, dissemination, distribution, or copying of this communication, or
any of its contents, is strictly prohibited. If you have received this communication in error, please notify the sender
immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the
attorney-client, work product or other applicable legal privilege. If you are not the intended recipient of the email, please
be aware that any unauthorized review, use, disclosure, dissemination, distribution, or copying of this communication, or
any of its contents, is strictly prohibited. If you have received this communication in error, please notify the sender
immediately and destroy all copies of the message from your computer system. Thank you.
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure, dissemination,
distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify
the sender immediately and destroy all copies of the message from your computer system. Thank you.
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=== Page 1 ===
From:
)"
To:
Subject: Read: RE: Question re Epstein Relativity
Date: Mon, 15 Mar 2021 14:09:46 +0000
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
November 9, 2021
BY ELECTRONIC MAIL
Christian Everdell, 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 the Government is producing additional materials, including Jencks Act and
Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced
case. Enclosed please find an index detailing the materials included in today's production.
Please note that this letter, the enclosed index, and the enclosed materials are governed
by the July 31, 2020 Protective Order in this case. In particular, the materials are designated
as "confidential" under the Protective Order. The index is itself designated as "confidential,"
because it includes information regarding records designated as "confidential" under the
Protective Order. The Department of Justice directed this office to cease the dissemination of
materials marked with the word "confidential" in order to avoid potential confusion with markings
reserved for classified documents. Accordingly, in order to note the appropriate designation of
this production under the operative Protective Order in this case, the materials being produced
today are marked with the following label: "SUBJECT TO PROTECTIVE ORDER
PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs
of the Protective Order that govern today's production.
EFTA00028257

=== Page 2 ===
Page 2
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by: s/
Assistant United States Attorneys
EFTA00028258


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=== Page 1 ===
SECURITY
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
New York, New YORK 10007
August 12, 2021
VIA FEDERAL EXPRESS
MDC-Metropolitan Detention Center
Legal Department
80 29th Street
Brooklyn, NY 11232
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The password for the drive containing discovery materials pertinent to Ghislaine Maxwell
(02879-509) is
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
Assistant United States Attorneys
EFTA00029417


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE:
Epstein
Date: Mon, 08 Jul 2019 02:19:34 +0000
Importance: Normal
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:
J
Sent: Sunday, July 07, 2019 18:51
To:
Cc:
is
Subject: Re:
- Epstein
Hi
No need to take any more time out of what I'm sure was a busy weekend for you. Let's set a time for Tuesday
morning (the earlier the better for me). Let me know what works for you.
Thanks,
Sent from my iPhone
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza 4th Floor
Miami Florida 33129
t.
f.
e.
www.crimlawfirm.com
On Jul 7, 2019, at 4:04 PM,
)
wrote:
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
EFTA00028373

=== Page 2 ===
you meet with Ms.
if that's helpful. Or if you'd like to talk sooner, we could schedule a time later today, or check in
tomorrow about a possible afternoon discussion. Please let us know what you prefer, and we look forward to being in
touch.
thank you,
Assistant U.S. Attorney
Southern District of New York
From:
Sent: Saturday, July 06, 2019 22:55
To:
Subject:
- Epstein
Begin forwarded message:
From:
Date: July 6, 2019 at 10:51:09 PM EDT
To:
Cc:
Subject:
- Epstein
Mr.
My former partner, Alan Ross, represented
(now known as
), prior to his passing in
2018. Agent
served Ms.
with a grand jury subpoena earlier today, and as Alan's former
partner and FL Bar appointed inventory attorney, she has contacted me. Unfortunately, I am unable to meet
with her until Tuesday, but I would appreciate a few minutes of your time at your convenience as I am getting
up to speed. Please let me know what day/time is best for you.
Look forward to speaking with you.
Best,
ROSS AMSEL RABEN NASCIMENTO, PLLC
Lawyer's Plaza 4th Floor
Miami Florida 33129
e.
www.crimlawfirm.com
EFTA00028374


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c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Accepted: Pre-Meeting US V Noel/Epstein FOIA
Date: Mon, 28 Jun 2021 10:52:30 +0000
Importance: Normal
Attachments: unnamed
EFTA00029533


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Ce: Christian Everdell
Subject: [EXTERNAL] Re: Ghislaine Maxwell 02879-509
Date: Thu, 14 Oct 2021 13:49:32 +0000
Inline-Images: :Screen_Shot_2021-10-13_at_631.26_PM.png;Screen_Shot_2021-10-13_at_6.26.05_PM.pmg
Good morning-
I am on the VTC with Ms. Maxwell who has confirmed that she has not received the hard drive
sent by the government and delivered to the MDC on Tuesday.
Further, there is legal material and books that have been delivered to the MDC and have not been given to Ms. Maxwell.
Please provide an explanation immediately.
Thank you.
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you.
On Oct 13, 2021, at 6:55 PM, BOBBI C STERNHEIM
wrote:
Good evening-
Per the govt email and FedEx tracking info (see below), two (2) FedEx envelopes sent by the government to the MDC
for Ms. Maxwell were delivered to the MDC yesterday (Tuesday 10/12) at 10:26 am.
As of this afternoon (10/13), Ms. Maxwell still had not received either FedEx..
Please immediately provide an explanation for the delay as it will be reported to the Court.
Bobbi
<Screen Shot 2021-10-13 at 6.46.32 PM.png><Screen Shot 2021-10-13 at 6.31.26 PM.png><Screen Shot 2021-10-13 at 6.26.05 PM.png>
EFTA00029294

=== Page 2 ===
Chrome File Edit View History Bookmarks Profiles Tab Window Help
S
1
4)) 94% [4]
Wed 6:31 PM BC Sternheim
8166 1429 9130
?
ADD NICKNAME
Delivered
Tuesday, October 12, 2021 at 10:26 am
DELIVERED
Signature release on file
GET STATUS UPDATES
OBTAIN PROOF OF DELIVERY
FROM
TO
NEW YORK, NY US
Brooklyn, NY US
SEE FULL DETAILS
Personalize Your Deliveries
Need to customize this delivery?
Learn how FedEx Delivery Manager can help
EFTA00029295

=== Page 3 ===
Safari File Edit View History Bookmarks Window Help
S
1
92%
Wed 6:26 PM BC Sternheim
<
>
fedex.com
+
FedEx®
Shipping
Tracking
Design & Print
Locations
Support
Sign Up or Log In
C
TRACK ANOTHER SHIPMENT
8166 1429 9141
?
ADD NICKNAME
Delivered
Tuesday, October 12, 2021 at 10:26 am
DELIVERED
Signature release on file
GET STATUS UPDATES
OBTAIN PROOF OF DELIVERY
FROM
TO
NEW YORK, NY US
BROOKLYN, NY US
Travel History
Shipment Facts
?
?
?
?
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you.
EFTA00029296


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c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00029245.pdf
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c7: images
c0:
=== Page 1 ===
From:
Subject: Re: OPR Epstein Final Report
Date: Sun, 31 Jan 2021 23:42:47 +0000
Hi
- With apologies I now have a childcare issue in the morning. Any chance we could chat in the
afternoon instead? I could do anything from 1-2 or after 3. Just let me know if anything in either window works
for you. Thanks, and apologies for the late change - -
Sent from my iPhone
On Jan 29, 2021, at 5:55 PM,
wrote:
Of course. Why don't you call me
(
)
at your convenience around 9:30 am? If another time works better,
just let me know.
From:
Sent: Friday, January 29, 2021 5:33 PM
To:
Cc:
Subject: Re: OPR Epstein Final Report
Hi
- I hope this finds you well. Do you have some time to connect early next week on this matter? If there's a good
time Monday morning, in particular, please let us know. Thanks,
Sent from my iPhone
On Nov 12, 2020, at 10:06 AM,
wrote:
Attached please find OPR's final Report in the Jeffrey Epstein matter, and a transmittal letter.
<OPR-#458587-v1-Epstein_Report_transmittal_to_SDNY_(letter_signed).PDF>
<OPR-#458557-v1-Epstein_Report_of_Investigation_and_Exhibits_pdf.PDF>
EFTA00029245


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=== Page 1 ===
From: "
To:
Subject: RE: MCC Employee Summary Table
Date: Tue, 13 Aug 2019 18:27:08 +0000
Attachments: MCC_Officer_Information.xlsx
Looks great. I made a couple tiny changes in the attached and on the shared. Thanks.
From:
Sent: Tuesday, August 13, 2019 2:11 PM
To:
Subject: MCC Employee Summary Table
For your review for chiefs/brass.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00027116


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=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 20-3061 United States of America V. Maxwell "Appendix FILED"
Date: Thu, 24 Sep 2020 23:51:32 +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 09/24/2020
Case Name:
United States of America V. Maxwell
Case Number: 20-3061
Document(s): Document(s)
Docket Text:
APPENDIX, volume 2 of 2, (pp. 124-314), on behalf of Appellant Ghislaine Maxwell, FILED. Service date
09/24/2020 by CM/ECF.[2938281] [20-3061]
Notice will be electronically mailed to:
Notice will be stored in the notice cart for:
, Deputy Clerk
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Appendix FILED
Original Filename: Appendix Vol. 2 PUBLIC COVER SHEET FINAL.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=09/24/2020] [FileNumber=2938281-0]
[a747691b9d1cf7ea69f597dd031e598925c550c957da80b7dc46c6528c949e1b0750bc27422fe2ea37361f486d8bf
EFTA00028064

=== Page 2 ===
50980fc24e2cc63cbaa38d678f7c98d1fd4]
EFTA00028065


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Subject: RE:
)
- Epstein
Date: Tue, 18 May 2021 14:31:16 +0000
No worries at all - thanks for sending.
From:
Sent: Tuesday, May 18, 2021 10:26 AM
To:
Subject: RE:
)
- Epstein
I apologize. Sent the wrong attachment. The correct one is now attached.
From:
Sent: Monday, May 17, 2021 8:36 PM
To:
(NY) (FBI)
Subject: [EXTERNAL EMAIL] - RE:
- Epstein
I think these are the notes for the 302?
From:
Sent: Monday, May 17, 2021 7:26 PM
To:
Subject: RE:
)
- Epstein
Signed.
From:
Sent: Friday, May 14, 2021 3:27 PM
To:
(NY) (FBI)
Subject: [EXTERNAL EMAIL] - FW:
- Epstein
Hi
When you have a chance, could you please initial the proffer agreement and send it back to me? Thanks!
From: Joe Nascimento
Sent: Friday, May 14, 2021 2:56 PM
To:
Cc:
(USANYS)
i
)
Subject: Re:
)
- Epstein
Hi
Thanks again for your time today. Attached, please find a copy of the proffer agreement with updated initials.
Have a nice weekend,
Joe
EFTA00029183

=== Page 2 ===
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
EFTA00029184


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
(USANYS)"
)"
i
)"
Subject: RE: birth certificates
Date: Fri, 27 Aug 2021 18:51:53 +0000
Attachments: 2021.08.27_Court_Subpoena_-_Sacramento_County_Clerk.pdf
Attached. Thanks!
From:
Sent: Friday, August 27, 2021 2:11 PM
To:
is
Cc:
(USANYS)
is
;
Subject: RE: birth certificates
Attached is
birth certificate. Still waiting on the others. Can you issue a subpoena for
DOB
:
Sacramento County Clerk/Recorder
Fair Oaks, CA 95628
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
From:
Sent: Friday, August 27, 2021 10:56 AM
To:
(NY) (FBI)
(NYPD)
Cc:
(USANYS)
is
is
)
Subject: [EXTERNAL EMAIL] - RE: birth certificates
Just checking in on this. Thanks!
From:
Sent: Friday, August 20, 2021 4:20 PM
To:
(NY) (FBI)
is
Cc:
(USANYS)
i
)
;
Subject: birth certificates
and
EFTA00027388

=== Page 2 ===
I'm checking in on the birth certificate project. Have you received any additional certificates? I think
mentioned
you might need a subpoena-please let me know.
Thanks!
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00027389


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=== Page 1 ===
From:
To:
Cc:
Subject: Maxwell bail briefing
Date: Thu, 01 Apr 2021 21:31:33 +0000
Attachments: 2021.04.01_GM_bail_appeal_motion_for_bail.pdf;
20cr330_Opinion_&_Order_12.28.20.pdf; 2021.03.22_GM_Third_Bail_Denial_Orderpdf;
2020.07.14,_Maxwell_arraignment,_initial_conference,_bail_hearing.pdf
Attached, thanks.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00027359


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=== Page 1 ===
Event: Accepted: Epstein Meeting
Start Date: 2020-01-06 17:30:00 +0000
End Date: 2020-01-06 18:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-01-08 03:24:02 +0000
Date Modified: 2020-01-08 03:24:02 +0000
Priority: 5
DTSTAMP: 2020-01-06 16:30:40 +0000
Attendee:
(USANYS)
EFTA00028715


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=== Page 1 ===
Epstein Device Contents
1B71
Contents
Type
Included in report
Total
Activities
18614
18614
Applications Usage Log
8923
8923
Bluetooth Devices
42
42
Calendar
452
(81 Deleted)
452
(81 Deleted)
Call Log
1072
(25 Deleted)
1072
(25 Deleted)
Chats
424
(16 Deleted)
424
(16 Deleted)
iMessage
4
4
iMessage: +12125333739
284
(16 Deleted)
284
(16 Deleted)
iMessage: jeeitunes@gmail.com
4
4
Skype: jeevacation
88
88
Threema
2
2
WhatsApp
42
42
Contacts
3754
(1 Deleted)
3754
(1 Deleted)
Cookies
10722
10722
Device Events
8355
8355
Emails
5487
(6 Deleted)
5487
(6 Deleted)
Installed Applications
599
599
IP Connections
132
132
Locations
2225
(2 Deleted)
2225
(2 Deleted)
Log Entries
2542
2542
MMS Messages
166
166
Notes
99
(13 Deleted)
99
(13 Deleted)
Recordings
111
(1 Deleted)
111
(1 Deleted)
Searched Items
2777
(88 Deleted)
2777
(88 Deleted)
2
SMS Messages
8082
8082
User Accounts
24
24
Voicemails
6
6
Web Bookmarks
239
239
Web History
13360
(45 Deleted)
13360
(45 Deleted)
Wireless Networks
201
201
N Timeline
165335
(251 Deleted)
165335
(251 Deleted)
Data Files
448673
(16 Deleted)
448673
(16 Deleted)
Applications
171
171
Archives
374
374
Audio
5124
(2 Deleted)
5124
(2 Deleted)
Configurations
225166
225166
Databases
1850
1850
Documents
4698
(1 Deleted)
4698
(1 Deleted)
Images
205046
(8 Deleted)
205046
(8 Deleted)
Text
5267
5267
Videos
977
(5 Deleted)
977
(5 Deleted)
EFTA00029155

=== Page 2 ===
1B72
Contents
Type
Included in report
Total
Bluetooth Devices
223
(13 Deleted)
223
(13 Deleted)
Calendar
560
(250 Deleted)
560
(250 Deleted)
Call Log
482
(1 Deleted)
482
(1 Deleted)
Chats
26
25
.
Message: jeeitunes@gmail.com
26
25
Contacts
1356
(17 Deleted)
1356
(17 Deleted)
Cookies
841
(42 Deleted)
841
(42 Deleted)
Installed Applications
474
474
Locations
97
97
Log Entries
248
248
Notes
6
(6 Deleted)
6
(6 Deleted)
Passwords
233
233
Searched Items
33
33
User Accounts
12
12
Web Bookmarks
364
364
Web History
85
(9 Deleted)
85
(9 Deleted)
Wireless Networks
90
90
Timeline
5236
(174 Deleted)
5261
(174 Deleted)
Data Files
3523
(6 Deleted)
3523
(6 Deleted)
Archives
5
5
@
Configurations
3168
(4 Deleted)
3168
(4 Deleted)
Databases
314
314
@
Documents
3
3
Text
22
22
Videos
11
(2 Deleted)
11
(2 Deleted)
EFTA00029156

=== Page 3 ===
1B67
Contents
Type
Included in report
Total
-
Bluetooth Devices
2
(1 Deleted)
2
(1 Delated)
Calendar
159
(22 Deleted)
150
(22 Deleted)
Contacts
1
1
Cookies
61
(43 Delated)
61
(43 Deleted)
B
Device Events
12
12
Installed Applications
314
314
Locations
3
(1 Deleted)
3
(1 Deleted)
X
User Accounts
9
9
User Dictionary
5
5
Y
Wireless Networks
4
4
Timeline
413
(11 Deleted)
413
(11 Deleted)
Data Files
94243
94243
.
Applications
652
652
.
Archives
409
409
#
Audio
3783
3783
Configurations
83337
83337
Databases
205
265
Documents
230
230
Images
3292
3292
#
Text
1933
1933
#
Videos
342
342
EFTA00029157

=== Page 4 ===
1B68
Contents
Type
Included in report
Total
Applications Usage Log
5
5
Bluetooth Devices
2
(1 Deleted)
2
(1 Deleted)
Calendar
208
(90 Deleted)
208
(90 Deleted)
Contacts
1
1
Cookies
90
(79 Deleted)
90
(79 Deleted)
Device Events
4
4
Installed Applications
387
387
Locations
4
4
User Accounts
9
9
User Dictionary
2
2
Wireless Networks
6
6
)
Timeline
351
(33 Deleted)
351
(33 Deleted)
Data Files
123171
123171
Applications
2
2
Archives
482
482
Audio
3745
3745
Configurations
101837
101837
Databases
306
306
Documents
235
235
Images
1960
1960
Text
14244
14244
Videos
360
360
EFTA00029158

=== Page 5 ===
1B69
Contents
Type
Included in report
Total
*
Bluetooth Devices
1
1
Calendar
151
(20 Deleted)
151
(20 Deleted)
Call Log
112
(3 Deleted)
112
(3 Deleted)
Chats
67
(7 Deleted)
67
(7 Deleted)
Message joeitunes@gmail.com
55
(4 Deleted)
55
(4 Deleted)
SMS Spotlight Search
12
(3 Deleted)
12
(3 Deleted)
Contacts
915
(58 Deleted)
915
(58 Deleted)
Cookies
592
(12 Deleted)
592
(12 Deleted)
Device Notifications
1
1
Emails
1167
(20 Deleted)
1167
(20 Deleted)
Installed Applications
268
268
IP Connections
14
14
Locations
15
(3 Deleted)
15
(3 Deleted)
Log Entries
40
40
Notes
4
(1 Deleted)
4
(1 Deleted)
Searched Items
9
9
User Accounts
13
13
User Dictionary
553
553
Web Bookmarks
5
5
Web History
42
42
Y
Wireless Networks
18
18
Timeline
7634
(70 Deleted)
7634
(70 Deleted)
Data Files
153054
153054
Applications
1186
1186
Archives
328
328
Audio
6175
6175
Configurations
66246
66246
Databases
320
320
Documents
157
157
Images
75346
75346
Text
3225
3225
Videos
71
71
EFTA00029159

=== Page 6 ===
1B84
Type
Included in report
Total
= Applications Usage Log
2
2
1 Bluetooth Devices
40
(9 Deleted)
40
(9 Deleted)
X Calendar
439
(317 Deleted)
439
(317 Deleted)
- Call Log
1247
(574 Deleted)
1247
(574 Deleted)
Chats
244
(1 Deleted)
244
(1 Deleted)
.
Message: jeeitunes@gmail.com
56
(1 Deleted)
56
(1 Deleted)
# PhoneRecentaLog
113
113
. Skype: jeevacation
70
70
# Skype ChallSync
5
5
R Contacts
2189
(8 Deleted)
2189
(8 Deleted)
W Cookies
1775
(10 Deleted)
1778
(10 Deleted)
11 Device Events
2
2
X Emails
1931
(816 Deleted)
1931
(616 Deleted)
. Form Data
2
2
00 Installed Applications
483
483
0 Journeys
1
1
E Locations
70
(19 Deleted)
70
(19 Deleted)
J Log Entries
29
29
D Mobile Cards
1
1
- Notes
1
11
17 Searched Items
70
(3 Deleted)
70
(3 Deleted)
2
P SMS Messages
1
!
R User Accounts
13
13
R User Dictionary
848
848
Web Bookmarks
580
580
- Web History
1299
(48 Deleted)
1299
(48 Deleted)
T Wireless Nebeorks
7
7
S Timeline
24685
(2380 Deleted)
24685
(2350 Deleted)
IV Data Files
253537
(5 Deleted)
253537
(5 Deleted)
R Date Files
253537
(5 Deleted)
253537
(5 Deleted)
. Applications
4
4
.
Archives
576
576
.
Audio
4231
4231
. Configurations
170259
170259
.
Databases
592
592
.
Documents
289
(2 Deleted)
289
(2 Deleted)
.
Images
64247
64247
* Text
12816
12816
.
Videos
523
(3 Deleted)
523
(3 Deleted)
EFTA00029160

=== Page 7 ===
1B83
Contents
Type
Included in report
Total
E Calendar
166
166
" Call Log
176
(6 Deleted)
176
(6 Deleted)
Chats
70
(1 Deleted)
70
(1 Deleted)
# Message: jeeitunes@gmail.com
30
(1 Deleted)
30
(1 Deleted)
# PhoneRecentsLog
40
40
R Contacts
114
114
19 Cookies
336
(10 Deleted)
336
(10 Deleted)
0 Device Notifications
101
101
Emails
583
(333 Deleted)
583
(333 Deleted)
90 Installed Applications
189
189
N Locations
44
(4 Deleted)
44
(4 Deleted)
Log Entries
10
10
X Mobile Cards
1
1
17 Searched Items
2
2
A User Accounts
10
10
- User Dictionary
7
7
Web Bookmarks
30
30
Y Wireless Networks
8
8
S Timeline
4560
(122 Deleted)
4560
(122 Deleted)
R Data Files
120499
120499
# Applications
549
549
# Archives
566
566
# Audio
1063
1003
# Configurations
74900
74900
# Databases
324
324
# Documents
224
224
# Images
31028
31028
2
# Text
11436
11436
# Videos
409
409
.
EFTA00029161


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=== Page 1 ===
From:
Subject: spreadsheets production
Date: Wed, 13 Oct 2021 23:50:11 +0000
Attachments: 2021.10.13_Maxwell_Discovery_Letter_v1.docx
Attached is a draft of the cover letter on the spreadsheets we will produce tonight. If we should add in any language, like
"as a courtesy" or other qualifying language, welcome your suggestions.
Thanks,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00029293


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=== Page 1 ===
Event: Accepted: Pre-Meeting US V Noel/Epstein FOIA
Start Date: 2021-06-28 19:45:00 +0000
End Date: 2021-06-28 20:00:00 +0000
Location
Office
Class: X-PERSONAL
Comment:
Date Created: 2021-06-28 11:00:21 +0000
Date Modified: 2021-06-28 11:00:21 +0000
Priority: 5
DTSTAMP: 2021-06-28 10:52:27 +0000
Attendee:
EFTA00029534


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Civilian Crime Report from A. Lombardino suggesting a prisoner has info about Epstein
Date: Mon, 24 Aug 2020 15:54:35 +0000
Attachments: 07_04_2020_Letter_From_Prisoner_Mentioned_By_Anthony_Lombardino.pdf
Sorry, this goes with that last one.
From:
Sent: Monday, August 24, 2020 11:49 AM
To:
Cc:
Subject: Civilian Crime Report from A. Lombardino suggesting a prisoner has info about Epstein
Attached is a Civilian Crime Report for you to review. We sent our usual letter with the
form to be completed, but this particular submission does not really fit that so we might
not get anything more, but let us know if we do that you want to see it.
please
make a note in the log. Thank you.
EFTA00027570


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Subject: RE: US V Epstein
Date: Wed, 14 Aug 2019 19:16:35 +0000
You can provide them with our contact information. Thanks.
From:
Sent: Wednesday, August 14, 2019 1:45 PM
To:
(USANYS)
is
(USANYS)
Subject: FW: US V Epstein
FYI, among several other recent requests and communications, Epstein's defense counsel says below that they would
"welcome a call" with whoever is conducting the investigation into his death and have asked us to provide you with their
contact information. Obviously leave it entirely to you whether you believe it would be appropriate or useful for your
investigation to be in touch with them in any capacity.
Separately, they have asked us to advise the individuals working on the investigation into Epstein's death that his brother,
Mark Epstein, is represented by Stacey Richman, from the Law Offices of Murray Richman. Should you find it appropriate
or useful for the investigation to be in touch with her (or him through her), it appears that the number of her and her
father's firm is
From: Martin G. Weinberg
Sent: Tuesday, August 13, 2019 09:30
To:
is
)
)
>; Reid Weingarten
>; 'Miller, Michael'
'Martin G. Weinberg'
Subject: US V Epstein
in light of yesterday's seizures of computers in the Virgin Islands from Mr Epstein's residence or residences, and in
light of the fact that emails and documents contained on some or all of these computers contain attorney-client and work
product privileged communications, I request that you provide us assurance that they will not be accessed by the "case
team" until a taint team is selected and until the procedures for a protection of those privileged communications is
established. You have agreed to that protocol for the phones seized from Mr. Epstein on July 6 and the computers etc
seized from his NYC residence shortly thereafter. I have a list of attorneys that I am prepared to send to a taint prosecutor
once one is identified to me.
Second, there remains the timing of the dismissal of the charge against Mr. Epstein. Are you awaiting a motion to dismiss
from us? Will the Indictment be nolle prossed today? Is there a reason for any delay beyond today?
Third, we would welcome a call with you or whoever is conducting the investigation into Mr. Epstein's death. Let us know.
Marty
Martin G. Weinberg, Esq.
Boston, MA 02116
- Office
- Cell
EFTA00027111

=== Page 2 ===
This Electronic Message contains information from the Law Office
of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee
only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents
of this message is prohibited.
EFTA00027112


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Epstein OIG/FBI--Document Preservation
Date: Tue, 13 Aug 2019 01:05:40 +0000
Thanks.
Sent from my iPhone
On Aug 12, 2019, at 8:24 PM,
wrote:
Done, thanks.
From:
Sent: Monday, August 12, 2019 19:57
To:
Cc:
Subject: RE: Epstein OIG/FBI--Document Preservation
Nothing further from me, but please fill out and return to
the more formal lit hold form that he
just sent around.
From:
Sent: Monday, August 12, 2019 7:55 PM
To:
Subject: RE: Epstein OIG/FBI--Document Preservation
In connection with the below, as one of the prosecutors on the case, I do have emails pertinent to Mr. Epstein's
conditions of confinement, both in connection with the incident of July 23, 2019 (and email communications following
up on, and seeking additional information about, that initial incident) and in connection with his apparent suicide on
August 10, 2019. I do not believe I have any handwritten notes or texts that are pertinent to his conditions of
confinement.
Please let me know if any additional action is required.
thank you,
From:
Sent: Monday, August 12, 2019 11:43
EFTA00027098

=== Page 2 ===
All - Please see below and follow
instructions. Additionally, if you believe there are others at SDNY to whom this
email should be sent, please let me know immediately.
Thanks,
From:
Sent: Monday, August 12, 2019 11:35 AM
Subject: Epstein OIG/FBI--Document Preservation
Please forward this to everyone who might have any documents relating to the Epstein suicide, and cc me:
Please make sure to preserve any documents you may have relating to Epstein's conditions of confinement.
Your emails will be adequately preserved, for present purposes, by the regular three-year backup. But
let me know if you have any or not.
If you have any hard-copy notes, please scan them and send them to me. If you have none, let me know
that too.
Most particularly, please check to see if you have texted anything pertinent. If so let me know, one
way or the other. If you do have anything, we'll figure out how to preserve that.
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
New York, NY 10007
EFTA00027099


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: RE: NEW YORK TIMES; Epstein
Date: Mon, 08 Jul 2019 16:34:25 +0000
Importance: Normal
Inline-Images: image001.jpg; image002.jpg
Was inevitable. The twitter is all over that paragraph from the detention memo.
From:
(USANYS)
Sent: Monday, July 08, 2019 12:31 PM
To:
(USANYS)
Subject: FW: NEW YORK TIMES; Epstein
I knew this would become the story
From
USANYS)
Sent: Monday, July 8, 2019 12:29 PM
To:
(USANYS)
is
(USANYS)
V.
(USANYS)
Cc:
(USANYS) [Contractor]
(USANYS)
Subject: NEW YORK TIMES; Epstein
Nude Photos of Underage Girls Seized From Jeffrey
Epstein Mansion
The prosecutors are seeking to detain the financier while he awaits trial on sexual trafficking charges, saying he
is a flight risk.
EFTA00028308

=== Page 2 ===
U.S. v. Jeffrey Epstein
JEFFREY
ALLEGED
EPSTEIN
SEX
ID
THE CHARGED
AND PALM
IF YOU RECOGNIZE THIS PERSON
BE A VICTIM, PLEASE CALL THE FOLLOWING NUMBER
1-800-CALL FBI
July 8, 2019
Investigators seized nude photographs of underage girls from the Manhattan townhouse of Jeffrey Epstein
as part of a new investigation into allegations he exploited dozens of minors for sex, prosecutors revealed
on Monday.
That detail was mentioned by federal prosecutors on Monday as they unsealed an indictment charging Mr.
Epstein with sex trafficking and made an appeal to other women who may have been abused by him to
come forward.
"They deserve their day in court and we are proud to stand up for them by bringing this indictment," the
United States attorney in Manhattan, Geoffrey S. Berman, said.
Mr. Epstein, 66, is accused of engaging in sex acts with dozens of vulnerable minors, some as young as 14,
during naked massage sessions, then paying them hundreds of dollars in cash. He also asked some of the
girls to recruit other underage girls, the indictment said.
"In this way, Epstein created a vast network of underage victims for him to sexually exploit in locations
including New York and Palm Beach," the indictment said.
Mr. Berman's decision to seek an indictment in Manhattan was an implicit rebuke to the decision by
prosecutors in Miami in 2008 to enter an agreement with Mr. Epstein that allowed him to avoid federal
prosecution and a possible life sentence.
Under that deal, Mr. Epstein pleaded guilty to state prostitution charges and spent about a year in a Palm
Beach jail. He was permitted to leave the facility six days a week to work.
Mr. Berman made it clear his office was not bound by the agreement, which was overseen by Alexander
Acosta, then the United States attorney in Miami who is now President Trump's secretary of labor.
"That agreement, by its terms, only binds the Southern District of Florida," Mr. Berman said.
The agreement has been examined in a series of reports in The Miami Herald and is being challenged in
court. A federal judge ruled earlier this year Mr. Epstein's accusers should have been consulted about the
deal before it was signed.
The indictment unsealed in Manhattan on Monday said that from 2002 to 2005 Mr. Epstein and his
employees engaged in a sex trafficking scheme, bringing underage girls to his Upper East Side mansion
and his palatial compound in Palm Beach, Fla., to engage in sex acts with him.
The indictment said Mr. Epstein used employees and assistants to arrange sexual rendezvous with at least
one girl at his New York residence and two at his home in Palm Beach.
EFTA00028309

=== Page 3 ===
Mr. Epstein is accused of having the girls perform nude massages, at which point he would masturbate and
touch their genitals with his hands or with sex toys.
The girls were paid hundreds of dollars in cash for each encounter and, once recruited, were asked to
return to the mansion several times, where they were abused again, the indictment said. Mr. Epstein, the
court documents read, "created a similar network of minor girls to victimize" in Florida.
"This conduct, as alleged, went on for years and involved dozens of young girls, some as young as 14,"
Mr. Berman said. "The alleged behavior shocks the conscience."
[Read the indictment.]
The charges unsealed Monday by the Southern District of New York signal a prosecution that some of his
accusers have been awaiting for years.
Accusations of pedophilia and sexual predation have dogged Mr. Epstein for decades. And now, in the
#MeToo era, his case has been held up as a prime example of insulated, powerful men avoiding
accountability.
For more than a decade, Mr. Epstein, a hedge fund manager, avoided a lengthy prison sentence, largely
because of the agreement his lawyers struck with federal prosecutors in 2008.
Mr. Epstein's social circle is filled with other high-profile connections, including to former President Bill Clinton, Prince
Andrew of Britain and a host of others.
In 2002, Mr. Trump described Mr. Epstein as "a terrific guy."
"He's a lot of fun to be with," Mr. Trump told New York Magazine. "It is even said that he likes beautiful
women as much as I do, and many of them are on the younger side."
On Saturday, F.B.I. agents and New York Police Department officers used a crow bar to force open the wooden doors of
Mr. Epstein's East 71st Street mansion.
EFTA00028310

=== Page 4 ===
The charges unsealed Monday mirror those that federal prosecutors had prepared in Miami against Mr.
Epstein more than a decade ago. In 2005, law enforcement officials there investigated Mr. Epstein after the
parents of one of his accusers reported an incident to the police.
As first reported in The Miami Herald last year, prosecutors had prepared a 53-page indictment accusing
Mr. Epstein of being a sexual predator. But those charges were shelved in 2008 after an eleventh-hour deal
was reached between the United States attorney's office in Miami and Mr. Epstein's lawyers.
The plea agreement granted Mr. Epstein immunity from federal prosecution and let him plead guilty to two
prostitution charges in state court. Federal prosecutors arranged for the plea deal to be kept secret from Mr.
Epstein's accusers until it was finalized in court.
In April, a federal judge ruled that prosecutors had violated the law in offering the plea agreement without
informing Mr. Epstein's accusers. The Justice Department also opened a probe into the incident in
February.
Public Affairs
United States Department of Justice
U.S. Attorney's Office Southern District of New York
Mobile:
Press Office
EFTA00028311


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=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 11062816 has received final approval
Date: Wed, 19 Feb 2020 19:15:57 +0000
Importance: Normal
Dear
Travel authorization 11062816 has received final approval.
Trip ID: 11062816
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R20NYS13401 - Epstein Investigation - Witness interview
Destination: Pensacola, FL, United States
Dates: 2020-02-19 - 2020-02-20
Current status: Authorization Approved
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0006
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.
EFTA00027826


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=== Page 1 ===
From:
"
To:
Subject: Epstein Proposed Press Remarks v3 (large).docx
Date: Tue, 02 Jul 2019 16:10:04 +0000
Importance: Normal
Attachments: Epstein_Proposed_Press_Remarks_v3_(large).docx
EFTA00028281


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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: RE: disclosure update
Date: Wed, 31 Jul 2019 17:59:25 +0000
Yes-5pm works. Call my cell:
From:
)
Sent: Wednesday, July 31, 2019 12:20 PM
To:
Cc:
Subject: RE: disclosure update
Thanks-it's possible we'll still be in a meeting at 4:30. Would it be possible to speak at 5 instead? If not, we can plan for
4:30 and let you know if we need to reschedule.
Thanks,
From:
Sent: Wednesday, July 31, 2019 11:18 AM
To:
Cc:
Subject: RE: disclosure update
Yes-would 4:30pm today work?
From:
Sent: Tuesday, July 30, 2019 6:20 PM
To:
Cc:
Subject: disclosure update
EFTA00028526

=== Page 2 ===
Hi
Do you have a few minutes for a quick call tomorrow afternoon? We are making a disclosure that relates to your client in
connection with our discovery obligations to Epstein's counsel, and we wanted to briefly make you aware of it.
Thanks,
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00028527


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=== Page 1 ===
From: "Berman, Geoffrey (USANYS)"
To:
(NY) (FBI)"
Cc:
(NY) (FBI)"
Subject: Re: Jeffrey Epstein 19 cr 490
Date: Mon, 26 Aug 2019 20:54:10 +0000
let me know if you have a report for today.
Geoff
On Aug 12, 2019, at 12:57 PM,
(NY) (FBI)
wrote:
For info on attached.
Forwarded message
From:
(USMS)"
Date: Aug 12, 2019 12:55
Subject: FW: Jeffrey Epstein 19 cr 490
To:
(NY) (FBI)"
Cc:
FYI
United States Marshal
Southern District of New York
500 Pearl Street, Suite 400
New York, NY 10007
Office
Fax
Original Message
From:
On Behalf Of
Sent: Monday, August 12, 2019 12:47 PM
To
Cc:
(USMS)
)
Subject: Jeffrey Epstein 19 cr 490
Importance: High
Please see attached letter from Judge Richard M. Berman.
(See attached file: Aug 12 letter.pdf)
<Aug 12 letter.pdf>
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=== Page 1 ===
From:
To:
Cc:
Subject: FW: OPR Epstein Final Report
Date: Thu, 12 Nov 2020 15:59:39 +0000
Attachments: OPR_458587-vI-Epstein_Report_transmittal_to_SDNY_(letter_signed).PDF; OPR-
458557-v1-Epstein_Report_of_nvestigation_and_Exhibits_pdf.PDF
From:
Sent: Thursday, November 12, 2020 10:07 AM
To:
Cc:
Subject: OPR Epstein Final Report
Attached please find OPR's final Report in the Jeffrey Epstein matter, and a transmittal letter.
EFTA00029071


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE: assume you know about this article (in press clippings today)?
Date: Mon, 03 Jun 2019 21:34:17 +0000
Importance: Normal
Yeah we have all sorts of google alerts set up, thanks.
From:
(USANYS)
Sent: Monday, June 03, 2019 17:34
To:
Subject: assume you know about this article (in press clippings today)?
Feds Are Asking Jeffrey Epstein's Victims About Sex-Trafficking Crimes
Daily Beast
By Kate Briquelet
6/3/19
Deputy Chief, Criminal Division
U.S. Attorney's Office, Southern District of New York
EFTA00027743


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=== Page 1 ===
Case 1:19-cr-00490-RMB Document 7 Filed 07/11/19 Page 1 of 3
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
)
)
UNITED STATES OF AMERICA
)
)
V.
)
)
CRIMINAL NO. 19-CR-490
JEFFREY EPSTEIN,
)
Defendant
)
)
)
DEFENDANT JEFFREY EPSTEIN'S MOTION FOR LEAVE TO FILE
SUPPLEMENTAL FINANCIAL DISCLOSURE UNDER SEAL
Defendant Jeffrey Epstein, by and through undersigned counsel, hereby respectfully moves
this Honorable Court for leave to file under seal his supplemental financial disclosure. As noted in
Mr. Epstein's bail submission, on advice of counsel, he has not yet provided a complete financial
disclosure. Counsel's advice on this point was motivated by a desire to ensure the accuracy and
completeness of the information provided to the Court. Mr. Epstein seeks leave to file his
forthcoming supplemental disclosure under seal. As grounds and reasons therefor, Mr. Epstein relies
on the exceptional amount of publicity that has been generated by this case, much of which relates
specifically to his finances. Under the Bail Reform Act, financial information provided by a
defendant to a pretrial services officer "shall be used only for the purposes of a bail determination
and shall otherwise be confidential." 18 U.S.C. $ 3153(c)(1). Here, in the event Mr. Epstein is
required to publicly file his financial statement, the information contained therein will inevitably be
widely disseminated in the news media, contravening the statutory requirement of confidentiality.
1
EFTA00028985

=== Page 2 ===
Case 1:19-cr-00490-RMB Document 7 Filed 07/11/19 Page 2 of 3
WHEREFORE, Mr. Epstein respectfully requests that this Honorable Court allow him leave
to file his supplemental financial disclosure under seal.
Respectfully Submitted,
Jeffrey Epstein
By His Attorneys,
/s/ Reid Weingarten
Reid Weingarten
Steptoe & Johnson, LLP (NYC)
1114 Avenue of the Americas
New York, NY 10036
(202)-506-3900
/s/ Martin G. Weinberg
Martin G. Weinberg (application for
admission pro hac vice forthcoming)
20 Park Plaza, Suite 1000
Boston, MA 02116
(617) 227-3700
owlmgw@att.net
/s/ Marc Allan Fernich
Marc Allan Fernich
Law Office of Marc Fernich
810 Seventh Ave., Suite 620
New York, NY 10019
(212) 446-2346
maf@fernichlaw.com
Dated: July 11, 2019
2
EFTA00028986

=== Page 3 ===
Case 1:19-cr-00490-RMB Document 7 Filed 07/11/19 Page 3 of 3
CERTIFICATE OF SERVICE
I, Reid Weingarten, hereby certify that on this date, July 11, 2019, a copy of the
foregoing document has been served via Electronic Court Filing system on all registered
participants.
/s/ Reid Weingarten
3
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS) [Contractor]"
Subject: FW: Mail on Sunday enquiry
Date: Fri, 13 Mar 2020 16:57:47 +0000
We'll decline, but just FYI.
From: Mark Hookham
Sent: Friday, March 13, 2020 12:56 PM
To:
(USANYS)
Subject: Mail on Sunday enquiry
Dear
We spoke earlier this week in relation to the Jeffrey Epstein case and you asked me to email if I had a specific enquiry.
I understand that a woman has recently made a report to the Metropolitan Police in London regarding a sexually
assaulted by Jeffrey Epstein.
Could you please tell me whether the Metropolitan Police has informed the office of the US Attorney of the Southern
District of New York and/or the FBI of this criminal complaint? When did the alleged assault take place and where? Is the
FBI investigating this new complaint?
Yours sincerely,
Mark
Mark Hookham
Senior News Reporter
The Mail on Sunday
Disclaimer
This e-mail and any attached files are intended for the named addressee only. It contains information, which may be confidential and
legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee)
you may not copy or use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then
delete it from your system. Associated Newspapers Ltd. Registered Office: Northcliffe House, 2 Derry St, Kensington, London, W8 5TT.
Registered No 84121 England.
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=== Page 1 ===
From:
)"
To:
Cc:
(NY) (FBI)"
,
)"
(USANYS)"
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials,
scenes
Date: Mon, 15 Mar 2021 20:16:16 +0000
Yep, thanks very much.
From:
Sent: Monday, March 15, 2021 4:15 PM
To:
Cc:
(NY) (FBI)
is
is
(USANYS)
Subject: Re: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Was just about to email you actually. Can we call you after 5?
On Mar 15, 2021, at 16:05,
wrote:
Hi
and
Could we get on a quick call to check in about this, please? Defense counsel is asking for an update on timing.
Thanks,
From:
Sent: Friday, March 12, 2021 1:44 PM
To:
Cc:
(NY) (FBI)
is
)
is
(USANYS)
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thanks very much,
From:
Sent: Friday, March 12, 2021 1:33 PM
To:
Cc:
(NY) (FBI)
is
)
is
(USANYS)
Subject: Re: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
I am not in today (and
is still out) but the full team should be back in on Monday to get working on this task list.
We will get you answers to these questions as soon as we know.
EFTA00028845

=== Page 2 ===
Thanks,
On Mar 11, 2021, at 20:20,
wrote:
Following up on this, we had a call with defense counsel, who asked a number of questions I couldn't answer. Would
you please let me know the answers to the below?
For the nude/partially nude highly confidential images:
How many highly confidential images are there in total, including both from the discs and from the devices?
What is the format of these images? Are they all going to be viewable as thumbnails on the computer, or does
each image have to be opened individually?
For the images extracted from iPhone and iPads, will the FBI please be sure to include Celebrite so the defense
can open those files?
What, if any, metadata will be included with the highly confidential files? Will the metadata include information
clarifying which device each image was extracted from?
Would it be possible to provide the defense with more than one laptop to review these images on? They will
have their whole team of lawyers, the defendant, and investigators reviewing these, so they asked if it would be
possible to have multiple laptops instead of all crowding around one.
For the physical evidence:
Does the FBI have a list of all physical items in its custody for this case? The defense is eager to have such a list
and does not seem to care if it is in the same excel spreadsheet format we previously provided. (My
recollection from other cases is that the FBI can usually generate a list of all 1B items, so if that's possible, we'd
be grateful for that).
How soon can defense counsel go to the vault to see the physical evidence? Would they be able to do so on
Friday of next week?
If the defense wants to review the contents of VHS tapes, cassette tapes, and CDs, would the FBI be able to
provide a space with the appropriate players for them to view the contents of that media?
Thanks,
From:
Sent: Tuesday, March 9, 2021 3:33 PM
To:
(NYPD)
Cc:
(NY) (FBI)
i
is
(USANYS)
Subject: FW: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Hi
Thanks very much for chatting this afternoon. To recap:
By tomorrow: Please check to see whether it would be possible to prepare all of the "HIGHLY CONFIDENTIAL"
nude/partially nude images and videos from the search of Epstein's devices for Maxwell and her counsel to
review at 500 Pearl by next Wednesday or Thursday. If that is not feasible, please let me know how much time
you need to prepare those materials for review.
EFTA00028846

=== Page 3 ===
Please confirm that the only categories of "HIGHLY CONFIDENTIAL" nude/partially nude images in our custody
that have not been produced to the defense are (1) the images seized from Epstein's NY and USVI residences,
which were already loaded onto a laptop and brought by the FBI to the MDC for Maxwell to review, and (2) the
images and videos seized from Epstein's devices.
Attached is the inventory you all provided us detailing the physical evidence items from the FBI-Florida
investigation. Please confirm that no items from the Florida case are missing from this index.
Please provide us with a similar inventory of all physical evidence items in FBI-NY custody gathered during our
investigation.
Please work with
to figure out the logistics of how to allow defense counsel and (where possible)
Maxwell at 500 Pearl Street to review the physical items in the FBI's custody.
Thanks,
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
is
)
V.
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
<image001.jpg>
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00028847


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=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: disclosure update
Date: Tue, 30 Jul 2019 20:17:22 +0000
Hi
Do you have a few minutes for a quick call either later today, or tomorrow afternoon? We are making a disclosure that
relates to your client in connection with our discovery obligations to Epstein's counsel, and we wanted to briefly make you
aware of it.
Thanks,
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00028437


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=== Page 1 ===
From:
To:
Cc:
,
Subject: Re: Mark Epstein
Date: Mon, 25 Nov 2019 14:46:29 +0000
Mark and I are downstairs awaiting
Sent from my iPhone
On Oct 28, 2019, at 7:52 PM, srichmanlaw@msn.com wrote:
Done- 11/7 at 10!
Sent from my iPhone
On Oct 28, 2019, at 7:43 PM,
wrote:
Confirmed for 11/7 at 10 am at our office.
From:
Sent: Monday, October 28, 2019 7:01 PM
To:
Cc:
Subject: Re: Mark Epstein
I will work with any date you have the week of 11/4. I truly apologize. After our conversation I called my client for
10/31. He is quite anxious. I did not intend to waste anyone's time or resources.
Sent from my iPhone
On Oct 28, 2019, at 6:26 PM,
wrote:
Hi
Per my email, we made ourselves available for today and confirmed 3 p.m. today. I did not confirm 10/31. We're not
available this week and I'll have to go back to the case team to see when they're available. You can send us some
dates for the weeks of 11/4 and 11/11 that work for you.
From:
Sent: Monday, October 28, 2019 6:19 PM
To:
EFTA00029277

=== Page 2 ===
Cc:
Subject: Re: Mark Epstein
What will? My client is flying in from Florida based on our original conversation. From our discussion you said 10/31
and I called him immediately.
Sent from my iPhone
On Oct 28, 2019, at 6:02 PM,
wrote:
No, that won't work for us unfortunately.
From:
Sent: Monday, October 28, 2019 6:00 PM
To:
Cc:
Subject: Re: Mark Epstein
I am sorry I would not have confirmed for today. I had a 4 pm doctors appointment scheduled for months. I had
told mark 10/31 as well. My apologies. Can we still do 10/31?
Sent from my iPhone
On Oct 28, 2019, at 5:51 PM,
wrote:
Hi
Per my email on October 24 below, we were confirmed for Monday (which was today, October 28).
From:
Sent: Monday, October 28, 2019 5:27 PM
To:
Cc:
Subject: Re: Mark Epstein
Greetings. We are set for 10/31 at three per your direction. Did I miss an update?
Sent from my iPhone
On Oct 28, 2019, at 3:12 PM,
wrote:
EFTA00029278

=== Page 3 ===
Hi
Are you en route? Thanks.
On Oct 24, 2019, at 10:55 AM,
> wrote:
We are confirmed for a meeting at 3:00 p.m. on Monday at
See you then. Thanks.
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00029279


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=== Page 1 ===
From: "Biase, Nicholas (USANYS)"
To:
(USANYS) [Contractor]"
Cc:
(USANYS)"
(USANYS)"
(USANYS)"
,
(USANYS)"
Bcc:
Subject: Re: Epstein and SDNY in 2016
Date: Tue, 13 Oct 2020 13:02:41 +0000
EmbeddedRe:_Epstein_and_SDNY_in_2016.msg
Sender:
Subject: Re: Epstein and SDNY in 2016
Message-Id: <BF01EAD6-1E40-44EE-B299-3C8BDEC1A58A@usa.doj.gov>
EFTA00029501


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=== Page 1 ===
From:
(NY) (FBI)"
To:
(USANYS)"
(USANYS)"
Subject:
Date: Thu, 09 Jan 2020 18:54:00 +0000
,
Thanks again for your time yesterday in allowing me the opportunity to get up to speed with the Epstein matters.
I know you mentioned that there will be SDNY executive staff meetings on those matters today.
If either of you have a moment after those meetings have concluded to provide me with a quick update, that
would be very much appreciated.
Thank you again,
Acting Assistant Special Agent in Charge
ofc
cell
EFTA00028720


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=== Page 1 ===
From:
"
)"
To:
,
N. (NY) (FBI)"
Subject: RE: Epstein
Date: Thu, 01 Aug 2019 15:07:59 +0000
Awesome, thanks.
From:
N. (NY) (FBI)
Sent: Thursday, August 01, 2019 11:06
To:
Subject: FW: Epstein
Left a message with his office. I'll try and touch base with him this afternoon.
On Aug 1, 2019 10:58 AM,
"
)"
wrote:
Hey could I ask you to please give Mike a call this morning just so he knows you got his voicemail the other day? And
just let me know when you connect with him? He's at
(office) or
(cell). Thank you!
From: Miller, Michael
Sent: Thursday, August 01, 2019 10:40
To:
)
Subject: Epstein
Hello
-
Any word on when I can send someone by to pick up the ring, diamonds, and funds?
Many thanks.
Mike
Michael C. Miller
Partner
www.steptoe.com/mmiller
Steptoe
Steptoe & Johnson LLP
1114 Avenue of the Americas
New York, NY 10036
www.steptoe.com
This message and any attached documents contain information from the law firm Steptoe & Johnson LLP that may be confidential and/or privileged. If
you are not the intended recipient, please do not read, copy, distribute, or use this information. If you have received this transmission in error, please
notify the sender immediately by reply e-mail and then delete this message.
EFTA00028087


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=== Page 1 ===
From:
Subject: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Date: Wed, 21 Apr 2021 19:13:39 +0000
Dear Judge Nathan,
The Government writes in response to the Court's April 19, 2021 scheduling Order, which directed the Government to
inform the Court by email regarding victim attendance at the upcoming arraignment in this matter.
The Government has conferred with the attorneys who represent all four victims referenced in the Superseding
Indictment, and reports the following:
Victim-1, Victim-3, Victim-4, and their respective counsel will not be attending the conference.
Victim-2 plans to attend the conference by phone. Her counsel have asked whether she should dial into the public
access line, or whether the Court will provide a separate access line for victims.
Victim-2's attorneys, David Boies and Sigrid McCawley, plan to attend the conference in person.
Respectfully,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00027158


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=== Page 1 ===
From:
To:
Subject: RE: Epstein subpoena return
Date: Tue, 15 Oct 2019 19:48:10 +0000
Thanks! Sorry, I was running around, but I'm at my desk now.
From:
Sent: Tuesday, October 15, 2019 2:54 PM
To:
Subject: RE: Epstein subpoena return
Of course. I will come by and grab the disc.
From:
Sent: Tuesday, October 15, 2019 2:47 PM
To:
Subject: Epstein subpoena return
Hi
Any chance you have time to help me out with loading a subpoena return for the Epstein case onto the share? I haven't
been able to open the disc myself, and it may require IT help.
Thanks!
EFTA00028839


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=== Page 1 ===
Grand Jury Subpoena
United States District Court
SOUTHERN DISTRICT OF NEW YORK
TO:
USAA Federal Savings Bank
Attn: Bank Counsel
9800 Fredericksburg Road
San Antonio, TX 78288
GREETINGS:
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before
the GRAND JURY of the people of the United States for the Southern District of New York, at the United States
Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the
Southern District of New York, at the following date, time and place:
Appearance Date:
August 30, 2019
Appearance Time: 10:00 a.m.
to testify and give evidence in regard to an alleged violation of :
18 U.S.C. §§ 201, 371, 1001, 1346, 1519, 2
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you
bring with you and produce at the above time and place the following:
Please see attached rider. Personal appearance is not required if the requested records are (1) produced on or
before the return date to Assistant U.S. Attorney
of the United States Attorney's Office, 1 St.
Andrew's Plaza, New York, NY 10007. Tel:
, email:
, and (2)
accompanied by an executed copy of the attached Declaration of Custodian of Records. Ref No. 2019R01059.
Failure to attend and produce any items hereby demanded will constitute contempt of court and will
subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
DATED: New York, New York
August 17, 2019
Geoffey
S.
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
DEPARTMENT IIIIII UNITED COURT
Assistant United States Attorney
FOR
One St. Andrew's Plaza
THE
RICT
YORK
New York, New York 10007
or
NEW
Telephone:
Email:
rev. 02.01.12
EFTA00027189

=== Page 2 ===
RIDER
(Grand Jury Subpoena to USAA Federal Savings Bank, dated August 17, 2019)
Ref. No. 2019R01059
REQUEST:
For the following account, and any other account controlled by the account holder of one of the below
accounts:
Please provide any and all documents, to include, but not limited to those identified below, for the period
January 1, 2019 until the present:
a. Account opening documents, including applications and signature cards;
b. Records of account holders for debit and credit cards liked to the accounts;
c. Account statements and ledgers;
d. Images of checks (both front and back) deposited in account;
e. Images of canceled checks (both front and back) drawn on account;
f. Images of cashier's checks (both front and back) and depositing bank account information;
g. Account deposit slips, withdrawal slips, debit & credit memos, and cash tickets;
h. Detailed wire transfer records, ACH transfer records (including routing/account numbers funds
transferred to/from), money orders, and traveler's check records;
i. All credit card and line of credit records, including, but not limited to: applications, monthly
statements, billing slips, and records evidencing the source of payment (copies of checks, ACH
records (including routing/account numbers funds transferred to/from), or cash received slips);
j. Customer information associated with the account, including name(s), address(es), telephone
number(s), e-mail address(es), and any other identifying or contact information.
INSTRUCTIONS FOR PRODUCTION OF DOCUMENTS:
1. All transactions-based information, include wire and ACH transfers, withdrawals/deposits,
charges/payments, and bank account activity should be provided in electronic spreadsheet
format (either Microsoft Excel or similarly compatible format). Specifically:
a. For wires and other types of transfers, the account holder name, account number, and bank
name of both the originator and beneficiary of the transaction should be clearly stated in
separate fields.
b. Cash and check transactions should be indicated within a transaction type field.
i. Check transactions should include the name of the payee in the recipient
field. Additionally, check images should be attached in graphic data files in a commonly
readable, non-proprietary format with the highest image quality maintained, and named in
a manner that uniquely associates them with the relevant transaction record(s).
ii. Cash withdrawals should be indicated with CASH written in the recipient field.
EFTA00027190

=== Page 3 ===
iii. Cash deposits should be indicated with CASH written in the sender/originator field.
c. Field headers should be included for each column of data, and a data dictionary or other
explanation of the contents of each column provided.
2. Where more than one account is being requested, each account's transaction records should be
returned in a separate file.
3. All document images are to be produced in electronic PDF format. Where images of checks,
deposit slips, withdrawal slips, or cash tickets are being produced, they should be produced no
more than two per page.
4. In lieu of an appearance you may comply with this subpoena by providing the requested
information, along with a business records certification pursuant to Fed. R. Evid. 803(6) to
Assistant U.S. Attorney
of the United States Attorney's Office, 1 St. Andrew's
Plaza, New York, NY 10007. Tel:
, email:
EFTA00027191

=== Page 4 ===
Declaration of Custodian of Records
Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare:
My name is
.
(name of declarant)
I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the
business named below, or I am otherwise qualified as a result of my position with the business named below to
make this declaration.
I am in receipt of a Grand Jury Subpoena, dated August 17, 2019, and signed by Assistant United States
Attorney
,
requesting specified records of the business named below. Pursuant to Rules 902(11) and
803(6) of the Federal Rules of Evidence, I hereby certify that the records provided herewith and in response to the
Subpoena:
(1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from
information transmitted by, a person with knowledge of those matters;
(2) were kept in the course of regularly conducted business activity; and
(3) were made by the regularly conducted business activity as a regular practice.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on
-
(date)
(signature of declarant)
(name and title of declarant)
(name of business)
(business address)
Definitions of terms used above:
As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any form, of acts,
events, conditions, opinions, or diagnoses. The term "business" as used in Fed. R. Evid. 803(6) and the above declaration
includes business, institution, association, profession, occupation, and calling of every kind, whether or not conducted for
profit.
EFTA00027192

=== Page 5 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 17, 2019
Re:
Grand Jury Subpoena
This letter describes the procedure for requesting reimbursement for subpoenaed records.
12 CFR part 219 (subpart A), issued by the Board of Governors of Federal Reserve System under section
1115 of the Right to Financial Privacy Act (12 U.S.C. $ 3415), sets the rates and conditions for reimbursement of
costs directly incurred by financial institutions in assembling or providing customer financial records to a
government authority pursuant to the Act. No costs are reimbursable if the records are those of a corporation or a
partnership comprised of more than five individuals.
If reimbursement is authorized, and the estimated billing to the government will exceed $500, advance
permission is necessary from
at
If the subpoenaed records indicated on the rider are eligible for reimbursement, please complete section B
of the enclosed form OBD-211, which will serve as your invoice, and return it with a copy of the subpoena to the
following address:
U.S. Attorney's Office - SDNY
Accounts Payable
86 Chambers Street, 3rd floor
New York, NY 10007
(212) 637-2662
Please send your invoice to the above address within 60 days of the submission of the subpoenaed records.
If no invoice is received within 120 days, funds will not be available to pay the invoice.
Thank you for your cooperation in this matter.
Very truly yours,
GEOFFREY S. BERMAN
United States Attorney
By:
/s/
Assistant United States Attorney
Enclosure: OBD- 211
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=== Page 1 ===
From:
To:
Subject: FW: CBP Question
Date: Tue, 10 Aug 2021 13:48:45 +0000
Attachments:
travel_from_1.1.1990_to_4.5.2021.pdf;
travel_from_1.1.1990_to_4.5.2021.pdf;
Maxwell_travel_from_1.1.1990_to_1.1.2000.pdf;JE_Travel.pdf
From:
Sent: Thursday, July 29, 2021 6:17 PM
To:
Cc:
Subject: RE: CBP Question
Thanks again for helping; we really appreciate it. Attached are the records. Please let us know if you have any questions.
Thanks,
From:
Sent: Thursday, July 29, 2021 5:31 PM
To:
Cc:
Subject: Re: CBP Question
Hey
Sorry I was on the road but I spoke with
he filled me in on what your looking for. I'm also available for a call to
further discuss.
Respectfully,
U.S. Customs and Border Protection
Task Force Officer - SDNY
US Attorney's Office
Southern District of New York
(LES/FOUO) LAW ENFORCEMENT SENSITIVE - FOR OFFICIAL USE ONLY
WARNING:
EFTA00029382

=== Page 2 ===
The information contained in this email is considered confidential and sensitive in nature as well as sensitive but
unclassified and/or legally privileged information. It is not to be released to the media, the general public, or to non-law
enforcement personnel who do not have a "need-to-know". This information is not to be posted on the Internet, or
disseminated through unsecured channels, and is intended for law enforcement personnel only. It is solely for the use of
the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable
laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender
and destroy all copies of the communication.
DISSEMINATION INSTRUCTIONS: This document is marked Law Enforcement Sensitive/For Official Use Only and may be
disseminated, with proper attribution, to Law Enforcement, DOD, or U.S. Intelligence Agencies. Further disclosure to
unauthorized entities could jeopardize ongoing investigations, operations, and personal safety. This product shall not be
released to the public or media.
From:
Sent: Thursday, July 29, 2021 3:56:15 PM
To:
Cc:
Subject: CBP Question
CAUTION: This email originated from outside of DHS. DO NOT click links or open attachments unless you recognize and/or trust the
sender. If you feel this is a suspicious-looking email, please report by using the Report Phish button option.
Hi Ray,
I hope you are well! Jared Eannucci passed along your info to us. We were hoping to connect with you by phone about a
question in one of our cases. Do you have time to talk today or tomorrow morning?
Thanks so much!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
New York, New York 10007
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=== Page 1 ===
From:
To:
Subject: RE: United States V. Ghislaine Maxwell --
opens
Date: Mon, 29 Nov 2021 01:55:11 +0000
Thanks,
From:
Sent: Sunday, November 28, 2021 10:19 AM
To:
>; Drescher, Sunny (USANYS) [Contractor]
is
Subject: RE: United States V. Ghislaine Maxwell
opens
Good Luck team!!!
From:
Sent: Sunday, November 28, 2021 9:59 AM
To: USANYS-CRIMINAL AUSAS <USANYS-CRIMINALAUSAS@usa.doj.gov>; USANYS-CRIMINAL PARALEGALS <USANYS-
CRIMINALPARALEGALS@usa.doj.gov>; USANYS-INVESTIGATORS <USANYS-INVESTIGATORS@usa.doj.gov>
Cc:
Subject: United States V. Ghislaine Maxwell --
opens
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors will
do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine Maxwell
sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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c4: DataSet 8/VOL00008/IMAGES/0006/EFTA00028265.pdf
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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
November 10, 2021
BY EMAIL
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:
At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint
letter regarding protections for witness identities at trial. In particular, the Court directed the
parties to: (1) provide nomenclature for witnesses whose identities should be protected, (2) propose
procedures for voir dire related to witness identities, (3) submit a proposed instruction to the jury
regarding witnesses testifying under pseudonyms or under their first name only, and (4) address
the logistics of offering sealed or redacted exhibits containing personal identifying information.
Below are the positions of the parties regarding these logistical considerations. Because this letter
contains identifying information relating to victims, the Government respectfully requests that the
Court accept the Government's proposed redactions to this letter.
Government position:
I.
Nomenclature
With respect to nomenclature for witnesses whose identities should be protected at trial,
the Government respectfully submits the following chart, which provides the true names of
witnesses and the proposed nomenclature for those witnesses at trial.
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Page 2
Witness Name
Nomenclature at Trial
The Government submits that this nomenclature can be used when trial begins on
November 29, 2021, but that the parties should be directed to continue referencing victims and
witnesses on the public record according to the nomenclature in the Superseding Indictment. The
Government further requests that the defense be directed to redact the true names of the witnesses
in this chart from all exhibits to filings, and to avoid using the true names of victims in filings with
the Court. Using the true names of victims delays public filings and creates otherwise unnecessary
redaction projects that waste the Government and the Court's time. Moreover, using victim names
in filings increases the risk that victim identities may become public, due to redaction errors or
other issues.
II.
Voir Dire
Regarding voir dire, the Government proposes that prospective jurors be handed a sheet
with a list of names and places that may come up at trial. That sheet, which would be filed under
seal, would contain the true names of witnesses. The sheet would not be read aloud; instead, the
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Government requests that the Court direct prospective jurors to read the sheet and to raise a hand
if they are familiar with the witnesses or locations. Examination of jurors on this subject would
then be conducted at sidebar, with the transcript redacted to remove witness identifying
information.
Similarly, with respect to employment information regarding witnesses, the Government
proposes that the list of names and places handed to prospective jurors should also contain a section
regarding entities, institutions, or programs with which jurors may be familiar. Examination on
this subject would similarly be conducted at sidebar, with the transcript redacted to remove witness
identifying information.
III.
Limiting Instruction
The Government requests that the Court give the jury an instruction that is similar to the
instruction Judge Garaufis gave the jury in United States V. Raniere, 18 Cr. 204 (E.D.N.Y.). In
that case, Judge Garaufis instructed the jury:
You may have noticed during yesterday's testimony that the witness used first
names of certain individuals. That is because the names of certain alleged victims
are being withheld from the public and the press to protect the privacy of those
individuals. I have therefore instructed the parties to refer to those individuals by
their first names only; however, those full names are known to the Government, the
defendant, and to the Court.
An excerpt of the relevant transcript is enclosed as Exhibit A. Here, the Government proposes that
the Court instruct the jury:
At this trial, certain witnesses will be testifying under their first name only. Other
witnesses will be testifying under pseudonyms - that is, under different names.
That is because the names of certain alleged victims and related witnesses are being
withheld from the public and the press to protect the privacy of those individuals. I
have therefore instructed the parties to refer to those individuals by their first names
only, or in some instances, by using a pseudonym. However, the full names of the
witnesses are known to the Government, the defendant, and to the Court.
The Government respectfully submits that the proposed instruction addresses any potential
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prejudice to the defendant, as the instruction makes clear to the jury that the identities of the
witnesses are being protected from the public and press only, and that the true names of the
witnesses are known to the Government, the Court, and the defendant.
IV.
Sealed and Redacted Exhibits
The Government anticipates offering certain exhibits entirely under seal or with redactions
to protect the personal identifying information of witnesses and third parties. With respect to
logistics, the Government would propose submitting redacted versions of exhibits - along with an
index noting which of the Government exhibits will be offered under seal - no later than November
29, 2021. To the extent the defense takes issue with the sealing requests or the proposed redactions,
the Court may rule on those exhibits on case-by-case basis during the trial.
The Government has considered how best to publish sealed exhibits to the jury while
protecting the identities of witnesses and the privacy of third parties. On that score, the
Government is mindful that exhibits published in electronic format on screens in the courtroom
may be seen by the public, since the screens at counsel table - and potentially the jury box- are
visible to the public from certain angles. For this reason, the Government requests permission to
provide jurors with individual binders containing sealed exhibits. The Government expects that
jurors will follow the Court's instruction to only view items in the binder when the Court instructs
jurors to do so.
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Defense position:
In light of the Court's ruling on the government's motion in limine, the defense will accept
the government's proposed nomenclature for the witnesses referenced above. The defense has no
objection to the procedures proposed by the government for voir dire and for sealing and redacting
exhibits on the understanding that the defense will have the opportunity to object to particular
sealing and redaction requests. The defense also proposes the following limiting instruction in
place of the government's proposed instruction:
This case has received, and will continue to receive, significant attention in the
media. To minimize the inconvenience and potential harassment of any witness, the
Court has permitted witnesses, if they choose, to be referred to by either their first
name or a pseudonym. However, the full names of the witnesses are known to the
Government, the defendant, and to the Court, and were shown to you during jury
selection. This process should not bear in any way on your evaluation of the
evidence in this case.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By:
Assistant United States Attorneys
Southern District of New York
Cc: Defense Counsel (By email)
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=== Page 1 ===
Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 1 of 22
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 9:08-cv-80736-KAM
JANE DOE 1 AND JANE DOE 2,
Petitioners,
V.
UNITED STATES,
Respondent.
/
JANE DOE 1 AND JANE DOE 2'S POSITION ON THE PROCEDURES TO BE
FOLLOWED TO DETERMINE A REMEDY FOR THE GOVERNMENT'S
VIOLATION OF THE CRIME VICTIMS' RIGHTS ACT
Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through
undersigned counsel, now file their position regarding the procedures to be followed to
determine a remedy for the Government's violation of the Crime Victims' Rights Act (CVRA).
For the reasons explained below, the Court should direct the Government to begin the process by
first publicly announcing what remedy (if any) it proposes as appropriate given this Court's
finding that the rights of Jane Doe 1 and 2 were violated. Thereafter, Jane Doe 1 and 2 will file a
response, including (if necessary) proposing further remedies. Further cross-briefing could
follow, assuring all parties (including intervenor Jeffrey Epstein) a chance to place their views
before the Court. This approach would place the Court in a position to rule expeditiously. While
the Government opposes having to disclose its proposed remedies first, this approach of
requiring the Government to initiate remedial action for the violation of the Jane Doe 1 and 2's
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rights is consistent with the CVRA's language and goals. It is also the best way to bring this
decade-old litigation to a prompt conclusion.
RELEVANT BACKGROUND
As the Court is aware, Jane Doe 1 and 2 filed this action in 2008, alleging a violation of
their rights. The focus of concern in this case has recently shifted from whether the Government
violated Jane Doe 1 and 2's CVRA rights to how to remedy that now-proven violation. As the
Court is aware, this case has spanned more than a decade, during which the Government
repeatedly created obstacles to reaching the merits of whether CVRA violations occurred when
the Government (and Epstein) purposely concealed the consummation and execution of a secret
non-prosecution agreement (NPA). On February 21, 2019, this Court brought the initial phase of
the case to an end, holding that Jane Doe 1 and 2's "right to conferral under the CVRA was
violated." Jane Does 1 and 2 V. U.S., 350 F.Supp.3d 1201, 1222 (S.D. Fla. 2019). As the Court
explained, the undisputed evidence establishes that "the Government entered into a[n] NPA with
Epstein without conferring with Petitioners [i.e., Jane Doe 1 and 2] during its negotiation and
signing." Id. at 1218.
At the end of the Court's opinion, the Court directed counsel for Jane Doe 1 and 2 and
the Government to "confer and inform the Court within 15 days of the date of entry of this Order
how they wish to proceed on determining the issue of what remedy, if any, should be applied in
view of the violation." Id. at 1222. The next day, Friday, February 22, 2019, the Court clarified
that it "did not expect the parties to agree on a remedy. The Court only directs the parties to
confer on what submissions or proceedings they believe are necessary in order for the Court to
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Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 3 of 22
make a determination on a remedy, if any. If the parties are unable to agree on the submissions
or proceedings necessary, they may submit separate filings." DE 437 at 1.
Consistent with the Court's direction for a submission within 15 days on proposed
procedures for a remedy determination, the next workday - Monday, February 25, 2019 -
Counsel for Jane Does 1 and 2 sent a letter to the U.S. Attorney for the Southern District of
Florida. See Ex. 1. The letter explained their position that the Government should take the next
step in abiding by its obligations under the CVRA. Jane Doe 1 and 2 noted that, under the
CVRA, all "[o]fficers and employees of the Department of Justice
shall make their best
efforts to see that crime victims are notified of, and accorded, the rights described in [the
CVRA]." Ex. 1. at 3 (citing 18 U.S.C. § 3771(c)(1) (emphases added)). Under this statutory
command, Jane Doe 1 and 2 suggested that the Government has an obligation to reasonably
confer with them. Id. Jane Doe 1 and 2 explained one possible approach to resolving the case
and their willingness to discuss others. Ex. 1 at 4.
The Government, however, did not respond to the letter. Accordingly, with the Court's
March 8 deadline drawing near, on March 4, 2019, Jane Doe 1 and 2 sent a second letter to the
U.S. Attorney for the Southern District of Florida. Noting their earlier request, Jane Doe 1 and 2
wrote "again and with increased urgency" to request that the Office "immediately work with us"
to resolve the case. Ex. 2 at 1. Jane Doe 1 and 2 requested a right to quickly confer, noting that
time was "of the essence" in view of the Court's March 8 deadline. Id. at 2.
Once again, the U.S. Attorney's Office did not respond to this request to confer. Instead,
on the evening of March 4, 2019, counsel received an email from the Government indicating that
"the Southern District of Florida has been recused from the CVRA litigation." The email did not
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Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 4 of 22
explain why, after more than ten years of litigation, the U.S. Attorney's Office for the Southern
District of Florida was now being recused in the matter. Nor did the email explain why the
matter was now being sent to Georgia for review. Indeed, reassignment of the matter to Georgia
seems quite curious, given that some seven years earlier, the Government had informed this
Court that it had "reassigned responsibility for the investigation and potential prosecution of such
criminal matters [involving Epstein's sexual activities with minor females] in the Southern
District of Florida to the United States Attorney's Office for the Middle District of Florida for
consideration of any prosecutorial action that may be authorized and appropriate." DE 205-2 at
9.
On March 6, 2019, the U.S. Attorney's Office for the Northern District of Georgia
contacted Jane Doe 1 and 2's counsel, requesting a 90-day extension of time in which to confer
and propose procedural steps for determining an appropriate remedy. Through counsel, Jane
Doe 1 and 2 conferred with the Office, noting that this case has been in litigation for more than a
decade - requesting that a resolution be expedited. That same day, the Government filed with
this Court a motion for a 90-day extension of time, arguing that it needed time to learn about the
case and to confer with Jane Doe 1 and 2's counsel about how to determine procedures for
developing a remedy. The Court then asked that counsel for Jane Doe 1 and Jane Doe 2 to
provide their views on how best to proceed. Their counsel suggested that, as a matter of
professional courtesy to the new attorneys, the Court should grant the Government's motion but
limit the extension to 45 days (until no later than April 22, 2019) and that the Government should
announce what remedy it was voluntarily willing to provide to them on or before May 10, 2019.
DE 447 at 1-2.
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Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 5 of 22
On March 13, 2019, this Court entered an order extending until May 10, 2019, the time
for the parties to confer on the appropriate mechanism to propose to the Court to make a
determination regarding an appropriate remedy. DE 448. Thereafter, counsel for Jane Doe 1 and
2 and the Government have conferred several times via telephone and additional correspondence
regarding appropriate procedures to be followed in this case. As stated in their February 25 and
March 4 letters described above, Jane Doe 1 and 2 contended that the Government should take
the first step to remedy the CVRA violation, consistent with its "best efforts" obligations under
the CVRA. Jane Does 1 and 2 expressed their willingness to confer with the Government
immediately, as they are the petitioners whose rights have already determined to have been
violated. The Government, however, took the position that it was not yet prepared to engage in
any substantive discussion. The Government has also insisted that Jane Doe 1 and 2 file an
additional pleading listing their proposed remedies first with the Court.
In addition, the Government took the position that substantive proceedings in this case
should be delayed for several months to permit it to confer with some unspecified number of
victims - beyond Jane Doe 1 and Jane Doe 2 - about how to resolve the petition filed by Jane
Doe 1 and 2. This is a dramatic change in position by the Government, now represented by the
U.S. Attorney's Office for the Northern District of Georgia. As the Court will recall, in 2015
two additional victims - Jane Doe 3 and Jane Doe 4 - sought to join this case. DE 280. The
Government, then represented by the U.S. Attorney's Office for the Southern District of Florida,
"vehemently" opposed joinder. See DE 324 at 2 (citing DE 290, 314). The Court adopted the
Government's position and denied the additional victims' motion to join. DE 324 at 9 (quoting
De 280 at 1). Today, some four years later, the Government now apparently wishes to confer
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Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 6 of 22
with (among others) the two victims whom it successfully blocked from joining this case
previously.
What specifically the Government wishes to confer about - and what it will tell the
victims, especially those who are not formally parties to the case and presumably have not kept
up on the intricacies of the case -- remains unclear. So far as we can determine, during the
nearly three months since this Court's summary judgment ruling, the Government has not
initiated any contact with any victims or their counsel. In fact, during an April 29, 2019,
conference call between attorneys from the U.S. Attorney's Office for the Northern District of
Georgia and counsel for Jane Does 1 and 2 (and 3 and 4), the Jane Does' counsel offered to
simply have the conferral with the Government at that time on that call. The Government
declined to do so. And the Government was unable to describe the nature of any conference they
intended to conduct, did not indicate what options they would propose to victims, and did not say
what message they intended to convey to the victims about what support the Government would
offer before apparently asking these individuals what remedy they would like to seek. The
Government could not even define the scope of the victim population from whom the
Government intended to seek input.
DISCUSSION
To be clear, Jane Doe 1 and 2 have never opposed the Government discussing the case
with anyone. Nor are they opposed to discussing a settlement of their petition. But at this point,
the Government has not substantively begun any such process, with the two Jane Does or anyone
else. The Government has had enough time to talk with whomever will help make up its mind
on its position and the case simply needs to move forward. The Government procrastination in
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Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 7 of 22
conferring should have no impact on its legal position regarding the appropriate remedy for
violating the CVRA. It is certainly not a condition precedent to the Government's ability to have
a position and at the current stage would not only cause delay but could create more issues with
concluding this case depending on the substance of the one-sided conferral they now seek.
Accordingly, Jane Doe 1 and 2 now offer their recommendations to the Court as to how
to proceed to resolve their petition. In setting up a mechanism for determining the appropriate
remedy in this case, two principles should be paramount. First, because the Government has a
statutory obligation to see that Jane Doe 1 and 2 "are
accorded" their CVRA rights, see 18
U.S.C. $ 3771(c)(1), it should initiate the process for remedying the established CVRA violation
these two victims suffered. And second, that remedial process should be expedited given the
extended length of time that the Government's numerous motions have taken to resolve and the
Government's obligations to ensure that proceedings are "free from unreasonable delay." In
light of both of these principles, the Court should now direct the Government to move forward
with announcing the procedure it intends to follow to correct the CVRA violations suffered by
the two petitioners. That announcement should be followed by subsequent expedited briefing as
provided below.
I.
THE COURT SHOULD DIRECT THE GOVERNMENT TO FIRST ANNOUNCE
WHAT REMEDIES IT IS WILLING TO PROVIDE TO JANE DOE 1 AND 2 FOR
THE VIOLATION OF THEIR CVRA RIGHTS.
While counsel for Jane Doe 1 and 2 and the Government have conferred on how to craft
an agreed procedure to propose to the Court for determining a remedy in this case, those efforts
foundered as to how to proceed at the opening step. Jane Doe 1 and 2 took the view that the
Government should take the first step by announcing its proposed remedy for the CVRA
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Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 8 of 22
violation of their rights. On the other hand, the Government has insisted that Jane Doe 1 and 2
propose a complete solution for the Government's illegal conduct even though the two victims
do not know what steps the Government is willing to undertake.
The Government should go first. Under the CVRA's plain language, the Government
must remedy the violation of the CVRA - a statutory obligation that the Government cannot
defer pending some action by unspecified victims, including dozens of women who are not
parties to this case. Under 18 U.S.C. $ 3771(c)(1), the Government has a "best efforts"
obligation to afford victims their rights, including doing so without "unreasonable delay," 18
U.S.C. $ 3771(a)(7). Even if Jane Doe 1 and 2 never submitted anything to the Government (or
to the Court), the Government would have to undertake its own corrective efforts to protect their
rights to confer. Under the CVRA, the Government is obligated to take remedial measures now,
independently of whatever procedure this Court may decide to put in place for determining a
remedy in this litigation.
Nor does any confusion exist about what possible steps the Government could take. The
Court will recall extensive litigation that occurred in this case on the issue of remedies some
seven years ago. On November 7, 2011, the Government filed its motion to dismiss this action,
arguing that it was impossible for Jane Doe 1 and 2 to obtain any remedy. DE 205-2 at 3-4. In
response to the Government's motion to dismiss, Jane Doe 1 and 2 responded that the CVRA in
fact permits multiple remedies. DE 127 at 8-13. Indeed, Jane Doe 1 and 2 also provided a list
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Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 9 of 22
of approximately 27 separate remedies that the Government could provide in addition to re-
opening the non-prosecution agreement. See id. at 13-18.¹
After the Government replied (DE 205-6), this Court rejected the Government's position
that no remedy was possible and agreed with Jane Doe 1 and 2. In discussing one possible
remedy, this Court specifically held that "the CVRA is properly interpreted to authorize the
rescission or "re-opening' of a prosecutorial agreement-including a non-prosecution
arrangement-reached in violation of a prosecutor's conferral obligations under the statute.
[T]he [CVRA] is properly interpreted impliedly to authorize a 're-opening' or setting aside of
pre-charge prosecutorial agreements made in derogation of the government's CVRA conferral
obligations
" Jane Does 1 and 2 V. United States, 950 F. Supp. 2d 1262, 1267 (S.D. Fla.
2013).
In light of this earlier and extensive briefing, the legal framework for permissible
remedies is already well developed. It makes no sense to delay this case further, given that
Jane Doe 1 and 2 provided a list of more than 20 specific remedies back in 2011, DE 127 at 8-18,
and on February 25, 2019 (four days after this Court's ruling) a follow up letter outlining a way
to resolve the case. By all reasonable appearances, the Government's request for Jane Doe 1 and
2 to provide some further enumeration of what remedies are being sought is a pointless effort at
delay. So that the record is clear on what remedies are being requested, Jane Doe 1 and 2 simply
reaffirm that they are seeking each and every remedy listed in 2011 - and are waiting (as they
1 Jane Doe 1 and 2 also filed a short, sealed pleading with additional remedies that are
appropriate in this case.
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Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 10 of 22
have since 2011) to see whether the Government will agree to some or all of them - or make
alternative proposals.
Directing the Government to go first is also consistent with judicial efficiency. In light
of the Court's binding ruling that the Government has violated its CVRA obligations, the
Government may decide to announce that it will voluntarily take the steps that are satisfactory to
Jane Doe 1 and 2. If so, this litigation might be brought to a swift conclusion without the need
for any further judicial rulings. And even if the Government's remedies are less-than-complete,
the existence of those voluntarily provided remedies may limit the scope of the dispute between
the parties² - and, accordingly, the scope of any hearings and rulings by this Court.
Finally, this case is unlike many cases that the Court has before it. In some cases, the
defendant in an action might be uncertain as to what sorts of remedies are being requested. But
here the issue of permissible remedies was litigated more than seven years ago. The Government
took the position that no remedies were possible in this case - and this Court rejected that
position. This case is an enforcement action, designed to enforce Jane Doe 1 and Jane Doe 2's
rights under the CVRA. One of the parties - the Government - has it entirely within its power to
provide all the various remedies being sought through the lawsuit - and then some. Indeed, as
explained above, the Government is statutorily obligated to use its "best efforts" to provide
appropriate remedies, 18 U.S.C. $ 3771(c)(1), even without any action by this Court. The
2
The Court has previously granted Epstein's motion to intervene on remedy issues that
might affect him. If any remedy is being proposed that affects Epstein, Jane Doe 1 and 2 have
no objection to him being heard and, indeed, have built in an opportunity for him to be heard in
the schedule that they propose.
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Government should first explain what its "best efforts" will be. Until it does so, there is no
reason to confer with Jane Doe 1 or Jane Doe 2 - or anyone else for that matter. What specific
remedy or remedies would the conference be about and what options is the Government making
available? After more than ten years of litigation, the Government's suggestion that it should
postpone explaining its proposed remedy is a transparent effort to do nothing but cause further
delay.
II.
THE COURT SHOULD ESTABLISH PROCEDURES THAT WILL EXPEDITE
PROVIDING A REMEDY TO JANE DOE 1 AND 2.
The other point that the Court should consider in crafting remedial procedures is the
extraordinary amount of time that the Government has already managed to delay a resolution of
the petition filed by Jane Doe 1 and 2. As the Court is aware, Jane Doe 1 (and then Jane Doe 2)
filed this action in July 2008, and the Government has since raised a seemingly non-stop series
of objections. And not to be outdone, Epstein also intervened and succeeded in delaying the case
for a year while he took a meritless interlocutory appeal to the Eleventh Circuit. See Jane Doe 1
and Jane Doe 2 V. U.S., 749 F.3d 999 (11th Cir. 2014). The upshot is that in this case involving
federal sex offenses against two child victims, a resolution of the petition has been delayed for
more than a decade.
The CVRA contemplates rapid resolution of the crime victims' issues. The CVRA's
enforcement provision provides that "[t]he district court shall take up and decide any motion
asserting a victim's right forthwith." 18 U.S.C. $ 3771(d)(3) (emphasis added). The Court of
Appeals is required to "take up and decide" any mandamus petition for review "within 72 hours
after the petition has been filed." Id. (emphasis added). To be clear, Jane Doe 1 and 2 have
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Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 12 of 22
appreciated the care with which this Court has reviewed this complicated case and believes that
the Court has satisfied its obligations under the CVRA. But with regard to the Government, the
Court must view any request for delay by the Government with a wary eye in view of the
accelerated timelines the CVRA establishes. Indeed, the Government is statutorily obligated to
protect victims' rights to proceedings free from "unreasonable delay." 18 U.S.C. $ 3771(a)(7).
Jane Doe 1 and 2 provided the Government with a specific list of possible remedies that
they were seeking in 2011. The Government has had seven years(!) to review that list - more
than ample notice of what was going to be requested as the remedies in this case. The Court
should evaluate any claim that the Government now needs more time to assess the situation
against that backdrop of years and years of litigation protracted by unfounded Government
resistance.
III.
JANE DOE 1 AND 2' PROPOSED PROCEDURE FOR THE COURT TO
DETERMINE A REMEDY.
In light of the principles discussed above, Jane Doe 1 and 2 propose that the Court order
the following schedule for determining a remedy in this case, which the Court should enter as
quickly as is feasible:
Not later than two weeks from the date of the Court's order: The Government should
specify in writing how and when it proposes to remedy the violation of the rights of the two
victims (Jane Doe 1 and Jane Doe 2) who are parties to this litigation. If the Government
desires, it can also simultaneously but separately specify whether, when, and how it proposes to
remedy any CVRA violations that denied other victims their rights.
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Not more than two weeks later: Jane Doe 1 and Jane Doe 2 should file any objections and
what (if any) additional remedies they seek from the Court beyond what the Government
voluntarily proposes to provide.
Not more than two weeks later: Intervenor Jeffrey Epstein should be permitted to file
responses to the proposals made by the Government and Jane Doe 1 and 2.
Not more than two weeks later: The Government responds to Jane Doe 1 and 2 and to
Epstein.
Not more than two weeks later: The Jane Doe 1 and Jane Doe 2 reply to the responses
filed to the proposals.
Thereafter, the Court would hold oral argument on the issue, and provide an opportunity
for anyone affected by the issues to address the Court.
Thereafter, the Court would rule as soon as practicable.
IV.
PROMPT MEDIATION
In addition, Jane Doe 1 and 2 and the Government have discussed the possibility of a
mediation in this case. Once again, however, the parties have a different point of view as to how
best to proceed. As Jane Doe 1 and 2 understand the Government's position, it is proposing a
briefing schedule that could take months before holding a mediation. As the Court will recall, in
2016 Jane Doe 1 and 2 had joined with the Government in requesting a mediation, which this
Court ordered. DE 374. However, that mediation effort was unsuccessful but led to a delay.
Compare DE 374 (March 23, 2016 order directing mediation in the case and delaying
government response to Jane Doe 1 and 2' summary judgment motion) with DE 403 (June 2,
2017 response by the Government to Jane Doe 1 and 2's summary judgment motion).
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In Jane Doe 1 and 2's view, the mediation went nowhere because of the stage the case
was in at the time - with the Government taking the position that its handling of the case was
entirely proper. The posture of the case is much different now - the Court has ruled that Jane
Doe 1 and 2's rights have been violated and the focus is on providing them a remedy. Jane Doe
1 and 2 are willing to have a second mediation at Government expense to discuss resolving the
case, but they strongly believe that mediation is more likely to be successful if it takes place
against a backdrop of an on-going schedule leading quickly to a court-imposed solution if the
mediation fails. Consistent with their wish to rapidly resolve this case, Jane Doe 1 and 2 ask for
a court-ordered mediation, to be concluded no later than June 3, 2019. The Court should also
direct the Government to have available at the mediation participant(s) with full settlement
authority. Because any resolution could impact on the rights of Epstein, Jane Doe 1 and 2
propose that he should have a full opportunity to participate in the mediation process in a
separate room from any victim.
Consistent with the position outlined here, Jane Doe 1 and 2 attach for the Court's
consideration a proposed order implementing all these scheduling matters.
V.
IF THE COURT GRANTS THE GOVERNMENT'S REQUEST FOR
ADDITIONAL DELAY, IT SHOULD SIMULTANEOUSLY PERMIT JANE DOE
1 AND 2 TO TAKE LIMITED DISCOVERY RELEVANT TO REMEDIAL
ISSUES.
For the reasons just explained, Jane Doe 1 and 2 request that the Court should put this
case on a path toward expeditious resolution as just outlined. The Government will apparently
propose a different approach, including (as we understand it) months of additional delay for
meetings with additional (and unspecified) victims (or lawyers) other than Jane Doe 1 and Jane
14
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Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 15 of 22
Doe 2. If the Court decides to approve the Government's approach, Jane Doe 1 and 2 would
request two additions to the Government's proposal. First, Jane Doe 1 and 2's counsel should be
permitted to participate in any meetings with other victims. And second, to ensure that any
additional time required to bring this case to a conclusion is minimized, Jane Doe 1 and 2 should
be allowed to take six depositions of witnesses with directly relevant information concerning
remedial issues.
Turning to the first point, the Government appears to want to meet individually with
dozens of victims (apart from Jane Doe 1 and Jane Doe 2) over the coming months - even
though it has not previously met (or, so far we can tell, even communicated) with these persons
during more than ten years of litigation. The Government misunderstands the current posture of
this case. As noted above, the Government had previously objected when just two additional
victims - Jane Doe 3 and Jane Doe 4 - tried to join the case. Indeed, the Government was quite
specific in its position: "[T]his Court should decline to enlarge these proceedings to allow
additional claims and additional petitioners
"
DE 314 at 3-4 (emphasis added). The
Government went on to argue that Jane Doe 3 and 4 "have provided no satisfactory explanation
for the delay" in attempting to join the case in 2015. Id. at 8. Indeed, the Government argued
that adding even two additional victims into the case "would prejudice the Government since it
would inject new issues into this litigation." Id. at 11. The Government never gave even a hint
that it was willing to allow Jane Doe 3 and 4 (for example) to be heard at the remedy stage.
On the particular issue of expanding that case to include two additional victims, the Court
agreed with the Government's objection. In so ruling, the Court noted that the Government had
"vehemently" opposed joinder. See DE 324 at 2 (citing DE 290, 314). The Court then explained
15
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Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 16 of 22
that the merits of this case will be decided based on a "determination of whether the Government
violated the rights of Jane Doe 1, Jane Doe 2, and all 'other similarly situated victims' under the
CVRA. Jane Doe 3 and Jane Doe 4 may offer relevant, admissible, and non-cumulative evidence
that advances that determination, but their participation as listed parties is not necessary in that
regard." DE 324 at 9 (emphasis deleted) (quoting DE 189 at 1; DE 311 at 2, 12, 15, 18-19).
In quoting Jane Doe 1 and Jane Doe 2's pleadings about "similarly situated victims," the
Court was implicitly recognizing the parallels between this case and a class action lawsuit. In
light of this ruling, Jane Doe 1 and Jane Doe 2 can be viewed as the functional equivalent of
"class representatives" in a class action lawsuit. See Fed. R. Civ. P. 23(a)(4). And, further
developing the parallel to a class action lawsuit, Jane Doe 1 and 2's proposed schedule outlined
above allows for a court hearing, during which any individual member of the victims' class
would be able to provide their views to the Court as to how best to proceed - subject to a later
Court ruling - a much more rapid way of obtaining any necessary input than the delay proposed
by the Government. And Jane Doe 1 and 2 also have made clear that Epstein should have a
chance to raise any points he believes that the Court should consider - and have built that into
their proposed schedule.
If the Court determines to allow the Government to delay the case to have meetings with
multiple other persons who are not parties to this case, then Jane Doe 1 and Jane Doe 2 - as class
representatives - should at least be permitted to participate in those meetings through their legal
counsel. The Government, of course, has been litigating against Jane Doe 1 and 2 for more than
ten years. Indeed, the Government even threatened at one point to accuse all the victims of being
criminal participants in their own abuse. See DE 344 at 3-4 (citing Nov. 23, 2015 Tr. at 4-5). It
16
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Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 17 of 22
is Jane Doe 1 and Jane Doe 2 who have been fighting the Government to vindicate their rights as
Epstein's victims. It makes no sense for the Government to now be able to present its side of this
case in private meetings with victims without the class representatives being able to participate,
in order to frame the proceedings in a way that could be designed to prompt a certain
(presumably pro-Government) view from the other victims.
In addition, as a second point, if the Court approves the months of delay that the
Government proposes, the Court should at least make sure that time is used productively to put
the case in a position for rapid resolution thereafter. The Court can do this by allowing Jane Doe
1 and Jane Doe 2 to collect evidence that might be necessary at any contested hearing on remedy.
In particular, it appears that the Government may attempt to inject into any remedy hearing the
extent to which Epstein was involved in the CVRA violations. The Government has vaguely
alluded in its discussions with Jane Doe 1 and 2 to the possibility that if, for example, the NPA
immunity provisions were rescinded in any way, then Epstein might have the ability to challenge
certain settlement payments made to some of his victims. Whether Epstein would actually make
such a challenge and potentially expose himself to far greater civil liability seems highly unlikely
- and the Government does not appear to have made any effort to even ask him his position.
(Again, Jane Doe 1 and 2 believe Epstein should be given a full and fair opportunity to provide
his position on these issues.) But even more important, the Government has not disclosed to
Jane Doe 1 and 2 the Government's position on any such hypothetical challenge by Epstein -
much less the evidence within the Government's possession that could be used to respond to that
challenge.
17
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=== Page 18 ===
Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 18 of 22
As Jane Doe 1 and 2 have made clear for years, it is their position that "Epstein has
'forfeited' any right to seek specific performance of the non-prosecution agreement.
[H]e
was a party to - and, indeed, the instigator of - the Government's CVRA violations.
[H]ere
the illegal agreement was a deliberate plan. In such circumstances, any equitable claim Epstein
has for specific performance of the non-prosecution agreement disappears." DE 127 at 9 (citing
U.S. V. Walker, 98 F.3d 944, 947 (7th Cir. 1996) (defendant forfeited right to seek specific
performance of a plea agreement because the agreement was illegal)). Jane Doe 1 and 2 have
reiterated that position in discussions with the Government over the past several months. But the
Government has yet to share with Jane Doe 1 and 2 all of the information it possesses that
Epstein instigated the illegal decision not to notify them of the agreement - or even if it will join
Jane Doe 1 and 2's legal position.
Given the Government's failure to disclose all its information about Epstein's
involvement in the illegal agreement, Jane Doe 1 and 2 need depositions of key witnesses on this
subject. This Court has previously ruled that Jane Doe 1 and 2 could undertake "limited
discovery in the form of document requests and requests for admissions from the U.S. Attorney's
Office." DE 99 at 11. The Court also stated that "[e]ither party may request additional discovery
if necessary." Id.
If the Government will not announce what remedy it is prepared to provide, then
depositions are necessary. Depositions will shed important light on remedial issues beyond what
the available documentary evidence currently reveals. One example of a subject for a deposition
is a "breakfast meeting" that appears to have taken place on around October 12, 2007, between
U.S. Attorney Acosta and Epstein attorney Jay Lefkowitz. This Court has previously noted that
18
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=== Page 19 ===
Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 19 of 22
this meeting occurred. See Jane Does 1 and 2 V. U.S., 359 F.Supp.3d 1201, 1210 (S.D. Fla.
2019). And a subsequent letter from Lefkowitz to Acosta briefly refers to "a commitment" by
the U.S. Attorney at that meeting that his Office "would not
contact any of the identified
[victims]
in this matter." Id. But what was discussed specifically does not appear to have
been memorialized. A deposition will answer that and other related questions and will, Jane Doe
1 and 2 believe, establish that the Epstein was ultimately responsible for the decision not to
disclose the existence of the immunity provisions to them.
With the assistance of the Court, Jane Doe 1 and 2 were able to secure various emails and
letters between the Government and Epstein's attorneys. But the documents available to Jane
Doe 1 and 2 do not fully reveal what was agreed to among the lawyers for the United States,
Palm Beach County, and Epstein. Indeed, it appears that some of the key players decided not to
put in writing what was happening - as this Court has previously noted. See Jane Does 1 and 2
V. U.S., 359 F.Supp.3d 1201, 1207 (S.D. Fla. 2019) ("Palm Beach County State Attorney
wrote the line prosecutor about the proposed agreement and added: "Glad we could get
this worked out for reasons I won't put in writing. After this is resolved I would love to buy you
a cup at Starbucks and have a conversation." (emphasis added)).
Accordingly, if the Court grants the Government's request for delay, Jane Doe 1 and 2
request that during the months of delay, they be given leave to depose six witnesses - former
U.S. Attorney Acosta, who negotiated restrictions on what the victims could be told, during the
"breakfast meeting" and otherwise; Assistant U.S. Attorney
who implemented the
directions she was given by the U.S. Attorney; former Palm Beach County State Attorney Barry
,
who was involved in the plea discussions and was "glad" to work a deal out for reasons
19
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=== Page 20 ===
Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 20 of 22
he would not "put in writing"; Epstein Attorney Jay Lefkowitz, who was a key participant in the
"breakfast meeting" and was deeply involved in crafting the restrictions on what the victims
were to be told; and FBI Agents
who were responsible
for interacting with the U.S. Attorney's Office on the subject of victim notifications and provided
some of those notifications.
Jane Doe 1 and 2 can provide further information about why these six witnesses have
important information connected with the remedies that are available in this case. But the
Government has already agreed that this Court has this power to allow such discovery. See DE
99 at 11 ("the United States agreed that this Court, under its inherent authority to manage this
case, could impose discovery obligations on each party."). And in its July 20, 2015 initial
disclosures under Fed. R. Civ. P. 26(a)(1)(A)(1), the Government itself listed all these witnesses
as persons who possess information relevant to this case. Jane Doe 1 and 2 respectfully submit
that it would expedite a resolution of this case if they were permitted to take depositions during
any delay in a resolution proposed by the Government.
CONCLUSION
For all the reasons explained above, the Court should adopt Jane Doe 1 and 2's proposed
procedures and schedule for reaching a resolution on the appropriate remedy in this case.
DATED: May 10, 2019
3
Based on their current (limited) understanding of the Government's position on
remedies in this case, Jane Doe 1 and 2 believe that with six depositions, they could collect the
necessary evidence for a remedial hearing. They reserve the right to seek additional discovery if
the Government's position on remedy necessitates it.
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=== Page 21 ===
Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 21 of 22
Respectfully Submitted,
/s/ Bradley I. Edwards
Bradley J. Edwards
Edwards Pottinger LP
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Paul G. Cassell
Pro Hac Vice
S.J. Quinney College of Law at the
University of Utah
383 S. University St.
Salt Lake City, UT 84112
John Scarola
Searcy Denney Scarola Barnhart & Shipley
2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
Attorneys for Jane Does 1 and 2
*
This daytime business address is provided for identification and correspondence
purposes only and is not intended to imply institutional endorsement by the University of Utah.
21
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=== Page 22 ===
Case 9:08-cv-80736-KAM Document 452 Entered on FLSD Docket 05/10/2019 Page 22 of 22
CERTIFICATE OF SERVICE
I certify that the foregoing document was served on May 10, 2019, on counsel of record
using the Court's CM/ECF system:
U.S. Attorneys' Office for the Northern District of Georgia
600 U.S. Courthouse
75 Ted Turner Drive, S.W.
Atlanta, GA 30303
Attorneys for the Government
Roy Eric Black
Jacqueline Perczek
Black Srebnick Kornspan & Stumpf
201 S Biscayne Boulevard
Suite 1300
Miami, FL 33131
Attorneys for Jeffrey Epstein
/s/ Bradley I. Edwards
22
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=== Page 23 ===
Case 9:08-cv-80736-KAM Document 452-1 Entered on FLSD Docket 05/10/2019 Page 1 of 6
EXHIBIT
1
EFTA00027798

=== Page 24 ===
Case 9:08-cv-80736-KAM Document 452-1 Entered on FLSD Docket 05/10/2019 Page 2 of 6
PAUL G. CASSELL
Ronald N. Boyce Presidential Professor of Criminal Law
S.J. Quinney College of Law at the University of Utah
383 S. University St.
Salt Lake City, UT 84112
February 25, 2019
Ms. Ariana Fajardo Orshan
U.S. Attorney for the
Southern District of Florida
500 E. Broward Blvd.
Ft. Lauderdale, FL 33394
Re:
Protecting the Rights of Jeffrey Epstein's Victims
Dear Ms. Orshan:
We represent several victims of sex abuse and trafficking crimes committed by
Jeffrey Epstein, including Jane Doe 1, Jane Doe 2, Jane Doe 3, and Jane Doe 4. We write
to request that you make your best efforts to see that these victims are accorded their
rights under the Crime Victims' Rights Act (CVRA), 18 U.S.C. $ 3771. In particular, we
ask you to immediately rescind the provisions in the non-prosecution agreement
barring prosecution of Epstein and his co-conspirators and reopen the investigation. As
Judge Marra has clearly ruled, your Office entered into those particular provisions with
Epstein in 2007 illegally. We ask that you now extend to our clients - and all of
Epstein's victims - their right to confer about the reasons Epstein and his co-
conspirators should be federally prosecuted by your Office for the crimes he committed
against them.
You are no doubt generally familiar with the facts surrounding Epstein's
numerous federal sex crimes committed within your District, so we will just highlight a
few salient facts that were all recently found by U.S. District Judge Kenneth Marra in his
detailed opinion and order granting our clients summary judgment and finding that
your Office had violated the CVRA. Opinion and Order, Jane Does v. United States, No.
9:08-cv-80736 (Feb. 21, 2019) (hereinafter referred to as "Summary Judgment Order").
As Judge Marra explained, between about 1999 and 2007, "Jeffrey Epstein
sexually abused more than 30 minor girls, including Petitioners Jane Doe 1 and Jane
Doe
2
at his mansion in Palm Beach, Florida, and elsewhere in the United States and
* This daytime business address is provided for identification and correspondence purposes only and is not intended
to imply institutional endorsement by the University of Utah.
EFTA00027799

=== Page 25 ===
Case 9:08-cv-80736-KAM Document 452-1 Entered on FLSD Docket 05/10/2019 Page 3 of 6
overseas. Because Epstein and his co-conspirators knowingly traveled in interstate and
international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they
committed violations of not only Florida law, but also federal law." Id. at 1-2 (internal
citations omitted). To make a long story short, ultimately in 2007 your Office entered
into a non-prosecution agreement with Epstein, in which your Office agreed not to
prosecute him for federal sex abuse crimes committed against Jane Doe 1 and Jane Doe
2 and countless other underage girls whom Epstein and his co-conspirators victimized.
Id. at 7-10. This non-prosecution agreement was an illegal agreement, as your Office
entered into it by violating the CVRA:
Here, it is undisputed that the Government entered into a NPA
with Epstein without conferring with [Jane Doe 1 and Jane Doe 2] during
its negotiation and signing. Instead, the Government sent letters to the
victims requesting their "patience" with the investigation even after the
Government entered into the NPA. At a bare minimum, the CVRA
required the Government to inform Petitioners that it intended to enter
into an agreement not to prosecute Epstein. Although the binding effect of
the NPA was contingent upon Epstein pleading guilty to the state charges,
that contingency was out of the control of the Government. The
Government's hands were permanently tied if Epstein fulfilled his
obligations under the NPA. Thus, Petitioners and the other victims should
have been notified of the Government's intention to take that course of
action before it bound itself under the NPA. Had the Petitioners been
informed about the Government's intention to forego federal prosecution
of Epstein in deference to him pleading guilty to state charges, Petitioners
could have conferred with the attorney for the Government and provided
input. In re Dean, 527 F.3d 391, 394 (5th Cir. 2008) (there are rights under
the CVRA including the "reasonable right to confer with the attorney for
the Government"). Hence, the Government would have been able to
"ascertain the victims' views on the possible details of the [non-
prosecution agreement]." Id. Indeed, it is this type of communication
between prosecutors and victims that was intended by the passage of the
CVRA. See United States v. Heaton, 458 F. Supp. 2d 1271 (D. Utah
2006)(government motion to dismiss charge of using facility of interstate
commerce to entice minors to engage in unlawful sexual activity would
not be granted until government consulted with victim); United States v.
Ingrassia, No. CR-04-0455ADSJO, 2005 WL 2875220, at *17 n. 11 (E.D.N.Y.
Sept. 7, 2005) (Senate debate supports the view that the contemplated
mechanism for victims to obtain information on which to base their input
2
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=== Page 26 ===
Case 9:08-cv-80736-KAM Document 452-1 Entered on FLSD Docket 05/10/2019 Page 4 of 6
was conferral with the prosecutor concerning any critical stage or
disposition of the case).
Id. at 26-27.
Judge Marra also noted that your Office had "concealed" the NPA from the
victims and "misled" the victims about the possibility of a federal prosecution:
Particularly problematic was the Government's decision to conceal the
existence of the NPA and mislead the victims to believe that federal
prosecution was still a possibility. When the Government gives
information to victims, it cannot be misleading. While the Government
spent untold hours negotiating the terms and implications of the NPA
with Epstein's attorneys, scant information was shared with victims.
Instead, the victims were told to be "patient" while the investigation
proceeded.
Id. at 28.
In light of these and other illegal actions by your Office, Judge Marra specifically
held that "under the facts of this case, there was a violation of the victims' rights under
the CVRA." Id. at 33. He granted Jane Doe 1 and Jane Doe 2's motion for summary
judgement on the issue of whether your Office violated the CVRA, holding that their
"right to conferral under the CVRA was violated." Id.
Because of these clear and specific findings, your Office now has clear and
specific obligations under the CVRA. In particular, under 18 U.S.C. $ 3771(c)(1), all
"[o]fficers and employees of the Department of Justice
shall make their best efforts to
see that crime victims are notified of, and accorded, the rights described in [the
CVRA]." Your Office must follow this congressional command and "accord" Jane Doe
1 and Jane Doe 2 - along with Epstein's numerous other victims - their right to
reasonably confer with your Office concerning the need for federally prosecuting
Epstein and his co-conspirators for the numerous sexual trafficking crimes they
committed in your District.
Judge Marra has already directly ruled on how your Office must protect
Epstein's victims' rights. Judge Marra has held that the victims' "rights under the
CVRA attach before the Government brings formal charges against a defendant."
Summary Judgment Order at 26 (citing Does v. United States, 817 F. Supp. 2d 1337, 1341
3
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=== Page 27 ===
Case 9:08-cv-80736-KAM Document 452-1 Entered on FLSD Docket 05/10/2019 Page 5 of 6
(S.D. Fla. 2011)). Judge Marra has also held that "the CVRA authorizes the rescission or
"reopening" of a prosecutorial agreement, including a non-prosecution agreement,
reached in violation of a prosecutor's conferral obligations under the statute." Id.
(emphasis added) (quoting Does v. United States, 950 F. Supp. at 1267). Judge Marra has
further held that "section 3771(d)(5) of the CVRA authorizes the setting aside of pre-
charge prosecutorial agreements Id. (citing Does v. United States, 950 F. Supp. 2d at
1267). And, finally, Judge Marra has further held that "the 'reasonable right to confer
in the case' extends to the pre-charge state of criminal investigations and proceedings."
Id.
In view of these findings - binding on your Office as a party to the litigation -
your Office has a statutory duty to protect the CVRA rights of Jane Doe 1 and Jane Doe
2 through "rescission or reopening" of Epstein's non-prosecution agreement. We
request that your Office immediately take that step and notify all of Epstein's victims
that the provisions in the agreement blocking the federal prosecution of Epstein and his
co-conspirators have been rescinded and that the victims now have a right to confer
with your Office about federal prosecution of Epstein. You and the other prosecutors in
your Office have specific and personal obligations under the CVRA to make your "best
efforts" to accord the victims of their rights. Congress did not limit those obligations in
any way, and your Office must follow that congressional command.
In the past, we have met at various times with your predecessor and the capable
prosecutors handling this matter, trying to resolve these issues without the need for
further litigation. All those efforts have been for naught, because your Office
continually asserted the position that it had not violated the victims' CVRA rights.
Now that Judge Marra has directly rejected your Office's claim, we hope that your
Office will rapidly do the right thing and give the victims' the conferral and other rights
to which they are entitled.
We would be happy to meet with your Office further to discuss how protecting
victims' rights can be most effectively accomplished. In light of Judge Marra's order
that we are to confer with your Office regarding issues concerning remedies in this case
by March 8, the favor of a prompt reply is requested.
4
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=== Page 28 ===
Case 9:08-cv-80736-KAM Document 452-1 Entered on FLSD Docket 05/10/2019 Page 6 of 6
Thank you in advance for considering these requests.
Sincerely,
Parl
Bradley Crd J. Edwards
Paul G. Cassell
Jack Scarola
Counsel for Jane Doe 1, Jane Doe 2, Jane Doe 3, and Jane Doe 4
cc:
5
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=== Page 29 ===
Case 9:08-cv-80736-KAM Document 452-2 Entered on FLSD Docket 05/10/2019 Page 1 of 3
EXHIBIT
2
EFTA00027804.

=== Page 30 ===
Case 9:08-cv-80736-KAM Document 452-2 Entered on FLSD Docket 05/10/2019 Page 2 of 3
PAUL G. CASSELL
Ronald N. Boyce Presidential Professor of Criminal Law
S.J. Quinney College of Law at the University of Utah
383 S. University St.
Salt Lake City, UT 84112
March 4, 2019
Ms. Ariana Fajardo Orshan
U.S. Attorney for the
Southern District of Florida
500 E. Broward Blvd.
Ft. Lauderdale, FL 33394
Via email: Sarah.Schall@usdoj.gov
Re:
Protecting the Rights of Jeffrey Epstein's Victims
Dear Ms. Orshan:
As you know, we represent several victims of federal sex abuse and sex
trafficking crimes committed by Jeffrey Epstein, including Jane Doe 1, Jane Doe 2, Jane
Doe 3, and Jane Doe 4. On February 25, 2019, we wrote to request that you make your
best efforts to see that these victims are accorded their rights under the Crime Victims'
Rights Act (CVRA), 18 U.S.C. $ 3771 - specifically that your Office immediately rescind
the provisions in the non-prosecution agreement barring prosecution of Epstein and his
co-conspirators and reopen the investigation. We requested the favor of a prompt
reply. Judge Marra has directed that we confer to determine whether we can jointly
fashion a remedy for the violation of the victims' rights and, in any event, what
submissions and proceedings are needed to reach a final resolution of the remedy issue.
We have a right to confer under the CVRA. You have not yet responded.
We write - again and with increased urgency - to request that your Office
immediately work with us to implement the only efficacious remedy for the victims that
is available: rescinding the provisions in the non-prosecution agreement barring
Epstein's prosecution for federal sex crimes by your Office. As we explained in our
earlier letter, Judge Marra has already ruled that the law permits this remedy. Judge
Marra has specifically held that "the CVRA authorizes the rescission or "reopening" of a
prosecutorial agreement, including a non-prosecution agreement, reached in violation of a
prosecutor's conferral obligations under the statute." Opinion and Order at 26, Jane
Does v. United States, No. 9:08-cv-80736 (Feb. 21, 2019) (quoting Does v. United States, 950
F. Supp. at 1267). Judge Marra has further held that "section 3771(d)(5) of the CVRA
authorizes the setting aside of pre-charge prosecutorial agreements
Id. (citing Does
v. United States, 950 F. Supp. 2d at 1267).
* This daytime business address is provided for identification and correspondence purposes only and is not intended
to imply institutional endorsement by the University of Utah.
EFTA00027805

=== Page 31 ===
Case 9:08-cv-80736-KAM Document 452-2 Entered on FLSD Docket 05/10/2019 Page 3 of 3
You and the prosecutors in your Office have an obligation to afford our clients
their congressionally granted right to confer about whether to prosecute Epstein. See 18
U.S.C. $ 3771(c)(1). Through more than a decade of litigation, the U.S. Attorney's Office
for the Southern District of Florida and sexual assault victims have been litigating
whether the victims' rights were violated. That issue has been decided. The only issue
for your Office now is whether it wants to confer with victims about whether federal
prosecution of serial pedophile and major international sex trafficker is appropriate.
Congress has directed that prosecutors must confer with victims about important
prosecutive decisions. The path forward now is simple. We could work together to
draft a proposed court order that will quickly resolve this long-running litigation, by
declaring the provisions of the NPA barring Epstein's prosecution to be invalid and that
your Office will confer about whether to prosecute. We stand ready to discuss details in
the proposed order, including creating time for Epstein to raise any objections he might
have with the court.
If for any reason you are unwilling to agree with what we believe is the obvious
resolution of this unfortunate split between victims of federal sex crimes and
prosecutors with power to prosecute those crime, we would - again - like to quickly
confer about the matter. On behalf of our clients, we have a right to confer under 18
U.S.C. $ 3771(a)(5).
Time is of the essence. On Friday of this week, we must advise the judge
whether the victims and the prosecutors are united - or divided. The favor of quick
response is - again - requested.
Sincerely,
Bradley J. Edwards
Paul G. Cassell
Jack Scarola
Counsel for Jane Doe 1, Jane Doe 2, Jane Doe 3, and Jane Doe 4
cc:
2
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=== Page 32 ===
Case 9:08-cv-80736-KAM Document 452-3 Entered on FLSD Docket 05/10/2019 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 9:08-cv-80736-KAM
JANE DOE 1 AND JANE DOE 2,
Petitioners,
V.
UNITED STATES,
Respondent.
/
ORDER REGARDING SCHEDULING ON REMEDY ISSUES
This matter is before the Court pursuant to the Court's order directing the parties to
confer regarding how they propose proceeding on the determining what remedy, if any, should
be applied in view of the Court's finding that petitioners Jane Doe 1 and Jane Doe 2's right to
conferral was violated. DE 435 at 33. The parties have conferred, and each have submitted
proposed procedures for making that remedy determination.
The Court having carefully reviewed that parties' submissions, it is hereby ORDERED
AND ADJUGED that:
Not later than two weeks from the date of the Court's order, the Government shall file a
statement specifying how and when it proposes to remedy the violation of the rights of the two
victims (Jane Doe 1 and Jane Doe 2) who are parties to this litigation. If the Government
desires, it can also simultaneously but separately specify whether, when, and how it proposes to
remedy any CVRA violations that denied other victims their rights.
Not more than two weeks later, Jane Doe 1 and Jane Doe 2 shall file any objections and a
statement of what (if any) additional remedies they seek from the Court beyond what the
Government voluntarily proposes to provide.
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=== Page 33 ===
Case 9:08-cv-80736-KAM Document 452-3 Entered on FLSD Docket 05/10/2019 Page 2 of 2
Not more than two weeks later, Intervenor Jeffrey Epstein is permitted to file, if he so
chooses, any response to the proposals made by the Government and Jane Doe 1 and 2.
Not more than two weeks later, the Government shall respond to Jane Doe 1 and 2 and to
Epstein.
Not more than two weeks later, Jane Doe 1 and Jane Doe 2 shall reply to the responses
filed to the proposals.
Thereafter, the Court may either rule on the basis of the submitted papers or may hold
oral argument on the issue at a time it shall direct, at which it will provide an opportunity for
anyone affected by the issues to address the Court.
The Court also refers this matter to mediation for purposes of conducting a conference
with respect to the manner in which violations of the CVRA will be remedied. The mediation
shall be held no later than June 3, 2019. The mediation shall be held in Palm Beach County,
Florida, unless otherwise agreed by the parties and shall be conducted by a mediator chosen by
agreement of the parties. The parties shall have available at the conference participant(s) with
full settlement authority. Because Intervenor Jeffrey Epstein has intervened on the issue of
remedy, he shall also participate in the mediation with appropriate legal counsel, who shall
remain in a separate room from Jane Doe 1 and Jane Doe 2. The Government shall bear the
costs associated with the settlement conference.
DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County,
Florida, this
day of May, 2019.
KENNETH A. MARRA
United States District Judge
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=== Page 1 ===
From:
To:
Subject: RE: United States V. Ghislaine Maxwell --
opens
Date: Mon, 29 Nov 2021 01:56:25 +0000
Thanks,
and thanks for all the help over the last month!
From:
Sent: Sunday. November 28. 2021 4:14 PM
To
Subject: RE: United States V. Ghislaine Maxwell --
opens
This group certainly isn't scared. I know this has been a slog, but it's all really summed up below - there isn't a crime
much worse than this one, and it's hard to think of something more worthy of prosecution. Good luck tomorrow!!
From:
Sent: Sunday, November 28, 2021 9:59 AM
To:
Cc:
Subject: United States V. Ghislaine Maxwell
opens
There are prosecutors who would be afraid to charge a case that would require them to prove sex crimes that took place
in 1994. If you want to find them, you'll have to go to Florida. This is the Southern District of New York.
It is never too late for justice. Sometimes, you just have to have faith in the power of the truth and hope twelve jurors will
do the right thing. At this trial, brave women will take the witness stand and the truth will come out: Ghislaine Maxwell
sexually exploited underage girls. She caused unspeakable harm to vulnerable kids. It is time to hold her accountable.
will open in the morning. Please come support. Details below. Updates to follow.
Main courtroom: 40 Foley, courtroom 318
Overflow courtrooms: 110, 506, 905, and 906. There is also a conference room on the first floor (room 130) that has a
very small monitor with a live feed just for our office.
Timing: we'll start at 8:30 a.m. with peremptory challenges, and we expect to go straight to preliminary instructions and
opening statements. In order to get a seat, we'd recommend that you go over early.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
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=== Page 1 ===
From: Chris Dilorio
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
Date: Thu, 23 May 2019 19:36:09 +0000
Attachments: IMG_7021.jpg
Inline-Images: image.png
Well done Ms Strauss
https://www.justice.gov/usao-sdny/pr/bank-ceo-stephen-m-calk-charged-corruptly-soliciting-presidential-
administration
Bank CEO Stephen M. Calk Charged With Corruptly
Soliciting A Presidential Administration Position In
Exchange For Approving $16 Million In Loans I USAO-
SDNY | Department of Justice
Audrey Strauss, the Attorney for the United States, Acting Under Authority
Conferred by 28 U.S.C. § 515, William F. Sweeney Jr., the Assistant Director-in-
Charge of the New York Field Office of the Federal Bureau of Investigation
("FBI"), and Patricia Tarasca, the Special Agent-in-Charge of the New York
Region for the Federal Deposit Insurance Corporation Office of Inspector
www.justice.gov
but, this is where the story BEGINS
Lorber/Vector/Elliman
AND
Apollo
New Valley
pg 7
https://www.sec.gov/Archives/edgar/data/106374/000095014405003084/g93826e10vk.htm
https://www.barrons.com/articles/sec-charges-phillip-frost-1536608366
EFTA00029043

=== Page 2 ===
SEC Charges Against Phillip Frost Might Just
Be the Tip of the Iceberg
The U.S. Securities and Exchange Commission filed stock fraud
charges late last week against billionaire drug entrepreneur Phillip
Frost and a group of associates, accusing them of making $27
million in pump-and-dump stock schemes
www.barrons.com
The SEC has left Alpha Capital Liechtenstein up and running despite overwhelming evidence in my claims.
pls tell IRS CI Agents in Chicago
and
I say 'Hi'
Christopher Dilorio
From: Chris Dilorio
Sent: Thursday, May 23, 2019 5:59 AM
Subject: Fw: Apollo/ Epstein/Kushner connection
So:
Leon Black/ Apollo/Schwarzman: Trump Kushner
Black/Apollo/Schwarzman: Epstein
Black/Apollo/Schwarzman: Putin/RU
https://www.reuters.com/article/russia-putin-fund-idUSL5E7KG0SI20110916
UPDATE 2-Putin gets SWF, PE backing for
Russia fund
* Apollo's Black shares platform with Putin
www.reuters.com
EFTA00029044

=== Page 3 ===
https://www.swfinstitute.org/nevs/33645/u-s-treasury-sanctions-russian-direct-investment-fund/amp
Black/Apollo/Schwarzman: money laundering shells
https://www.businessinsider.com/blackstone-dodged-a-bullet-with-knight-capital-2012-8
Blackstone Dodged A Bullet With Knight
Capital - Business Insider
A trader consulted by Business Insider said that Blackstone envied
Knight Capital's market-making team, which executed an average
of more than $20 billion trades last year and is designated market
www.businessinsider.com
https://www.sec.gov/Archives/edgar/data/1082278/000092242313000183/0000922423-13-000183-index.htm
Knight/Trimark/Optimark born out of "worthless paper"/ Russian/US Mafia/ money laundering shell: Ashton
Technologies
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001003740&owner=exclude&count=40&hidefilings=0
https://ag.ny.gov/press-release/us-attorney-lynch-and-nys-attorney-general-spitzer-announce-20-defendants-
indicted-50
U.s. Attorney Lynch And N.y.s. Attorney General Spitzer Announce 20
Defendants Indicted In $50 Million Boiler Room Stock Fraud Scheme | New
York State Attorney General
LORETTA E. LYNCH, United States Attorney for the Eastern District of New York, ELIOT SPITZER, New York
State Attorney General, BARRY W. MAWN, Assistant Director-in-Charge of the Federal Bureau of
Investigation in New York, and RICHARD H. WALKER, Director of the Division of Enforcement of the
Securities and Exchange Commission, today announced the unsealing of an indictment charging 20
ag.ny.gov
Spitzer taken down by RUSSIAN hooker
https://nypost.com/2016/02/16/spizter-accuser-a-young-jobless-ex-hooker-who-lives-a-life-of-luxury/
EFTA00029045

=== Page 4 ===
Spitzer accuser was a $5K-a-night hooker
who lives life of luxury - New York Post
The Russian vixen who accused Eliot Spitzer of choking her at The
Plaza hotel is a divorced, globe-trotting beauty who once bared
all the dirty details of her life as a $5,000-a-night hooker, The
nypost.com
Any questions?
Cheers traitorous scumbags!
Christopher Dilorio
From: Chris Dilorio
Sent: Sunday, May 19, 2019 8:03 AM
Subject: Fw: Apollo/ Epstein/Kushner connection
I reiterate:
The SEC is a grossly corrupt criminal organization bought and paid for by criminals who threaten the integrity of
our markets to the clear and very egregious detriment of the investing public it is sworn to protect.
http://www.marketrap.com/article/view_article/9152/bernard-madoff-the-mafia-and-the-friends-of-michael-
milken
Bernard Madoff, the Mafia, and the Friends of Michael Milken - Market Rap
- The Investor Empowerment Community
In 2005, Patrick Byrne, the CEO of Overstock.com and future Deep Capture investigative reporter, began a
public crusade against illegal naked short selling (hedge funds and brokers creating phantom stock to
EFTA00029046

=== Page 5 ===
manipulate stock prices down). said, over and over, that the crime was destroying public companies and
had the notential to trigger a systemic meltdown of our financial markets
www.marketrap.com
Cheers!
Christopher Dilorio
From: Chris Dilorio
Sent: Friday, May 17, 2019 6:22 AM
To
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Wednesday, May 15, 2019 11:27 AM
Today (5/15/19) the grossly corrupt scumbags at the SEC approved ANOTHER massive fraud on the investing
public:
https://www.sec.gov/Archives/edgar/data/1665300/999999999519001111/xslEFFECTX01/primary_doc.xml
The "genius f'n quant" AQR/Greek shipping
/Economou/DRYS/ORIG/Astra/Nautilus/Navios/Gerber/AIPAC/Nordlicht/Glass/1MDB/Knitowski/Caneum/Trym
etris/Liquid etc etc etc money laundering shell.
Well done!
BTW, HOW is the George Economou/ Georgios EKONOMOU SEC "investigation" coming along anyway?
https://en.wikipedia.org/wiki/George_Economou_(shipbuilder)
George Economou (shipbuilder) - Wikipedia
George Economou or Georgios Ekonomou (Гешругос Olkovójiou, born 1953) is a Greek billionaire
shipowner, CEO of DryShips Inc. and Ocean Rig, and the owner of Cardiff Marine.Economou owns oil
EFTA00029047

=== Page 6 ===
tankers as well as dry bulk ships and manages them through Cardiff Marine. He was on the Forbes
Magazines list of the world's billionaires on place 707.
en.wikipedia.org
What a coincidence:
https://www.vanityfair.com/news/2018/03/andrew-ekonomou-donald-trump-legal-team/amp
Trump's Last Line of Defense Against Mueller
Is an Obscure Medieval Historian
Andrew Ekonomou had a "mid-life crisis" and became an expert
on Byzantium. Now he's helping lead the president's legal team in
the Russia investigation.
www.vanityfair.com
Dude is DEFINITELY not getting the attention he deserves
Then again,
WHO actually believes Marc Bistricer of Toronto Canada was INVESTING in the $$$ laundering Ekonomou
shell known as DryShips?
https://seekingalpha.com/article/4096781-strong-court-case-dryships-kalani
Very Strong Court Case Against DryShips And
Kalani - DryShips Inc. (NASDAQ:DRYS)
|
Seeking Alpha - Stock Market Insights
|
Seeking Alpha
Source: rgrdlaw.com (court document) In 2012, DRYS generated
$1.23 billion in total revenue, yet posted a $246 million loss. In
fact, the company has been posting losses every year for the last
seekingalpha.com
"Charity not the motive"
https://www.tradewindsnews.com/legal/1738610/kalani-claims-charity-not-a-motive-for-dryships-aid
Kalani claims charity not a motive for DryShips
aid | TradeWinds
Kalani claims charity not a motive for DryShips aid Marc Bistricer-
led investment house says it had risk and profit in mind lending
EFTA00029048

=== Page 7 ===
to George Economou's struggling public company, not attempt to
www.tradewindsnews.com
The Toronto connection runs MUCH deeper though
The overlap with AQR blank check shells and Polar Asset Mgmt Toronto
The Toronto based Bistricer and EKONOMOU
Bistricers in New Jersey TOO!
AND
DAVID Bistricer happens to be a real estate developer
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001649096&owner=exclude&count=40&hidefilings=0
1 Bistricer/Clipper "investor"
Toronto based C I Investments
https://www.sec.gov/Archives/edgar/data/1649096/000116364819000009/0001163648-19-000009-index.htm
Check out this Reg D offering Bistricer/ Clipper did in Jan 2016
https://www.sec.gov/Archives/edgar/data/1649096/000161577416004014/xslFormDX01/primary_doc.xml
$130,000 Reg D offering for this Bistricer/Clipper publicly traded "real estate" company was done with an
Atlanta based firm called H&L Equities
Atlanta is home of the obscure Trump Russia Counsel Andrew EKONOMOU
Nothing to see here.
Of Course, then there's the Hail Mary pass Kushner threw on his Toronto based Brookfield deal for 666 5th
Avenue
https://www.thestar.com/news/world/2019/03/12/toronto-based-brookfield-faces-scrutiny-from-democrats-
over-deal-with-kushner-company.html
Toronto-based Brookfield faces scrutiny from
Democrats over deal with Kushner company
I
The Star
The real estate giant says politics were not at all involved in its
decision to acquire a New York office tower from the family of
Jared Kushner, President Donald Trump's son-in-law and senior
aide.
www.thestar.com
which was brokered by Apollo/Epstein Degenerate Black/Harris/Rowan
https://therealdeal.com/2018/11/15/brookfield-turns-to-apollo-for-666-fifth-financing/
EFTA00029049

=== Page 8 ===
666 Fifth | Brookfield | Apollo Global
Management
Private equity company Apollo Global Management is funding
Brookfield Property Partners' redevelopment of 666 Fifth Avenue
with a $300 million-plus mezzanine loan, sources told The Real
Deal
therealdeal.com
Apollo and other Kushner financing pal Blackstone just happen to be BOTH granted free reign on the US
insurance/annuity industry.
Crazy shit huh?
Greek shipping Bag man Georgios Ekonomou meets Jared Kushner
But it gets better still:
Stephen Feinberg: Cerberus
https://www.bloomberg.com/news/articles/2018-05-11/trump-chooses-cerberus-sfeinberg-to-lead-spy
advisory-panel
Trump Chooses Cerberus's Stephen Feinberg
to Lead Spy Advisory Panel - Bloomberg
President Donald Trump has chosen billionaire investor Stephen
Feinberg to lead his intelligence advisory board, the White House
said Friday. Trump intends to appoint Feinberg, the co-founder
and
www.bloomberg.com
Bawag/Refco
Virtu first bid for Knight post "glitch"
and now: Money Laundering Bank HSH
Stephen Feinberg: Scum of the Earth meet Georgio EKONOMOU
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&ClK=0001369241&owner=exclude&count=40&hidefilings=0
Janey, IG update my various pending TCR's and complaints
Yours VERY TRULY
And INFINITELY smarter than anyone on this e mail list
Christopher J Dilorio
Whistleblower
EFTA00029050

=== Page 9 ===
From: Chris Dilorio
Sent: Monday, May 13, 2019 5:41 AM
To:
Subject: Fw: Apollo/ Epstein/Kushner connection
From: Chris Dilorio
Sent: Saturday, May 11, 2019 8:00 AM
To:
Subject: w.Apollo/ Epsten/kushner conmection
From: Chris Dilorio
Sent: Monday, May 6, 2019 6:38 AM
Subject: Fw: Apollo/ Epstein/Kushner connection
Greetings grossly corrupt SEC et al scumbags
As with ALL of my allegations: beyond a shadow of a doubt, 100% accurate
https://www.sec.gov/litigation/complaints/comp17673.htm
Complaint: SEC V.
COMPLAINT. Plaintiff United States Securities and Exchange Commission ("Commission") alleges as
follows: SUMMARY. 1. This case involves a $15 million "pump and dump" scheme involving the securities
EFTA00029051

=== Page 10 ===
of Environmental Solutions Worldwide, Inc. ("Environmental"), a public company whose common stock is
registered with the Commission under the Securities Exchange Act of 1934 ("Exchange Act"), and is
www.sec.gov
ESWW was a money laundering shell.
The SEC knows it. The degenerate Epstein knows it. The Degenerate Leon Black/Kushner BFF/ Milken
proteges/Marc Rowan/Apollo knows it.
The DOJ/IRS knows it.
IG, I have repeatedly offered to come to SEC DC HQ to have the brightest minds at the SEC totally humiliate me
by refuting my allegations 1 by 1. The grossly corrupt SEC scumbags have never taken me up on my generous
offer. For the very simple reason that ALL of my allegations are accurate and true.
So, I again put the offer out there:
refute my claims OR go to jail for the criminal obstruction ACTIVELY being facilitated by your office and the SEC.
So, let's give these scumbags the insurance/annuities market.
This will NOT end well for tens of thousands of Americans.
Who "green lighted" this take over of the insurance industry by PE/Hedge funds?
https://www.forbes.com/sites/antoinegara/2018/02/01/apollo-and-blackstone-pick-insurance-as-their-next-
bet-to-disrupt-wall-street/#5d647dbe7689
Apollo And Blackstone Pick Insurance As Their
Next Bet To Disrupt Wall Street - Forbes
For decades, Wall Street's gambit in insurance was to write
policies and use the float as a source of capital for new
investments. It's a staple of Berkshire Hathaway and copycats like
Markel and
www.forbes.com
Cheers!
Christopher Dilorio
Whistleblower
From: Chris Dilorio
Sent: Thursday, May 2, 2019 3:35 PM
EFTA00029052

=== Page 11 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
IG,
This was a blatant attempt to intimidate a whistleblower. "HE" (I think a male although very effeminate voice)
was an anonymous, coward, scumbag who threatened me. AND then called me another 11/12 times after that.
This is a VERY serious matter. Felony. I intend to see "him" prosecuted to the fullest extent of the law. Within
weeks of filing a complaint against the SEC and you.
I obviously have hit a nerve.
https://www.nbcnews.com/politics/white-house/white-house-tels-official-who-gave-kushner-security-
clearance-don-n997476
White House whistleblower speaks out on
security clearance controversy
Carl Kline was supposed to appear before House committee staff
Tuesday to face questions related to his handling of White House
security clearances.
www.nbcnews.com
Cheers!
Christopher Dijorio (no L's scumbag)
From: Chris Dilorio
Sent: Thursday, April 25, 2019 6:27 AM
EFTA00029053

=== Page 12 ===
Subject: Fw: Apollo/ Epstein/Kushner connection
ESWW: A money laundering NASDAQ/OTCM shell
Milken degenerate Leon Black/Joshua Harris: Apollo
AND
Jeffrey Epstein
The SEC has known for years that Epstein is running a extortion/Ponzi/Slush Fund
My Claims AGAIN
https://seekingalpha.com/article/3715526-environmental-solutions-worldwide-revisiting-holding-gone-dark-
can-sleep-better-night?mod=mw_quote_news
Environmental Solutions Worldwide: Revisiting
A Holding That's Gone Dark, So I Can Sleep
Better At Night - Environmental Solutions
Worldwide, Inc. (OTCMKTS:ESWW) | Seeking
Alpha - Stock Market Insights | Seeking Alpha
New CEO and recent trading activity warranted a review of a
holding that no longer files. Based on the environment, difficult
y/y comparisons and results from competitors, 2015 is likely a
down year.
seekingalpha.com
"Not credible"???
How about the SEC's OWN words?
https://www.bloomberg.com/news/articles/2018-10-01/sec-spots-a-way-to-starve-the-most-suspicious-penny-
stocks
EFTA00029054

=== Page 13 ===
SEC Spots a Way to Starve the Most
Suspicious Penny Stocks - Bloomberg
"If a company is a dark company and listed in the OTC market
and hasn't put out financials for six months, maybe it shouldn't
be quoted or offered to retail investors," Redfearn said
www.bloomberg.com
See my comment letters on this subject.
The SEC INTENTIONALLY puts the investing public at risk of frauds like this and thousands others like it.
The core biz at NITE/VIRT,CDEL etc and the reason WHY the OTCM exists: Abusive naked shorting publicly
traded shells to facilitate money laundering.
Shells go dark only AFTER a massive fraud has been perpetrated on the investing public: Main Street
ANOTHER "genius" degenerate: Apollo
the grossly corrupt SEC: Bought and paid for by common criminals and degenerates
IG, I have time for that REQUIRED 3rd party cc today
Call me
Cheers!
Christopher Dilorio
From: Chris Dilorio <0
Sent: Sunday, April 14, 2019 1:04 PM
Subject: Fw: Apollo/ Epstein/Kushner connection
A little Steffie Avakian//Heiss/O'Melveny/Wilmer Hale/ Apollo/Kushner Home Cooking!
https://www.omm.com/professionals/howard-e-heiss/
EFTA00029055

=== Page 14 ===
Howard E. Heiss - O'Melveny & Myers
Howard Heiss has an extensive litigation practice focused on
government regulatory investigations and enforcement actions,
grand-jury investigations, and the defense of clients in criminal
cases, with a particular emphasis on securities matters.
www.omm.com
https://www.sec.gov/Archives/edgar/data/1411494/000119312508077312/ds1.htm
Form S-1 - SEC.gov
Table of Contents. The information in this prospectus is not complete and may be changed. The securities
may not be sold until the registration statement filed with the Securities and Exchange Commission is
effective.
www.sec.gov
https://www.wilmerhale.com/en/people/jamie-gorelick
Jamie Gorelick | WilmerHale
Jamie Gorelick's career has spanned the legal, policy and corporate landscapes. As one of Washington's
best-known litigators, Ms. Gorelick has represented corporations and individuals in a wide array of matters,
particularly in the regulatory and enforcement arenas, involving issues as diverse as antitrust,
environmental regulation, securities enforcement, national security regulation, etc.
www.wilmerhale.com
https://www.wilmerhale.com/en/insights/news/former-director-of-the-fbi-robert-mueller-i-joins-wilmerhale.
Former Director of the FBI Robert Mueller III
Joins WilmerHale
WilmerHale is pleased to announce that Robert S. Mueller III is
joining the firm as a partner after serving as the sixth Director of
the Federal Bureau of Investigation (FBI), a position he took one
week prior to the September 11 attacks and held for 12 years
under two presidents.
www.wilmerhale.com
https://www.sec.gov/biography/avakian-stephanie
EFTA00029056

=== Page 15 ===
SEC.gov | Stephanie Avakian
Stephanie Avakian was named Co-Director of the U.S. Securities and Exchange Commission's Division of
Enforcement in June 2017, after serving as Acting Director since December 2016.
www.sec.gov
SEC drops Apollo investigation after Kush Jr met with Harris at the WH
and Apollo gives Kush's some $$$$
And, Apollo gets $60 bil+ in inflows in 2018
Did I miss something?
Cheers!
You corrupt fucking scumbags
Christopher Dilorio
From: Chris Dilorio
Sent: Saturday, April 13, 2019 11:30 AM
Subject: Apollo/ Epstein/Kushner connection
Find a shell
Find a fraud
Enviromental Solutions Worldwide Inc
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001082278&owner=exclude&count=40&hidefilings=0
Florida?
Pennsylvania?
or
Canada?
EFTA00029057

=== Page 16 ===
Welcomed on Cromwell/Wimpfheimer OTCM
De registered in 2015 and Frozen in time
Literally
http://eswgroup.com/esw-group-corporate/our-board/
Our Board - ESW Group®
MARK YUNG Mr. Yung is Co-Founder and Managing Principal of
OCV Management, LLC ("OCV"), an investor, owner and operator
of technology and life science companies based in Los Angeles.
Previously, Mr. Yung was a Managing Director at Orchard Capital
Corp., a firm he joined in 2006. Through his affiliation with [...]
eswgroup.com
Dozens of filings by former Milken (ahem) right hand man Leon Black, Apollo, his family Trust, et al
Then,
There's this:
Has anyone (anyone) ever seen Pedophile Jeffrey Epstein on the other side of a trade?
The ONLY SEC filing of Epsteins' Financial Trust Company Inc is in
wait for it
Leon Black/Apollo Environmental Solutions Worldwide
https://www.sec.gov/Archives/edgar/data/1082278/000090901211000390/0000909012-11-000390-index.htm
Enter the Amicus blocking release of Epstein docs
Krieger, Kim and Lewin
https://www.kkllp.com/
Krieger Kim & Lewin LLP
We are committed to providing the highest level of partner-driven representation in order to efficiently
achieve client objectives. Over the last decade, we have conducted and supervised dozens of federal
criminal trials involving some of the highest profile and most sensitive matters prosecuted by the United
States Government.
www.kklllp.com
Financial fraud appears to be a specialty of this recently formed/SDNY Alum firm
Now,
it gets VERY interesting
https://www.cnbc.com/2018/02/28/apollo-citigroup-loaned-kushner-companies-millions-new-york-times.html
EFTA00029058

=== Page 17 ===
Trump: Kushner's security clearance is up to
Kelly
Kushner even discussed the possibility of a White House job for
the founder of private equity firm Apollo, the New York Times
reported on Tuesday.
www.cnbc.com
Where another Milken protégé/Apollo founding partner Josh Harris was considered for a White House job
"Coindences"
https://nypost.com/2018/03/02/sec-dropped-probe-month-after-firm-aided-kushner-company/
SEC dropped probe month after firm aided
Kushner company
The feds last year dropped an investigation into a financial
company a month after the firm gave Jared Kushner's family real
estate business a $180 million loan, a new report said Friday.
There
---
nypost.com
Oh, baby
$60 billion+ inflows in 2018 for Apollo
https://www.businesswire.com/news/home/20180802005343/en/Apollo-Global-Management-LLC-Reports
Quarter-2018
Apollo Global Management, LLC Reports
Second Quarter 2018 Results I Business Wire
NEW YORK--(BUSINESS WIRE)--Apollo Global Management, LLC
(NYSE:APO) (together with its consolidated subsidiaries, "Apollo")
today reported results for the second quarter ended June 30,
2018.
www.businesswire.com
Mr's Krieger,Kim,Boltz et al:
Discovery will be a hoot!
EFTA00029059

=== Page 18 ===
Fucking A
I am good
Cheers!
Christopher Dilorio
EFTA00029060


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=== Page 1 ===
From
To
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:57:31 +0000
Attachments: U.S._v_Ghislaine_Maxwell_Indictment.pdf; Ghislaine_Maxwell_Indictment_PR.pdf
Inline-Images: image001.png
Congratulations!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI ORO DOMINA JUSTITIA OF JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
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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.
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
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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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Case 1:20-cr-00330-AJN Document 282 Filed 05/14/21 Page 1 of 2
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT
DOC #:
SOUTHERN DISTRICT OF NEW YORK
DATE FILED: 5/14/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
On April 29, 2021, counsel for Ghislaine Maxwell wrote to the Court requesting that the
Court address her sleeping conditions, with particular emphasis on counsel's representation,
unsupported by affidavit or other factual showing, that guards are shining a flashlight in
Maxwell's eyes every 15 minutes at night. Dkt. No. 256. Defense counsel claims that the
flashlight surveillance in Maxwell's eyes is disrupting her sleep, which in turn is impacting her
ability to prepare for and withstand trial. The Court sought more information by ordering the
Government to confer with legal counsel for the Bureau of Prisons and to respond to certain
questions. Dkt. No. 257. In response, the Government states that MDC staff conduct flashlight
checks of all inmates as a matter of course. Dkt. No. 270. As reported by the Government,
inmates housed with cell mates in the Special Housing Unit are checked with flashlights every
30 minutes. Inmates housed with others in the general population are checked multiple times per
night at regular intervals. The Government further reports that to conduct the checks, flashlights
are pointed at the ceiling of the cell to confirm that the inmate is present, breathing, and not in
distress. As the Government explains, there are a number of neutral reasons why BOP's
flashlight checks of Maxwell are relatively more frequent than those of other inmates, including
that Maxwell is housed alone, the nature of the charges, and the potential stress for inmates that
1
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Case 1:20-cr-00330-AJN Document 282 Filed 05/14/21 Page 2 of 2
can arise in high-profile cases. The MDC has determined that these factors necessitate more
frequent safety and security checks. The Government also indicates that the prohibition on eye
masks is a generally applicable policy, but that Maxwell, like other inmates, may use other non-
contraband items to cover her eyes.
To the extent that Maxwell's April 29, 2021 letter asks the Court to override BOP's
determination as to the frequency of appropriate safety and security check procedures, that
request is denied as factually unsubstantiated and legally unsupported. Certainly nothing in the
record plausibly establishes that current protocols interfere with Maxwell's ability to prepare for
her trial and communicate with her lawyers. Defense counsel's May 7, 2021 letter, Dkt. No.
272, describes generalized grievances but makes no additional specific and supported application
for relief. Nevertheless, the Court urges the MDC to consider whether sleep disruption for pre-
trial detainees can be reduced. The Court also admonishes the MDC and the Government to
continue to ensure that Maxwell is subjected to only those security protocols that BOP
determines are necessary for her safety and security, based upon neutral and applicable factors,
and consistent with the treatment of similarly situated pre-trial detainees.
The Government shall provide a copy of this Order to the Warden and General Counsel
for the MDC.
so ORDERED.
Alin D.Nitto
Dated: May 14, 2021
New York, New York
ALISON J. NATHAN
United States District Judge
2
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=== Page 1 ===
From:
To:
Subject: RE: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
Date: Thu, 17 Sep 2020 22:57:49 +0000
Thank you!
From:
Sent: Thursday, September 17, 2020 12:35 PM
To:
Subject: RE: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB
This has been downloaded and saved to the shared.
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:
JSvEpstein-
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
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein - Additional Requests/ Interviews
Date: Tue, 13 Aug 2019 15:30:07 +0000
I will work on getting physical descriptions of
I spoke to
at MCC, all but
have union representation.
If
is available to talk with us today, is there a time, location, ect. That works best?
U.S. Department of Justice
Office of the Inspector General
New York Field Office
New York, NY 10004
From:
Sent: Tuesday, August 13, 2019 10:38 AM
To
Cc:
Subject: Epstein - Additional Requests/ Interviews
We just spoke with OCME, and they would like (i) the responding ambulance reports; and (ii) physical descriptions (height
and weight) for
Could you please get us this information?
Second, below are the people that we would like to set up voluntary interviews with in the next few days.
can you
please reach out to
to set these up:
Name
Position
Shift
OPS Lt.
8/10 from 12-8
Internal
8/10 from 12-8
Internal
8/9 from 4-12
Internal
8/9 from 4-12
Control
8/10 from 12-8
Control
8/9 from 4-12
Control
8/9 from 2-10
Thanks,
Assistant United States Attorney
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=== Page 2 ===
Southern District of New York
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=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein victim requests
Date: Mon, 16 Nov 2020 23:54:01 +0000
Hi
Thanks, that looks right to us. Our team isn't sure how to respond to these requests, and now that we have
slightly more bandwidth than we did last month, we were hoping to discuss how to approach this. A call with
would probably be helpful to sort out how we should proceed here-- I'll send an email
momentarily to schedule a call.
Thanks very much,
Original Message
From:
Sent: Tuesday, November 3, 2020 4:03 PM
To:
Cc:
Subject: RE: Epstein victim requests
Hi
Per our call, please find attached the requests from
including names in footnotes, as well as the Masseuse
list document that I was looking at. I'm probably missing something, but I don't see the names on the list (with
the exception of
but the last name on the list doesn't match the requester's or is not included).
Thanks,
Original Message
From:
Sent: Tuesday, November 3, 2020 2:26 PM
To:
Cc:
Subject: Epstein victim requests
Hi
Do you have time this afternoon for a brief call? I'm
if you have a moment.
Thanks!
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=== Page 2 ===
Sent from my iPhone
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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
Subject: Fwd: Update: Jeffrey Epstein Estate/Southern Country International Bank/USVI
Date: Wed, 01 Apr 2020 17:10:26 +0000
Inline-Images: image001.jpg; image001(1).jpg
I don't know why this guy continues to email Geoff! Can you see if you can redirect that?
Begin forwarded message:
From:
(USAVI)"
Date: April 1, 2020 at 1:07:30 PM EDT
To: "Berman, Geoffrey (USANYS)"
Cc:
(USAVI)"
(USANYS)"
Subject: RE: Update: Jeffrey Epstein Estate/Southern Country International Bank/USVI
Mr. Berman,
I hope that you and your office are staying safe in these strange days.
I wanted to let you know that our office is moving forward with the investigation referenced below, and in particular I
wanted to make you aware that we expect the grand jury to issue subpoenas for Epstein's jail calls and related custodial
materials.
Thank you and please contact me if you have any questions. - Nate
Assistant United States Attorney
District of the Virgin Islands
5500 Veterans Drive, Suite 260
From:
(USAVI)
Sent: Friday, March 13, 2020 10:06 AM
To: Berman, Geoffrey (USANYS)
Subject: RE: Update: Jeffrey Epstein Estate/Southern Country International Bank/USVI
Mr. Berman,
EFTA00028346

=== Page 2 ===
Hope you are well. As referenced below, I'm working with investigators on this matter. I would love to speak with
someone in your office so that they can be aware of what we are looking at, and vice versa. Would you mind letting me
know who in SDNY I should contact? Thank you so much,
Assistant United States Attorney
District of the Virgin Islands
5500 Veterans Drive, Suite 260
From:
(USAVI)
Sent: Thursday, March 05, 2020 6:35 AM
To: Berman, Geoffrey (USANYS)
Cc:
(USANYS)
Subject: RE: Jeffrey Epstein Estate/Southern Country International Bank/USVI
Thanks so much, Geoff.
By all means, let's coordinate here. Your unit chiefs should contact the VI-USAO Senior Litigation Counsel,
Best wishes,
From: Berman, Geoffrey (USANYS)
Sent: Wednesday, March 04, 2020 11:04 AM
To:
(USAVI)
Cc:
(USANYS)
Subject: Re: Jeffrey Epstein Estate/Southern Country International Bank/USVI
thanks for the heads up. We are looking into aspects of the estate. I would like to put our unit chiefs in
contact with someone in your office in charge of the matter to coordinate. Who would you suggest? Best, Geoff
On Mar 3, 2020, at 11:15 AM,
(USAVI)
wrote:
Good afternoon and greetings from the USVI:
We are opening an investigation of the Jeffrey Epstein estate and Southern Country International Bank in the
USVI. The investigation will be worked by FBI and IRS-CI. I wanted to reach out to you, in order to make
certain that we are not interfering with any ongoing investigation that your office may have.
EFTA00028347

=== Page 3 ===
I am happy to discuss.
Best wishes,
U.S. Attorney for the Virgin Islands
Office of the U.S. Attorney
Ron De Lugo Federal Building
5500 Veterans Drive, Suite 260
Charlotte Amalie,
-6214
340-774-5757 (front desk)
https://www.justice.gov/usao-vi
<image001.jpg>
PRINTENT
EFTA00028348


