# docs_fts_content

c1: EFTA00014916
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014916.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Re: Ghislaine Maxwell custody
Date: Fri, 03 Jul 2020 18:14:21 +0000
On Jul 3, 2020, at 2:01 PM,
wrote:
Yes
Sent from my iPhone
On Jul 3, 2020, at 1:01 PM,
wrote:
Thanks! Am I correct that this means Maxwell will be able to call both Chris and Mark today?
(And please tell
hi back!)
On Jul 3, 2020, at 12:47 PM,
wrote:
Done.
P.S.
says hi!
From:
Sent: Friday, July 3, 2020 12:42 PM
To:
Subject: RE: Ghislaine Maxwell custody
Terrific, thanks very much.
Both attorneys are partners at Cohen & Gresser LLP.
Chris Everdell's number is
Mark Cohen's number
Thanks again,
EFTA00014916

=== Page 2 ===
From:
Sent: Friday, July 3, 2020 11:39 AM
To:
Subject: RE: Ghislaine Maxwell custody
is on it. Can I please have name of law firm and best contact number for each lawyer?
Thanks.
From:
Sent: Friday, July 3, 2020 11:32 AM
To:
Subject: RE: Ghislaine Maxwell custody
Appreciate it, thank you.
From:
Sent: Friday, July 3, 2020 11:21 AM
To:
Subject: Re: Ghislaine Maxwell custody
I will call
and advise - he can be a little touchy.
Sent from my iPhone
On Jul 3, 2020, at 11:13 AM,
wrote:
Thanks. I think it's fine to speak with
about it, but my sense is that we would also need USMS approval,
based on the email from
If you think it would be ok, I'm happy to reach out to
directly to discuss.
From:
Sent: Friday, July 3, 2020 11:05 AM
To:
Subject: Re: Ghislaine Maxwell custody
I will try. Can I start with
he may be in the best position to get it done?
J
Sent from my iPhone
On Jul 3, 2020, at 10:23 AM,
wrote:
Thanks very much for passing this along. The permitted attorney contact on the list below only includes
Vogelman without reference to her New York counsel. Would it be possible to add her two New York attorneys-
Chris Everdell and Mark Cohen-to the list of people Maxwell can speak with on the phone, please?
EFTA00014917

=== Page 3 ===
Ideally, we would like to get them added today so that they can speak with their client over the weekend to
facilitate our discussions with them about next steps in the case.
Thanks,
From:
Sent: Thursday, July 2, 2020 3:47 PM
To:
Subject: Fwd: Ghislaine Maxwell custody
FYI
Sent from my iPhone
Begin forwarded message:
From:
Date: July 2, 2020 at 3:43:43 PM EDT
To: "NHD-SUPERVISORS (USMS)"
Cc:
Subject: Ghislaine Maxwell custody
To all:
Below are the restrictions we have put in place regarding Ms. Maxwell during her stay at Merrimack DOC. I. If
you have any questions please feel free to call or email me.
Due to the high profile status of this case Inmate Maxwell will be closely monitored. The following
directives apply and shall not be deviated from without express permission from
, myself or
1.
Inmate Maxwell will be housed in M1
2.
SRT personnel will be posted in medical and will only be relieved only by SRT personnel
3.
Staff will not converse with the inmate outside of the standard communication required related to
the inmate's health and safety
4.
Inmate Maxwell will remain on a 15 minute observation watch
5.
All rounds, and touch probe rounds will be conducted and documented in XJail
6.
Third Shift Supervisors will download the touch probe rounds and camera footage from the
previous day at 0000 hours each day. The video from the medical cell DVR will be downloaded onto a
USB drive and will be tracked via the designated tracking form provided. Supervisors are directed to
deliver this documentation and video to
Monday July 6th
7.
Inmate Maxwell will be authorized to communicate with her legal counsel, Lawrence Vogelman.
This contact is only authorized after Atty Vogelman provides the appropriate PIN
EFTA00014918

=== Page 4 ===
8.
Any and all requests from Inmate Maxwell are to be directed to
only
At no time are staff authorized to make statements to the press regarding this matter or our SOP
regarding this inmate.
Supervisory Deputy United States Marshal
District of New Hampshire
Concord, New Hampshire
office
This e-mail is property of U.S. Marshals Service. It is intended only for the person or entity to which it is
addressed and may contain information that is privileged, confidential, or otherwise protected from disclosure.
Distribution or copying of this e-mail or the information contained herein by anyone other than the intended
recipient is prohibited. If you have received this e-mail in error, please notify me immediately and destroy all
electronic and paper copies of this e-mail.
EFTA00014919


c1: EFTA00014564
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014564.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: Michael Bachner
Cc:
)"
Subject: Re: Epstein investigation
/
Date: Mon, 15 Jul 2019 23:57:28 +0000
Importance: Normal
That works. See you then. Thanks,
On Jul 15, 2019, at 7:53 PM, Michael Bachner
wrote:
Hi. Perfect. 2:00?
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is not
the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-mail
and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax
advice.
On Jul 15, 2019, at 7:29 PM,
)
wrote:
Hi Michael,
How about Thursday afternoon?
Thanks,
Assistant United States Attorney
EFTA00014564

=== Page 2 ===
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Michael Bachner
Sent: Monday, July 15, 2019 7:20 PM
To:
Cc:
is
Subject: Re: Epstein investigation
Any updates on dates?
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is
not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you
are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-mail
and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax
advice.
On Jul 15, 2019, at 2:28 PM, Michael Bachner
wrote:
was just notified that a client was arrested and is being arraigned in Queens County tomorrow on
a state RICO charge at about 11 or 1130. I'm concerned that the 330 may be cutting it close. It may be better
to do it at four or on Wednesday. Please advise
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
EFTA00014565

=== Page 3 ===
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or
confidential information, which is intended only for use of recipient. If the reader of this communication is
not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you
are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-
mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or
tax advice.
On Jul 15, 2019, at 1:55 PM,
)
wrote:
Thanks very much. Let's plan for tomorrow at 3:30pm. You and
can come to our office at 1 St.
Andrews and just give security my name.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Original Message
From: Michael Bachner
Sent: Monday, July 15, 2019 1:42 PM
To:
Cc:
)
Subject: RE: Epstein investigation
Hi
Tomorrow or Wednesday at 11 or 3:30. Thursday any time after 11:30 to 4.
https://www.actl.com/
Michael Bachner, Esq.
Bachner & Associates, PC
EFTA00014566

=== Page 4 ===
39 Broadway, Suite 1610
New York, NY 10006
www.bhlawfirm.com
CONFIDENTIAL NOTICE: This E-mail (including any attachments) is covered by the Electronic
Communications Privacy Act, 18 USC Sections 2510-2521, is confidential, and may be legally privileged.
If you are not the intended recipient, you are hereby notified that any retention, dissemination, distribution,
or copying of this communication is strictly prohibited. Please reply to the sender that you have received
the message in error and then delete it. Thank you.
Original Message
From:
)
[mailto:
Sent: Monday, July 15, 2019 12:50 PM
To: Michael Bachner
Cc:
)
;
)
Subject: Re: Epstein investigation
Hi Michael,
Apologies for the delay. Would you please let us know what times would work for you and
in
the next two or three days? We'll then figure out a time when we can all meet.
Thank you,
On Jul 11, 2019, at 10:43 PM, Michael Bachner
wrote:
Hello
6 'clock is somewhat late. The client lives in
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
[X]
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential
information, which is intended only for use of recipient. If the reader of this communication is not the
intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-
EFTA00014567

=== Page 5 ===
mail and delete this email from your system. Nothing in this email should be construed as a legal opinion
or tax advice.
On Jul 11, 2019, at 9:01 PM,
)
<mailto:
wrote:
Michael,
Would 7/16 at around 6pm work for the reverse proffer in our office at 1 St. Andrews?
Thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
mailto:
From: Michael Bachner
Sent: Thursday, July 11, 2019 12:26 PM
To:
<mailto:
Cc:
<mailto:
Subject: Re: Epstein investigation
Regarding the reverse proffer, We are available next week from the 15-18. I have a 2 o'clock meeting in
my office on the 16th and 17th that should last an hour. So I can meet with you on those days at 11 or 1030
in the morning if that works. Please let me know
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential
information, which is intended only for use of recipient. If the reader of this communication is not the
intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
EFTA00014568

=== Page 6 ===
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-
mail and delete this email from your system. Nothing in this email should be construed as a legal opinion
or tax advice.
On Jul 10, 2019, at 11:20 AM, Michael Bachner
wrote:
Sure.
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD000.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential
information, which is intended only for use of recipient. If the reader of this communication is not the
intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-
mail and delete this email from your system. Nothing in this email should be construed as a legal opinion
or tax advice.
On Jul 10, 2019, at 11:08 AM,
)
<mailto:
wrote:
Mike,
I think it would be useful to get a better understanding of your position-it would be helpful for us to
know, for example, how much time you propose to take to evaluate matters, and whether we can provide
any additional information that might be useful for that process of evaluation. That likely will affect our
determination regarding the grand jury appearance, at which we would expect, were we to call
to ask her a number of questions we would expect to argue to the court do not implicate a fifth amendment
privilege-i.e., that she couldn't simply blanket invoke. Would it be useful to discuss via phone?
thanks,
From: Michael Bachner
Sent: Wednesday, July 10, 2019 10:25
To:
<mailto:
Cc:
<mailto:
<mailto:
Subject: Re: Epstein investigation
Dear Counsel:
EFTA00014569

=== Page 7 ===
I met with
and I need time to evaluate matters. Regarding the subpoena to testify before the
Grand Jury on
we hereby notify you that if called as a witness
would invoke her Fifth
Amendment privilege against compelled self-incrimination. Please let me know if you will require her to
invoke in person or whether this communication suffices and no appertaining will be required.
Yours truly,
Michael Bachner
Michael Bachner
Bachner & Associates, PC
39 Broadway-Suite 1610
New York, NY 10006
Please excuse typographical errors. Messages sent through dictation.
<~WRD026.jpg>
https://www.actl.com/
NOTICE: The information contained in this communication is legally privileged and/or confidential
information, which is intended only for use of recipient. If the reader of this communication is not the
intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are
hereby notified that any dissemination, distribution, or reproduction of this communication is strictly
prohibited. If you have received this communication by error, please immediately notify the sender by e-
mail and delete this email from your system. Nothing in this email should be construed as a legal opinion
or tax advice.
On Jul 9, 2019, at 11:43 AM,
)
<mailto:
wrote:
Mr. Bachner,
Following up on our conversation earlier this morning, we wanted to provide you with the additional
information and materials we discussed. In the first instance, so that you have full contact info for the
team, please feel free to reach out to any of us at any time; we're all available via email or at the following
phone numbers:
Additionally, attached are the non-prosecution agreement, previously publicly filed in civil proceedings in
Florida, and a blank version of our standard proffer agreement, both as discussed.
As we mentioned, please don't hesitate to reach out with any questions, and we look forward to setting a
time to speak again after you're able to confer with
thank you,
EFTA00014570

=== Page 8 ===
Assistant U.S. Attorney
Southern District of New York
<blank proffer agreement.pdf>
<Epstein NPA, dated 2007-09-24.pdf>
EFTA00014571


c1: EFTA00014518
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014518.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
)"
Cc:
"
(USANYS)"
Subject: RE: Yesterday's Epstein hearing
Date: Tue, 25 Jun 2019 14:22:40 +0000
Importance: Normal
Thanks. A few things in here to discuss next time we meet.
From:
)
Sent: Tuesday, June 25, 2019 10:09 AM
To:
(USANYS)
is
)
is
Cc:
(USANYS)
Subject: RE: Yesterday's Epstein hearing
Attached here.
From:
(USANYS)
Sent: Tuesday, June 25, 2019 10:04 AM
To:
is
is
Cc:
(USANYS)
Subject: FW: Yesterday's Epstein hearing
Can you circulate to us the NDGA's papers?
From: Strauss, Audrey (USANYS)
>
Sent: Tuesday, June 25, 2019 9:55 AM
To:
(USANYS)
>;
(USANYS)
is
is
is
Subject: FW: Yesterday's Epstein hearing
In case you didn't see:
From:
(USANYS) [Contractor] <
Sent: Tuesday, June 25, 2019 9:50 AM
USANYS)
>; ; Berman, Geoffrey (USANYS)
>;
(USANYS)
is
(USANYS)
Subject: Yesterday's Epstein hearing
https://www.miamiherald.com/news/state/florida/article231916968.html
Special Assistant to the U.S. Attorney
United States Attorney's Office, SDNY
EFTA00014518

=== Page 2 ===
EFTA00014519


c1: EFTA00016949
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016949.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
EXHIBIT 1

=== Page 2 ===
DEPARTMENT
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
April 23, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Pursuant to Rule 16(a)(1)(G) of the Federal Rules of Criminal Procedure, the Government
hereby provides notice that it may call as an expert witness at trial
, a clinical
The Government reserves the right to call additional expert witnesses and will promptly provide
notice if the Government elects to do so.
I.
Disclosure by the Government
EFTA00016950

=== Page 3 ===
Page 2
is expected to testify, based on her relevant education, training, experience,
and research to the following: Individuals with particular vulnerabilities are often targeted by
perpetrators of sexual abuse. Sexual abuse of minors frequently occurs through the use of
manipulation or coercion in the context of an established relationship that is developed over time,
rather than through the use of forcible rape. Minor victims are often subject to a strategic pattern
of behaviors, often called grooming, that can take a variety of forms and function to render the
victims vulnerable to abuse, to obscure the nature of the abuse, and to build trust and attachment
with their abuser. The relationship of trust and attachment can prevent victims from being aware
that what they are experiencing is abuse and can prevent disclosure. Minor victims therefore may
not identify themselves as victims of abuse while it is ongoing, and may not recognize the
consequences of that abuse until adulthood. Repeated exploitation and abuse can increase the
likelihood of victimization later in life and can result in long-term traumatic and psychological
consequences, especially when it occurs in the context of complex trauma. The presence of other
individuals can facilitate the sexual abuse of minors.
is also expected to testify that
nondisclosure, incremental disclosure, and secrecy are common among victims of sexual abuse for
a variety of reasons, and that memory and disclosure of traumatic or abusive events is impacted
by a number of factors, including the circumstances surrounding the trauma.
has not
evaluated any specific victim in this case, and the Government does not presently intend to offer
testimony regarding any specific victim.
expected testimony relies on her education and training on psychological
trauma, traumatic stress, interpersonal violence, and sexual abuse. It also relies on
extensive clinical experience treating individuals who suffered sexual abuse and trauma in
childhood and adolescence, as well as
experience conducting forensic psychological
evaluations of people who have experienced sexual abuse and trauma. The Government is
producing notes from the Government's interviews with
today as well.
II.
Request for Reciprocal Discovery and Expert Notice
In light of your request for the foregoing notice, the Government hereby requests reciprocal
notice under Rule 16(b)(1)(C) of the Federal Rules of Criminal Procedure regarding any expert
witness that the defendant intends to rely upon, including a written summary of any testimony that
the defendant intends to use under Rules 702, 703, or 705 of the Federal Rules of Evidence, as
well as the witness's qualifications.
1
has previously testified in state court and has been deposed in the course of federal
and state litigation. As a courtesy, a list of that testimony is also being produced to you today
bearing Bates number 3502-002.
EFTA00016951

=== Page 4 ===
Page 3
Additionally, the Government reiterates its August 5, 2020 request for reciprocal discovery
under Fed. R. Crim. P. 16(b). Specifically, we request that you allow inspection and copying of:
(1) any books, papers, documents, data, photographs, tangible objects, buildings or places, or
copies or portions thereof, which are in the defendant's possession, custody or control, and which
the defendant intends to introduce as evidence or otherwise rely on at trial; and (2) any results or
reports of physical or mental examinations and of scientific tests or experiments made in
connection with this case, or copies thereof, which are in the defendant's possession or control,
and which the defendant intends to introduce as evidence or otherwise rely on at trial or which
were prepared by a witness whom the defendant intends to call at trial.
The Government also reiterates its August 5, 2020 request that the defendant disclose prior
statements of witnesses she will call to testify, including expert witnesses. See Fed. R. Crim. P.
26.2; United States V. Nobles, 422 U.S. 225 (1975). The Government requests that such material
be provided on the same basis upon which the Government agrees to supply the defendant with
3500 material relating to Government witnesses.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by: /s/
Assistant United States Attorneys
EFTA00016952


c1: EFTA00014491
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014491.pdf
c6: pdf
c7: images
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=== Page 1 ===
Case 1:19-cr-00490-RMB Document 23-1 Filed 07/16/19 Page 1 of 2
Date:
M BEACH POLICE DEPARTMENT
Page:
Time:
Incident Report
Program:
Case No
(Continued)
Entered By. :
On May 22, 2006, I received several phone calls throughout the day
from
who stated he had been followed aggressively by a private
investigator.
stated that as he drove to and from work and
running errands throughout the county, the same vehicle was behind him
running other vehicles off the road in an attempt not to lose sight of
S vehicle.
I explained to him as Mr. Epstein had retained new legal council it
was possible it would be new private investigators following him to
observe his daily activities. I also explained to him that there was
a meeting scheduled with
and Attorney Jack
Goldberger at
scheduled on June 1, 2006 at 9:00
am. I attempted to call
to inform
of the
private investigators following
however;
On May 23, 2006, I received other phone calls from
and
who
advised they were able to acquire the private investigators license
plate information. The subject following them was again driving very
aggressively and caused
to run off the road.
stated
the vehicle is a green Chevy
bearing Florida tag
The vehicle is registered to
of
Florida.
is employed with
Investigations from
Florida.
is a licensed Private Investigator in the State of Florida.
Since the discovery of the threat made against one of the victims in
this case
/ I requested subpoenas for all calls made to and
received from
during the month of March 2006 for her
cell phone and home phone. I had confirmed with
the exact dates of Spring Break for 2006 The Spring Break
was from March 4, 2006 through March 12, 2006. I received a subpoena
from
with all calls made during the month of March 2006.
I reviewed the 989 calls made and received during the month of March
2006. I observed on March 7, 2006,
made and received thirty
five calls during that day.
Date
Time
Seconds
In/Out
To/From
7-Mar-06
11:03 AM
492
Outbound
7-Mar-06 11:16 AM
6
Inbound
7-Mar-06
11:22
AM
887.2
Inbound
7-Mar-06 11:37 AM
48
Outbound
7-Mar-06 11:39 AM
28.2
Inbound
7-Mar-06 12:02 PM
727.2
Inbound
The table reflects the date of the calls, time of day (EST), duration
EFTA00014491

=== Page 2 ===
Case 1:19-cr-00490-RMB Document 23-1 Filed 07/16/19 Page 2 of 2
Date:
LM BEACH POLICE DEPARTMENT
Page:
Time:
Incident Report
Program:
Case No
:
(Continued)
of call in seconds, inbound or outbound calls and calls made to or
from
phone. On March 7, 2006, at 11:03 am,
made a call
to the victim
which lasted 492 seconds (8 minutes and 2 seconds)
The victim then returned the call at 11:16 am which lasted 6 seconds.
The victim then made contact with
at 11:22 am for 877.2 seconds
(14 minutes and 6 seconds). These sequences of calls were consistent
with what the victim had described to me on the date of the
intimidation. Immediately after speaking with the victim,
makes
a call to
Epstein's assistant, which lasts for
forty-eight seconds. A call is then immediately received, a telephone
number registered to a Corporation affiliated with Jeffrey Epstein
located at 457 Madison Ave in New York. An extensive computer check
revealed 457 Madison Ave is a business address in which Epstein has
his corporations assigned to. Epstein had corporation attorney,
register the businesses and register himself as an
agent. I also observed Epstein has his El Zorro Ranch Corporation,
New York Strategy Group, Ghislaine Corporation, J Epstein and Company
and the Financial Strategy Group registered to this same address.
Finally, a third call is received by
at 12:02 pm from the same
corporate number which lasts 12 minutes and 1 second. It should be
noted that there is no further contact with either the victim during
the month of March or April of 2006. I also noted that there was no
further contact with
or Jeffrey Epstein during the
remainder of the month of March or April 2006.
On June 1, 2006,
telephoned me to inform me of the
meeting that occurred with Atty. Jack Goldberger and
reference
this case
Inv Continues.
EFTA00014492


c1: EFTA00015576
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015576.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Travel approval request
Date: Tue, 09 Jul 2019 23:37:51 +0000
Importance: Normal
Traveler,
Please have your legal asst. create a travel auth. in E2 for
to officially fund & approve today. Thanks
Each time you book a trip, you should check these links to see the maximum lodging allowed for your destination city & if
the office will be able to reimburse you for room taxes.
Click here - is the city lodging tax exempt?
State/City tax exempt link https://usanet.usa.doj.gov/staffs/RMP/_layouts/15/WopiFrame2.aspx?
sourcedoc=/staffs/RMP/RMP%20Document%20Library/TravelStateTaxExemption.pdf&action=default
https://www.gsa.gov/travel/plan-book/state-tax-exemption-information-for-government-charge-cards
If applicable, print & submit form to hotel front desk Lodging taxes will no longer be reimbursed for cities that allow an
exemption.
Click here Per diem Rates link - the maximum lodging reimbursable for your destination is Per diem Rates link
Misc. fees maybe considered part of the per night rate & may need to be factored into the total per night cost
PIV Card Driven Link - E2 Solutions, select USA identity provider OR Password Driven link - Click here to log back into the System.
You or your legal asst. should create an E2 travel auth. & book air, rail & or hotel in E2 E2 Solutions, today
Be sure to complete the process by clicking send to approver at the end,. This is the only way your request can reach
for approval.
Rental Cars
Travelers must reserve rental cars via E2-E2 Solutions to ensure the rental car company is under the U.S. Government Car Rental Agreement.
Only Compact or Economy vehicles are authorized. Contact travel coordinator for acceptable justifications/ authorization for bother vehicle classes
Refueling charges charged by the rental car company cannot be reimbursed Be sure to gas up BEFORE you return the car
For travel to TDY sites that are less than 400 miles in distance, the GOV must be used when available. If the GOV is not available, the traveler
should then consider the least
costly economy rental vehicle
The traveler must decline insurance coverage within CONUS but accept the coverage when traveling in OCONUS and foreign locations areas.
Receipts/ Expense claims must be submitted the day after the trip is completed
From:
Sent: Tuesday, July 09, 2019 2:09 PM
To:
is
Cc:
is
Subject: RE: travel approval request
Thanks!
From:
Sent: Tuesday, July 9, 2019 2:08 PM
To:
is
EFTA00015576

=== Page 2 ===
Cc:
Subject: RE: travel approval request
Approved for the travel and necessary conference room.
Thank you for correctly setting your priorities.
From:
Sent: Tuesday, July 09, 2019 2:00 PM
To:
is
Cc:
Subject: RE: travel approval request
Hi
In connection with the Epstein case (2018R01618), we would like to request permission to travel this week for victim
interviews in Palm Beach, Florida. Our agents will be there starting tomorrow, through Sunday, and our current plan is for
some combination of our team
(
, and me) to be there from Thursday** through Sunday. And also same as
last time, we'd like to ask permission to reserve a conference room at the hotel for those four days.
Thanks very much,
***we would never miss the BBQ.
From:
Sent: Wednesday, June 12, 2019 3:28 PM
To:
Cc:
is
Subject: RE: travel approval request
Approved.
From:
Sent: Wednesday, June 12, 2019 2:51 PM
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,
EFTA00015577

=== Page 3 ===
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
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
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.
EFTA00015578

=== Page 4 ===
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00015579


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=== Page 1 ===
From:
To:
Cc:
Subject: MM Digital Evidence
Date: Tue, 08 Dec 2020 17:36:33 +0000
Attachments: MM-108062_Evidence - Digital.xlsx; MM-108062_Miami_Evidence_Inventory.xlsx
Hey all,
Attached is the spreadsheet for the Miami digital items listed in evidence. For your reference, I've also attached the
original spreadsheet that was completed during the scan project. Let me know if you have any questions.
Thanks,
FBI New York Field Office
Child Exploitation/Human Trafficking
EFTA00016463


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=== Page 1 ===
OF
THE
STATE
OFFICE OF THE STATE ATTORNEY
OF
STATE ATTORNEY
GREAT
FLORIDA
FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY
USA
CIRCUIT
SEAL GOD
DAVID ARONBERG
STATE ATTORNEY
September 14, 2020
Via Electronic Mail:
Assistant United States Attorney
Southern District of New York
RE: Response to Agency Request
Our Public Record No.: 2020PR000426AMB
Dear
We have completed your agency's request received by our office on September 3,
2020 for a copy (un-redacted) investigation and prosecution concerning Jeffrey
Epstein:
Please be advised that in response to your request copies of the state's entire (un-
redacted) files are being provided to you electronically via our agency's CIP portal.
Your records consists of 4,421 pages of information, 43 audios and 6 videos. Also
included are two pages of "Case Relationships" retrieved from our electronic Stac
database system.
You will receive an email request to create an account allowing you to access and
download the items. Once you create the account, a verification email will be sent to
you. Please be sure to check your spam folder if you do not receive it as the
verification email has a lifespan of 20 minutes. These items will be available in the
CIP Portal.
If you have further questions, please feel free to contact me by e-mail at
or directly at
Sincerely,
Public Records Department
West Palm Beach, Florida 33401
Phone:
www.sa15.org
EFTA00016315


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=== Page 1 ===
WIRELINE
2996479
06/17/2020
AT&T has queried for records from 03/01/2020 12:00:00am to 06/15/2020 11:59:59pm
AT&T
AT&T has queried for records using Eastern Time Zone. AT&T's records are stored and provided in
UTC.
Run Date:
06/17/2020
Run Time:
18:45:32
Voice Usage For:
Item
ConnDateTime
Originating
Sec. Orig.
Terminating
Dialed
Elapsed
CIC
Call Code
Orig.
(UTC)
Number
Number
Number
Time
Acc.
1
03/01/20 19:58:27
0:00
829
601
2
03/02/20 16:36:53
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829
3
03/02/20 16:43:46
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829
601
4
03/02/20 16:44:06
2:06
829
5
03/03/20 21:36:01
30:41
343
6
03/04/20 18:52:26
1:40
827
602
7
03/04/20 19:46:37
0:05
343
8
03/04/20 22:07:25
47:57
343
9
03/04/20 23:04:25
0:39
343
10
03/05/20 00:56:24
0:00
829
11
03/05/20 00:58:15
0:25
827
602
12
03/05/20 13:22:45
1:13
829
13
03/05/20 15:49:48
0:01
829
601
14
03/05/20 15:50:04
0:00
829
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03/05/20 17:14:11
0:36
343
16
03/05/20 17:15:32
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343
17
03/05/20 18:27:34
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343
18
03/05/20 18:29:16
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343
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03/05/20 18:42:42
0:04
343
20
03/05/20 20:38:45
9:05
343
21
03/05/20 20:51:31
0:00
343
22
03/06/20 15:08:16
1:08
343
23
03/06/20 20:02:56
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343
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03/06/20 20:51:23
0:59
343
25
03/06/20 21:03:38
0:00
829
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03/06/20 21:04:01
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829
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27
03/06/20 21:04:33
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28
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11
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03/08/20 18:09:41
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34
03/09/20 00:45:22
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601
35
03/09/20 14:52:35
0:00
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601
36
03/09/20 15:46:24
0:00
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37
03/09/20 18:49:59
0:00
829
38
03/10/20 17:41:33
0:00
829
601
AT&T Proprietary
Page 1
The information contained here is for use by authorized persons only and is not
for general distribution.
EFTA00017134

=== Page 2 ===

=== Page 3 ===

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=== Page 1 ===
1
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1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
2
X
UNITED STATES OF AMERICA,
New York, N.Y.
3
V.
19 Cr. 490 (RMB)
4
JEFFREY EPSTEIN,
5
Defendant.
6
X
Conference
7
July 8, 2019
1:20 p.m.
8
9
Before:
10
HON. HENRY B. PITMAN,
11
Magistrate Judge
12
13
APPEARANCES
14
GEOFFREY S. BERMAN
United States Attorney for the
15
Southern District of New York
BY:
16
17
Assistant United States Attorneys
18
STEPTOE & JOHNSON, LLP
Attorneys for Defendant
19
BY: REID H. WEINGARTEN
20
MARTIN G. WEINBERG
Attorney for Defendant
21
MARC FERNICH
22
Attorney for Defendant
23
Also Present:
24
Special Agent
FBI
25
Detective
, NYPD
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015661

=== Page 2 ===
2
j782epsC kjc
1
(Case called)
2
THE DEPUTY CLERK: Counsel, please state your name for
3
the record.
4
MR.
:
Good afternoon, your Honor. For the
5
government,
6
With us are Special Agent
of the F.B.I. and
7
Detective
,
NYPD task force officer.
8
THE COURT: Okay.
9
MR. WEINGARTEN: Good afternoon, your Honor. For
10
Jeffrey Epstein, Reid Weingarten from the law firm of Steptoe &
11
Johnson.
12
MR. WEINBERG: Good afternoon, your Honor. Martin
13
Weinberg. I'm an attorney from Boston, Massachusetts; and,
14
with your Honor's permission, I will be filing a pro hac vice
15
to represent Mr. Epstein.
16
THE COURT: Okay.
17
MR. FERNICH: Good afternoon, your Honor. Marc
18
Fernich, New York, New York, also for Mr. Epstein.
19
THE COURT: All right. I have spoken to Judge Berman.
20
The matter has been referred to me for the initial appearance,
21
arraignment, and bail.
22
Mr. Epstein, my name is Magistrate Judge Pitman. The
23
purpose of this proceeding is to inform you of certain rights
24
that you have, to inform you of the charges against you, to
25
consider whether counsel should be appointed for you, and to
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015662

=== Page 3 ===
3
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1
decide under what conditions, if any, you should be released.
2
Can I have the date and time of arrest, please?
3
MR.
: Yes, your Honor. The defendant was
4
arrested on Saturday, July 6, at approximately 5:30 p.m.
5
THE COURT: Thank you.
6
Mr. Epstein, you have the right to remain silent. You
7
are not required to make any statements. Even if you have made
8
any statements to the authorities, you need not make any
9
further statements. Anything you do say can be used against
10
you.
11
You have the right to be released, either
12
conditionally or unconditionally, pending trial unless I find
13
that there are no conditions or combination of conditions that
14
would reasonably assure your presence in court and the safety
15
of the community.
16
You have the right to be represented by counsel during
17
all court proceedings, including this one, and during all
18
questioning by the authorities. If you cannot afford an
19
attorney, I will appoint one to represent you.
20
It is my understanding that you are being represented
21
by retained counsel. I want to advise you that the right to
22
the appointment of counsel is an ongoing right that you possess
23
throughout these proceedings. If at any time you are unable to
24
continue with retained counsel for financial reasons, you can
25
apply to the court at any time for the appointment of counsel.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015663

=== Page 4 ===
4
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1
Do you understand that?
2
THE DEFENDANT: Yes, your Honor.
3
THE COURT: Mr. Epstein, you are charged in an
4
indictment in two counts.
5
Count One charges you with a sex trafficking
6
conspiracy in violation of Title 18 United States Code § 371.
7
Count Two charges with you with the substantive
8
offense of sex trafficking in violation of Title 18 United
9
States Code $ 1591.
10
Mr. Weingarten, are you going to be lead counsel here
11
today?
12
MR. WEINGARTEN: Yes, your Honor.
13
THE COURT: Mr. Weingarten, have you received a copy
14
of the indictment?
15
MR. WEINGARTEN: Yes, your Honor.
16
THE COURT: Have you reviewed it with your client?
17
MR. WEINGARTEN: Yes, your Honor.
18
THE COURT: Do you waive its reading?
19
MR. WEINGARTEN: Yes, your Honor.
20
THE COURT: Mr. Epstein, how do you plead?
21
THE DEFENDANT: Not guilty, your Honor.
22
THE COURT: Because the defendant has been indicted,
23
there will be no preliminary hearing, and that takes us to the
24
question of bail. In that regard, I have received the Pretrial
25
Services report. I have also received a letter from the
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015664

=== Page 5 ===
5
j782epsC kjc
1
government dated July 8, 2019.
2
I take it all counsel have the same documents?
3
MR. WEINGARTEN: Yes, your Honor.
4
THE COURT: I will hear from the government first, and
5
then I will hear from defense counsel.
6
MR.
: Yes, your Honor.
7
The government intends to seek detention, and I am
8
happy to explain the reasons why. Would the court prefer that
9
I speak from the table or from the podium?
10
THE COURT: Whatever your pleasure is.
11
MR.
:
Your Honor, the defendant poses an
12
extraordinary risk of flight and danger presented by him.
13
Given the charges and the characteristics of the defendant, he
14
simply cannot reasonably be expected to appear in court if he
15
is granted bail. Accordingly, the government joins the
16
recommendation of Pretrial Services that the defendant be
17
detained pending trial for a number of reasons.
18
Starting with the conduct alleged, the defendant is
19
charged with trafficking minors for sex acts, as the court
20
explained, in violation of 18 United States Code $ 591, and is
21
charged with a count of conspiracy to traffic minors for sex
22
acts in violation of 18 U.S.C. 371.
23
In particular, the indictment charges that the
24
defendant engaged in a years-long scheme to sexually abuse
25
underage girls, paying minor girls to themselves be abused, and
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015665

=== Page 6 ===
6
j782epsC kjc
1
also paying certain victims to recruit other girls to be
2
subject to the defendant's sexual abuse.
3
The indictment alleges that the defendant undertook
4
this conduct at at least two locations, including his mansion
5
in Manhattan and his estate in Palm Beach, Florida. In both
6
locations, victims were initially recruited to provide massages
7
to the defendant, which would be performed nude or partially
8
nude, would become increasingly sexual in nature, and would
9
typically include one or more sex acts, including
10
These victims, who were often
11
particularly vulnerable, were as young as 14, and the defendant
12
knew he was abusing underage girls. The indictment further
13
alleges that the defendant perpetrated these crimes by working
14
with others, including employees and associates who facilitated
15
these abusive encounters.
16
Regarding the defendant himself, your Honor, he is
17
extraordinarily wealthy, mobile, and unattached to the Southern
18
District of New York. He maintains at least six residences in
19
the United States and abroad, including the ownership of a
20
private island in the U.S. Virgin Islands and a residence in
21
Paris, France. Among other things, the defendant owns two
22
private jets and routinely uses them to travel abroad. He is a
23
man of nearly infinite means, your Honor; and, as set forth in
24
our submission, he has tremendous incentives to use those means
25
to flee prosecution.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015666

=== Page 7 ===
7
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1
The government notes as an initial matter that this is
2
a presumption case because sex trafficking is charged; and,
3
moreover, each of the four factors to be considered in the
4
detention analysis strongly militates towards pretrial
5
detention.
6
So starting with the nature and seriousness of the
7
offense, as previously discussed, the nature and circumstances
8
of the crime are the most serious crime that this court sees.
9
The defendant is alleged to have spent years sexually abusing
10
minors in multiple locations and with dozens of victims.
11
The seriousness of the charge is also reflected in the
12
potential penalties, which include up to 45 combined years of
13
incarceration on Counts One and Two, and the likelihood of a
14
substantial period of incarceration is supported by the fact
15
that the government's evidence is strong. There are multiple
16
individual identified victims in the indictment, numerous
17
specified overt acts, and dozens of overall victims alleged.
18
In order to protect the privacy of the victims, your
19
Honor, I'm not going to go into detail about particular
20
victims, but we can say that information provided by victims
21
has been detailed, it has been credible, and it has been
22
corroborated by other witnesses and contemporaneous documents
23
and records, including from a recent search of the defendant's
24
Manhattan mansion, as I will discuss further in a moment.
25
Separately, your Honor, in just the last 36 hours,
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015667

=== Page 8 ===
8
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1
that is, post charge, we have been contacted by multiple
2
attorneys and several additional individuals who have
3
identified themselves as victims and are interested in speaking
4
with the government, none of whom the government has previously
5
spoken with.
6
Your Honor, the defendant is 66 years old. He is
7
charged with appalling crimes, and those charges are supported
8
by significant evidence, including victim and witness testimony
9
and damning record evidence. He faces the very real prospect
10
of spending the rest of his life in prison. He has every
11
motivation in the world to flee, and he has the means to do it.
12
And I will note for the court that this is a case
13
where the government has really put its money where its mouth
14
is on the risk of flight. This district took extraordinary
15
efforts to maintain the covert status of its investigation for
16
many months due to the risk of flight of the defendant -- not a
17
single media report, not a single public statement, no appeals
18
for victims to come forward because of precisely the flight
19
risks we are discussing now.
20
Turning to the characteristics of the defendant, your
21
Honor, some individuals who face significant charges lack the
22
means to flee. Not this defendant. As set forth in the
23
government's submission, in the defendant's most recent sex
24
offender registration, he lists six residences worth tens or
25
hundreds of millions of dollars, including a residence abroad.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015668

=== Page 9 ===
9
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1
The defendant has refused to answer any questions
2
about his income or assets for the Pretrial Services report, so
3
the scope of his wealth and his assets remains entirely
4
concealed to the government and to the court. But the
5
defendant certainly has access to endless means to flee,
6
including two private jets. He has no meaningful family ties,
7
and any argument that his properties would keep him in the
8
United States ignores his ability to simply leave those
9
properties behind in favor of moving beyond the reach of U.S.
10
authorities to live off his extensive wealth abroad, extensive
11
wealth, I should add, that the court doesn't even have any
12
accounting of. He travels abroad extensively, has a residence
13
in France, and all of those factors further contribute to the
14
risk of flight.
15
With respect to danger and obstruction, again, this is
16
a presumption case, and not only is the defendant charged with
17
the sexual abuse of minors, he has previously pled guilty to
18
solicitation of an underage girl. This court knows that
19
defendants are routinely detained in this district when facing
20
such charges and that this is not an unusual position for the
21
government to take.
22
It is further concerning that there are credible
23
allegations from the prior investigation that the defendant or
24
his agents engaged in witness tampering and harassment, and in
25
fact there is evidence that he was contemplating pleading
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015669

=== Page 10 ===
10
j782epsC kjc
1
guilty to that kind of offense in Florida. Those allegations
2
include verbal harassment, evasion of legal process, and
3
forcing off the road the father of an individual relevant to
4
that investigation.
5
THE COURT: Can you elaborate on that last point about
6
forcing somebody off the road?
7
MR.
:
Your Honor, what we have is the
8
record evidence from an underlying civil dispute in Florida
9
that discusses this incident and discusses it in the context of
10
a potential plea of the defendant to obstruction or harassment
11
charges. The government sets before this court that if the
12
defendant was willing to undertake such measure simply as a
13
result of an investigation, the potential for dangerous and
14
obstructive activity in an indicted case is alarming and very
15
real.
16
Despite having been previously convicted of a sex
17
offense involving an underage victim and being a registered sex
18
offender, the defendant has continued to maintain a vast trove
19
of lewd photography of young-looking women or girls at his
20
mansion. Your Honor, pursuant to judicially authorized
21
warrants, law enforcement agents searched his home on Saturday
22
and found at least hundreds, and perhaps thousands, of sexually
23
suggestive photographs of nude females, many of whom appear to
24
be underage.
25
I also want to note that the search revealed specific
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015670

=== Page 11 ===
11
j782epsC kjc
1
evidence from his home consistent with victim accounts. Even
2
the room where the abuse occurred, your Honor, the massage
3
room, was still set up in the same way it was 15 years ago,
4
with a massage table and sex paraphernalia.
5
And with respect to the photographs --
6
THE COURT: When you say the evidence was consistent
7
with victim accounts, is it limited to the massage table and
8
massage room or is there something else?
9
MR.
:
Descriptions of the massage room and
10
the massage table, that's correct, your Honor.
11
THE COURT: Okay. All right.
12
MR.
:
With respect to the photographs, your
13
Honor, some of those were found in a locked safe which also
14
held electronic disks with labels that included the words
15
"Young Miscellaneous Nudes 1" and "Girl Pics Nude."
16
Your Honor, this is not an individual who has left his
17
past behind. He is a continuing danger to the community and an
18
extraordinary risk of flight and, for those reasons, the
19
government joins the pretrial recommendation that the defendant
20
be detained pending trial.
21
THE COURT: All right. Thank you.
22
Mr. Weingarten.
23
MR. WEINGARTEN: Thank you, your Honor. I will use
24
the podium, if that's okay.
25
THE COURT: That's fine.
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015671

=== Page 12 ===
12
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1
MR. WEINGARTEN: So your Honor, I would like to start
2
by providing some context, and then I'm going to make a
3
suggestion as to how we proceed.
4
The beginning here is 2005 in Florida. That's when an
5
allegation was received by the local police that Mr. Epstein
6
was engaged in sexual conduct for money, prostitution.
7
Thereafter, there was a very sophisticated three-year
8
investigation by law enforcement, including locals and feds,
9
into Mr. Epstein's conduct. Numerous girls were interviewed,
10
employees were interviewed, and it is fair to say that a
11
significant segment of the law enforcement community in Florida
12
thought what we had in hand was simple prostitution. There was
13
no coercion. There were no threats. There was no violence.
14
And it is also fair to say that a significant portion of the
15
law enforcement community in Florida believed that a local
16
misdemeanor was the appropriate sanction.
17
Now, it is also --
18
THE COURT: Did you represent Mr. Epstein in the
19
Florida investigation?
20
MR. WEINGARTEN: No, but I'm familiar with the
21
records.
22
THE COURT: All right.
23
MR. WEINGARTEN: It is also true that there was a
24
contrary view largely taken by the feds, and what ensued was a
25
complex set of discussions and negotiations and finally an
SOUTHERN DISTRICT REPORTERS, P.C.
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13
j782epsC kjc
1
agreement, an agreement that was consummated and agreed to all
2
the way up to main justice at a very, very high level.
3
The agreement involved a plea in state court to
4
soliciting an underaged girl, which would require registration,
5
compensation paid to alleged victims, and an NPA from the feds,
6
in other words, a declination by the federal government, an
7
agreement that was approved all the way up in main justice and
8
it sure seemed like a global solution at the time to everyone
9
involved, including my client.
10
What happened since then? Mr. Epstein continued a
11
life of success, generosity, creativity and, more important, a
12
law-abiding life from 2008 forward. How do we know? Because
13
when you are in registration the way he is, every single night
14
his whereabouts are known. There is constant reporting,
15
constant monitoring, and absolutely, to our knowledge, no
16
complaints by anybody from that moment forward about his
17
conduct until we have arrived in court here.
18
Now, what has happened in court from that moment?
19
There have been lawsuits, many of them ludicrous, dismissed out
20
of hand. But when something like this happens, a lot of stuff
21
comes out of the woodwork, and there were lawsuits that
22
Mr. Epstein settled also in the normal course.
23
There was one particular litigation that leads to this
24
occasion, and that is, under the Crime Victims Rights Act, that
25
act simply says that victims have a right to be consulted by
SOUTHERN DISTRICT REPORTERS, P.C.
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14
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1
the United States, and there are alleged victims in this case
2
who complain that they were not, and there has been extensive
3
litigation in the Southern District of Florida before
4
Judge Marra on that very subject. In fact, the judge concluded
5
that the prosecutors from the Southern District of Florida did
6
not adequately notify some of the victims about the ongoing
7
discussions and the consummation of the deal and, in
8
particular, the NPA. The United States took the position that
9
they had no responsibility to do so, that they had treated the
10
victims properly, and that matter continues to this day.
11
The consequences of that matter are overwhelming,
12
because the judge suggested, I think three times, that the NPA,
13
the declination, could be voided. And we think about that for
14
a second. So a defendant negotiates what he thinks is a global
15
solution with the feds. He does his time --
16
THE COURT: Does the nonprosecution agreement in
17
Florida -- the nonprosecution agreements in the Southern
18
District routinely say they are limited to the Southern
19
District of New York.
20
MR. WEINGARTEN: Obviously --
21
THE COURT: Is there a similar provision in the
22
Florida agreement?
23
MR. WEINGARTEN: I don't want to misstate. It is not
24
before me. It is obviously going to be an important part of
25
the pretrial motions. What is for sure is that there was --
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00015674

=== Page 15 ===
15
j782epsC kjc
1
the negotiation with the Southern District included
2
negotiations with main justice. What's also true is the
3
investigation extended into the Southern District of New York
4
and elsewhere in terms of girls being interviewed.
5
So obviously your question is relevant and will be
6
part of the pretrial litigation for sure. But what matters
7
here and for now is there certainly was a belief that there was
8
a global solution based upon the facts on the ground.
9
THE COURT: Have you seen the Florida nonprosecution
10
agreement?
11
MR. WEINGARTEN: Yes.
12
THE COURT: And --
13
MR. WEINGARTEN: I don't have it before me. I don't
14
want to make a specific representation and not be completely
15
accurate.
16
THE COURT: Okay. All right. Go ahead.
17
MR. WEINGARTEN: The consequences of this are huge in
18
that if in fact there is a negotiation with a defendant, the
19
defendant does his time, the defendant pays his victim, and the
20
defendant spends ten years on the registration list and
21
prosecutors don't adequately notify the victims, how in the
22
world can that deal be undone? Every prosecutor in the world
23
has to oppose that possibility. No defense attorney in their
24
right mind would negotiate a deal with that potential
25
consequence.
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 16 ===
16
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1
So this is a huge problem for the department and what
2
solution ensues, and I suggest the solution that ensued is this
3
indictment. To us, this indictment is essentially a do-over.
4
The allegations are from 2002 to 2005. This is old stuff.
5
This is ancient stuff. This is the very stuff that was
6
investigated by the feds in Florida, a sophisticated three-year
7
investigation. Two of the alleged victims in this indictment
8
are from Florida. The indictment here tracks the conduct that
9
was investigated in Florida back before the agreement was
10
reached. Obviously we need to get discovery to find out just
11
how inextricably linked the investigation back in Florida is
12
with what's going on here. We do know we are talking about
13
ancient conduct. We do know we are talking about facts that
14
are from 2002 to 2005, facts that were known to the United
15
States prosecutors before they entered into the NPA, the
16
declination. This is essentially a redo. That's how it feels
17
to us. And if we are correct, that should chill the blood of
18
every defense attorney who negotiates a deal with the United
19
States.
20
In addition, we have -- the central allegation here is
21
trafficking, and obviously it is useful and relevant to make
22
inquiry as to why the trafficking law was passed. It is to
23
cover abhorrent conduct, where young girls are kidnapped, they
24
are fooled, they are forced to come usually to unfamiliar
25
places, work in brothels where they service 15, 20 guys in a
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 17 ===
17
j782epsC kjc
1
day. They can't leave or else their families are threatened.
2
This is dreadful conduct.
3
I remember an occasion when the Attorney General Eric
4
Holder and I think Director Comey had a press conference
5
establishing this as a law enforcement priority. Every
6
sensible person in the world would think that this is the exact
right thing law enforcement should do.
8
This is not this case. There was no violence. There
9
was no coercion. There was no intimidation. There is no
10
deception. The bottom line, if you take a fair look at the
11
facts of this case as alleged and in the record, you may come
12
to the conclusion there was prostitution involved and maybe a
13
lot of it, but that doesn't mean that the person involved is a
14
pedophile, a rapist or, heaven knows, a trafficker. Just --
15
THE COURT: Well, if the women involved were under 18,
16
isn't that rape?
17
MR. WEINGARTEN: My understanding
:
18
THE COURT: Legally they are incapable of consent, are
19
they not?
20
MR. WEINGARTEN: Well, it could be statutory rape.
21
But what I am talking about is trafficking and why the
22
statute was passed, and obviously the statute was passed to
23
protect women from the horrors that occur in such settings, and
24
that is light years removed to what happened in this case.
25
So what about bond? I would suggest that the
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 18 ===
18
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1
traditional issues that we look at, the issues involved, let's
2
start with that, we believe we have extremely powerful motions
3
relating to the government seeking two bites at the apple and
4
for due process reasons, double jeopardy reasons, we don't
5
think that will stand. We also think fundamentally what's at
6
issue here is not trafficking. That's not why the statute was
7
passed.
8
The risk to others, what we have here is at least ten
9
years post incarceration in the State of Florida of conduct
10
that has never been challenged by anyone until now. The
11
registration requirements are onerous. He is under constant
12
surveillance. Law enforcement knows, if they choose to look,
13
exactly where he is at any time.
14
The risk of flight, what is true is from the moment of
15
Judge Marra's litigation in the Southern District of Florida,
16
the defendant knew that there would be challenges to the NPA.
17
From 2013 on, there were representations made in court that
18
that challenge was ongoing, and the defendant never sought to
19
flee, never anticipated a time when he would flee, continued to
20
live his law-abiding life. So the risk of flight, I think, is
21
dramatically overstated in the government's presentation.
22
I think the traditional remedies that the court finds
23
appropriate in case after case -- a large cash bond; passport
24
relinquished; waiving extradition; a bracelet on; some form of
25
supervision that is adequate to guarantee his appearance, it
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 19 ===
19
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1
will be child's play to find that; bonds from other people,
2
surety bonds from other people.
3
Because we have not had an opportunity to see our
4
client until today and because we have just received the
5
government's submission, what we would like to do is have the
6
opportunity to sit down and put together a bail package, a
7
coherent bail package in writing and provide it to the court.
8
I would point out on the obstruction allegation --
9
THE COURT: Let me ask you this -- sorry to interrupt
10
you -- do you want to adjourn the detention hearing? Under the
11
statute, you have up to three days.
12
MR. WEINGARTEN: What I would like is to have until
13
the end of the week to provide something in writing, a specific
14
recommendation in writing.
15
THE COURT: So you want to adjourn a determination of
16
bail?
17
MR. WEINGARTEN: Yes.
18
THE COURT: Is there any objection to that from the
19
government? The defendant is detained in the interim under
20
3142(f).
21
MR. WEINGARTEN: Right.
22
MR.
:
Your Honor, we certainly don't object
23
if the defendant is consenting to detention with leave to make
24
a further application.
25
I think the government would like at least a brief
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 20 ===
20
j782epsC kjc
1
opportunity to respond to some of those points, to the extent
2
that the defense is arguing that Mr. Epstein should be granted
3
bail as a general matter and the court is going to consider
4
those arguments.
5
THE COURT: Well, the court always considers the
6
parties' arguments.
7
But let me just come back to Mr. Weingarten for a
8
minute. Mr. Weingarten, under the Bail Reform Act you are
9
entitled to a continuance of three days, which I guess would
10
take us to Thursday.
11
MR. WEINGARTEN: Right.
12
THE COURT: The other alternative, I guess, if you
13
want to de facto extend that three days is consent to detention
14
without prejudice.
15
MR. WEINGARTEN: We estimated that by Thursday we
16
could get you something in writing and then appear back before
17
you at your convenience.
18
THE COURT: Okay. Do you want to schedule it -- well,
19
I think Thursday's proceedings right now would be in front of
20
Judge Berman unless he wants to send it back to me for bail,
21
but do you want to put this down for detention hearing on
22
Thursday?
23
MR. WEINGARTEN: Can I make one point that I don't
24
want to forget that I think is extremely important?
25
THE COURT: Go ahead.
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 21 ===
21
j782epsC kjc
1
MR. WEINGARTEN: The last thing we did today was
2
refuse to answer questions. What we said at Pretrial is heaven
3
forbid we make a mistake, and in terms of assets, we wanted to
4
be precise. So there was no refusal. There was a request for
5
time to supplement. That was accepted. And that's part of the
6
reason we want to sit down and make sure we get our information
7
correct to provide to the court.
8
THE COURT: All right.
9
MR. WEINGARTEN: Can I make one other point?
10
THE COURT: Sure.
11
MR. WEINGARTEN: In terms of the obstruction, I think
12
it is such a significant part of our argument that the conduct
13
at issue is ancient. It is from 2002 to 2005. So obviously if
14
the defendant is a threat to obstruct justice, the court needs
15
to take that into account. The allegations raised -- and I
16
just read them briefly because we just got the government's
17
letter -- relate to negotiations between the feds and the
18
defendant. Back when the Southern District of Florida was
19
attempting to find an appropriate remedy, there were
20
discussions going back and forth: Can we squeeze you into this
21
statute? And it didn't work, and it didn't work because there
22
is no factual basis. That is the reference to the alleged
23
obstruction. Not obstructive acts. Instead, the feds in
24
Florida agreed to the plea to the state offense because there
25
was no appropriate statute that covered conduct that was
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 22 ===
22
j782epsC kjc
1
proveable. That is the answer to the obstruction issue.
2
THE COURT: All right. So you want to adjourn the
3
detention hearing until Thursday?
4
MR. WEINGARTEN: Yes.
5
THE COURT: All right. Is there any objection to that
6
from the government? I think under the statute he is entitled
7
to three days.
8
MR.
: That is, of course, fine, your Honor.
9
I think we would like just a very brief opportunity to
10
respond to some of those arguments so that they don't sort of
11
hang with the court for three days unresponded to.
12
THE COURT: All right. Go ahead.
13
MR.
: Just very briefly, your Honor, I
14
think a lot of that discussion was entirely orthogonal to the
15
issues here.
16
But just very briefly, with respect to the charges
17
here, there is simply no force required for underage victims.
18
A grand jury has properly returned an indictment, and these are
19
fact issues that are being presented in large part.
20
Certainly the concept of child prostitution is,
21
frankly, offensive and not recognized in federal law. The idea
22
that children can consent to sex and be prostitutes is beyond
23
the realm of federal law which contemplates trafficking, which
24
is what has been charged here. Mr. Weingarten is free to argue
25
to a jury that trafficking minors was only statutory rape or
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 23 ===
23
j782epsC kjc
1
that those victims weren't treated as badly as the parade of
2
horribles he has in mind. But for now the question is whether
3
the defendant's attendance can be assured.
4
And with respect to the nonprosecution agreement --
5
THE COURT: I'm not sure I would refer to something as
6
only statutory rape. The use of the word "only" before
7
"statutory rape" I'm not sure sits well. But go ahead.
8
MR.
:
And I agree, your Honor.
9
With respect to the actual substance, the Southern
10
District of Florida has represented in public filings that the
11
nonprosecution agreement was limited to the Southern District
12
of Florida, and we can litigate that in a motion to dismiss,
13
but it is simply not relevant here.
14
With respect to the statute of limitations,
15
Mr. Weingarten says that the conduct is old. He did not say
16
that that it is beyond the statute of limitations because it is
17
not.
18
And, finally, it is not the same conduct. Some of the
19
conduct overlaps. Some of the conduct does not. And in
20
particular, one of the two counts of the indictment is
21
predicated exclusively on New York victims.
22
So for all of those reasons, we just ask the court to
23
consider those responses as it awaits the defendant's filings
24
later this week.
25
MR. WEINGARTEN: Can I just make one point to clarify?
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 24 ===
24
j782epsC kjc
1
THE COURT: Go ahead.
2
MR. WEINGARTEN: On the statutory rape thing, I had a
3
senior moment. There is no statutory rape because there is no
4
penetration, and that is the answer to that question.
5
THE COURT: All right.
6
We will set this down for a detention hearing on
7
Thursday, July 11, for the continuation of the detention
8
hearing. Thursday, July 11, at 2 p.m.
9
The defendant is detained at least until the
10
continuation of the detention hearing pursuant to 18 United
11
States Code 3142 (f)
12
I have been advised by Judge Berman that he wants to
13
see counsel right after these proceedings. Judge Berman's
14
courtroom is 17B. So counsel and Mr. Epstein should go to 17B.
15
All right. Anything else from the government?
16
MR.
:
Your Honor, ordinarily we would ask
17
to exclude speedy trial time, but I think because we are going
18
directly to Judge Berman, we have no such application.
19
THE COURT: Mr. Weingarten, anything else?
20
MR. WEINGARTEN: No, thank you, your Honor.
21
THE COURT: Mr. Weingarten, anything else?
22
MR. WEINGARTEN: No, your Honor.
23
THE COURT: All right. Thank you all.
24
o0o
25
SOUTHERN DISTRICT REPORTERS, P.C.
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=== Page 1 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
III Information
ADDITIONAL SENTENCING INFORMATION MAY BE AVAILABLE FROM ORIGINATING AGENCY
CRIMINAL HISTORY RECORD
Introduction
The information in this rap sheet is subject to the following caveats:
This record contains
information only. When explanation of a
charge or disposition is needed, communicate directly with the agency
that contributed the record information. (; 2021-10-06)
This record may only be used for the purpose requested as defined by
the Code of Federal Regulations and/or
(; 2021-10-06)
** Sealed pursuant to
** (; 2021-10-06)
This is a multi-source offender record. (; 2021-10-06)
IDENTIFICATION
1/14
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Fingerprint Images
(No Fingerprint Image Transmitted
Comment:)
DNA Data
(No DNA Detail Transmitted )
CRIMINAL HISTORY
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Cycle 009
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INDEX OF AGENCIES
Agency
Address
Agency
Address
Agency
Agency
Agency
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Agency
Address
Agency
Agency
Agency
Agency
*** END OF RECORD ***
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=== Page 1 ===
From: "Hamilton,
) [Contractor]"
To:
"
)"
Cc:
(NY) (FBI)"
)"
,
)"
Subject: RE: RE: financial documents (Epstein)
Date: Thu, 18 Jul 2019 15:17:24 +0000
I have the discs, where should I bring them?
From:
Sent: Wednesday, July 17, 2019 8:47 PM
To: Hamilton,
) [Contractor]
Cc:
(NY) (FBI)
>;
is
is
Subject: RE: financial documents (Epstein)
Tomorrow morning could you please burn the following folders to a disc:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY investigation\Subpoena
Returns\American Express
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\#2018 SDNYinvestigation\Subpoena
Returns\Deutsche Bank
and put the disc in an envelope addressed to:
Special Agent
Detective
If it's possible to get the disc by 11:30, we'll give the disc to
at the conference, or if not, if you could put
the envelope with security and reply all that it's ready, they can pick up when convenient.
thanks,
Assistant U.S. Attorney
Southern District of New York
212.637.2415
EFTA00014608


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=== Page 1 ===
JANE DOE #1
(
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
O.A. 2
3/12/04
EPSTEIN
Conspiracy to entice a minor to
engage in prostitution
O.A. 3
3/12/04
EPSTEIN
Conspiracy to entice a minor to
engage in prostitution
O.A. 95
2/6/05
EPSTEIN
Conspiracy to entice a minor to
engage in prostitution
O.A. 96
2/6/05
EPSTEIN
Conspiracy to entice a minor to
engage in prostitution
O.A. 97
2/6/05
EPSTEIN
Conspiracy to entice a minor to
engage in prostitution
O.A. 117
3/30/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 120
3/31/05
Conspiracy to entice a minor to
engage in prostitution
O.A. 122
3/31/05
EPSTEIN
Conspiracy to entice a minor to
engage in prostitution
O.A. 123
4/1/05
EPSTEIN
Conspiracy to entice a minor to
engage in prostitution
Ct 5
3/7/04 -
EPSTEIN
Enticement of a minor to engage in
3/11/04
prostitution
CONFIDENTIAL GRAND JURY MATERIAL
PAGE 1 OF 1
JANE DOE #1
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=== Page 1 ===
From:
To:
Subject: RE: Jeffrey Epstein pleads not guilty to sex trafficking charges
Date: Mon, 08 Jul 2019 19:15:45 +0000
Importance: Normal
you look great!!
Original Message
From:
Sent: Monday, July 08, 2019 15:13
To:
Subject: Jeffrey Epstein pleads not guilty to sex trafficking charges
Pretty good artwork of me.
https://nypost.com/2019/07/08/jeffrey-epstein-pleads-not-guilty-to-sex-trafficking-charges/
Sent from my iPhone
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=== Page 1 ===
From:
)"
To:
Cc:
)"
Subject: RE: Requested Info
Date: Thu, 03 Jan 2019 16:44:52 +0000
Importance: Normal
Inline-Images: image001.png
With apologies for the bother, and understanding that we've been in the midst of holidays, do you have a sense of when
we might be able to receive the list of clients represented
/ you / BSF currently represent? We're in the process of
planning a possible trip to Florida potentially as early as the beginning of next week and we think a meeting would be
most productive if we can do some groundwork on relevant individuals in advance, ideally today or tomorrow if at all
possible. Similarly, if we're able to get the confidentiality / protective order this week, we can consider what steps we can
take in the coming days regarding those issues as well.
If it would be helpful for us to do a call with
to make the requests directly, or to talk through any issues, we are also
very happy to do that, that's no problem at all. And if we are able to get that information this week, and we can get
permission and funding to travel next week, we can set up a meeting with him as well. We're on the starters blocks here
and very ready to start running (again, fully recognizing that the past couple weeks have been holidays and vacation time
for most folks).
thanks again,
From:
Sent: Saturday, December 29, 2018 16:04
To:
)
Cc:
Subject: RE: Requested Info
Yes, we will get that for you,
Best, S
EDWARDS
LLC
Partner
www.epllc.com
EFTA00014496

=== Page 2 ===
From:
Sent: Saturday, December 29, 2018 2:41 PM
To:
Cc:
Subject: RE: Requested Info
Thanks very much, this is helpful, and in terms of follow up, the absolute most helpful thing for us at this stage - - and this
may be forthcoming, but just wanted to reiterate - - would be to have a list of the names of the victims currently
represented by you / BSF /
If that needs to wait until
is back from vacation, that's no problem at all, but it
would just be, I think, the names of the plaintiffs in the VRA lawsuit (unless there are other civil suit clients separate from
that case and in addition to the two SDNY cases we've already discussed).
thanks again,
From:
Sent: Saturday, December 29, 2018 12:48
To:
)
Cc:
Subject: Requested Info
In further reply to your asks, here is some information that may be of help:
1.
has a list of all known victims of JE who were victims during the period of his trafficking in Florida.
also
knows the names of the lawyers who represent the girls. You have a number of lawyers' names from yesterday,
but
can match them up to specific clients, by names. He said that the USA also has that information-that is,
attorney names and their client names-so that may be how you prefer to proceed. He said there are 40 names
attached to the NPA, which I assume you have-or have access to. But
also has the names of additional girls,
beyond the 40, and will provide them to you. (He may be the only person who has these additional names. Not
sure that the USA or the Bureau has them.)
2. I will be receiving a copy of Judge Sweet's confidentiality order in
V. Maxwell and will forward it to you when
I get it. (Vacations this week are slowing things a bit.)
3. With regard to lawyers who represent, or did at one time, various victims and actors, here are their names as
recalled by
from his hammock on a beach with his wife and kids in Costa Rica, mojito (I am guessing) in hand:
LAWYERS FOR EPSTEIN: ALAN DERSHOWITZ, ROY BLACK. GUY LEWIS. MICHAEL TIEN. MARTY WEINBERG. BOB
CRITTON. MIKE PIKE. SCOTT LINK. REID WEINGARTEN. GERRY LEFCOURT. JAY LEFKOWITZ. KEN STARR. CHET
BREWER. JACK GOLDBERGER. FRED HADDAD. TONJA HADDAD. LIKLY SANCHEZ. JOE ACKERMAN. CHRIS KNIGHT.
MICHAEL MILLER. JUSTIN CHU. THERE WERE A COUPLE MORE INSIGNIFICANT ONES.
LAWYERS FOR PILOTS, JE HOUSE STAFF, AND
- All represented by BRUCE REINHART (now a
federal magistrate judge); ERICA DUBNO. JOHN STEPHENSON. (Make a note to discuss Erica Dubno, NYC attorney,
when we talk. I wonder if she might not be of some help.)
LAWYERS FOR GHISLAINE MAXWELL: REPRESENTED BY COHEN GRESSER FIRM FIRST, THEN LAURA MENNINGER,
DENVER, COLO.
OTHER ATTORNEYS PAID BY EPSTEIN WHO TO REPRESENT VARIOUS WITNESSES: MIKE DUTKO. "THERE ARE SEVERAL
OTHERS THAT SLIP MY MIND BUT ILL REMEMBER AND SEND THEM."
EFTA00014497

=== Page 3 ===
Best regards,
ГД
EDWARDS
LI
POTTINGER LLC
Partner
www.epllc.com
EFTA00014498


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
)"
Cc:
)"
(USANYS)"
Subject: RE: Request re Maxwell Relativity
Date: Tue, 08 Dec 2020 15:07:13 +0000
Inline-Images: image002.jpg
Hello
Can you please confirm that the below search is the correct data to secure:
US V. Epstein (SW Returns) - Potentially Non-Responsive - https://d1pe.nss.pae.com/Relativity/go?id=2370462-4350955
Can you also please confirm that the Potentially Non-Responsive data will be placed in two subfolders under the following
parent folders:
Search Warrant Returns
New_Search Warrant Returns_FBI
USvE_20200728
Thank you.
From:
Sent: Friday, December 4, 2020 10:55 AM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: Request re Maxwell Relativity
Now that we have completed our responsiveness review in the "US V Epstein (SW Returns)" database, we need to lock off
access to any non-responsive materials in that database. Would it be possible to please lock off access to the 397,365
documents in that database that are NOT currently tagged "Identified Responsive"? That should leave just the 1,218,719
documents that are tagged "Identified Responsive" accessible to the team for use in our case.
Happy to have a call to discuss if that would be useful.
Thanks very much,
EFTA00016464


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=== Page 1 ===
From:
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
)"
Subject: RE: Epstein Sharing Order Part II
Date: Thu, 30 Jan 2020 17:05:16 +0000
Just wanted to circle back on this -
are you signed off? Is this something we could get over to Part I today or
tomorrow? Thanks
From:
Sent: Wednesday, January 29, 2020 3:56 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
is it the intent to share those? If so, l'll just add it to every mention of each document, but if not then it's
unnecessary. I don't think those are substantive docs but I defer.
From:
(USANYS)
Sent: Wednesday, January 29, 2020 15:55
To:
>;
(USANYS)
Cc:
is
-
Subject: RE: Epstein Sharing Order Part II
Please add it in the right place and send me the order. Remember, I'm not a T&E lawyer. But you are getting to
be
From:
Sent: Wednesday, January 29, 2020 3:22 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
Yes, I think this document accurately describes the materials we've received, with just a note that it doesn't appear to
include revocations, so to the extent those are intended to be shared, I think that word may need to be added.
thanks,
From:
(USANYS)
Sent: Wednesday, January 29, 2020 10:40
To:
(USANYS)
is
Subject: Epstein Sharing Order Part Il
- I've updated the sharing order application to be one to share the additional trust and will documents we have now
received. Would you take a look when you can?
EFTA00016816

=== Page 2 ===
- I've tried to describe the various materials we have gotten from the estate attorneys over the last two weeks.
Would you mind taking a look (or asking a paralegal to take a look) to make sure I've accurately described/characterized
the new stuff we're looking to share?
Thanks,
EFTA00016817


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=== Page 1 ===
From:
To:
Subject: FW: SDNY NEWS CLIPS, OCTOBER 13, 2020
Date: Tue, 13 Oct 2020 15:13:23 +0000
Inline-Images: image001.png
A few Maxwell/Epstein articles here in case you're interested.
From
Sent: Tuesday, October 13, 2020 11:03 AM
To: 'Chiefs'
Co
Subject: SDNY NEWS CLIPS, OCTOBER 13, 2020
OF JUSTICE.
SDNY PRESS CLIPPINGS
JUSTITIA
MAXWELL
NYDN: https://www.nydailynews.com/new-york/my-jefrey-epstein-maxwellcase-20201013-jmzhl7zdrzdgrbbs7yc6bfnszu-story.html
NY POST: https://nypost.com/2020/10/11/new-photos-show-ghislaine-maxwel-at-anti-sex-trgficking-event/
US NEWS: https://www.usnews.com/news/top-news/articles/2020-10-13/ghislaine-maxwel-tourge-us-appeals-court-to-keep-damaging-deposition-secret
MOTHER JONES:https://www.motherjones.com/politics/2020/10/i-called-everyone-in-ieffrey-epsteins-Iittle-black-book/
CNN: https://www.cnn.com/2020/10/12/business/leon-black-jeffrey-epstein-opollo/index.htmi
OK: https://okmagazine.com/exclusives/jeffrey-epstein-withdrew-800k-cash-arrest/
NYT: https://www.nytimes.com/2020/10/13/books/review/what-tech-calls-thinking-adrian-daub.html
MATTERS OF INTEREST
POLITICO: https://www.politico.com/newsleters/weekly-transportation/2020/10/13/a-tale-of-two-responses-to-pandemic-travei-790929
TELEGRAPH: https://www.telegraph.co.uk/technology/2020/10/12/microsoft-takes-massive-cyber-crime-network-feors-will-used/
CNN: https://www.cnn.com/2020/10/12/politics/judges-reject-voterfraud-claims/index.html
BLOOMBERG: https://news.bloombergtax.com/financial-accounting/fraud-and-ineptitude-undermine-covid-relief-opinion
NYT: https://www.nytimes.com/2020/10/12/nyregion/cuomo-coronavirus-orthodox-shutdown.htn
BUZZFEED NEWShttps://www.buzzfeednews.com/article/kenbensinger/new-york-owed-money-man-tweeted-trump-ventilators
JD SUPRA: https://www.jdsupra.com/legalnews/rnc-deputy-finance-chair-elliott-broidy-29590/?
THE HILL: https://thehill.com/homenews/house/520712-two-ethics-groups-cal-on-house-to-begin-impeachment-proceedings-against-bar-
WAPOhttps://www.washingtonpost.com/politics/2020/10/13/democrats-confirmation-hearing-/flubs-loom-over-barret-hearing/
BUFNWhtps:/buffolonews.com/news/local/inexplicblepenivecolinsprepores/or-prison-while-blasting-prosecutorsjudge/atice d80624e-0c6-11eb-d885-ef62ad25901.htm
BUSINESS INSIDER:https://www.businessinsider.com/exclusive-interview-rick-gates-book-mueler-star-witness-2020-10
BREITBART: https://www.breitbart.com/2020-election/2020/10/12/polak-joe-bidens-disastrous-shortlist-for-attorneygeneral-cuomo-yotes-abrams-bharara-weisman/
NBC: https://www.nbcrightnow.com/crime/free-human-trafficking-awarenes-webinar/article_ec374086-0c1-11eb-803a-fb1024d21d4.html
BARRON'S: https://www.barrons.com/articles/deutsche-bank-makes-bold-buy-call-on-ford-stock-51602597239
LEXOLOGY: https://www.lexology.com/library/detail.aspx?g=6b349d6e-eafe-43d4-ae3e-33005f4ffe6d
CNN: https://www.con.com/2020/10/13/us/nypd-election-protest-deployment/index.html
EFTA00015207

=== Page 2 ===
EFTA00015208


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=== Page 1 ===
From: "Kathleen E. Cassidy"
To:
Cc: Susan Necheles
>, , Samidh Guha
Subject:
Date: Tue, 31 Mar 2020 01:40:03 +0000
Attachments: 2020.03.30
final_submission_(910pm).pdf
Attached is our submission on behalf of our client
Please let us know if you have any questions. Take care and stay healthy.
Best,
Kate
Kate Cassidy
Hafetz & Necheles LLP
EFTA00016236


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=== Page 1 ===
Begin forwarded message:
Forwarded message
From:
Date: Wed, Sep 29, 2010 at 4:22 PM
Subject:
Trip to NYC
To:
Dear
It was lovely to meet you outside Kinnerton St the other day, although I think we may
have met before sometime.
I am booked to come to NYC on the 15th through the 21st of October and would be
delighted if there might be a place for me to stay.
Please let me know asap.
I may also be coming to Paris this weekend and wondered if team Epstein will still be
there?
EFTA00015034

=== Page 2 ===
I can be reached by return email or on my cell
Best
Tel:
?
This message is for the designated recipient only and may contain privileged,
proprietary, or otherwise private information. If you have received it in error,
please notify the sender immediately and delete the original. Any other use of
the email by you is prohibited.
EFTA00015035


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: MCC Visit Thursday
Date: Wed, 14 Aug 2019 16:25:34 +0000
Hi
Not a problem. I will add them to the list. Do you have everyone's titles?
I will advise the Warden of the request that he accompany us on the tour.
Thank you
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
-
150 Park Row
New York, New York 10007
> 8/14/2019 12:17 PM>>>
Two additional people from DOJ will join the visit:
In addition,
has asked that the new acting warden join the tour. Let me know if you have any questions, thanks.
From:
Sent: Tuesday, August 13. 2019 4:03 PM
To:
Cc:
Subject: RE: MCC Visit Thursday
If it is not too much of an imposition, we ask that all visitors come to our front lobby for screening before admission. Thanks!
>>>
(USANYS)" <
>
8/13/2019 3:58 PM >>>
Yes, thank you. Where should we go?
From
Sent: Tuesday, August 13, 2019 3:38 PM
To:
EFTA00017761

=== Page 2 ===
Cc:
Subject: Re: MCC Visit Thursday
Hi
It should not be a problem. Does 10 am work for Mr. Berman and the rest of his staff?
Thank you,
Supervisory Staff Attorney
CLC New York
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
> 8/13/2019 2:05 PM >>>
The list of visitors from our office is below:
As discussed, we would like to see the 2nd floor pscyh observation and suicide watch area; the 9th floor SHU, and Epstein's
cell, which we understand to still be cordoned off. As discussed, we would appreciate if only MCC legal would escort us,
and we will not speak to any of the guards present given the ongoing investigations. Please give me a call with any
questions, and let us know what time and where we should go, and if it would be easier for us to enter via the 3rd floor
bridge.
Thanks,
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00017762


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=== Page 1 ===
From:
)"
To:
Cc:
)"
Subject: FW: travel approval request
Date: Thu, 12 Dec 2019 23:10:22 +0000
Hi
In connection with this trip, could you please assist with booking the following travel? Thanks!
Hotel-same as last time, the DoubleTree in Santa Monica is fine. Checking in 12/15, checking out the next day
We do not need a conference room
Outbound flight: Sunday, 12/15, departing JFK at 11:40 am on Delta, landing at LAX at 3:01 p.m.
Inbound flight: Monday, 12/16, departing LAX at 8:32 p.m. on JetBlue, landing at JFK at 4:47 a.m.
If you could please make all flights refundable, that would be great - it's possible we'll need to rebook parts of
this if witness availability changes or we're able to stay longer and meet with an additional witness.
Thanks a bunch.
From:
Sent: Wednesday, December 11, 2019 10:01 AM
To:
Cc:
is
is
is
is
Subject: RE: travel approval request
Approved
From:
Sent: Wednesday, December 11, 2019 9:58 AM
To:
Cc:
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 for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16
and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior trips,
we'd like to request approval to get a conference room for one of those days.
thank you,
EFTA00016932

=== Page 2 ===
From:
Sent: Tuesday, November 05, 2019 16:53
To:
Cc:
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 for the team to travel next week for an interview in Los Angeles on November 14. We expect to be traveling,
respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip).
thanks,
From:
Sent: Tuesday, October 22, 2019 13:55
To:
>
Cc:
is
V.
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,
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,
EFTA00016933

=== Page 3 ===
From:
Sent: Friday, May 24, 2019 14:57
To:
Cc:
is
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
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.
EFTA00016934

=== Page 4 ===
From:
Sent: Thursday, March 14, 2019 18:32
To:
Cc:
Subject: travel approval request
and I would like to please request permission for travel for United States V. Epstein, 2018R01618, an
investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on
Saturday.
Please let us know if any other information would be helpful, and thanks as always.
Assistant U.S. Attorney
Southern District of New York
EFTA00016935


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=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: Tartaglione document request
Date: Mon, 14 Dec 2020 17:55:11 +0000
Embedded: RE:_Tartaglione_document_request.msg
Sender:
Subject: RE: Tartaglione document request
Message-Id: <5FD7A6F6020000DE000DFFA4@SMTP1.BOP.GOV>
Recipient:
EFTA00016540


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=== Page 1 ===
From:
)"
To: Nathan NYSD Chambers
Cc:
)"
)"
>, , Jeff
Pagliuca
>, , Laura Menninger
,
bcsternheim mac.com
, Christian Everdell
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Reply letter
Date: Sun, 28 Nov 2021 23:11:07 +0000
Attachments: 2021-11-28_GM_reply_re_precluding_cross_[final].pdf
Chambers,
Please see the attached reply letter regarding the Government's motion to preclude certain cross-examination. The
Government respectfully submits this letter under seal.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00014898


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=== Page 1 ===
From:
To:
Subject: Material Witness PA
Date: Fri, 03 Apr 2020 23:30:56 +0000
Attachments: Material_Witness_PA_4.02_Final_ signed.pdf; ATT00001.htm
I've attached the request.
I will follow this up next week with an email explaining the process which usually follows after the Home Office
receives an MLA request.
Have a great weekend.
Best.
EFTA00016244


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=== Page 1 ===
11/26/21, 7:20 PM
Mail
(NY) (FBI) - Outlook
[EXTERNAL EMAIL] - Re: Spreadsheets
Wed 10/13/2021 10:55 AM
To:
Cc:
>
Disregard
On Oct 13, 2021, at 10:49,
>
wrote:
Is this for the trial exhibit material? I sent it last week
From: BYRNE,
Sent: Tuesday, October 12, 2021 7:06 PM
To:
>;
Subject: [EXTERNAL EMAIL] - Fwd: Spreadsheets
FYI
They had asked me to ask you about this project.
Not sure if you were aware of this.
Begin forwarded message:
From:
Date: October 12, 2021 at 19:04:31 EDT
To:
Subject: Spreadsheets
CAUTION! EXTERNAL SENDER
STOP WHEN UNSURE. Never click on links or open attachments if sender is unknown,
and never provide user ID or password. Suspicious? Please report to this email
address: reportphishing@nypd.org
Just spoke with
about this to check in, but if we could get these spreadsheets by
tomorrow morning that would be ideal.
Thanks!
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
1/2
EFTA00014963

=== Page 2 ===
11/26/21, 7:20 PM
Mail
(NY) (FBI) - Outlook
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
2/2
EFTA00014964


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=== Page 1 ===
From: "Roy BLACK"
To:
Subject: Jeffrey Epstein
Date: Tue, 17 Jun 2008 14:12:38 +0000
Importance: Normal
is there a chance I could discuss the epstein investigation with you? My office number is
and cell
Thanks Roy
EFTA00014170


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=== Page 1 ===
From:
To:
Cc:
,
>, , "Martin G. Weinberg"
Subject: U.S. V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Date: Tue, 16 Jul 2019 21:49:16 +0000
Importance: Normal
Attachments Exhibit_C_(under_seal).pdf; 2019-07-16_JE_detention_submission_(under_seal).pdf;2019-
07-16_JE_detention_submission_Redacted.pdf;Exhibit_A.pdf;_Exhibit_B_(under_seal).pdf
Dear Judge Berman,
Attached are courtesy copies of the Government's supplemental submission, which has been filed on ECF. In particular,
we have attached both the redacted (and publicly filed) version of the Government's submission, as well as an unredacted
version, which is respectfully requested to be filed under seal.
Attached are three exhibits. Exhibit A has been publicly filed on ECF. Exhibits B and C are respectfully requested to be
filed under seal.
Sincerely,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00014606


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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 17:26:16 +0000
Inline-Images: image001.png
Congratulations guys. Amazing work.
From
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA JUSTITIA OF JISTICE.
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.
EFTA00017713

=== 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.
EFTA00017714

=== 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.
EFTA00017715


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=== Page 1 ===
From:
To:
Subject: FW: CACI Proposal-USAO SDNY US V. Maxwell Epstein Scanning
Date: Wed, 24 Mar 2021 16:25:43 +0000
Attachments: SDNY_US_v_Epstein.pdf;
35058_GSA_S36_USAO_SDNY_Epstein_Scanning_Submission.xlsx
Inline-Images: image001.png
Oh! I was going to ask if you had any update on this.
From:
Sent: Tuesday, March 23, 2021 4:42 PM
To:
Subject: Fwd: CACI Proposal-USAO SDNY US V. Maxwell Epstein Scanning
I have
and
going ahead with this. It will be in place if Florida breaks down. If Florida comes through, we just
cancel it. CACI understands.
Sent from my iPad
Begin forwarded message:
From:
Date: March 23, 2021 at 4:40:09 PM EDT
To:
Cc:
Subject: Fwd: CACI Proposal-USAO SDNY US V. Maxwell Epstein Scanning
Please go ahead with this. Time sensitive.
I suggest using AFF for now.
Sent from my iPad
Begin forwarded message:
From:
=
Date: March 23, 2021 at 3:56:48 PM EDT
To:
Cc:
Subject: CACI Proposal-USAO SDNY US V. Maxwell Epstein Scanning
Hello
EFTA00016153

=== Page 2 ===
I hope this email finds you well and that you are having a wonderful Tuesday.
In response to the Request for Proposal, attached is CACI's proposal information for your review and
consideration.
Please let me know if you have any questions
Respectfully,
I
Contracts Administration
CACI INC. - Federal
Shared Services Center
7725 West Reno Ave.
Oklahoma City, OK 73127
Cell Phone:
Office Phone:
Email:
This electronic message contains information from CACI International Inc or subsidiary companies, which may be company sensitive, proprietary, privileged or
otherwise protected from disclosure. The information is intended to be used solely by the recipient(s) named above. If you are not an intended recipient, be
aware that any review, disclosure, copying, distribution or use of this transmission or its contents is prohibited. If you have received this transmission in error,
please notify us immediately at
With the exception of messages sent by authorized CACI contracts or purchasing personnel, nothing in
this message may be interpreted as a digital or electronic signature that can be used to: (a) authenticate either the submission or the acceptance of a proposal
or offer to contract, or (b) modify an existing contract.
CACI
EVER VIGILANT
EFTA00016154


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
)"
Cc:
)"
Subject: RE:
Date: Mon, 12 Apr 2021 17:21:14 +0000
Yes, we went with the conservative approach of pulling all the emails in the folder.
Original Message
From:
(USANYS)
Sent: Monday, April 12, 2021 1:20 PM
To:
(USANYS) [Contractor]
Cc:
Subject: RE:
is traveling. I took a look in the folder - it looks like you pulled all of the emails for the second
production, right? That seems right to me, thanks again.
Original Message
From:
(USANYS) [Contractor]
Sent: Monday, April 12, 2021 11:09 AM
To:
Cc:
i
(USANYS)
Subject: RE:
Hey
,
Should all of the emails in the folder be pulled or just the ones found in the "Emails Epstein Investigation"
folder?
Thanks,
Original Message
From:
Sent: Monday, April 12, 2021 9:06 AM
To:
(USANYS) [Contractor]
Cc:
(USANYS)
Subject:
Hi
For this folder, could you please pull the emails that are in the folder and put them in a second production folder?
We'll review them later for a second wave. Thanks!
Sent from my iPhone
EFTA00015855


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=== Page 1 ===
From:
To:
Cc:
) [Contractor]"
Subject: RE: Epstein
Date: Mon, 18 Mar 2019 04:41:25 +0000
Circling back / following up on the records issue, and adding
to this chain, it looks like we have some version of the
case file as it existed with the FOIA office in D.C. But when I last spoke with D.C., they said that they had only been able to
transfer approximately 16,000 pages - out of 29,000 total - to
an you remind what the latest is with D.C. in terms of figuring out what they actually transferred to
? I can't
tell from looking at the hard drive we have uploaded. I want to get it onto Relativity, but not if it's just a subset and we're
still working on getting the whole file from them.
I changed the file title slightly to reflect its contents - and some time when I can let the file transfer run overnight l'll put it
as a subfolder in FBI materials, but for now it's here -
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\nvestigation\2019-03-06,case file from DC, hard
drive
I also moved the folder of video discs we got into the 72 File folder, since those were all from that investigation (the black
book sting).
Was thinking of this just because I want to make sure any docs we're getting are put on Relativity for review - l'll do the
same for the Boies docs, and it made me think of the D.C. stuff too since I think we may be a little stalled on that (unless
what
got was in fact the full 29,000 pages).
From:
)
[Contractor]
Sent: Thursday, March 07, 2019 12:00
To:
Cc:
(NY) (FBI) ;
Subject: RE: Epstein
Hi
The materials on the hard drive
dropped off have been placed here:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\2019.03.06Hard Drive
She also dropped off a number of discs, which have been individually loaded here:
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\2019.03.06 Discs
Please let me know if you have any questions.
Best,
From:
Sent: Wednesday, March 6, 2019 1:28 PM
To:
)
[Contractor]
Cc:
(NY) (FBI)
is
Subject: Epstein
Hi
The FBI has a large amount of data for us on the Epstein case-can the case agent,
(copied here) give you
the data for uploading to the shared? If you guys could coordinate on the logistics, that would be great.
Thanks!
Assistant United States Attorney
Southern District of New York
EFTA00016295

=== Page 2 ===
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=== Page 1 ===
Exhibit C
EFTA00016532

=== Page 2 ===
30th November 2020
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
Dear Judge Nathan:
I have known Ghislaine
all her life.
Ghislaine and I have always enjoyed
sharing the personal experience of our lives with each other.
she was
full of 'vim and vigor' and always just lovely to be with.
she and I have seen our
relationship strengthen through shared common interests. In particular, Ghislaine's passion
for making a positive difference in the world, notably through her creation of the non-profit
TerraMar Project focusing on the protection of the world's oceans, gave me
Although always in touch we have talked
and met up much more consistently over the past seven years
It is a joy to
be
one of her best friends.
1 I Page
EFTA00016533

=== Page 3 ===
Throughout her school life Ghislaine
always had friends and seemed to be genuinely grounded in her love of life and learning. We
were all quite proud when she graduated from Oxford with her Bachelor's degree. She,
learned early on the value of hard work
Around 1990, Ghislaine came to live in New York to continue
Maxwell Corporate Gifts, a successful company she had founded in the UK which was
subsequently absorbed
in 1991, Ghislaine had to rely on her personal
compass, inner resilience and sheer determination to build a fresh life for herself. Her prior
'big picture' experience, top-level entertaining skills and talent for organizing, coupled with
her multi-cultural and multi-lingual sophistication, opened doors into New York society.
Although it is true that for many years Ghislaine was frequently involved in high society and
attended fashionable social gatherings; what irks me greatly is the press's one dimensional
'socialite' focus on Ghislaine, that completely denies and refuses to acknowledge the very
serious, highly intellectual and passionate caring sides of Ghislaine. For example, since 2003,
Ghislaine devoted all her energy, her own financial resources and intellectual skills to helping
save the Oceans, through her establishment of the not-for-profit company, The Terramar
Project. Ghislaine's deep knowledge and appreciation of the significant role the oceans play
in our world's fragile ecosystem enabled her to work with key partners to influence the
United Nations in 2014 in enunciating its Sustainable Development Goal 15 "To conserve
and sustainably use the oceans, seas and marine resources for sustainable development."
Indeed, it seemed so clear to me that this mission encompassed her life's passion and offered
a way for her proactively to give something back of real value to society.
Ghislaine showed a huge amount of courage and forbearance in the face of great adversity
and in the years that followed. I have seen this strength more than ever
during the times
Despite the tremendous daily pressures she has been under, notably from the world's media,
universally hostile to her, she has shown simultaneously a deal of humility and fortitude. She
has the profoundly deep conviction (through every fibre of her being) of her innocence in the
face of all the unsupported accusations and criminal charges latterly filed against her.
To the best of my knowledge and belief,
Ghislaine has never been brought in for
questioning, arrested, or charged with any criminal offense by law enforcement until now.
Notwithstanding the seriousness of the offenses with which she has been charged, as a US
Citizen, she has the constitutional right to the presumption of innocence and a fair trial. For
the purpose of increasing their profits by boosting TV ratings and / or newspaper readership,
the world's media has aired or printed the most heinous accusations against her, in some
cases for years now, that have never been cross-examined in a criminal court in front of an
2 I Page
EFTA00016534

=== Page 4 ===
independent judge and jury. Ghislaine is not a malicious or jealous person. In all the
I have known her, I have never seen her be violent or act inappropriately against anyone, let
alone young adults or children as has been alleged.
I
believe in her innocence. I know
she would never do anything to put my life or my family's life in jeopardy in any way, which
is why I have no hesitation in placing the one property that I own - which is my only nest-
egg for my retirement-up as part of her bail application. The value is $1.5 Million dollars. I
do not have any other savings and it would be completely devastating financially and in every
way to my own family were the house to be taken over by the Government due to a breach of
bail conditions. I know in every fibre of my being that
Ghislaine will
never try to flee and will absolutely turn up to her trial, to have the opportunity to fight the
charges against her. Based on my deep knowledge and experience with Ghislaine
I totally trust and believe that I do not have to worry in any way about my home being
put up as a part of her bail application.
Until her arrest, I spoke often with Ghislaine over the phone and in the early summer of this
year, two to four times a week.
I witnessed how hard she worked every day and well into the nights going through the
ever-growing tsunami of press clippings, videos, audio files, etc, that so gravely traduced her
and continue to do so. Ghislaine is completely horrified and flabbergasted by these
unfounded and completely horrendous accusations, as indeed am I.
I feel totally safe around Ghislaine, in fact, I feel safer with her. I have never had any
hesitation in my children visiting her or being with her - as they have been - both as young
children and now they are older. Neither they nor I have ever seen any signs or signals of the
alleged criminal conduct. I personally witnessed her be a warm, lovely, understanding and
caring
When visiting Ghislaine more recently as well as in
the past
I was
impressed by her interaction with them and by their evident trust in and great affection for her
which was entirely natural and unforced. Every exchange was totally normal and just lovely
to watch how each of these
clearly liked
and she them. Although
Ghislaine was certainly part of the New York social scene in the past, for many years, it had
become clear to me that she was happy in a long-term loving relationship with her previous
partner of over 7 years far away from the New York scene and with
leading a happy family life with people she loved and trusted and who were similarly equally
loving and trusting of her. I saw the same pattern of strong domesticity and family happiness
with her spouse
I have personally witnessed how much they love
being with and being loved by Ghislaine.
In terms of character, Ghislaine is compassionate, capable, and proactive. Ghislaine is very
kind and caring. She brought
to stay with
her in New York for extended periods so that they could spend quality time together. She
took them all around the US to see the sights and to visit with family and friends. Even under
the terrible weight of her present circumstances, she has consistently demonstrated her
consideration for others. Whenever we spoke, she asked about
The fact that she could care enough and not just be thinking only of herself at this impossible
time remains deeply moving to me.
3 I Page
EFTA00016535

=== Page 5 ===
has called the United States her home for almost 30 years. She has deep affective
family ties here in this country
Most of all, her
own husband
are here. During the past 18 months in particular Ghislaine has
gone out of her way to continue to stay in the United States expressly so that she could put
her case forward in a court of law should it ever come to that. I therefore feel great
consternation and deep shock and sadness when I hear about the conditions of her present
incarceration, which include over 150 days of solitary confinement and other extreme
deprivations and restrictions. The great toll that this physical, mental, and emotional stress is
taking on
makes it even more impossible for her to adequately prepare her defence
from inside jail.
If she is granted bail, I will be in continuous touch with her during the weeks and months
leading up to her trial, providing whatever support I can while she has the chance to fairly
prepare for her upcoming trial and fight for her innocence.
I am grateful for the opportunity to provide this statement.
Sincerely,
4 I Page
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=== Page 1 ===
From:
"
(USANYS)"
To:
)"
(USANYS)"
Cc:
)"
)"
Subject: RE: Epstein Sharing Order Part II
Date: Fri, 31 Jan 2020 19:00:32 +0000
I am also okay with those changes. Thanks
From:
Sent: Friday, January 31, 2020 1:50 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
Those highlights look okay to me, but I defer to
on final approval.
From:
(USANYS)
Sent: Friday, January 31, 2020 11:43
To:
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part II
OK, I made some idiosyncratic changes, plus a few things highlighted in green for you to verify. I have one Q set
forth in the footnote.
From:
>
Sent: Friday, January 31, 2020 11:29 AM
To:
(USANYS)
in
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
is out, but the clerk's office says to use the same miscellaneous number because the applications are related. The
prior misc number was: 19 Misc. 0586
And attached for reference in case that's helpful.
From:
(USANYS)
Sent: Friday, January 31, 2020 10:32
To:
(USANYS)
is
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
Working on it right now.
please check with
to see if we should use the same docket no as was
assigned to the first 6e order.
EFTA00016818

=== Page 2 ===
From:
(USANYS)
Sent: Friday, January 31, 2020 9:54 AM
To:
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part II
Great, thanks for catching.
let us know if you have any comments/thoughts. Thanks
From:
Sent: Friday, January 31, 2020 9:53 AM
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
Yes, this looks good, thanks - I made one more typo correction in the attached (in the new Trust Two language, "and
revocations" got repeated in the footnote and the order) but otherwise no changes.
From:
(USANYS)
Sent: Friday, January 31, 2020 09:48
To:
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part II
Thanks for flagging,
I made a few small changes (which I highlighted since we've got a fair bit of track already) which
I think should make this broad enough to cover the Trust II stuff. Can you take a quick look and if everyone is okay with
this, perhaps we can plan to get this to CM on Monday morning? Thanks
From:
Sent: Thursday, January 30, 2020 7:22 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
I apologize for the delay on this - I've added the relevant language about revocations to both the application and the
order, and corrected a stray typo, so that stuff is good to go. But two quick things to note, not to belabor this, but - it
doesn't look like there's any reference to the Trust Two documents - that may be because they're not referenced in any
will? At a glance I don't see Trust Two in any of the wills, but I'd want to go back and look more thoroughly unless
somebody already made the decision on that basis. And second, it references a 2019 Trust but I don't see any documents
on that? I have to run out tonight but can certainly circle up with
and/or
tomorrow on any of this, or just ignore
it if I've misread.
thanks,
From:
(USANYS)
Sent: Thursday, January 30, 2020 12:05
To:
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
Just wanted to circle back on this -
are you signed off? Is this something we could get over to Part I today or
tomorrow? Thanks
EFTA00016819

=== Page 3 ===
From:
Sent: Wednesday, January 29, 2020 3:56 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
Subject: RE: Epstein Sharing Order Part Il
is it the intent to share those? If so, l'll just add it to every mention of each document, but if not then it's
unnecessary. I don't think those are substantive docs but I defer.
From:
(USANYS)
Sent: Wednesday, January 29, 2020 15:55
To:
)
y.
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
Please add it in the right place and send me the order. Remember, I'm not a T&E lawyer. But you are getting to
be
From:
Sent: Wednesday, January 29, 2020 3:22 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: RE: Epstein Sharing Order Part Il
Yes, I think this document accurately describes the materials we've received, with just a note that it doesn't appear to
include revocations, so to the extent those are intended to be shared, I think that word may need to be added.
thanks,
From:
(USANYS)
Sent: Wednesday, January 29, 2020 10:40
To:
(USANYS)
is
)
>
Subject: Epstein Sharing Order Part Il
- I've updated the sharing order application to be one to share the additional trust and will documents we have now
received. Would you take a look when you can?
- I've tried to describe the various materials we have gotten from the estate attorneys over the last two weeks.
Would you mind taking a look (or asking a paralegal to take a look) to make sure I've accurately described/characterized
the new stuff we're looking to share?
Thanks,
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From:
)"
To:
"
(NY) (FBI)"
Cc:
(NY) (FBI)"
(NYPD)"
)"
(USANYS)"
Subject: Image/Video file review for Maxwell case
Date: Fri, 16 Oct 2020 17:45:05 +0000
Hi
My supervisors gave me your name as the point of contact at the FBI to help coordinate the review of images and videos
from Jeffrey Epstein's devices for discovery in the Ghislaine Maxwell case. Thank you so much for being willing to help out
with this while
and
are traveling.
I've spoken with
about some of the logistics, and it would be great if you and I could have a call to talk about
next steps. Is there a time this afternoon when you would be free for a call?
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00015209


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=== Page 1 ===
From:
)"
To:
)"
N. (NY) (FBI)"
,
)"
Subject: RE:
Checks
Date: Tue, 02 Jul 2019 01:16:24 +0000
Importance: Normal
Hi
Thanks, we'll take a look-if you could send over a summary of her flights with him over the past 6 months, that would be
helpful. Have you guys looked at the phone numbers associated with the email accounts we got subscriber info for? Let us
know if you think any of those numbers are live.
Thanks,
From:
Sent: Monday, July 1, 2019 8:53 PM
To:
)
>;
)
>;
N. (NY) (FBI)
is
^
Subject:
Checks
See attached phone records for
As per our conversation her cell phone number may be
relevant to her recent travels with Epstein.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
EFTA00014449


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=== Page 1 ===
From:
(USANYS) [Contractor]"
To:
(USANYS)"
)"
Cc:
)"
Subject: RE: NT 3500
Date: Sun, 11 Apr 2021 06:48:02 +0000
Hey, I think we'll plan on starting stamping early tomorrow afternoon. Let me know if we should be holding off on certain
folders for your review.
From:
(USANYS)
Sent: Saturday, April 10, 2021 7:01 PM
To:
is
(USANYS) [Contractor]
Cc:
Subject: RE: NT 3500
Hi
I indicated a few additional folders that should be deleted:
(I could not change the title of this folder from "To Discuss" to "Delete")
I am done reviewing the first 100 folders so if you want to get started stamping, please feel free. (If you are planning to
start tomorrow, let me know as I may look back over one or two folders).
Thank you again!
From:
Sent: Saturday, April 10, 2021 12:33 AM
To:
(USANYS) [Contractor]
Cc:
is
(USANYS)
Subject: NT 3500
Hi
Thanks for all your work on this project. I few things from my review, though l'll likely send some additional things
tomorrow:
The
folder contains just one report, and I think that goes in the
folder instead.
Please move it and delete his folder. Same thing for the
folder.
are the same person and the folders can be merged under the name
is the same person as
a potential testifying witness. Could you please move those
materials and delete the folder?
The stuff in the
folder should actually go in the
folder, and you can delete
the one for Pry once the stuff is moved over.
EFTA00015829

=== Page 2 ===
In the
folder, there's a transcript of a deposition of Mark Epstein. Could you please move that into a
new, NTW folder for him?
could you please
move these to the not-a-witness folder you created? We'll deal with the contents later, but not in the context of
the NTW production.
Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00015830


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=== Page 1 ===
UNITED STATES DISTRICT COURT
USDC SDNY
SOUTHERN DISTRICT OF NEW YORK
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 11/28/21
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 Government's letter motion to preclude certain lines of
cross-examination of Government witnesses. The Court hereby GRANTS the Government's
request to file the letter motion under seal in order to protect the privacy interests of anticipated
witnesses, including those who are subject to the Court's pseudonym order. See Lugosch V.
Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006).
The Defendant is hereby ORDERED to respond by today, November 28, 2021, at 2:00
p.m.
so ORDERED.
Dated: November 28, 2021
New York, New York
Alim D.Netto
ALISON J. NATHAN
United States District Judge
EFTA00014896


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: interlocutory appeals
Date: Mon, 21 Dec 2020 19:55:25 +0000
Attachments: Maxwell_Brief_re_Interlocutory_Appeals.pdf
Assistant United States Attorney
Southern District of New York
Office
Cell:
Email:
EFTA00015971


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=== Page 1 ===
From:
To:
Subject: detention memo
Date: Wed, 01 Jul 2020 16:50:35 +0000
Attachments: 2020-07-01,GM,_detention_memo.docx
Here's the most recent version. Thanks.
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00014392


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=== Page 1 ===
From:
To:
Subject: couple JE things
Date: Sat, 29 Jun 2019 20:20:14 +0000
Importance: Normal
Attachments:2019-06-29,_JE_government_unsealing_request_and_order.docx;2019-06-
29,_JE,_victim_notification,_arrest,_draft.docx
In an effort to reduce the number of things we'll have to scramble to do whenever the arrest occurs, there are a couple
new saved docs in the share for whichever one of us ends up handling particular random things - in the Grand Jury /
Indictment materials folder is an unsealing request and proposed order, since we'll want to do that immediately upon
arrest.
Also, I created a new "Victim notification" folder and added a draft of what I think we should put up on a victim
notification page on our website (like
), which we can add updates to as the case goes along.
can put that up
when it's time.
Neither is any rush at the moment, obviously, but they're attached in case anybody wants to take a look and have any
comments / corrections / edits so they're ready to go when necessary. And if either of you can think of anything else we
should be doing now to save ourselves a few minutes down the road, say the word! Thx.
Assistant U.S. Attorney
Southern District of New York
EFTA00014435


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=== Page 1 ===
From:
To:
Subject: RE: pictures
Date: Mon, 29 Jun 2020 00:40:05 +0000
Attachments: Roberts_Defamation_Complaint.pdf
Here's the defamation complaint.
From:
Sent: Sunday, June 28, 2020 8:38 PM
To:
Subject: Re: pictures
Yes I will be. What's up?
-
On Jun 28, 2020 8:36 PM,
wrote:
I forgot to ask earlier: are you heading into the office afterwards?
Sent from my iPhone
On Jun 28, 2020, at 8:23 PM,
wrote:
No problem. Thanks for the heads up.
From:
Sent: Sunday, June 28, 2020 8:21 PM
To:
Subject: pictures
H
FYI, I swapped out some of the pictures in the powerpoint to these ones, but they're the same subjects.
Assistant United States Attorney
Southern District of New York
EFTA00014395


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=== Page 1 ===
From:
"
)"
To:
)"
Subject: RE: 2019 Right of Access
(Epstein). pdf
Date: Mon, 15 Jul 2019 21:42:11 +0000
Importance: Normal
Thanks,
From:
)
Sent: Monday, July 15, 2019 10:45 AM
To: Skotko,
is
)
Subject: 2019 Right of Access
(Epstein). pdf
Not super relevant to Reporters Committee, but at least the latest word on the subject of right of public access
EFTA00014516


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=== Page 1 ===
From:
To: BOBBI C STERNHEIM
Cc: Christian Everdell
"Mark S. Cohen"
Subject: RE: Ghislaine Maxwell 02879-509
Date: Tue, 29 Dec 2020 17:49:42 +0000
Bobbi,
I just spoke with MDC legal counsel. Below are the responses to your concerns:
MDC legal confirmed that since the beginning of the pandemic, MDC inmates in general population have been
permitted out of their cells for no more than 3 hours per day. For approximately the past month, MDC inmates in
general population have been permitted out of their cells for no more than 30 minutes per day due to a lockdown at
the institution. When that lockdown is lifted, inmates will still be permitted out of their cells no more than 3 hours
per day while the pandemic persists. Accordingly, Ms. Maxwell has far more hours out of her cell than any other
inmate in the MDC at this time. The MDC will not further expand that time. As I previously noted, if general
population inmates eventually end up receiving more than 13 hours per day out of their cells, I will ask that Ms.
Maxwell receive the same amount of time.
I have again asked MDC legal counsel if Ms. Maxwell may use the laptop on weekends. MDC legal counsel
indicated they would pass that request up their chain and would circle back to me with a response.
MDC legal counsel confirmed that no staff member has ever directed Ms. Maxwell to remain in a particular location
within her isolation cell. They confirmed that staff understand that no such directions should be given.
MDC legal counsel confirmed that Ms. Maxwell has continued to have access to the laptop 13 hours per day every
weekday. That access has been documented, and MDC legal counsel is not aware of any restrictions on Ms.
Maxwell's use of the laptop during those times.
MDC legal counsel confirmed that staff absolutely cannot see Ms. Maxwell when she showers and do not record her
when she showers. They indicated that Ms. Maxwell has two shower curtains that cover her when she showers
such that only her feet are visible when she is in the shower.
MDC legal counsel confirmed that staff have not observed any condensation on the walls of Ms. Maxwell's isolation
cell. The most recent temperature reading from Ms. Maxwell's isolation cell, which was taken last night, indicated
the cell was 72.8 degrees. Ms. Maxwell currently has three blankets in her cell and is the only inmate in the entire
institution that is permitted to have a third blanket in her cell.
MDC legal counsel indicated that Ms. Maxwell is patted down when she is moved, just like any other inmate. She is
wanded once per week when she receives a body scan. MDC legal counsel confirmed that staff do not put their
fingers inside of Ms. Maxwell's (or any other inmate's) mouth. MDC legal counsel is inquiring as to the frequency
of searches during which Ms. Maxwell is required to lower her mask and open her mouth and will circle back to
me with that information. They understand my request that those searches be kept to a minimum. MDC legal
counsel (and I) have never heard of in-and-behind ear searches. Would you be able to explain what that term refers
to, please?
MDC legal counsel confirmed that Ms. Maxwell's cell is searched no more than once per day during weekdays only.
They further confirmed that the searchers make reasonable efforts to replace any moved items where they were
originally located (in other words, the searches do not include a "toss" of the cell). They also confirmed that staff
do not read any of Ms. Maxwell's legal papers.
MDC legal counsel indicated that the institution has been having some delays in mail delivery generally. They asked
whether you can please provide the name of the sender of the certified mail you referenced so that they can attempt
to locate that mail.
Best,
EFTA00015883

=== Page 2 ===
From: BOBBI C STERNHEIM
Sent: Tuesday, December 29, 2020 12:09 PM
To:
Cc: Christian Everdell ; Mark S. Cohen
Subject: Re: Ghislaine Maxwell 02879-509
Much appreciated.
Thank you-
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
Main:
917-912-9698
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.
On Dec 29, 2020, at 11:02 AM,
wrote:
Bobbi,
I hope you and your team are having a wonderful holiday season too, thanks.
I am reaching out to MDC legal counsel to discuss the issues you have raised in your email and will reach back out to you
after that conversation.
Best,
From: BOBBI C STERNHEIM
Sent: Monday, December 28, 2020 8:42 PM
To:
Cc: Christian Everdell
>; ; Mark S. Cohen
Subject: Ghislaine Maxwell 02879-509
Good evening,
EFTA00015884

=== Page 3 ===
We hope you and your family had a joyful holiday.
In response to your 12/14 email, we are requesting that Ms. Maxwell be permitted to use the
laptop, in lieu of the MDC computer,, during the typical length of time other inmates are permitted
out of their cells (our understanding is 6 am - 9:30 pm daily, extended to 10:30 pm on weekends.)
The voluminous discovery is easier to access and review on the laptop. The MDC computer turns
off every two hours and is not capable of opening all documents, and volume of discovery
may be too taxing for the operating system.
We also want to bring to your attention some of the ongoing issues concerning Ms. Maxwell's
conditions and restrictions.
The constant rotation of security staff results in inconsistency of rules and restrictions, the current
shift being unnecessarily restrictive, punitive, and threatening.
Ms. Maxwell is ordered to remain in specific locations within her isolation cell
to accommodate capture on the handheld camera, restricting her use of an already small
confinement area.
Her use of the laptop has been restricted.
She is invasively surveilled while showering.
Her cell is cold and precipitation accumulates on the concrete block walls.
Over the holiday weekend, a third blanket, used by Ms. Maxwell to keep herself warm, was
removed leaving her cold; and she now has the onset of a cold.
The blanket was returned the next day, after complaint was made by counsel.
The open-mouth, wanding, pat-down, and in-and-behind ear searches continue,
with more frequently than other inmates are searched.
Her cell and legal papers are searched multiple times a day, a disruption to the organization of her
legal work and an invasion into her privileged work product.
She has not received daily newspapers for almost 3 weeks, and has not received certified mail
(return receipts indicating delivery to MDC on 12/17) and non-certified mail for more than a week.
We will keep you apprised of our concerns.
Your assistance is appreciated.
Best-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
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.
EFTA00015885

=== Page 4 ===
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.
EFTA00015886


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)
[Contractor]"
Cc:
(USANYS)"
(USANYS)"
Subject: RE: COVID Language for Press Release
Date: Tue, 30 Jun 2020 15:11:57 +0000
Inline-Images: image001.png; image003.jpg
For sure. Just wanted everyone to get a peek at how it'll generally look.
From:
(USANYS)
Sent: Tuesday, June 30, 2020 11:09 AM
To:
(USANYS)
in
(USANYS) [Contractor]
Cc:
(USANYS)
is
(USANYS)
Subject: RE: COVID Language for Press Release
It's tough to be more precise until we pin down a venue, but what do you think about a little more specificity regarding
protocols as a placeholder, e.g.: MANDATORY COVID-19 SAFETY PROTOCOLS WILL BE
IN PLACE, INCLUDING MASKS AND SOCIAL DISTANCING. We can add some more
language once we know if it'll be here or
to reflect any other relevant particulars.
As an update on arrest timing, the latest thinking is that tomorrow remains possible but that we may well be pushing to
Thursday. We'll of course keep you posted.
From:
(USANYS)
Sent: Tuesday, June 30, 2020 11:04 AM
To:
(USANYS)
is
(USANYS) [Contractor]
Cc:
(USANYS)
is
(USANYS)
Subject: RE: COVID Language for Press Release
I'm here in the press office, if needed.
Draft advisory below and attached in Word format:
United States Attorney
Southern District of New York
OM
PESTITIA
There will be a press conference today at XX:00 a.m. to announce charges against
Ghislaine Maxwell for her role in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. The
press conference will be livestreamed on Facebook @USAOSDNY. Relevant documents are attached.
EFTA00015356

=== Page 2 ===
WHO:
Audrey Strauss, Acting United States Attorney for the Southern District of New York
, Assistant Director-in-Charge of the New York Office of the Federal
Bureau of Investigation
WHAT:
Press Conference
WHEN:
Wednesday, July, 1, 2020
xx:00 p.m.
WHERE:
U.S. Attorney's Office, Southern District of New York
CONTACT:
NOTE:
Please silence all cell phones, PDAs, and pagers before start of press conference.
MANDATORY COVID-19 PROTOCOLS WILL BE IN PLACE.
CLICK HERE FOR GUIDANCE.
-
DO NOT REPLY TO
From:
(USANYS)
Sent: Tuesday, June 30, 2020 10:45 AM
To:
(USANYS) [Contractor]
is
(USANYS)
Cc:
(USANYS)
>;
(USANYS)
Subject: RE: COVID Language for Press Release
Thanks very much,
Looping in
and
Please do keep exploring the
option. If it's doable it might
beat out our lobby-definitely seems like a stronger visual. On that note, if it was possible for one of you to take Audrey
on a walk-through of
as we figure it out, she'd appreciate it.
From:
(USANYS) [Contractor]
Sent: Tuesday, June 30, 2020 10:38 AM
To:
(USANYS)
>;
(USANYS)
Subject: RE: COVID Language for Press Release
Wait, I thought we were now targeting the lobby of
I just got off the phone with
from the FBI
press office, inquiring about the logistics of that. I think they can get chairs for press, check with GSA on their Covid
protocols (capacity, etc.), provide a "step-and-repeat" (a portable background with "FBI" and their seal) to reduce glare
from the windows on the Duane Street side. The concerns are the acoustics (as you know, that space is cavernous, with
all hard surfaces and a high ceiling) and their lack of a podium (so we'd have to lug ours over there). Is our lobby
preferable? I can call
back and call off the dogs.
EFTA00015357

=== Page 3 ===
From:
(USANYS)
Sent: Tuesday, June 30, 2020 10:15 AM
To:
(USANYS) [Contractor]
>;
(USANYS)
Cc:
(USANYS)
i
(USANYS)
Subject: COVID Language for Press Release
The International Court of Trade has said no, so it looks like we're likely at Plan B (Plan Z?) option of using our whole lobby
space in an effort to create some social distance.
With apologies for adding to your full plate, Audrey asked if you could please come up with a paragraph to put at the top
of tomorrow's press advisory, notifying the press of safety protocols-masks, social distancing, etc.-and asking them to
please leave extra time to get into the building (which may mean we should also send out the advisory earlier than
usual). I've attached our safety protocols and am cc'ing
(and
though he's out), since I know you'll want to
coordinate with them on how press screening will work. Happy of course to talk or help in any way.
Thanks!
EFTA00015358


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=== Page 1 ===
U.S. DEPARTMENT OF TRANSPORTATION
OMB Control No. 2120-0043
FEDERAL AVIATION ADMINISTRATION
Expires 12/31/2018
NOTICE OF RECORDATION- AIRCRAFT SECURITY CONVEYANCE
PART I- CONVEYANCE RECORDATION NOTICE
This section acknowledges the recording of a security conveyance covering the collateral shown.
NAME (last name first) OF DEBTOR
HELIBRO LLC
NAME and ADDRESS OF SECURED PARTY/ASSIGNEE
1ST SOURCE BANK
100 N MICHIGAN ST
SOUTH BEND IN 46601
NAME OF SECURED PARTY'S ASSIGNOR (if assigned)
THE FOLLOWING COLLATERAL IS COVERED BY THE CONVEYANCE:
N405PJ 53375
BELL
407
N N N
CW019053 Conveyance Recorded Feb/26/2021 11:47 AM FAA
ROLLS 250-C47B CAE-847407
THE SECURITY CONVEYANCE DATED 4/7/2016
COVERING THE ABOVE COLLATERAL WAS RECORDED BY
THE CIVIL AVIATION REGISTRY ON Jun 03, 2016
AS CONVEYANCE NUMBER
SY000344
Shantel Young Shantel Young
SHANTEL YOUNG, LEGAL INSTRUMENTS EXAMINER
PART II- RELEASE
Use of this section of the form by the security holder is optional. This section is only a suggested form of release that meets the
recording requirements of the Federal Aviation Act of 1958, as amended, and the regulations issued thereunder. In addition to
those requirements, the form used by the security holder should be drafted in accordance with the pertinent provisions of local
statutes and other applicable federal statutes. This form may be reproduced. There is no fee for recording a release.
Send to: Aircraft Registration Branch, PO Box 25504, Oklahoma City, Oklahoma 73125.
The undersigned hereby certifies that they are the true and lawful holder of the note or other evidence of indebtedness
secured by the conveyance referred to herein on the above described collateral and that the same collateral is hereby
released from the terms of the conveyance. Provided that no express warranty is given nor implied by reason of execution
or delivery of the release, any title retained in the collateral by the conveyance is hereby sold, granted, transferred and
assigned to the party that executed the conveyance or to the assignee of said party if the conveyance was assigned.
DATE OF RELEASE
ACKNOWLEDGMENT (If Required By Applicable Local Law):
SECURITY HOLDER: 188 SOURCE BANK
SIGNATURE (In Ink)
TITLE:
HELOW PITKINSON, OPERATIONS
MONTH YER
(A person signing for a corporation must be a corporate officer or hold a
managerial position and must show title. A person signing for another
should see 14 CFR Parts 47 and 49 of the Federal Aviation Regulations.)
AC Form 8050-41 (08/12)
EFTA00016622

=== Page 2 ===
EFTAO
FILMD WITH FAA
AIRCRAFT
REGISTRATION BR
2020 DEC 21 PH 1: 57
ORGANOMA CITY
OKLAHOMA

=== Page 3 ===
DOCUMENT LEVEL ANNOTATIONS
SEE RECORDED CONV#SY000344 DOC ID 5917
EFTA00016624

=== Page 4 ===
EFTA00016625

=== Page 5 ===
PRINT PAGE 1
PRIVACY ACT STATEMENT
OMB Control Number 2120-0042
Expires 09/30/2020
PRA Public Burden Statement: A federal agency may not conduct or sponsor, and a person is not required to respond to, nor shall a person be subject to a penalty for failure
to comply with a collection of information subject to the requirements of the Paperwork Reduction Act unless that collection of information displays a currently valid OMB Control
Number. The OMB Control Number for this information collection is 2120-0042. Public reporting for this collection of information is estimated to be approximately 30 minutes
per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed. completing and reviewing the collection
of information. All responses to this collection of information are required to retain aircraft registration in accordance with 14 CFR Part 47. Send comments regarding this burden
estimate or any other aspect of this collection of information, including suggestions for reducing this burden to: Information Collection Clearance Officer, Federal Aviation
Administration, 10101 Hillwood Parkway, Fort Worth, TX 76177-1524.
Accepted IR Feb/20/2019
FAILURE TO RENEW REGISTRATION WILL
DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION
RESULT IN CANCELLATION OF REGISTRATION
AIRCRAFT REGISTRATION RENEWAL APPLICATION
AND REGISTRATION NUMBER ASSIGNMENT
(See 14 C.F.R. §§ 47.15(i). 47.40 and 47.41)
AIRCRAFT REGISTRATION NUMBER
SERIAL NUMBER
N 405PJ
53375
MANUFACTURER
MODEL
Bell
407
DATE OF ISSUANCE
DATE OF EXPIRATION
TYPE OF REGISTRATION
4/1/2016
4/30/2019
Individual
ENTER REGISTERED OWNER(S) & ADDRESS FROM FAA FILE
HELPFUL INFORMATION
(Owner 1) HELIBRO, LLC
Review Aircraft Registration File Information for this aircraft
at: http://registry.faa.gov/aircraftinguiry.
(Owner 2)
Note: Enter any additional owner names on page two.
Assistance may be obtained
(Address) 903 Langley Wav
at our web page: http://registry.faa.gov/renewregistration
by e-mail at:
faa.aircraft.registry@faa.gov. or
(Address)
by telephone at: (866) 762 9434 (toll free). or (405) 954 - 3116
City Red Bluff
State CA Zip 96080
When mailing fees, please use a check or money order made
Country
payable to the Federal Aviation Administration.
Physical Address: Required when mailing address is a P.O. Box or mail drop.
Signature and Title Requirements for Common Registration Types:
(Address)
same
Individual
owner must sign, title would be "owner".
(Address)
Partnership
general partner signs showing "general partner" as
title.
City
State
Zip
Corporation
corporate officer or manager signs, showing full title.
Country
Limited Liability Co
authorized member, manager, or officer identified in
the LLC organization document signs, showing full title.
TO RENEW REGISTRATION: REVIEW aircraft registration information,
Co-owner
each co-owner must sign; showing "co-owner" as title.
Government
SELECT the appropriate statement, ENTER any change in address in the
authorized person must sign and show their full title.
spaces below, SIGN. DATE. & SEND form with the $5 renewal fee to the:
Note: All signatures must be In Ink, or other permanent media.
FAA Aircraft Registry, PO Box 25504, Oklahoma City OK 73125-0504, or
To correct entries: Draw a single line through error. Make correct entry In
by courier to: 6425 S Denning Rm 118, Oklahoma City OK 73169-6937
remaining space, or complete the form on-line. An application form will be
rejected if any entry is covered by correction tape or similarly obscured.
I (WE) CERTIFY, THE NAME(S) AND ADDRESSES FROM THE FAA FILES
FOR THE OWNER(S) OF THIS AIRCRAFT ARE CORRECT, OWNERSHIP
TO CANCEL THE REGISTRATION FOR THIS AIRCRAFT:
MEETS CITIZENSHIP REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS
CHECK All applicable block(s) below, COMPLETE, SIGN, DATE & MAIL
NOT REGISTERED UNDER THE LAWS OF ANY FOREIGN COUNTRY.
this form with any fees to the: FAA Aircraft Registry,
PO Box 25504, Oklahoma City, OK, 73125-0504, or by courier to:
UPDATE THE MAILING / PHYSICAL ADDRESS AS SHOWN BELOW.
6425 S Denning Rm. 118, Oklahoma City OK 73169-6937
I (WE) CERTIFY THE: NAME(S) SHOWN ABOVE FOR THE OWNER(S) OF
THIS AIRCRAFT IS CORRECT, OWNERSHIP MEETS THE CITIZENSHIP
CANCELLATION OF REGISTRATION IS REQUESTED.
REQUIREMENTS OF 14 CFR $47.3, AIRCRAFT IS NOT REGISTERED
UNDER THE LAWS OF ANY FOREIGN COUNTRY.
THE AIRCRAFT WAS SOLD TO:
(Show purchaser's name and address.)
NEW MAILING ADDRESS
THE AIRCRAFT IS DESTROYED OR SCRAPPED.
NEW PHYSICAL ADDRESS: complete if physical address has changed, or
THE AIRCRAFT WAS EXPORTED TO:
the new mailing address is a PO Box or Mail Drop.
OTHER, Specify
PLEASE RESERVE N-NUMBER IN THE OWNER'S NAME
AND ADDRESS. The $10 reservation fee is enclosed.
SIGNATURE OF OWNER 1 (required field)
PRINTED NAME OF SIGNER
(required field)
TITLE
(required field)
DATE
Mark
Mark Gunsauls
Member
1/2/2019
SIGNATURE OFOWNER 2
PRINTED NAME OF SIGNER
TITLE
DATE
Use page 2 for additional signatures.
190080904565
AC Form 8050-1B (10/18)
$5.00 01/08/2019
EFTA00016626

=== Page 6 ===
EFTA00016627
FILED WITH FAA
AIRCRAFT
REGISTRATION BR
2019 JAN-8 AM 10: 10
OKLAHOMA CITY
OKLAHOMA

=== Page 7 ===
DOCUMENT LEVEL ANNOTATIONS
FFR APP DOC ID 7735 10/30/18
183030859124 $5 10/30/18
EFTA00016628

=== Page 8 ===
EFTA00016629

=== Page 9 ===
RECORDED CONVEYANCE FILED IN:
U.S. DEPARTMENT OF TRANSPORTATION
NNUM: 405PJ
FEDERAL AVIATION ADMINISTRATION
SERIAL NUM: 53375
MFR: BELL
CROSS-REFERENCE-RECORDATION
MODEL: 407
AIR CARRIER:
This form is to be used in cases where a conveyance covers several aircraft and engines, propellers, or locations. File original of this form
with the recorded conveyance and a copy in each aircraft folder involved.
TYPE OF CONVEYANCE
DATE EXECUTED
LOAN AND SECURITY AGREEMENT
APRIL 7, 2016
FROM
DOCUMENT NO.
HELIBRO LLC
SY000344
TO OR ASSIGNED TO
DATE RECORDED
1st SOURCE BANK
JUN 03, 2016
THE FOLLOWING COLLATERAL IS COVERED BY THE CONVEYANCE:
Total Aircraft: 1
Total Engines: 1
Total Props:
Total Spare Parts:
N405PJ
ROLLS 250-C47B CAE-847407
AFS-750-23R (08/09)
EFTA00016630

=== Page 10 ===
EFTA00016631

=== Page 11 ===
Source
Bank
#1m20160411112843
LOAN AND SECURITY AGREEMENT
Document Date: april 7
, 2016
Customer (Exact Legal Name):Helibro, LLC
Address:
903 Langley Way
City/State/Zip Code:
Red Bluff, CA 96080
Phone: (530) 527-5059
Fax:
Email:
1. 1st Source Bank ("Bank") has agreed to lend money to the individual or entity identified above as the "Customer", and may agree to lend
additional money to Customer from time-to-time. The principal amount, the interest rate, payment amount, payment due dates, the maturity
date and other particulars for each loan shall be set forth in a promissory note, addendum, schedule or other separate document containing
such terms (each a "Note"). Customer will make payments when due and payable without offset, defense or counterclaim. All payments will
be given tentative credit when received by Bank in Indiana and posted to Customer's account in accordance with standard Bank practices,
subject to final collection. All final payments shall be made in immediately available collected funds unless Bank agrees otherwise. All
SY000344 Conveyance Recorded Jun/03/2016 11:01 AM FAA
payments shall be applied first to interest, then to principal unless otherwise provided in this Agreement. Interest shall accrue based on a 360-
day year and the days actually elapsed.
2. To secure repayment of the loans and performance of the other obligations of Customer under this Agreement, and also to secure all other
monetary and non-monetary obligations of Customer to Bank under any other agreement, whether absolute or contingent, direct or indirect,
now existing or hereafter arising, Customer grants to Bank a continuing security interest in the "Collateral" as defined in the following
sentence. "Collateral" means the aggregate of (a) the property described in any addendum, schedule or other separate document that, by its
terms, is made a part of this Agreement; plus (b) any other assets of Customer in which Customer has granted Bank a security interest under
any other existing or future agreement, whether or not related to this Agreement. If the property included in Collateral is equipment (whether
or not held as "Equipment"), then Collateral also includes (i) all logs, records and manuals relating to the Equipment, (ii) all present
and future attachments, accessories, parts, repairs, additions, accessions, substitutions, exchanges and replacements identified with or relating
to the Equipment; (iii) all present and future rights of Customer relating to the physical condition of the Equipment, including under any
warranties, service or maintenance agreements, storage agreements or insurance policies; (iv) all present or future rights of Customer in
connection with the use and/or operation of the Equipment by any third party under any lease, rental agreement or license; and (v) proceeds
of the Equipment and any of (i) through (iv).
161091446271
3. Customer represents and warrants that:
$10.00 04/18/2016
(a) Customer is a limited liability company organized and in good standing under the laws of California, and in good standing in all
jurisdictions where qualification is necessary;
(b) if applicable, the execution and delivery hereof, and all other agreements or writings by and between Customer and Bank have been duly
authorized by appropriate action of Customer's governing body;
(c) Customer is the absolute owner of the Collateral and has full power and authority to grant a security interest in the Collateral to Bank;
(d) the Collateral is free and clear from all liens, encumbrances, security interests, or other claims other than the security interest of Bank;
(e) none of the terms of this Agreement or any other agreements between Customer and Bank are in violation of any agreements Customer
may have with any third party;
(f) all financial statements, credit applications, and other information Customer has provided to Bank are truthful and accurate, and all
financial statements and other information Customer delivers or provides to Bank in the future also will be truthful and accurate;
(g) since the date of the most recent financial statements delivered to Bank, there has been no material adverse change in Customer's financial
condition or prospects;
(h) Customer understands and acknowledges that Bank is neither the manufacturer nor distributor of the Equipment and has no knowledge
of or familiarity with it. Customer will be accepting the Equipment "as is" and Bank has not made, and will not make, any representation
or warranty, express or implied, as to the value, condition, quality, material, workmanship, design, capacity, merchantability, durability,
fitness or suitability of the Equipment for any use or purpose, or any other representation or warranty whatsoever, express or implied;
and
(i) Customer acknowledges that by requiring insurance herein (or in the insurance letter) as provided below, Bank does not represent that
coverage and limits will necessarily be adequate to protect Customer and such coverage and limits shall not be deemed as a limitation on
Customer's liability under Customer's indemnities otherwise set forth in this Agreement.
4. Customer will, at its own cost and expense as applicable:
(a) deliver to Bank from time-to-time its financial statements, in the same form and type as submitted with Customer's loan request. Customer
will deliver its full-year annual financial statements each year as soon as available, but in any event not later than one hundred twenty
(120) days after the close of each of its fiscal years, together with the opinion or other report of the accountant(s) (if any) retained to
Loan and Security Agreement 9-10-2013
Page 1 of 5
EFTA00016632

=== Page 12 ===
EFTA00016633
BR
18 PM 1 55
OKLAHOMA OKLAHOMA CITY

=== Page 13 ===
compile, review or audit the financial statements. Bank may specify a different form, type or frequency in any addendum, schedule or
other separate document that, by its terms, is made a part hereof, or as Bank may reasonably request in any written notice delivered by
Bank to Customer;
(b) promptly deliver to Bank such other information and documents regarding the loans, the Collateral, and the business affairs, operations,
financial condition or other properties of Customer as Bank may reasonably request from time-to-time;
(c) at all times insure the Collateral with companies acceptable to Bank against loss, collision, theft, vandalism, or other physical damage,
liability and other risks and hazards, as Bank reasonably requires, giving due consideration to the kinds of coverage that owners of the
property-type(s) included in the Collateral commonly obtain, for an amount(s) not less than the amount(s) set forth in any "Insurance
Letter" delivered by Bank to Customer or Customer's insurance agent in connection with any of the Collateral, under policy(ies) of
insurance that include a standard long form, loss payable endorsement in favor of Bank, "breach of warranty" or similar coverage against
any acts, omissions or neglect by Customer or any other party (other than Bank) that otherwise would negate coverage under such
policy(ies), and the insurer's agreement to give written notice to Bank thirty (30) days (or such lesser period as Bank may reasonably
accept) before cancellation of or any material change to any such policy(ies) becomes effective as to Bank, whether such cancellation or
change is at the request or direction of Customer or the insurer, provided however, that Bank may from time-to-time, upon written notice
to Customer, modify or add other insurance requirements so that the scope and amount of coverage required hereunder is consistent with
best industry practice and the reasonable commercial interests of Bank; and will deliver to Bank certificates of insurance or other evidence
reasonably satisfactory to Bank of compliance with the foregoing insurance requirements;
(d) keep the Collateral safe and secure, in good order, repair, operating condition and appearance, use and operate the Collateral with care
and only with qualified personnel in the ordinary course of Customer's business and in conformity with all laws and regulations, keep
accurate and complete records concerning the Collateral, and maintain and use the Collateral within the United States unless Customer
obtains the Bank's prior written consent to move the Collateral;
(e) pay when due any tax, assessment, levy or charge on or against the Collateral by any governmental authority or other third party, and not
suffer or permit, and promptly remove or cause to be removed, any lien, encumbrance, claim, security interest, mechanic's lien, levy,
attachment or other interest of any individual or entity other than Bank upon or against the Collateral, except for any of the foregoing
that Customer is contesting in good faith;
(f) permit Bank, at all times during business hours, to inspect all or any portion of the Collateral, wherever located, and to inspect, audit,
check, and make copies of or extracts from, Customer's books, records, correspondence and other data relating to Customer's financial
condition or the Collateral;
(g) do all such acts and execute all instruments, financing statements or other documents as reasonably requested by Bank for the purpose of
fully carrying out and effectuating this Agreement and its intent or which Bank reasonably deems necessary to protect the Collateral or
perfect the security interests granted herein;
(h) not mortgage, sell, lease, transfer, set over, abandon, assign, grant a security interest in, permit its identity to be lost, or otherwise dispose
of Collateral or any interest therein or any part thereof, except as may be provided in any applicable addendum, schedule or other separate
document that, by its terms, is made part of this Agreement; and
(i) advise Bank within thirty (30) days of any change of Customer's name, location of principal office or residence or form of business
entity.
5. Other monetary obligations of Customer hereunder include the following:
(a) If Customer is ten (10) days late in making a payment, then Customer shall pay a delinquency charge equal to five percent (5%) of the
amount of the late payment (both principal and interest), and Bank shall assess such delinquency charge on the tenth (10th) calendar day
after the payment due date. After a default as defined below has continued for 30 days and as long as the default continues, Bank may by
notice of default charge interest at the rate set forth in the applicable Note plus three percent (3%) per annum (the "Default Rate"). If
imposed, the Default Rate shall apply retroactively to the date the default began.
(b) Customer also shall pay to Bank, or if requested by Bank, directly to the applicable vendor or other third party, any fees, costs, expenses,
penalties or interest incurred by Bank in connection with this Agreement, any Note or any of the Collateral, including without limitation,
fees, costs or expense of: (i) filing, registering or recording this Agreement and Bank's interests under this Agreement, or any UCC
financing, continuation or termination statement or similar official filings or registrations, (ii) any transfer or stamp taxes, (iii) inspection,
appraisal or monitoring of the Collateral as Bank may conduct for itself or obtain from a third party in its discretion, (iv) exercising its
rights herein or under applicable law to protect its interest in the Collateral by performing obligations of Customer in the event Customer
fails to timely perform same, (v) taking possession of, holding, preparing for sale or other disposition and selling or otherwise disposing
of the Collateral, and (vi) all attorneys' and other professionals retained by Bank in connection with any of the foregoing, or any exercise
of other remedies upon occurrence of a default, whether such fees, costs or expenses are incurred before or after commencement of any
bankruptcy case or other insolvency proceeding. All of the foregoing fees, costs or expenses thus incurred or expended by Bank, and any
other monies paid by Bank to collect Customer's obligations under any Note or protect its interests in the Collateral shall, at Bank's
option, for each instance of fees, cost or expense so incurred or paid by Bank, either be added to the balance of the applicable Note or if
more than one Note, then pro-rated among the Notes, and be subject to all of the provisions of this Agreement, or be paid immediately
by Customer upon demand by Bank, with interest accruing on the amount so demanded at the Default Rate.
(c) Customer will at all times be liable to and indemnify and hold Bank harmless from and against any and all claims and liabilities on
account of death, bodily injury or property damage occasioned by the use or ownership of Collateral.
6. Customer will be in default if any one or more of the following events takes place:
Loan and Security Agreement 9-10-2013
Page 2 of 5
EFTA00016634

=== Page 14 ===

=== Page 15 ===
(a) Customer fails to make any payment when due under (i) this Agreement, (ii) any Note, (iii) any addendum, schedule or other separate
document delivered by Customer or Bank that relates to this Agreement, or (iv) under any other agreement between Customer and Bank;
(b) Customer fails to make payment when due or otherwise fails to perform under any agreement for borrowed money, or any obligation of
Customer for borrowed money is declared due and payable before its original maturity date;
(c) Customer or any guarantor fails to perform any obligation under this Agreement or any Note, any addendum, schedule or other separate
document that, by its terms, is made a part hereof, any guaranty, or under any other agreement between Customer and Bank, provided,
however, that, to the extent any such obligation, other than a payment or insurance obligation, can still be performed, such failure
continues for more than ten (10) business days after delivery by Bank of a written demand to perform;
(d) any representation or warranty made by Customer in this Agreement is false in any material respect when made, or subsequently becomes
no longer true (except for representations and warranties that become untrue solely due to the passage of time);
(e) Customer, or any guarantor of Customer's obligations to Bank, dies, dissolves, merges with another entity, suspends or terminates
his/her/its usual business, is unable to pay his/her/its debts as they become due, makes an assignment for the benefit of creditors, applies
to any court for the appointment of a trustee or a receiver of all or a substantial part of his/her/its assets or commences any proceeding
under any bankruptcy, receivership, insolvency, dissolution or liquidation law of any jurisdiction, or any other individual or entity
commences such proceedings against Customer or any such guarantor and Customer or such guarantor acquiescence thereto, or denies
liability to Bank or seeks to terminate any agreement with Bank;
(f) Bank, in good faith, believes that the prospect of payment and performance hereunder has substantially diminished or that there is a
material adverse change in the financial condition or operations of Customer or any guarantor; or
(g) Customer's principals as of the inception of this Agreement no longer control or operate the business of Customer.
7. Upon the occurrence of any of the foregoing events of default and at any time thereafter that any event of default is continuing, Bank may do
any or all of the following, cumulatively: (i) declare all or any part of the remaining unpaid indebtedness of Customer to Bank to be
immediately due and payable, together with all unpaid interest and any other accrued and unpaid monetary obligations of Customer hereunder;
(ii) exercise all rights and remedies provided in this Agreement, under the Uniform Commercial Code as in effect in all pertinent jurisdictions
and under any other applicable law, treaty or convention, including without limitation the right (a) to immediate possession of all or a portion
of the Collateral, (b) to require Customer to assemble the Collateral and deliver it to Bank at a place designated by Bank that is reasonably
convenient to both parties, (c) to enter upon any premises on which Collateral or any portion thereof may be located and take possession of
same, at any time or times, with or without demanding delivery, with or without judicial process, and with or without the assistance of others,
(d) to dispose of Collateral on any premises, including those of Customer, (e) to setoff any property of Customer in the possession or control
of Bank, and (f) in Bank's sole discretion, to undertake payment or other performance of any obligation of Customer hereunder that Customer
has failed to perform.
In connection with any sale or other disposition of the Collateral by Bank, the requirements of reasonable notice shall be met if such notice is
given to Customer and any guarantors at least ten (10) days before the date of any public or private sale or other disposition of Collateral is to
be made.
Customer's obligation to repay each Note and all other obligations of Customer hereunder are independent of the obligation of any other
individual or entity that has signed this Agreement or other documents as a Customer or a guarantor ("Signer(s)"). It is not necessary for Bank
to exercise its rights and remedies in respect of the Collateral before collecting from a Signer. Bank may extend the time for payment of any
installment, reduce the size of monthly payments, release Collateral, release one or more Signers from their obligations, waive any right Bank
might have against any Signer, extend, renew or agree to alter this Agreement, all without releasing other Signers from their obligations under
this Agreement or any guaranty agreement. Any delay by Bank in exercising any rights or remedies hereunder or under any other instrument
executed and delivered by Customer to Bank in connection herewith shall not operate as a waiver thereof and no single or partial exercise of
any right or remedy shall preclude other or further exercise thereof, or the exercise of any other right or remedy. Bank's acceptance of late or
partial payments, or waiver of any default, shall not establish a custom or course of conduct and the waiver by Bank of any default shall not
constitute a waiver of any subsequent defaults, but shall be restricted to the default so waived.
8. If any part of this Agreement is determined to be contrary to any law or otherwise defective, then the other provisions of this Agreement shall
not be affected thereby, but shall continue in full force and effect. If the effective interest rate, late charges, fees or expenses in connection
with any indebtedness hereunder exceeds the maximum lawful amount, then the amount of such item shall be reduced to the maximum lawful
amount, and the amount of any excess amount shall be applied to principal, and returned to Customer to the extent the indebtedness has been
or is thereby paid in full. This application or refund process shall be Customer's sole remedy for excessive charges.
9. No transfer, renewal, extension or assignment of any loan or Note or this Agreement or any interest hereunder or thereunder, or loss, damage,
or destruction of Collateral shall release Customer from Customer's obligations hereunder. Customer hereby waives presentment, demand,
protest, notice of protest, notice of non-payment or dishonor, notice of sale of Collateral or any part thereof and all benefit of valuation,
appraisement, and all exemption laws now in force or hereafter passed, including stay of execution and condemnation.
10. This Agreement (which includes each Note and all addenda, schedules or other separate documents that, by their terms, are made a part hereof)
constitutes the entire agreement between Customer and Bank. Bank may by written notice to Customer correct any error or complete any
blank space necessary to cause this Agreement to be accurate and effective. Except to the extent provided otherwise herein, this Agreement
can be modified or amended only by a written document signed by both Customer and Bank. Customer hereby authorizes and ratifies any
prior filing of a financing statement by Bank, and appoints Bank as its attorney-in-fact to affix Customer's signature to any form relating to
the Collateral and to any Uniform Commercial Code financing statement(s), to take any other action Bank deems necessary to perfect and
maintain perfection of the security interests provided herein or as may be required hereby and to do all other acts and things necessary to carry
out the intent of this Agreement. Customer further appoints Bank as Customer's attorney-in-fact for Customer and in its name, place and stead
Loan and Security Agreement 9-10-2013
Page 3 of 5
EFTA00016636

=== Page 16 ===

=== Page 17 ===
(i) if any of the Collateral is covered by a certificate of title, for the sole and limited purpose of endorsing in its behalf any necessary forms
required to apply for or transfer title and/or indicate Bank's security interest on the certificate of title as contemplated under this Agreement,
(ii) to endorse the name of Customer to instruments and documents for purposes of collection or expedition, (iii) in obtaining payment,
adjusting, canceling or settling any claims upon or under any insurance policies covering the Collateral, and hereby authorizes Bank to endorse
the name of Customer on any checks, drafts or other instruments received or given in payment or liquidation of any claim under any such
insurance policy, and (iv) to perform each and every act Bank deems necessary in connection with this power of attorney. Customer further
authorizes Bank to execute a power-of-attorney form in Customer's name if and to the extent necessary or convenient to confirm the foregoing
grant of authority. The foregoing powers of attorney are coupled with interests in the underlying subject matter and are therefore irrevocable.
Bank may assign this Agreement at any time. Customer may not assign its rights or delegate its duties under this Agreement without the
express prior written consent of Bank.
11. With respect to any disputes between the parties, any proceeding by Bank against Customer may be brought by Bank in a court of competent
jurisdiction located in the County of St. Joseph, State of Indiana (which court shall have jurisdiction to hear such matters) and Customer
hereby irrevocably consents and submits itself to jurisdiction in any such court. Customer consents to service of process by first-class mail or
messenger directed to Customer at Customer's address set forth above. Nothing herein affects or limits the rights of Bank to serve legal process
in any other manner permitted by law or the rights of Bank to bring any action or proceeding against Customer or its property in courts of any
other jurisdiction. Customer waives any bond or surety or security upon such bond or surety that might, but for this waiver, be required of
Bank. Due to the complexity, high cost and time involved in commercial litigation before a jury, Customer and Bank each knowingly,
voluntarily, irrevocably, and after the opportunity to consult with respective counsel, without coercion, waives any and all rights to trial by
jury of any disputes between them and further waives any right to consolidate, by counterclaim or otherwise, any action or proceeding
concerning any dispute between them with any other action or proceeding in which there is a trial by jury or in which a jury trial cannot be or
has not been waived. Nothing herein shall affect Bank's right before, during or after commencing proceedings for court enforcement of its
rights hereunder to exercise self-help remedies, such as repossession or set-off under the Uniform Commercial Code or other applicable law,
convention or treaty, including Bank's right to bring an action in any court of competent jurisdiction for the purpose of enforcing any self-
help remedies. This Agreement, together with each Note and Bank's interests in the Collateral, shall be governed in all respects by the laws
of the State of Indiana (without regard to conflict of law principles).
12. Any notice or other communication given under this Agreement must be in writing and be delivered to the recipient party. Notices to Customer
shall be delivered personally, sent via fax, or mailed (by regular first class mail, or certified or registered mail, or by recognized overnight
courier), postage prepaid to Customer at its address or fax number shown at the beginning of this Agreement. Notices to Bank shall be delivered
personally or mailed (by regular first class mail, or certified or registered mail, or by recognized overnight courier), postage prepaid to Bank's
address for notices: P. O. Box 783, South Bend, IN 46624 for mail, 100 North Michigan Street, South Bend, IN 46601 for overnight courier,
in either case to the attention of Credit Notice Desk. The parties may give notice to designate a different address for notices to the party.
13. In addition to notices or other formal communications given under this Agreement, Customer authorizes Bank to send communications to it
via fax or regular email from time to time. Although email generally is an efficient and effective means of communicating, it is not a secure
means of communication. Customer acknowledges that there is risk of improper interception of sensitive, confidential or proprietary
information when that information is transmitted via regular email. To mitigate such risk, Bank offers to encrypt information it sends to
Customer via email or to communicate such information by secure fax or overnight delivery. Because these more secure means of transmitting
information are not as convenient as regular email, Customer prefers to accept those risks rather than pursue less convenient means of
communication. Accordingly, Customer (i) acknowledges its acceptance of the risks associated with regular email transmission of confidential
information, and (ii) releases Bank from any claim for losses or damages as a consequence of improper interception of confidential information
while in route to or from Customer via regular email.
14. A fax or other electronic reproduction of this page or any other Note, document, schedule, exhibit or attachment to this Agreement executed
in connection with this Agreement with the signature of either party to this Agreement shall be as effective and valid as if such page bore the
original signature of such party. This Agreement may be executed and delivered in counterparts and via fax or other electronic means.
Customer acknowledges that Customer has received and retained a completed copy of this Agreement and any UCC financing statement filed
or to be filed in respect of the Collateral. Customer confirms that if it has received copies of documents for execution from Bank via any
means of electronic delivery (including email), that it has made no changes to such documents and the documents are identical in content to
the version dispatched by Bank to Customer.
15. This Agreement shall be deemed accepted by Bank in South Bend, Indiana, by the Bank's act of funding the first loan made under this
Agreement.
Loan and Security Agreement 9-10-2013
Page 4 of 5
EFTA00016638

=== Page 18 ===

=== Page 19 ===
Executed by Customer on april 7
, 2016.
Helibro, LLC
By:
X
David Gunsauls, Member
By: Mark X Gunsauls, Member
By: xigh Years
Mike Gunsauls, Member
1st SOURCE BANK
By:
Name:
Greg M. Holst
Vice President
Title:
Loan and Security Agreement 9-10-2013
Page 5 of 5
EFTA00016640

=== Page 20 ===
EFTA00016641
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2016 APR 18 PM 1 55
OKLAHOMA CITY
OKLAHOMA

=== Page 21 ===
Source.
Bank
Specialty Finance Group, Aircraft Division
+1m2016041112843
Retail/Owner/Operator
Loan No.
SCHEDULE "A"
This Schedule A is a part of the Loan and Security Agreement dated april 7
2016 ("Agreement") between Helibro, LLC
("Customer") and 1st Source Bank ("Bank"). This Schedule A describes certain property that is included in the "Collateral" (as defined in the Agreement) and
includes additional terms in respect of such property, and is executed in connection with a specific loan being made under the Agreement that is indicated above
("Loan").
1. Customer grants Bank a security interest in the following Aircraft (which shall be included in the "Equipment" described in the Agreement):
YEAR MFG
MFG OF AIRCRAFT
MODEL NO.
SERIAL NO.
FAA REG NO.
1999
Bell (Bell Helicopter)
407
53375
N405PJ
MFG OF
ENGINE MODEL NO(S)
ENGINE SERIAL NO(S)
MFG OF PROPELLER(S)
PROP SERIAL NO(S)
ENGINE(S)
550+ HP
X
Yes
750 or greater HP
Yes
or 1750+ lbs thrust
No
No
Rolls Royce
250-C47B (250-C47)
CAE-847407 (847407)
DESCRIBE EXTRA EQUIPMENT:
The Collateral also specifically includes (a) all propellers, extra engines, furnishings, avionics and other instruments, and spare parts, identified with or otherwise
related to the Aircraft; (b) all logs, manuals and other records relating to Collateral items; (c) all rights under any management, operating or similar agreement
in respect of the Aircraft; and (d) all rights under any engine or maintenance services contracts (such as an MSP or JSSI program) and under any computerized
aircraft maintenance programs or similar recordkeeping service arrangements (together "Maintenance Programs").
2. The Collateral is at least in part subject to the Convention on International Interests in Mobile Equipment and the Protocol to the Convention on International
Interests in Mobile Equipment on Matters Specific to Aircraft Equipment adopted on November 16, 2001 at a diplomatic conference in Cape Town, South
Africa (the "Cape Town Convention"), and the foregoing grant of a security interest creates in Bank's favor an "international interest" (as provided in the Cape
Town Convention) in the Collateral that is subject to the Cape Town Convention.
3. Customer confirms that it has been approved as a "transacting user entity" by the international registry located in Dublin, Ireland, established pursuant to the
Cape Town Convention (the "International Registry"), and that it has appointed an administrator who is a "transacting user" that can consent to the registration
on the International Registry of the international interest created in the Collateral under the Agreement (the "international registration"). Customer hereby
consents to the international registration, and agrees that it will:
(a) cooperate fully with Bank in connection with making and maintaining the international registration, and in particular Customer will timely consent to the
international registration upon issuance of the International Registry's request for consent, according to the procedures of the International Registry:
(b) not consent to any registration relating to the Aircraft's airframe or engines with the International Registry other than Bank's interests under the Agreement
without Bank's advance written consent;
(c) not permit any terminations of Bank's international interests hereunder without Bank's advance written consent;
(d) not grant or issue an Irrevocable De-Registration and Export Request Authorization ("IDERA") pursuant to the Cape Town Convention relating to the
Collateral in favor of any party other than Bank;
(e) promptly on request effect a discharge of any non-consensual or other international interests that may be registered on the International Registry other
than Bank's interests under the Agreement.
4. In connection with this Schedule A, Customer has executed an IDERA in favor of Bank. Customer consents to Bank filing the IDERA with the FAA. If a
default under the Agreement occurs, in addition to the rights and remedies described in the Agreement Bank shall have all of the rights and remedies specified
in the Cape Town Convention including in particular the right to exercise its rights pursuant to the IDERA. These rights include the procurement of the de-
registration of the Aircraft and the export and physical transfer of the Aircraft from the United States.
5. Pursuant to the Cape Town Convention, Customer hereby expressly consents in advance to any assignment by Bank of all or part of the Agreement, the Loan,
this Schedule A and Bank's "international interest" created by this Schedule A (including all of the associated rights therein).
6. The Aircraft shall be used and operated in compliance with all applicable Federal Aviation Regulations and the applicable regulations of any foreign country in
which the Aircraft may be operated. Customer shall not remove the Aircraft from the United States for a period exceeding thirty (30) consecutive days, without
the prior written consent of Bank. Customer will notify Bank immediately if the police or any other authority seizes or impounds the Aircraft.
7. The Aircraft is eligible for, and is, registered with the FAA in Customer's name as "owner" and shall remain on the US FAA registry during the term of the
Agreement. Customer qualifies as a "citizen of the United States" as defined in 49 U.S.C. Section 40102(a)(15), because: (a) the president of the Customer is a
citizen of the United States as defined in 49 U.S.C. § 40102(a)(15); (b) at least two-thirds of the managing officers and members of the board of directors of the
Customer are individuals who qualify as citizens of the United States as defined in 49 U.S.C. § 40102(a)(15); (c) the Customer is under the actual control of
citizens of the United States; and (d) at least 75% of the voting interest of the Company is owned by citizens of the United States as defined in 49 U.S.C. $
40102(a)(15).
8. Customer confirms and agrees that Customer has inspected and accepted the Aircraft as satisfactory in all respects. In addition to its obligations in the Agreement,
Customer will keep the Aircraft airworthy and in good repair and operating condition in accordance with all rules and regulations of the Federal Aviation
Administration ("FAA") and the manufacturer's approved maintenance and operations manuals, use the Aircraft for the purposes and in the manner required
Schedule A Aircraft Retail/Owner/Operator 3-19-2014
Page 1 of 2
EFTA00016642

=== Page 22 ===
EFTA00016643
BR
2016 APR 18 PM 1 55
OKLAHOMA OKLAHOMATY

=== Page 23 ===
for the insurance coverage in respect of the Aircraft and its use, and only operate the Aircraft with currently certified pilots having the minimum total pilot hours
required by such rules, regulations and/or insurance.
9.
Customer will keep its current Maintenance Programs in full force and effect. If there are no Maintenance Programs in effect at the time this Schedule A is
executed, then on Bank's request Customer will enroll and thereafter keep in effect a Maintenance Program as designated by Bank. Customer will at all times
allow Bank to have full access to all records or reports by all Maintenance Programs, and on Bank's request will confirm to any Maintenance Program provider
or sponsor that Bank has such access to information. Customer appoints Bank as its attorney-in-fact to deal with any Maintenance Program as necessary or
appropriate in order to enforce or assure Bank's rights to information under the Maintenance Program. This power of attorney is coupled with an interest in the
underlying subject matter and is expressly made irrevocable.
10. Customer will not sell, lease or otherwise transfer ownership or possession of any of the Aircraft to another person without Bank's prior written consent.
Executed by Customer on april 7
2016
Helibro, LLC
By: X
David Gunsauls, Member
By:
Mark X Gunsauls, Member Yours
By:
X Mah Summer
Mike Gunsauls, Member
Schedule A Aircraft Retail/Owner/Operator 3-19-2014
Page 2 of 2
EFTA00016644

=== Page 24 ===

=== Page 25 ===
Source.
Bank
1st Source Loan No.
IRREVOCABLE DE-REGISTRATION AND EXPORT REQUEST AUTHORIZATION
THIS IDERA IS LINKED TO AND PART OF THAT CERTAIN LOAN AND SECURITY AGREEMENT DATED
april 7
, 2016 BY AND BETWEEN Helibro, LLC AND 1st SOURCE BANK AND A CERTAIN
SCHEDULE A THERETO DATED
april 7
, 2016 WHICH IS BEING FILED WITH THE
FEDERAL AVIATION ADMINISTRATION CONTEMPORANEOUSLY HEREWITH
Document Date: april 7
2016
To: Federal Aviation Administration (US)
Re: Irrevocable De-Registration and Export Request Authorization
The undersigned is the registered Owner of the Bell (Bell Helicopter) 407 bearing manufacturer's serial number 53375 and registration number
N405PJ (together with all installed, incorporated or attached accessories, parts and equipment, the "aircraft").
This instrument is an irrevocable de-registration and export request authorization issued by the undersigned in favor of 1st Source Bank ("the
authorized party") under the authority of Article XIII of the Protocol to the Convention on International Interests in Mobile Equipment on Matters
specific to Aircraft Equipment. In accordance with that Article, the undersigned hereby requests:
(i)
recognition that the authorized party or the person it certifies as its designee is the sole person entitled to:
(a) procure the de-registration of the aircraft from the civil aircraft registry maintained by the Federal Aviation
Authority for the purposes of Chapter III of the Convention on International Civil Aviation, signed at Chicago,
on 7 December 1944; and
(b) procure the export and physical transfer of the aircraft from the United States of America; and
(ii)
confirmation that the authorized party or the person it certifies as its designee may take the action specified in clause
(i) above on written demand without the consent of the undersigned and that, upon such demand, the authorities in the
United States shall co-operate with the authorized party with a view to the speedy completion of such action.
The rights in favor of the authorized party established by this instrument may not be revoked by the undersigned without the written consent of the
authorized party.
Please acknowledge your agreement to this request and its terms by the appropriate notation in the space provided below and lodging this instrument
in the Aircraft Register maintained by the Federal Aviation Administration.
OWNER:
Helibro, LLC
By:
X
David Gunsauls, Member
By:
Mark Gunsauls, Member Summy
By: X Mun
Mike Gunsapls, Member
Agreed to and lodged this
2016.
Federal Aviation Administration:
Insert relevant notational details: im 20160411112843
Irrevocable De-Registration and Export Request Authorization 2-28-2006
Page 1 of 1
EFTA00016646

=== Page 26 ===
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2016 APR 18 PM 1 55
OKLAHOMA CITY
OKLAHOMA

=== Page 27 ===
U.S. Department
Flight Standards Service
P.O. Box 25504
of Transportation
Aircraft Registration Branch,
Oklahoma City, Oklahoma 73125-0504
AFS-750
(405) 954-3116
Federal Aviation
Toll Free: 1-866-762-9434
Administration
WEB Address: http://registry.faa.gov
Date of Issue: April 1, 2016
HELIBRO LLC
903 LANGLEY WAY
RED BLUFF, CA 96080-4559
Fax 763-5999
ATTENTION: AEROTITLE
T162337
This facsimile must be carried in the Aircraft as a Temporary Certificate of
Registration for
N405PJ BELL 407 Serial 53375 and is valid until May 01, 2016.
This is not an airworthiness certificate. For airworthiness information, contact the nearest
Federal Aviation Administration Flight Standards District Office.
Sharra
for
Jana L. Hammer
Manager, FAA Aircraft Registry, AFS-750
Federal Aviation Administration
AFS-750-FAX-4 (01/14)
EFTA00016648

=== Page 28 ===
EFTA00016649

=== Page 29 ===
FORM APPROVED
OMB No. 2120-0042
UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION-MIKE MONRONEY AERONAUTICAL CENTER
AIRCRAFT REGISTRATION APPLICATION
CERT: ISSUE DATE
UNITED STATES
REGISTRATION NUMBER
N 405PJ
AIRCRAFT MANUFACTURER & MODEL
Bell 407
AIRCRAFT SERIAL No.
53375
FOR FAA USE ONLY
Accepted SD Apr/01/2016
TYPE OF REGISTRATION LLC (Check One box)
1. Individual
2. Partnership
3. Corporation
4. Co-Owner
5. Government
8. Non-Citizen Corporation
9. Non-Citizen Corporation Co-Owner
NAME OR APPLICANT (Person(s) shown on evidence of ownership. If individual, give last name, first name, and middle initial.)
Helibro, LLC
TELEPHONE NUMBER: 536 527 - 5059
ADDRESS (Permanent mailing address for first applicant on list) (If P.O. Box is used, physical address must also be shown.)
Number and street: 903 Langley Way
Rural Route:
P.O. Box:
CITY
STATE
ZIP CODE
Red Bluff
CA
96080
CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS
ATTENTION! Read the following statement before signing this application.
This portion MUST be completed.
A false or dishonest answer to any question in this application may be grounds for punishment by fine and/or imprisonment
(U.S. Code, Title 18, Sec. 1001).
CERTIFICATION
I/WE CERTIFY:
(1) That the above aircraft is owned by the undersigned applicant, who is a citizen (including corporations)
of the United States.
(For voting trust, give name of trustee:
). or:
CHECK ONE AS APPROPRIATE
a.
A resident alien, with alien registration (Form 1-151 or Form 1-551) No.
b.
A non-citizen corporation organized and doing business under the laws of (state)
and said aircraft is based and primarily used in the United States. Records or flight hours are available for
inspection at
(2) That the aircraft is not registered under the laws of any foreign country; and
(3) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration
NOTE: If executed for co-ownership all applicants must sign. Use reverse side if necessary.
TYPE OR PRINT NAME BELOW SIGNATURE
SIGNATURE TITLE
member
DATE 3/24/16
EACH PART OF THIS
APPLICATION MUST
BE SIGNED IN INK.
31616
SIGNATURE yourself
DATE 3/24/16
Mike Gunsauls
Member
3-16-16
SIGNATURE consrols Mike Gansauls
DATE 3/24/16
Mombon
3-16-16
Dave Gunsauls
NOTE Pending receipt of the Certificate of Aircraft Registration, the aircraft may be operated for a period not in excess of 90
days, during which time the PINK copy of this application must be carried in the aircraft.
AC Form 8050-1 (5/12) (NSN 0052-00-628-9007)
EFTA00016650

=== Page 30 ===
EFTA000166
FILED WITH FAA
IRCRAFT REGISTRATION BR
2016 MAR 31 PM 1 25
OKLAHOMA VITY
OKLAHOMA

=== Page 31 ===
UNITED STATES OF AMERICA
OMB Control No. 2120-0042
Exp. 04/30/2017
U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION
AIRCRAFT BILL OF SALE
FOR AND IN CONSIDERATION OF $ 1+OVC THE
UNDERSIGNED OWNER(S) OF THE FULL
LEGAL
AND BENEFICIAL TITLE OF THE AIRCRAFT
DESCRIBED AS FOLLOWS:
UNITED STATES
REGISTRATION NUMBER
405PJ
AIRCRAFT MANUFACTURER & MODEL
Bell 407
AIRCRAFT SERIAL No.
53375
DOES THIS 24th
DAY OF MARCH
,
2016
HEREBY SELL, GRANT, TRANSFER AND
DELIVER ALL RIGHTS, TITLE, AND INTERESTS
SD008983 Conveyance Recorded Apr/01/2016 09:59 AM FAA
IN AND TO SUCH AIRCRAFT UNTO:
Do Not Write In This Block
FOR FAA USE ONLY
NAME AND ADDRESS
(IF INDIVIDUAL(S), GIVE LAST NAME, FIRST NAME, AND MIDDLE INITIAL.)
Helibro, LLC
PURCHASER
903 Langley Way
Red Bluff, CA 96080
DEALER CERTIFICATE NUMBER
AND TO IT'S Successors
EXECUTORS, ADMINISTRATORS, AND ASSIGNS TO HAVE AND TO HOLD
SINGULARLY THE SAID AIRCRAFT FOREVER, AND WARRANTS THE TITLE THEREOF:
IN TESTIMONY WHEREOF I
HAVE SET MY
HAND AND SEAL THIS 24th DAY OF MARCH 2016
NAME(S) OF SELLER
SIGNATURE(S)
TITLE
(TYPED OR PRINTED)
(IN INK) (IF EXECUTED FOR
(TYPED OR PRINTED)
Villeneuve Helicopters
Ltd
SELLER
CO-OWNERSHIP, 90 ALL MUSTSIGN
President
(Foreign Seller lowner)
ACKNOWLEDGMENT (NOT REQUIRED FOR PURPOSES OF FAA RECORDING: HOWEVER, MAY BE REQUIRED BY LOCAL LAW FOR
VALIDITY OF THE INSTRUMENT.)
ORIGINAL: TO FAA:
AC Form 8050-2 (01/12) (NSN 0052-00-629-0003)
160911354155
$5.00 03/31/2016
*including one ROLLS ROYCE 250-C47B engine bearing the manufacturer's serial number 847407
EFTA00016652

=== Page 32 ===
EFTA000
FILED WITH FAA
RCRAFT REGISTRATION BR
2016 MAR 31 PM 1 25
OKLAHUMA JITY
OKLAHOMA

=== Page 33 ===
Transport Transports
Canada Canada
Certified true copy
of the original information
contained in the Canadian
Operational Airworthiness, Standards
Civil Aircraft Register
Tower C, 330 Sparks Street (AARTM), Ottawa, ON, K1A 0N5
Telephone: (613) 952-4386
Accepted SD Apr/01/2016
Facsimile: (613) 990-1007
Email: AircraftRequirements-ExigencesAeronefs@tc.gc.ca
File - Dossier
March 31, 2016
5008-GPVS
U.S.A.
FEDERAL AVIATION ADMINISTRATION AIRCRAFT REGISTRATION BRANCH
(AFS-750) OKLAHOMA CITY OK 73125
1-405-954-3548 KOEXYAYX
URGENT AARTM 2016-0235
This confirms that the following aircraft was removed from the Canadian Civil Aircraft
Register effective March 31, 2016.
MANUFACTURER:
Bell Helicopter TEXTRON A Division of Textron Canada Ltd.
MODEL:
407
SERIAL NUMBER:
53375
REGISTRATION:
C-GPVS
Manay Values
For Jeffrey Phipps
IMPORT
Chief, Operational Airworthiness,
Standards, Transport Canada
Canadian Civil Aircraft Register website:
http://wwwapps2.tc.gc.ca/saf-sec-sur/2/CCARCS/aspscripts/en/menu.asp
Canada
CAR
COPY
EFTA00016654

=== Page 34 ===
EFTA00016655
CORAFT REGISTRATION BR
FILED WITH FAA
2016 MAR 31 PM 1 24
OKLAHOMA VITY
OKLAHOMA

=== Page 35 ===
titl
Bonded and Insured
Accepted MC Apr/01/2016
3426 S. Lakeside Dr., Oklahoma City, Oklahoma 73179
Phone: (405)763-5980 Toll Free: (866)738-8330 Fax: (405) 763-5999
www.AEROtitle.com info@AEROtitle.com
March 23, 2016
Federal Aviation Administration
Aircraft Registry
IMPORT
Oklahoma City, Oklahoma
N# ASSIGNMENT
Please have N405PJ assigned to the aircraft:
IMPORT (Prior Record N491GM), Bell 407, Serial Number 53375
This aircraft has been purchase by:
Helibro, LLC
903 Langley Way
Red Bluff, CA 96080
Attached is the fee of $10.
Should you have any questions or need additional information, please contact
AEROtitle at (405) 763-5980.
Sincerely,
A.Sannan
Adele Lannon
Escrow Executive
AEROtitle
EFTA00016656

=== Page 36 ===
EFTA00016657
FILED WITH FAA
TIRCRAFT REGISTRATION BR
2016 MAR 31 PM 1 24
OKLAHOMA CITY
OKLAHOMA

=== Page 37 ===
MEMORANDUM TO THE FILE
MAURICE COLEMAN
April 1, 2016
ID
DATE
A Prior Record search was performed for BELL 407, 53375 on April 1, 2016. Search results:
Prior Record N491GM
Re-instated as N405PJ
EFTA00016658

=== Page 38 ===
EFTA00016659

=== Page 39 ===
TELEGRAPHIC MESSAGE
NAME OF AGENCY
PRECEDENCE
SECURITY CLASSIFICATION
FEDERAL AVIATION ADMINISTRATION
MIKE MONRONEY AERONAUTICAL CENTER
ACTION PRIORITY
OKLAHOMA CITY, OKLAHOMA 73125
UNCLASSIFIED
INFO:
ACCOUNTING CLASSIFICATION
DATE/TIME PREPARED
FILE
5/7/2012 9:48:00 AM
FOR INFORMATION CALL
NAME
PHONE NUMBER
TYPE OF MESSAGE
RONALD B WARCUP
AFS-752
405-954-3116
SINGLE ADDRESS
THIS SPACE FOR USE OF COMMUNICATION UNIT
MESSAGE TO BE TRANSMITTED (Use double spacing and all capital letters)
TO:
FAX: 613-990-1007
TRANSPORT CANADA
OTTAWA, ONTARIO
CANADA KIA 0N8
THIS CONFIRMS DEREGISTRATION OF N491GM BELL 407 SERIAL NUMBER 53375 FROM THE UNITED STATES CIVIL
AIRCRAFT REGISTER EFFECTIVE 7:30 AM CDT MAY 7 2012. OUR RECORDS SHOW NO UNRELEASED RECORDED
LIENS AGAINST THE AIRCRAFT. THE LAST REGISTERED OWNER WAS COPTER LEASE LLC TRUSTEE.
Wendy Hedrick
for
WALTER L. BINKLEY
MANAGER, FAA AIRCRAFT REGISTRY AFS-750
FEDERAL AVIATION ADMINISTRATION
CC: JETS
SECURITY CLASSIFICATION
PAGE NO.
NO. OF PGS
WENDY HEDRICK
1
1
AFS-750-FAX-1 (04/07)
EFTA00016660

=== Page 40 ===
EFTA00016661

=== Page 41 ===
DEREGISTRATION OF UNITED STATES CIVIL AIRCRAFT
U.S. Registration
Temp
I.R.
Manufacturer
Model
Serial Number
N-491GM
Yes
No
X
Yes
X
No
BELL
407
53375
Last Registered Owner
COPTER LEASE LLC TRUSTEE
GENEVA CONVENTION- - Lien/Lease Information on File
X
None
Lien
Conveyance No.
Lien holder:
Lien
Conveyance No.
Lien holder:
Lease
Conveyance No.
Lessee:
Lease
Conveyance No.
Lessee:
CAPE TOWN TREATY - Lien Information on File
Written certification was received from IDERA authorized party that all registered interests ranking in priority to authorized party
have been discharged or the holders of such interests have consented to the export.
Conveyance No.
IDERA Authorized Party:
X
Written certification was received from the owner that all outstanding interests in the FAA aircraft record have been discharged or
the holders of such interests have consented to the export.
X
None
Lien
Conveyance No.
Lien holder:
Lien
Conveyance No.
Lien holder:
Lease
Conveyance No.
Lessee:
Lease
Conveyance No.
Lessee:
The above registration is to be cancelled for the reason checked below:
Expired
X
Exported to: CANADA
Totally destroyed or scrapped
At the request of:
Registrant
Owner
IDERA Authorized Party (Export only)
Other (Specify)
Official approving the cancellation:
TIME:
DATE:
Name: WENDY HEDRICK
May 7, 2012
CONFIRM TO: CANADA
COPY TO:
X
WIRE
MAIL
FOREIGN MARKINGS:
JETS - PD ROOM
The above registration has been cancelled
DATE:
and records adjusted accordingly.
Wendy Hedrick
May 7, 2012
AFS-750-17 (01/12)
EFTA00016662

=== Page 42 ===
EFTA00016663

=== Page 43 ===
Accepted WH May/07/2012
REQUEST TO DEREGISTER
Federal Aviation Administration
Oklahoma City, Oklahoma
Attn: Export/Priority
Date: May 1, 2012
Re: N491GM, Bell Helicopter 407, s/n 53375
To Whom It May Concern:
As owner of the above-referenced aircraft, we hereby request immediate deregistration as the
aircraft has been sold and is being exported to Canada.
We hereby certify that all registered interests ranking in priority have been discharged or the
holders of such interests have consented to the cancellation for export.
Once deregistered, please forward a copy of the confirmation to our representative, Jetstream
Escrow & Title Service, Inc., in the Public Documents Room.
Sincerely,
Copter Lease LLC TRUSTEE
Garth Sonnenberg
M
President / Managing Member
Signature
Title
EFTA00016664

=== Page 44 ===
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2012 MAY 3 PM 3 39
OKLAHOMA CITY
OKLAHOMA
-

=== Page 45 ===
DECLARATION
of
Accepted WH May/07/2012
INTERNATIONAL OPERATIONS
The undersigned owner of aircraft N 491GM , Manufacturer Bell
Model 407
, Serial Number 53375
declares that this aircraft is scheduled to make an international flight on may 3. (date) 2012
as Flight Number n/a departing New York, New York, US
(City/State)
with a destination of Canada
(City/Country)
Expedited registration in support of this international flight is requested
this 30th day of April
2012 20 , with knowledge that:
Whoever, in any matter within the jurisdiction of the executive branch of the Government
of the United States, knowingly and willfully makes or uses any false writing or document
knowing the same to contain any materially false, fictitious or fraudulent statement of
representation shall be fined under Title 18 United States Code or imprisoned not more
than 5 years, or both. 18 U.S.C. §1001(a).
Name of Owner:
Copter Lease LLC Trustee
Signature:
M
Typed Name and Title of Signer:
By: Garth Sonnenberg President / Managing Member
Comments:
EFTA00016666

=== Page 46 ===
EFTA00016667
FILED WITH FAA
AIRCRAFT REGISTRATION OR
2012 MAY 3 PM 3 39
OKLAHOMA CITY
OKLAHOMA

=== Page 47 ===
U.S. Department
Flight Standards Service
P.O. Box 25504
of Transportation
Aircraft Registration Branch,
Oklahoma City, Oklahoma 73125-0504
AFS-750
(405) 954-3116
Federal Aviation
Toll Free: 1-866-762-9434
Administration
WEB Address: http://registry.faa.gov
Date of Issue: May 3, 2012
COPTER LEASE LLC TRUSTEE
4701 HAWKINS ST NE
ALBUQUERQUE, NM 87109-4333
Fax 405-703-4748
HAND DELIVERED TO JETS IN THE PD ROOM
T122866
This facsimile must be carried in the Aircraft as a Temporary Certificate of
Registration for
N491GM BELL 407 Serial 53375 and is valid until Jun 02, 2012.
This is not an airworthiness certificate. For airworthiness information, contact the nearest
Federal Aviation Administration Flight Standards District Office.
Wendy Hedrick
for
Walter Binkley
Manager, FAA Aircraft Registry, AFS-750
Federal Aviation Administration
AFS-750-FAX-4 (03/10)
EFTA00016668

=== Page 48 ===
EFTA00016669

=== Page 49 ===
DECLARATION
of
INTERNATIONAL OPERATIONS
Accepted WH May/03/2012
The undersigned owner of aircraft N 491GM , Manufacturer Bell
Model 407
, Serial Number 53375
declares that this aircraft is scheduled to make an international flight on may 2,2012 (date)
as Flight Number n/a
departing
us
(City/State)
with a destination of Carada
(City/Country)
Expedited registration in support of this international flight is requested
this 30th day of April
20 12 , with knowledge that:
Whoever, in any matter within the jurisdiction of the executive branch of the Government
of the United States, knowingly and willfully makes or uses any false writing or document
knowing the same to contain any materially false, fictitious or fraudulent statement of
representation shall be fined under Title 18 United States Code or imprisoned not more
than 5 years, or both. 18 U.S.C. 1001(a).
Name of Owner:
Copter Lease LLC Trustee
Signature:
M
Typed Name and Title of Signer:
By: Garth Sonnenberg President / Managing Member
Comments:
EFTA00016670

=== Page 50 ===
EFTA00016671
FILED WITH FAA
AIRCRAFT REGISTRATION DR
2012 APR 30 PM 1 34
OKLAHOMA CITY
OKLAHOMA

=== Page 51 ===
FORM APPROVED
OMB No. 2120-0042
UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION-MIKE MONRONEY AERONAUTICAL CENTER
AIRCRAFT REGISTRATION APPLICATION
CERT: ISSUE DATE
UNITED STATES
REGISTRATION NUMBER
N 1491GM
AIRCRAFT MANUFACTURER & MODEL
Bell 407
AIRCRAFT SERIAL No.
53375
FOR FAA USE ONLY
TYPE OF REGISTRATION (Check One box)
Accepted WH May/03/2012
1. Individual
2. Partnership
3. Corporation
4. Co-Owner
5. Government
8. Non-Citizen Corporation
9. Non-Citizen Corporation Co-Owner
NAME OR APPLICANT (Person(s) shown on evidence of ownership. If individual, give last name, first name, and middle initial.)
Copter Lease LLC Trustee
TELEPHONE NUMBER: 505 345-5557
ADDRESS (Permanent mailing address for first applicant on list) (If P.O. Box is used, physical address must also be shown.)
Number and street: 4701 HAWKINS st NE
Rural Route:
P.O. Box:
CITY
STATE
ZIP CODE
Albuquerque
NM
87109
CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS
ATTENTION! Read the following statement before signing this application.
This portion MUST be completed.
A false or dishonest answer to any question in this application may be grounds for punishment by fine and/or imprisonment
(U.S. Code. Title 18, Sec. 1001).
CERTIFICATION
I/WE CERTIFY:
(1) That the above aircraft is owned by the undersigned applicant. who is a citizen (including corporations)
of the United States.
(For voting trust, give name of trustee:
). or:
CHECK ONE AS APPROPRIATE:
a. A resident alien, with alien registration (Form 1-151 or Form 1-551) No.
b.
A non-citizen corporation organized and doing business under the laws of (state)
and said aircraft is based and primarily used in the United States. Records or flight hours are available for
inspection at
(2) That the aircraft is not registered under the laws of any foreign country: and
(3) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration
NOTE: If executed for co-ownership all applicants must sign. Use reverse side if necessary.
TYPE OR M PRINT NAME BELOW SIGNATURE
SIGNATURE
TITLE Pres/managing maho
DATE
EACH PART OF THIS
APPLICATION MUST
BE SIGNED IN INK.
4/25/12
TITLE
DATE
By: SIGNATURE GARTH Somenherg
SIGNATURE
TITLE
121211344579
DATE
$5.00 04/30/2012
NOTE Pending receipt of the Certificate of Aircraft Registration, the aircraft may be operated for a period not in excess of 90
days, during which time the PINK copy of this application must be carried in the aircraft.
AC Form 8050-1 (1/09) (NSN 0052-00-628-9007) Supersedes Previous Edition
EFTA00016672

=== Page 52 ===
EFTA00016673
pd: MEILED,WITH-FAA
AIRCRAFT REGISTRATION BR
2012 APR 30 PM 1 34 manya 1/50/100
OKLAHOMA CITY
OKLAHOMA
VIA
ssind
HJOI Harpyne 2/A- WE
202 PAR-PREJ
Coloper 1600 ITS therefor
x
23312
5511 tel
didicil

=== Page 53 ===
EAGLE
COPTERS
BILL OF SALE
For and in consideration of Valuable Consideration, the undersigned owner of the
full and legal and beneficial title, free of liens, to the Aircraft Bell 407 N491GM
WH004801 Conveyance Recorded May/03/2012 12:22 PM FAA
S/N 53375 does this 30H dayot April, 2012, hereby sell, grant, transfer and
deliver all rights, title and interests in and to such Aircraft, unto:
PURCHASER:
Copter Lease L.L.C. Trustee
4701 Hawkins, N.E.
Albuquerque, New Mexico 87109
USA
In testimony whereof, I have set my signature this 30th day of April, 2012.
SELLER:
Eagle Copters Ltd.
823 McTavish Road N.E.
Calgary, Alberta, Canada
T2E 7G9
Signature:
Mr. 250g
Name:
Mike O'Reilly
Title:
President
Eagle Copters Ltd.
(foreign seller)
121211344579
$5.00 04/30/2012
823 McTavish ROAD N.E., CALGARY, ALBERTA, T2E 7G9 CANADA
Tel: (403) 250-7370, Fax: (403) 250-9276, Email: moreilly@eaglecopters.com
EFTA00016674

=== Page 54 ===
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2012 APR 30 PM 1 34
OKLAHOMA CITY
OKLAHOMA

=== Page 55 ===
UNITED STATES OF AMERICA
OMB Control No. 2120-0042
U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION
Exp. 11/30/2014
AIRCRAFT BILL OF SALE
FOR AND IN CONSIDERATION OF $ 140vc THE
UNDERSIGNED OWNER(S) OF THE FULL
LEGAL
AND BENEFICIAL TITLE OF THE AIRCRAFT
DESCRIBED AS FOLLOWS:
UNITED STATES
REGISTRATION NUMBER
N 1491GM
AIRCRAFT MANUFACTURER & MODEL
Bell 407
AIRCRAFT SERIAL No. 53375
DOES THIS
30th
DAY OF April
2012
HEREBY SELL, GRANT, TRANSFER AND
DELIVER ALL RIGHTS, TITLE, AND INTERESTS
IN AND TO SUCH AIRCRAFT UNTO:
Do Not Write In This Block
WH004800 Conveyance Recorded May/03/2012 12:22 PM FAA
FOR FAA USE ONLY
NAME AND ADDRESS
(IF INDIVIDUAL(S), GIVE LAST NAME, FIRST NAME, AND MIDDLE INITIAL.)
PURCHASER
Eagle Copters Ltd.
823 McTavish Road NE
Calgary, AB Canada T2E 7G9
DEALER CERTIFICATE NUMBER
AND TO
its successors
EXECUTORS, ADMINISTRATORS, AND ASSIGNS TO HAVE AND TO HOLD
SINGULARLY THE SAID AIRCRAFT FOREVER, AND WARRANTS THE TITLE THEREOF:
IN TESTIMONY WHEREOF I
HAVE SET my
HAND AND SEAL THIS 30th DAY OF April,2012
NAME(S) OF SELLER
SIGNATURE(S)
TITLE
(TYPED OR PRINTED)
(IN INK) (IF EXECUTED FOR
(TYPED OR PRINTED)
CO-OWNERSHIP, ALL MUSTSIGN.
Freedom Air
SELLER
International, Inc
Darreak. Ind yhe
Vice President
ACKNOWLEDGMENT (NOT REQUIRED FOR PURPOSES OF FAA RECORDING: HOWEVER, MAY BE REQUIRED BY LOCAL LAW FOR
VALIDITY OF THE INSTRUMENT.)
ORIGINAL: TO FAA:
AC Form 8050-2 (01/12) (NSN 0052-00-629-0003)
EFTA00016676

=== Page 56 ===
EFTA00016677
FILED WITH FAA
AIRCRAFT REGISTRATION BR
2012 APR 30 PM 1 34
OKLAHOMA CITY
OKLAHOMA

=== Page 57 ===
FORM APPROVED
OMB No. 2120-0042
UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION-MIKE MONRONEY AERONAUTICAL CENTER
AIRCRAFT REGISTRATION APPLICATION
CERT: ISSUE DATE
UNITED STATES
REGISTRATION NUMBER
N 491GM
AIRCRAFT MANUFACTURER & MODEL
Bell 407
AIRCRAFT SERIAL No
53375
FOR FAA USE ONLY
Accepted MC Aug/25/2010.
TYPE OF REGISTRATION (Check One box)
1. Individual
2. Partnership
3. Corporation
4. Co-Owner
5. Government
8. Non-Citizen Corporation
9. Non-Citizen Corporation Co-Owner
NAME OR APPLICANT (Person(s) shown on evidence of ownership. If individual, give last name, first name, and middle initial.)
Freedom AirInternational, Inc.
TELEPHONE NUMBER: (
)
ADDRESS (Permanent mailing address for first applicant on list) (If P.O. Box is used, physical address must also be shown.)
Number and street: 103 FOUIK Road, Suite 202
Rural Route:
P.O. Box:
CITY
STATE
ZIP CODE
Wilmington
DE
19803
CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS
ATTENTION! Read the following statement before signing this application.
This portion MUST be completed.
A false or dishonest answer to any question in this application may be grounds for punishment by fine and/or imprisonment
(U.S. Code, Title 18, Sec. 1001).
CERTIFICATION
I/WE CERTIFY:
(1) That the above aircraft is owned by.the undersigned applicant, who is a citizen (including corporations)
of the United States.
(For voting trust, give name of trustee:
). or:
CHECK ONE AS APPROPRIATE
a.
A resident alien, with alien registration (Form 1-151 or Form 1-551) No.
b.
A non-citizen corporation organized and doing business under the laws of (state)
and said aircraft is based and primarily used in the United States. Records or flight hours are available for
inspection at
(2) That the aircraft is not registered under the laws of any foreign country; and
(3) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration
NOTE: If executed for co-ownership all applicants must sign. Use reverse side if necessary.
TYPE OR PRINT NAME BELOW SIGNATURE
SIGNATURE Darrenk Imdghe
TITLE
DATE
EACH PART OF THIS
APPLICATION MUST
Darren Indyke
Vice President
8/2/10
BE SIGNED IN INK.
SIGNATURE
TITLE
DATE
SIGNATURE
TITLE
DATE
102280834295
$5.00 08/16/2010
NOTE Pending receipt of the Certificate of Aircraft Registration, the aircraft may be operated for a period not in excess of 90
days, during which time the PINK copy of this application must be carried in the aircraft.
AC Form 8050-1 (1/09) (NSN 0052-00-628-9007) Supersedes Previous Edition
EFTA00016678

=== Page 58 ===
EFTA00016679
FILED WITHFAA
AIRCRAFT REGISTRATION BR
2010 AUG 16 AM 8 30
OKLAHOMA CITY
OKLAHOMA

=== Page 59 ===
DOCUMENT LEVEL ANNOTATIONS
NAME CHANGE
REV/DOI 11/13/2002
EFTA00016680

=== Page 60 ===
EFTA00016681

=== Page 61 ===
U.S. Department
Flight Standards Service
P.O. Box 25504
of Transportation
Aircraft Registration Branch,
Oklahoma City, Oklahoma 73125-0504
AFS-750
(405) 954-4206
Federal Aviation
Toll Free: 1-866-704-4715
Administration
WEB Address: http://registry.faa.gov
Date of Issue: February 23, 2010
SHMITKA AIR INC
103 FOULK RD
WILMINGTON, DE 19803-3742
HAND DELIVERED TO IATS IN THE PD ROOM
T100820
This facsimile must be carried in the Aircraft as a Temporary Certificate of
Registration for
N491GM BELL 407 Serial 53375 and is valid until Mar 25, 2010.
This is not an airworthiness certificate. For airworthiness information, contact the nearest
Federal Aviation Administration Flight Standards District Office.
Thema Mc allough
for
Walter Binkley
Manager, FAA Aircraft Registry, AFS-750
Federal Aviation Administration
AFS-750-FAX-4 (10/05)
EFTA00016682

=== Page 62 ===
EFTA00016683

=== Page 63 ===
PRIORITY
Accepted TM Feb/23/2010
DECLARATION OF INTERNATIONAL OPERATIONS
THE UNDERSIGNED OWNER OF AIRCRAFT N491GM, MANUFACTURER:
BELL, MODEL 407, WITH SERIAL NUMBER 53375, HEREBY DECLARES
THAT THIS AIRCRAFT IS SCHEDULED TO MAKE AN INTERNATIONAL
FLIGHT ON MARCH 2 2010, AS FLIGHT NUMBER N491GM, DEPARTING:
WEST PALM BEACH, FLORIDA, WITH A DESTINATION OF: NASSAU,
BAHAMAS.
EXPEDITED REGISTRATION IN SUPPORT OF THIS INTERNATIONAL
FLIGHT IS REQUESTED THIS 23RD DAY OF FEBRUARY, 2010, WITH
KNOWLEDGE THAT:
Whoever, in any matter within the jurisdiction of the executive
branch of the Government of the United States, knowingly and
willfully makes or uses any false writing or document knowing
the same to contain any materially false, fictitious or fraudulent
statement of representation shall be fined under Title 18 United
States Code or imprisoned not more than 5 years, or both (18
U.S.C. Sec. 1001(a).
NAME OF OWNER:
Shmitka Air, Inc
TYPED NAME OF SIGNER: Darren Indyke
SIGNATURE: Dowen DuShr
TITLE:
Vice President, Shmitka Air, Inc.
COMMENTS:
Filed by: INSURED AIRCRAFT TITLE SERVICE/JOAN ROBERTS
405-681-6663
PLEASE SEND ORIGINAL TO I.A.T.S. (INSURED AIRCRAFT TITLE
SERVICE)
Return Certificate of Registration to
PRIORITY
I.A.T.S.
CAR
COPY
EFTA00016684

=== Page 64 ===
AIRCRAFT REGISTRATION
BR
2010 FEB 23 AM 10 55
OKLAHOMA CITY
OKLAHOMA

=== Page 65 ===
FORM APPROVED
OMB No. 2120-0042
UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION-MIKE MONRONEY AERONAUTICAL CENTER
AIRCRAFT REGISTRATION APPLICATION
CERT. ISSUE DATE
UNITED STATES
REGISTRATION NUMBER
N491GM
AIROBAFT MANUFACTURER & MODEL
Bell 407
AIRCRAFT 53375 BERIAL No
FOR FAA USE ONLY
Accepted TM Feb/23/2010
TYPE OF REGISTRATION (Check one box)
1. Individual
2. Partnership
3. Corporation
4. Co-owner
5. Gov't
8.
Non-Citizen
Corporation
NAME OF APPLICANT (Person(s) shown on evidence of ownership If individual, give last name, first name, and middle initial.)
Shmitka Air, Inc.
TELEPHONE NUMBER: (
)
ADDRESS (Permanent mailing address for first applicant listed.) (If P.O. BOX is used, physical address must also be shown.)
Number and street: 103 Foulk Road, Suite 202
Rural Route:
P.O. Box:
CITY
STATE
ZIP CODE
Wilmington
DE
19803
CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS
ATTENTION! Read the following statement before signing this application.
This portion MUST be completed.
A false or dishonest answer to any question in this application may be grounds for punishment by fine and or imprisonment
(U.S. Code. Title 18, Sec. 1001).
CERTIFICATION0541056293
I/WE CERTIFY:
$5.00 02/23/2010
(1) That the above aircraft is owned by the undersigned applicant, who is a citizen (including corporations)
of the United States.
(For voting trust, give name of trustee:
1. or:
CHECK ONE AS APPROPRIATE
a.
A resident alien, with alien registration (Form 1-151 or Form 1-551) No.
b.
A non-citizen corporation organized and doing business under the laws of (state)
and said aircraft is based and primarily used in the United States Records or flight hours are available for
inspection at
(2) That the aircraft is not registered under the laws of any foreign country: and
(3) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration
NOTE: If executed for co-ownership all applicants must sign. Use reverse side if necessary.
TYPE OR PRINT NAME BELOW SIGNATURE
SIGNATURE
TITLE
DATE
EACH PART OF THIS
APPLICATION MUST
BE SIGNED IN INK
DamenKillife DARREN K. INDYKE
Vice President
2/16/10
SIGNATURE
TITLE
DATE
SIGNATURE
TITLE
DATE
NOTE Pending receipt of the Certificate of Aircraft Registration, the aircraft may be operated for a period not in excess of 90
days. during which time the PINK copy of this application must be carried in the aircraft.
AC Form 8050-1 (5/03) (0052-00-628-9007)
EFTA00016686

=== Page 66 ===
EFTA00016687
AIRCRAFT REGISTRATION
BR
2010 FEB-23 AM 10 55
OKLAHOMA CITY
OKLAHOMA
INFO
EPBLIC
3°N to
Hollow

=== Page 67 ===
FORM APPROVED
00000001813
OMB NO. 2120-0029
EXP. DATE 10/31/84
UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION-MIKE MONRONEY AERONAUTICAL CENTER
AIRCRAFT REGISTRATION APPLICATION
CERT. ISSUE DATE
UNITED STATES
REGISTRATION NUMBER
N
491GM
J NOV 1 2002
AIRCRAFT MANUFACTURER & MODEL
BELL 407
ISSUED TEMP CERT OF
REG TO EXPIRE
AIRCRAFT SERIAL No.
53375
T
FOR FAA USE ONLY
TYPE OF REGISTRATION (Check one box)
1. Individual
2 Partnership
X3 Corporation
4. Co-owner
5. Gov't
8. Foreign-owned
Corporation
NAME OF APPLICANT (Person(s) shown on evidence of ownership. If individual, give last name, first name, and
middle initial.)
AIR GHISLAINE INC.
TELEPHONE NUMBER:
917, 868-6145
ADDRESS (Permanent mailing address for first applicant listed.)
103 FOULK ROAD
Number and street:
Rural Route:
P.O. Box:
CITY
STATE
ZIP CODE
WILMINGTON
DELAWARE
19803
CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS
ATTENTION! Read the following statement before signing this application.
A false or dishonest answer to any question in this application may be grounds for punishment by fine and / or
imprisonment (U.S. Code, Title 18, Sec. 1001).
CERTIFICATION
I/WE CERTIFY:
(1) That the above aircraft is owned by the undersigned applicant, who is a citizen (including corporations)
of the United States
(For voting trust, give name of trustee:
). or:
CHECK ONE AS APPROPRIATE
a.
A resident alien, with alien registration (Form 1-151 or Form 1-551) No.
b.
A foreign-owned corporation organized and doing business under the laws of (state or possession)
and said aircraft is based and primarily used in the United States. Records
of flight hours are available for inspection at
(2) That the aircraft is not registered under the laws of any foreign country: and
(3) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration
NOTE: If executed for co-ownership all applicants must sign. Use reverse side if necessary.
TYPE OR PRINT NAME BELOW SIGNATURE
TITLE
DATE
Lary SIGNATURE SIGNATURE Uisk
DIRECTOR
10-7-02
EACH PART OF THIS
APPLICATION MUST
BE SIGNED IN INK.
TITLE
DATE
SIGNATURE
TITLE
DATE
NOTE: Pending receipt of the Certificate of Aircraft Registration. the aircraft may be operated for a period not
in excess of 90 days, during which time the PINK copy of this application must be carried in the air-
craft.
AC FORM 8050-1 (1-83) (0052-00-628-9005)
EFTA00016688

=== Page 68 ===
AIRCRAFT WITH FAX BR
FILED
'02 NOV 12 PM 1 49
OKLAHOMA Y
OKLAHOMA

=== Page 69 ===
FORM APPROVED
0
UNITED STATES OF AMERICA
018
12
OMB NO. 2120-0042
U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION
AIRCRAFT BILL OF SALE
2A287611
FOR AND IN CONSIDERATION OF sio+ovc THE
UNDERSIGNED OWNER(S) OF THE FULL LEGAL
AND BENEFICIAL TITLE OF THE AIRCRAFT DES.
CRIBED AS FOLLOWS:
UNITED STATES
REGISTRATION NUMBER
N G-IORB
CONVEYANCE
AIRCRAFT MANUFACTURER & MODEL 5537 BELL 407
RECORDED
AIRCRAFT SERIAL No.
53375
DOES THIS 30th DAY OF QCT 2002 10
'02 HOW 13 AM 8 27
HEREBY SELL, GRANT, TRANSFER AND
DELIVER ALL RIGHTS, TITLE, AND INTERESTS
FEDERAL
AVATION
IN AND TO SUCH AIRCRAFT UNTO:
ADMIN FOR FAA USE ONLY
Not Write in This Block
NAME AND ADDRESS
(IF INDIVIDUAL(S). GIVE LAST NAME, FIRST NAME. AND MIDDLE INITIAL)
AIR GHISLAINE INC
PURCHASER
457 MADISON AVENUE
FOURTH FLOOR
NEW YORK
NEW YORK 10022
DEALER CERTIFICATE NUMBER
AND TO
EXECUTORS, ADMINISTRATORS, AND ASSIGNS TO HAVE AND TO HOLD
SINGULARLY THE SAID AIRCRAFT FOREVER, AND WARRANTS THE TITLE THEREOF.
IN TESTIMONY WHEREOF
HAVE SET
HAND AND SEAL THIS 304 DAY OF Oct 2002
NAME (S) OF SELLER
SIGNATURE (S)
TITLE
(TYPED OR PRINTED)
(IN INK) (IF EXECUTED
(TYPED OR PRINTED)
FOR CO-OWNERSHIP ALL MUST
SIGN.)
Robard
COMPANY
SELLER
Consultants LVC
&
SECRETARY
foreign owner
Seller
023161350501
$5.00 11/12/2002
ACKNOWLEDGMENT (NOT REQUIRED FOR PURPOSES OF FAA RECORDING HOWEVER, MAY BE REQUIRED
BY LOCAL LAW FOR VALIDITY OF THE INSTRUMENT.)
ORIGINAL: TO FAA
AC Form 8050-2 (9/92) (NSN 0052-00-629-0003) Supersedes Previous Edition
EFTA00016690

=== Page 70 ===
'02
OKLAHOMATITY
1 49

=== Page 71 ===
04-NOV. 02 (MON) 16:36
CAA AIRCRAFT REGISTRATION
FAX : +44 20 7453 6670
P. 001
J NOV 1 3 2002
Safety Regulation Group
PRIOR RECORD N 407RB
Aircraft Registration
10 NOV 04 2002
Civil Aviation
Authority
REINSTATED
as n 491Gm
CANCELLATION OF REGISTRATION OF AIRCRAFT
10 NOV 06 2002
Clvil Aircraft and the registration marks cancelled.
This is to certify that the following aircraft has been removed from the United Kingdom Register of
Mark
: G-IORB
Certificate number
:
G-IORB/R1
Manufacturer:
:
BELL HELICOPTER TEXTRON CANADA
Type
:
BELL 407
Serial number
: 53375
Removal date
:
4 NOVEMBER 2002 15:35 UTC
Removal reason
:
Transferred to another country or authority
Remarks
:
TO UNITED STATES OF AMERICA
This aircraft was last registered in the name(s) of :-
ROBARD CONSULTANTS LTD
GLOBE SQUARE
DUKINFIELD
SK16 4RG
NATION
Dieres
CIVIL
AUTHORITY
M STEVENS
For the Civil Aviation Authority
4 November 2002
Civil Aviation Authority
Aircraft Registration CAA House 45-59 Kingsway London WC2B 6TE www.caa.co.uk
Telephone (020) 7453 6686 Fax (020) 7453 6670 alrcraft.reg@cae.co.uk
Confumstion retal, # 1623, ffr 11/5/02
INVESTOR DN POOPLE
Canf RETD #1814 FFR 11/12/2002
11/04/2002 MON 09:37 [TX/RX NO 7612] 0 001
Imler
EFTA00016692

=== Page 72 ===
EFTA00016693
FILED FAA
AIRCRAFT TRATION BR
'02 NOV 4 AM 10 11
OKLAHOMA CITY
OKLAHOMA

=== Page 73 ===
00000001622 11-4-02
Registry DEPT.
PLEASE ASSIGN TAIL NUMBER
N491GM GM
To HELICOPTER SERIAL # 53375
1999 BELL 407"
COMPANY NAME:
AiR GhisLAINE INC.
103 FOUCK RD
Wilminston D.E.
19803
DIRECTOR of Aviption
:
023091359285
Contact: LARRY Visoski
$10.00 11/05/2002
Lang V.P. 917-868-6145
EFTA00016694

=== Page 74 ===
FILED WITHFAA
IRCRAFT REGISTRATION BR
'02 NOV 5- PM 2 16
OKLAHOMA CITY
OKLAHOMA

=== Page 75 ===
TELEGRAPHIC MESSAGE
NAME OF AGENCY
PRECEDENCE
SECURITY CLASSIFICATION
FEDERAL AVIATION ADMINISTRATION
ACTION:
PRIORITY
UNCLASS
MM AERONAUTICAL CENTER
OKLAHOMA CITY, OKLAHOMA 73125
INFO:
9-1
ACCOUNTING CLASSIFICATION
DATE PREPARED
FILE
MAY 23, 2000
FOR INFORMATION CALL
NAME
PHONE NUMBER
TYPE OF MESSAGE
MULTIPLE-
SANDI RUSHING
AFS-752
X4-3116
SINGLE
BOOK
ADDRESS
THIS SPACE FOR USE OF COMMUNICATION UNIT
MESSAGE TO BE TRANSMITTED (Use double spacing and all capital letters)
TO:
FAX: +44 20 7453 6670
CIVIL AVIATION AUTHORITY
LONDON WC2, ENGLAND
THIS CONFIRMS DEREGISTRATION OF N407RB BELL 407 SERIAL 53375 FROM THE
UNITED STATES CIVIL AIRCRAFT REGISTER EFFECTIVE 7:30AM CDT MAY 23, 2000.
OUR RECORDS SHOW NO UNRELEASED RECORDED LIENS AGAINST AIRCRAFT.
Charlene adams
for
JULIE A. STANFORD
MANAGER, FAA AIRCRAFT REGISTRY AFS-750
FEDERAL AVIATION ADMINISTRATION
CC: USAT-PD ROOM
BELL HEL TEXTRON INC
SECURITY CLASSIFICATION
MAGGIE MIXON
PAGE NO.
NO. OF PGS.
LYKINS:mf
1
1
STANDARD FORM 14
Previous editions usable NSN 7540-00-634-3968
REVISED 11-80
14-103
GSA FPMR (41 CFR) 101-35.306
*U.S. Government Printing Office: 1992-312/071/40312
EFTA00016696

=== Page 76 ===
9
EFTA00016697

=== Page 77 ===
8-1
DEREGISTRATION OF UNITED STATES CIVIL AIRCRAFT
Aircraft Registration No.
Manufacturer and Model
Serial Number
N-407RB
BELL
407
53375
LAST OWNED BY:
Lien Information on File:
LIENHOLDER:
BELL HELICOPTER TEXTRON INC
X
None
Outstanding
Recorded Conveyance
No.
The above registration is to be canceled for the reason checked below:
Accident
X
Exported to: UNITED KINGDOM
Totally destroyed or scrapped
At the request of:
Registrant
Owner
Revocation
AC Form 8050-73 Action
INDEX CHECKED THROUGH:
Other (Specify)
5-22-00
Name: Official Shirley approving F. fundy Lykins the cancellation: Jefkin
TIME:
DATE:
0730 A.M. CST
May 23, 2000
CONFIRM TO: UNITED KINGDOM
COPY TO:
X
WIRE
MAIL
FOREIGN MARKINGS:
U.S. AIRCRAFT TITLES, INC., PD ROOM
AND
CHARGE INFO WIRE TO:
BELL HELICOPTER TEXTRON, INC., ATTN: MAGGIE
MIXON, P.O. BOX 482, FORT WORTH, TX 76101
The above registration has been canceled
DATE:
Records AC and Form records 8050-17 Clerk adjusted huly (4/97) accordingly. Jykins
May 23, 2000
EFTA00016698

=== Page 78 ===
8
EFTA00016699

=== Page 79 ===
MAY-22-00 02:35 PM U.S. AIRCRAFT TITLES
4056887732
P.02
01290001377
Facsimile Mercare
7-1
UU MAY 23 2000
Bell Helicopter TEXTRON
Mailing Address:
Pouching Address:
Bell Helloopter Textron Inc.
Bell Helloopter Textron Inc.
P.O. Box 482, Dept. M9
Telephone: (817) 280-3001
3000 South Norwood
Fort Worth, Texas 76101, USA
Faceimile: (817) 278-9097
Hurst, Texas 76053, USA
COMMERCIAL BUSINESS OPERATIONS
DATE:
22 May, 2000
FAX NO: (405) 680-3188
FAX TO:
Federal Aviation Administration
ATTN:
Export Examiner
FROM:
M. Mixon
REF:
De-registration of Model 407, S/N 53375
This message is to advise that Bell Helicopter Model 407, S/N 53375, Registration No.
N407RB has been sold and will be exported to U.K.
This aircraft was previously entered on the US Registry as US. Registration No. N407RB.
Accordingly, it is requested that this US. Registration is canceled effective immediately.
It is eincerely requested that the Civil Aviation Air Authority In the U.K. be notified
Immediately. Additionally, would you please mail a copy of your message to Maggle Mixon.
Charge communications to Bell Helicopter Textron Inc., PO Box 482, Fort Worth. Texas
76101.
Thank you for your prompt handling of this request.
Respectfully,
Bell Helicopter Textron Inc.
Maggie Misor
Maggle Mixon
Sr. Customizing & Delivery
Contracts Manager
MM:kkw
-/- 10.00 years 143.01 00/22/20
'Twan "720 TIMA :Aa tue:
EFTA00016700

=== Page 80 ===
EFTA00016701
FILED WITHFAA
'00 MAY 22 PM 2 59
OKLAHOJA CITY
OKLAHOMA
4

=== Page 81 ===
6-1
1000000126
407RB
CHANGED TO
4
AUG 17 1999
DATE
ASSIGNMENT OF SPECIAL REGISTRATION NUMBERS
Special Registration Number
N 407RB
Aircraft Make and Model
us Department
of Transportation
BELL
407
Present Registration Number
Federal Aviation
Serial Number
Administration
N
53375
1182206
61161
Issue Date:
ICAO AIRCRAFT ADDRESS CODE
AUGUST 03, 1999
FOR N407RB = 51144033
This is your authority to change the United States registra-
tion number on the above described aircraft to the special
BELL HELICOPTER TEXTRON INC
registration number shown.
PO BOX 482
Carry duplicate of this form in the aircraft together with the
FORT WORTH TX 76101-0482
old registration certificate as Interim authority to operate the
aircraft pending receipt of revised certificate of registration.
Obtain a revised certificate of airworthiness from your near-
est Flight Standards District Office.
The latest FAA Form 8130-6, Application
For Airworthiness on file is dated:
The airworthiness classification and category:
INSTRUCTIONS:
SIGN AND RETURN THE ORIGINAL of this form to the Civil Aviation Registry, AFS-750, within 5 days after the special registration number is
affixed on the aircraft. A revised certificate will then be issued. This authority is valid for 90 days from the issue date.
The authority to use the special number expires:
AUGUST 03, 2000
CERTIFICATION: I certify that the special registration number was placed on the
RETURN FORM TO:
aircraft described above.
S.P.M.Pay
Civil Aviation Registry, AFS-750
P.O. Box 25504
Signature of Owner.
Oklahoma City, Oklahoma 73125-0504
Title of Owner:
Contract Manager
Date Placed on Aircraft:
6 August 1999
EFTA00016702
AC Form 8050-64
(5/95) Supersedes Previous Edition
3

=== Page 82 ===
6
EFTA00016703
OKLAHONA
A110 VWOHVINO
LI OT WU OI 909 88.
02

=== Page 83 ===
5-1
TITLE SEARCH
00000 MORTGAGE-LIN FINGS 0
ESCROWS
FEDERAL AVIATION
Title and Guaranty Company
incorporated
not affiliated
TITLE INSURANCE
with U.S. Govt
STREET ADDRESS
TEL. 405-682-3400
MAILING ADDRESS.
6501 S. DENNING
WATS- 800-654-5694
P.O. BOX 19929
OKLAHOMA CITY. OK 73159
FAX - 405-681-4763
OKLA CITY, OKLA 73144-0929
SPECIAL 'N' NUMBER REQUEST
ATTN: CENTRAL RECORDS
At 407RB
FAA
41161
4
AUG 03 1999
PLEASE ASSIGN N 407RB
WHICH HAS BEEN RESERVED FOR:
BELL HELICOPTER TEXTRON, INC.
P.O. BOX 482
FORT WORTH, TX 76101-0482
THIS SPECIAL NUMBER IS TO BE PUT ON THE FOLLOWING AIRCRAFT:
BELL 407, SN: 53375, CURRENTLY N61161
ADDITIONAL INFORMATION:
PLEASE SEND CONFIRMATION (8050-64) TO US IN PD ROOM FOR MAILING.
THANK YOU FOR YOUR ASSISTANCE,
FEDERAL AVIATION TITLE COMPANY
Susie Willins
SUSIE WILKINS
DATE: JULY 26, 1999
682-3400
EFTA00016704

=== Page 84 ===
EFTA00016705
'83 JUL 28 AM 9 22
OKLAHOMA CITY
CKLAHOMA
5

=== Page 85 ===
H-1
FORM APPROVED
00000
549 OMB No. 2120-0042
UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION-MIKE MONRONEY AERONAUTICAL CENTER
AIRCRAFT REGISTRATION APPLICATION
CERT. ISSUE DATE
UNITED STATES
REGISTRATION NUMBER
N
61161
-
AIRCRAFT MANUFACTURER & MODEL
BELL 407
AIRCRAFT SERIAL No.
NN JUN 07 1999
53375
FOR FAA USE ONLY
TYPE OF REGISTRATION (Check one box)
1. Individual
2. Partnership
XX
3. Corporation
4. Co-owner
5. Govt.
8.
Non-Citizen
Corporation
NAME OF APPLICANT (Person(s) shown on evidence of ownership. If individual, give last name, first name, and middle initial.)
BELL HELICOPTER TEXTRON INC.
3000 S. NORWOOD AT TRINITY
HURST, TX 76053
TELEPHONE NUMBER: 817) 280-8411
ADDRESS (Permanent mailing address for first applicant listed.)
Number and street:
Rural Route:
P.O. Box: 482
CITY
STATE
ZIP CODE
FORT WORTH
TX
76101
CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS
ATTENTION! Read the following statement before signing this application.
This portion MUST be completed.
A false or dishonest answer to any question in this application may be grounds for punishment by fine and/or imprisonment
(U.S. Code, Title 18, Sec. 1001).
CERTIFICATION
I/WE CERTIFY:
(1) That the above aircraft is owned by the undersigned applicant, who is a citizen (including corporations)
of the United States.
(For voting trust, give name of trustee:
). or:
CHECK ONE AS APPROPRIATE:
a.
A resident alien, with alien registration (Form 1-151 or Form 1-551) No.
b.
A non-citizen corporation organized and doing business under the laws of (state)
and said aircraft is based and primarily used in the United States. Records or flight hours are available for
inspection at
(2) That the aircraft is not registered under the laws of any foreign country; and
(3) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration
NOTE: If executed for co-ownership all applicants must sign. Use reverse side if necessary.
TYPE SRM OR PRINT NAME BELOW SIGNATURE
SIGNATURE
Reg. TITLE TITLE Manager
DATE
6-4-99
EACH PART OF THIS
APPLICATION MUST
BE SIGNED IN INK.
SIGNATURE
DATE
SIGNATURE
TITLE
DATE
NOTE Pending receipt of the Certificate of Aircraft Registration, the aircraft may be operated for a period not in excess of 90
days, during which time the PINK copy of this application must be carried in the aircraft.
TEMP CERT OF
AC Form 8050-1 (12/90) (0052-00-628-9007) Supersedes Previous Edition- TO EXPIRE 7-7-99
T 993415
EFTA00016706

=== Page 86 ===
H
MEDHYSHO
AMOUNT
STOTWY h MM 83,
EFTA00016707

=== Page 87 ===
3-1
0'07000548
2A277718
Do not write in this block
BILL OF SALE
for FAA/DOT use only
CONVENINCE
For and in consideration of $10+, the undersigned owner(s) of the full
MICROFILM CODE
legal and beneficial title of the aircraft described as follows:
IC
JC
Aircraft Make and Model
163 JUN 7 fill 10 10
BELL
407
FEDERAL TICH
Manufacturer's Serial Number
Nationality and Registration Marks
ADMINISTRATION
53375
U.S.
N61161
does this 3rd day of June, 1999, sell, grant, transfer and deliver all
rights, title, and interests in and to such aircraft unto:
Name and Address
(If individual(s), give last name, first name and middle initial)
LOCOTIONE
Bell Helicopter Textron Inc.,
P.O. Box 482
Fort Worth,
Texas 76101
and to its executors, administrators, and assigns to have and to hold singularly the said aircraft
forever, and certifies that same is not subject to any mortgage or other encumbrance except:
NONE
Type of encumbrance
Amount
Dated
In favor of
IN TESTIMONY WHEREOF I HAVE SET MY HAND AND SEAL, THIS 3RD DAY OF JUNE , 1999
NAME OF SELLER: BELL HELICOPTER TEXTRON, A DIVISION OF TEXTRON CANADA LIMITED
BY: Marcel
/ S. MARCIL
TITLE:
DIRECTOR, CONTRACTS AND CORPORATE AFFAIRS
991551018554
$5.00 06/04/1999
EFTA00016708

=== Page 88 ===
EFTA00016709
08/2210
'99 JUN 4 AM 10 13 3
OKLAHOMA
OKLAHOMA
w

=== Page 89 ===
JUN-03-1999 10:11
TRANSPORT CANADA - RECAV-
P.03
Transport Canada
Transports Canada
Safety and Security
Sécurité et sûrété
NN JUN 07 1999
Civil Aviation
Aviation civile
L-1
Ottawa ON K1A 0N8
Telephone - Téléphone : (613) 990-1119
Facsimile - Télécopieur : (613) 990-1007
Internet: http://www.tc.gc.ca/aviation/general/ccarcs/index.htm.
File. Dossier
June 3, 1999
5008-4-12
FEDERAL AVIATION ADMINISTRATION
AIRCRAFT REGISTRATION BRANCH (AFS-750)
OKLAHOMA CITY OK 73125
N61161
1-405-954-3548 (U.S.A.)
6 JUN 07 1999
URGENT AARRC 1999-0425NR
This confirms that the following aircraft has never been entered on the Canadian Civil
Aircraft Register.
MANUFACTURER:
BELL HELICOPTER DIVISION TEXTRON CANADA
LTD.
MODEL:
407
SERIAL NUMBER:
53375
Sheila Dowd
form
Chief
Aircraft Registration and Leasing
INFOCOPY TO:
CHRISTINE SAVOIE
ADMINISTRATOR, AIRCRAFT
CERTIFICATION
TEXTRON CANADA LTD.
1-450-437-2848
56
Canada
Im
TOTAL P.03
JUN 3 '99 09:00
PAGE.003
cay #550 for 4-4-99 itd
EFTA00016710

=== Page 90 ===
I
66. HV HT 01 E NOT
EFTA00016711

=== Page 91 ===
00000001267
1-1
Bell Helicopter TEXTRON
Bell Helicopter Textron Inc.
Post Office Box 482
A Subsidiary of Textron Inc.
Fort Worth, Texas 76101
(817) 280-2011
Federal Aviation Administration
Aircraft Registration Branch
P.O. Box 25504
Oklahoma City, OK 73126-0504
DESCRIPTION OF AIRCRAFT
DATE: 27 April 1999
MANUFACTURER: Bell Helicopter Textron, A Division of Textron Canada Ltd.
MODEL: 407
SERIAL NUMBERS: 53375
REGISTRATION NUMBER: TBD
Please assign a number to the above-described aircraft.
I certify this "N" number will not be painted on the aircraft until foreign registration has
ended.
Bell Helicopter Textron, Inc.
B.D.Baun
-
Manager
Commercial Aircraft Completion & Delivery
STATE OF TEXAS
}
COUNTY OF TARRANT
}
Before me, a Notary Public, in and for the State of Texas, personally appeared B.J. Brown
known to me to be the identical person who signed the within and foregoing instrument.
Said person does hereby attest he is duly authorized to execute such instrument and has
done so on his free act and deed.
NOTARY
PUBLIC
OLGA A. CROYLE
*
*
Notary Public
Notary Public
Olga A. Croyle
STATE OF TEXAS
STATE OF TEXAS
My Commission Expires: 4-13-2000
My Comm. Exp. 04/13/2000
EFTA00016712

=== Page 92 ===
EFTA00016713
FATC
FILED FILED
AIRCRAFT
'99 MAY 3 PM1 P7 PA 1 17
99 MAY
OKL
OKLAHOP ORLAHOMA ONL


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c0:
=== Page 1 ===
10/6/21, 12:58 PM
III/FBI/State Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
III Information
The following information is provided in response to your request for a III search from the State of Florida based on:
FBI number:
Name:
Purpose Code:
ADDITIONAL SENTENCING INFORMATION MAY BE AVAILABLE FROM ORIGINATING AGENCY
CRIMINAL HISTORY RECORD
Introduction
This rap sheet was produced in response to the following request:
FBI Number
State Id Number
Request Id
Purpose Code
Attention
The information in this rap sheet is subject to the following caveats:
This record contains
information only. When explanation of a
charge or disposition is needed, communicate directly with the agency
that contributed the record information. (; 2021-10-06)
This record may only be used for the purpose requested as defined by
the Code of Federal Regulations and/or
(; 2021-10-06)
This is a multi-source offender record. (; 2021-10-06)
IDENTIFICATION
1/4
EFTA00015090

=== Page 2 ===
10/6/21, 12:58 PM
III/FBI/State Delayed Response
Fingerprint Images
(No Fingerprint Image Transmitted
Comment:)
DNA Data
(No DNA Detail Transmitted )
CRIMINAL HISTORY
Earliest Event Date
Arrest Date
Arrest Case Number
Arresting Agency
Charge
Charge Literal
Statute
NCIC Offense Code
State Offense Code
Counts
Severity
Tracking Number
Earliest Event Date
Arrest Date
Arrest Case Number
Arresting Agency
Charge
Charge Literal
Charge Description
Statute
State Offense Code
Counts
Severity
Prosecutor Disposition
Prosecutor Agency
2/4
EFTA00015091

=== Page 3 ===
10/6/21, 12:58 PM
III/FBI/State Delayed Response
Charge
Charge Tracking Number
Charge Literal
Charge Description
Statute
State Offense Code
Counts
Severity
Disposition
Court Disposition
Court Case Number
Court Agency
Charge
Charge Literal
Charge Description
Statute
State Offense Code
Counts
Severity
Disposition
Sentencing
Sentence Date
Sentencing Agency
Charge
Charge Literal
Charge Description
Statute
State Offense Code
Counts
Severity
Disposition
Sentence
Sentence
Sentence
Sentence
Sentence
Sentence
Tracking Number
Earliest Event Date
Arrest Date
Arresting Agency
Charge
Charge Literal
Charge Description
Statute
State Offense Code
Counts
Severity
Prosecutor Disposition
Prosecutor Agency
Charge
Charge Tracking Number
Charge Literal
Charge Description
Statute
3/4
EFTA00015092

=== Page 4 ===
10/6/21, 12:58 PM
III/FBI/State Delayed Response
INDEX OF AGENCIES
Agency
Address
Agency
Agency
Agency
Address
Agency
Address
*** END OF RECORD ***
4/4
EFTA00015093


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: Jeffrey Epstein -- Letter from Roy Black
Date: Wed, 09 Dec 2009 22:13:08 +0000
Importance: Normal
Attachments:
Rothstein.pdf
Hi all - I have attached a letter I just received from Roy Black. The odd thing about this is that it is addressed
directly to me. Roy (and Epstein's team) always sends everything to Jeff or someone far more important than me.
I haven't seen the Complaint against the Rothstein firm yet, but I did have a voicemail from Brad Edwards this
morning, which I haven't responded to.
Can someone fill me in on any developments? When I receive the criminal complaint I will send the copies out
tomorrow.
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach. FL 33401
From: Roy BLACK
Sent: Wednesday, December 09, 2009 5:01 PM
To:
(USAFLS)
Subject: Jeffrey Epstein
Please see attached letter regarding Jeffrey Epstein. The original, with the
attachment, should arrive via Federal Express tomorrow.
EFTA00014177


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=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: RE:
/ Epstein
Date: Wed, 02 Oct 2019 19:57:15 +0000
Sounds good, thanks. I'll come by then.
From:
(USANYS)
Sent: Wednesday, October 2, 2019 3:53 PM
To:
Subject: Re:
/ Epstein
415?
Sent from my iPhone
On Oct 2, 2019, at 3:52 PM,
)
wrote:
Yes, is now a good time for me to swing by?
From:
(USANYS)
Sent: Wednesday, October 2, 2019 3:39 PM
To:
)
Subject: FW:
/ Epstein
Hey, can you find me to discuss today?
From: Bourtin, Nicolas
Sent: Wednesday, October 2, 2019 3:10 PM
To:
(USANYS)
Cc: Levin, Sharon Cohen
Subject: RE:
/ Epstein
Sorry to press. I know you haven't had this long. The AML folks at
are anxious to close these accounts unless the
government requests that we not do so, and they asked me to check in. If there's someone on the team you'd rather I
harass, let me know.
Thanks.
Nic
From: Bourtin, Nicolas
Sent: Tuesday, October 01, 2019 9:31 PM
To:
(USANYS)'
Cc: Levin, Sharon Cohen
Subject: RE:
/ Epstein
Many thanks.
EFTA00015852

=== Page 2 ===
From:
(USANYS)
Sent: Tuesday, October 01, 2019 7:45 PM
To: Bourtin, Nicolas
Cc: Levin, Sharon Cohen
Subject: [EXTERNAL] Re:
/ Epstein
Thanks very much, Nic. I will discuss with the team and I or one of them will get back to you.
Best,
Sent from my iPhone
On Oct 1, 2019, at 7:20 PM, Bourtin, Nicolas
wrote:
-
As I mentioned last night, attached is a SAR that
filed today in connection with persons
associated with Jeffrey Epstein. The bank would like to close all of the accounts of the entities named
in the SAR as soon as possible. (The current balance on those accounts is approximately $30 million.)
Before doing so, the bank wanted to make your office aware of these accounts in case the government
intends to take any action.
Please advise once you've had a chance to consider.
Many thanks.
Nic
Nicolas Bourtin Sullivan & Cromwell LLP
125 Broad Street New York, NY 10004-2498
This e-mail is sent by a law firm and contains information that may be privileged and
confidential. If you are not the intended recipient, please delete the e-mail and notify us
immediately.
<TD Filed SAR 2019-43693.do.pdf>
This is an external message from:
EFTA00015853


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Date: Wed, 26 Aug 2020 19:40:53 +0000
Hi
Thank you! I have at least been advised that the audio issue was possibly operator error and resolved, but I'll follow up
tomorrow and ask if she'd be willing to identify particular files there are issues with and let you know.
Thanks again,
8/26/2020 3:22 PM >>>
Thanks very much for reaching out. I'm adding
who may be able to answer your question.
If there are particular files that Maxwell is having difficulty opening, please let us know, and we can try to figure out how to
address the issue.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Wednesday, August 26, 2020 2:45 PM
Subject: Re: delivery of hard drive to MDC for discovery production to inmate
Good afternoon,
Maxwell was provided this drive on Tuesday. Staff have reported to me that she has reported that certain files do not work.
Can you advise what types of files (i.e., video/excel/etc.) are on the drive and what players or applications may be necessary
to view them? I'm trying to figure out what reasons may be for issues with the material on the drive.
EFTA00016292

=== Page 2 ===
Thank you,
8/21/2020 9:01 PM >>>
We just sent another drive via FedEx. This drive contains all of the discovery in the case to date. The password for the drive
is
which we also sent in a separate letter).
Yes, these productions contain audio as well as video.
Let me know if you have any other questions. Have a good weekend.
Best,
Sent from my iPhone
On Aug 14, 2020, at 7:34 AM,
wrote:
Thank you for letting me know! Are you aware of whether this production contains any audio discovery?
Thank you,
8/13/2020 5:05 PM >>>
I just sent the next round of discovery via FedEx. The password for this drive is
We also sent a letter
with the password in a separate envelope.
Please let us know when it arrives.
Thank you,
From:
Sent: Monday, August 10, 2020 6:03 PM
Subject: Re: delivery of hard drive to MDC for discovery production to inmate
That should be enough to track it down, thank you! If I have any issues, I'll let you know.
Best,
8/10/2020 5:59 PM >>>
I sent this via FedEx. When I enter the tracking number it says:
Delivered
Friday 8/07/2020 at 7:16 am
Let us know if you have any other questions.
Thanks!
Sent from my iPhone
EFTA00016293

=== Page 3 ===
On Aug 10, 2020, at 5:48 PM,
wrote:
Good evening
Just confirming - did you use FedEx, USPS, or some other carrier to send the discovery here? I have not received it yet,
but it could just be that staff did not notify me a package arrived. Depending on the carrier, it could be in the warehouse
or mailroom, so I just want to verify so I can find it expeditiously.
Thanks!
8/5/2020 7:13 PM >>>
That's extremely helpful, thanks so much. We'll plan to put the drive in the mail tomorrow, and of course please let us
know if any issues arise.
thanks again,
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Hard drives should be mailed to the facility to the attention of the legal department. We need to etch the drive with a
number and provide an authorization memo so she can retain it. Then it will be provided to her. It can be password
protected so long as you include a cover letter that contains the password for her.
Hope this helps,
8/5/2020 4:34 PM >>>
We have a hard drive with loaded discovery that we need to deliver to Ghislaine Maxwell,
at MDC. Could
you please let us know what the current protocol is for that? Also, it's our understanding that hard drives with
discovery materials for inmates needs to be non-encrypted (and not have a password for access), is that also correct?
We're hoping to get these materials to her tomorrow if at all possible, so we greatly appreciate your help. And I'm
reachable any time at
if it would be helpful to discuss.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00016294


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=== Page 1 ===
From:
To:
Subject: Canceled: Epstein: NDO for Google/Apple/Oath Subpoenas Expires
Date: Thu, 15 Aug 2019 17:28:07 +0000
Importance: High
EFTA00014338


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=== Page 1 ===
November 19, 2021
WebEx Meeting
Asked
whether he wants counsel, told
could have an attorney appointed if he could
not afford one;
said he did not feel he needed or wanted a lawyer
JE received between 2 and 4 massages every day when he was in Palm Beach
JE's massage appointments were set up through his assistants
(
)
received phone call from assistants that people were coming at certain time to give JE
massages; when person rang doorbell,
let her in; most of time, they waited in kitchen;
waited until
or
showed up and took person up to massage room
did not recall answering phone calls where people said they wanted to give a massage
People who came to give JE massages did not wear uniforms; they wore casual clothes
(jeans, t-shirts, sneakers, sweatpants)
People giving massages were female; they were not professional, trained masseuses; they
did not show up with equipment to give massages
saw some females waiting outside house,
thought they were waiting for someone to
pick them up after massage
sometimes saw females walking to ring doorbell; most of the time heard doorbell and let
females in
Sometimes more than one female came at a time;
remembers one time when two girls
came, one girl waited in the kitchen and one went upstairs;
doesn't remember what the
girls looked like; the two girls seemed like friends; came together and left together after
certain period of time; they were young girls (high school age)
Impression was they were young; under 20 years old
understood that all the girls coming to give massages were "school girls"
impression was that all the girls coming for appointments were high school girls
sometimes heard the girls talk about school; does not know what grade they were in
overheard the girls talk about soccer games, time to go to classes;
doesn't remember
which classes
started seeing school girls at the PB house within a few days of when
started working
there
EFTA00014648


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=== Page 1 ===
From: BOBBI C STERNHEIM
To: Nathan NYSD Chambers
Cc: Nicole Simmons
Jeff Pagliuca
Laura Menninger
"Christian Everdell"
Subject: [EXTERNAL] Re: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Ltr. Motns to Quash EVCP
Sub ]
Date: Mon, 22 Nov 2021 23:27:41 +0000
Good evening-
We have conferred with the government and they have agreed to serve the moving parties after applying appropriate redactions.
They have informed us that the EVCP has been served. We will inform the Court when the government has served the remaining parties.
Best-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
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 Nov 22, 2021, at 5:37 PM, BOBBI C STERNHEIM
wrote:
Good afternoon:
We have contacted the government and are awaiting a response to work through any redaction issues.
We will notify the Court as soon as service has been completed.
Best-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be
EFTA00014699

=== Page 2 ===
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 Nov 22, 2021, at 5:07 PM, Nathan NYSD Chambers
wrote:
Counsel:
Please confirm as soon as possible that a copy of the response was served on counsel for the moving parties.
Sincerely,
Chambers of the Hon. Alison J. Nathan
From: Nicole Simmons
Sent: Monday, November 22, 2021 1:40 PM
To: Nathan NYSD Chambers
Cc: Jeff Pagliuca
>; Laura Menninger
y
>; bcsternheim_mac.com <bcsternheim@m
ac.com>;
is
is
is
Subject: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Ltr. Motns to Quash EVCP Sub ]
CAUTION - EXTERNAL:
Dear Judge Nathan:
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Response to the Letter Motions to Quash her Rule 17(c)
subpoena to the Epstein Victims' Compensation Program.
Pursuant to our established protocol, we are submitting the Response to the Court under temporary seal to allow the government to
propose any redactions it deems necessary.
Regards,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
150 East 10th Avenue
Denver, Colorado
<image001.jpg>80203
PH
FX
DIRECT:
www.hmflaw.com
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening attachments or
clicking on links.
EFTA00014700


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=== Page 1 ===
From:
To: "Berman, Geoffrey (USANYS)"
Cc:
Subject: Re: Epstein/
meeting
Date: Fri, 10 Jan 2020 02:01:46 +0000
Thanks for your thoughtful contributions.
Sent from my iPhone
> On Jan 9, 2020, at 8:35 PM, Berman, Geoffrey (USANYS)
wrote:
>
> Good to hear.
>
>>
On Jan 9, 2020, at 8:04 PM,
wrote:
>> FYI, our sense that it was a good meeting was universally shared. Both
said the team was
very pleased with the thoughtful reception, and
reiterated that to me tonight. Well handled on your part.
>> Sent from my iPhone
EFTA00016733


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=== Page 1 ===
From:
To:
Cc:
Subject: FW: Jeffrey Epstein Victim; Ms
,
17 years old
Date: Fri, 22 Nov 2019 18:24:08 +0000
Passing along the below per our usual policy.
thanks,
From:
Sent: Friday, November 22, 2019 13:17
To:
Subject: FW: Jeffrey Epstein Victim; Ms
17 years old
Can you send to FBI.
From:
Sent: Thursday, November 21, 2019 8:12 PM
To:
Subject: Jeffrey Epstein Victim; Ms
17 years old
I am a very close friend of Ms.
and her guardian, Ms.
of Calderitas, Mexico. Ms.
was abused by
Jeffrey Epstein on numerous occasions at his townhome in New
York and his caribbean island home in the Virgin Islands. They
both have expressed their interest in asking me to register her claim
as a victim in any case involving Mr. Epstein's estate, which she
believes she may have a claim.
She does not have legal representation yet, but is in negotiations to
retain and attorney soon.
Regards,
EFTA00015992

=== Page 2 ===
EFTA00015993


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=== Page 1 ===
From:
To:
Cc:
Subject: Epstein
Date: Fri, 12 Jul 2019 21:28:40 +0000
Importance: Normal
Attachments: 2019-07-12,_JE,_government_opposition_to_bail_motion_(with_exhibits).pdf
Publicly filed version of our response attached.
Co-Chief, Public Corruption Unit
U.S. Attorney's Office for the
Southern District of New York
EFTA00015531


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: Booking travel for tomorrow
Date: Wed, 11 Sep 2019 14:34:47 +0000
Thank you!
On Sep 11, 2019, at 10:32 AM,
)
wrote:
Hi
-
I will email you the airfare/hotel confirmation shortly.
Thank you!
From:
Sent: Wednesday, September 11, 2019 9:59 AM
To:
Cc:
Subject: Booking travel for tomorrow
Hi
I just spoke with
who approved the use of USAO funds to pay for an Epstein victim named
to fly from
Palm Beach to New York tomorrow 9/12 so that she can meet with us. She will be meeting with the Epstein team of
AUSAs and agents at 5pm tomorrow evening, and then will need to stay over in a hotel tomorrow night, flying back to
Palm Beach on Friday 9/13.
Would you please book her travel? Info is below:
Full name on ID:
DOB:
Flying from: Palm Beach, FL
Flying to: NYC (needs to arrive in SDNY in time for 5pm meeting on 9/12)
Hotel: Needed for one night 9/12 into 9/13, then flight back to Palm Beach on 9/13
Witness email address:
Please let me know if you have any questions or need any additional information.
Thanks so much,
EFTA00015296


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=== Page 1 ===
From: BOBBI C STERNHEIM
To: Nathan NYSD Chambers
Cc: Nicole Simmons
Jeff Pagliuca
Laura Menninger
"Christian Everdell"
Subject: [EXTERNAL] Re: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Ltr. Motns to Quash EVCP
Sub ]
Date: Tue, 23 Nov 2021 00:36:45 +0000
Good evening-
The government has confirmed that all moving parties have been served.
Best-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
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 Nov 22, 2021, at 6:27 PM, BOBBI C STERNHEIM
wrote:
Good evening-
We have conferred with the government and they have agreed to serve the moving parties after applying appropriate redactions.
They have informed us that the EVCP has been served. We will inform the Court when the government has served the remaining
parties.
Best-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
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.
EFTA00014710

=== Page 2 ===
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 Nov 22, 2021, at 5:37 PM, BOBBI C STERNHEIM
wrote:
Good afternoon:
We have contacted the government and are awaiting a response to work through any redaction issues.
We will notify the Court as soon as service has been completed.
Best-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
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 Nov 22, 2021, at 5:07 PM, Nathan NYSD Chambers
wrote:
Counsel:
Please confirm as soon as possible that a copy of the response was served on counsel for the moving parties.
Sincerely,
Chambers of the Hon. Alison J. Nathan
From: Nicole Simmons
Sent: Monday, November 22, 2021 1:40 PM
To: Nathan NYSD Chambers
Cc: Jeff Pagliuca
>; Laura Menninger
is
>; bcsternheim_mac.com <bcsternheim@
mac.com>;
is
Subject: U.S. V. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Ltr. Motns to Quash EVCP Sub ]
CAUTION - EXTERNAL:
Dear Judge Nathan:
At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Response to the Letter Motions to Quash her Rule 17(c)
subpoena to the Epstein Victims' Compensation Program.
Pursuant to our established protocol, we are submitting the Response to the Court under temporary seal to allow the government to
propose any redactions it deems necessary.
EFTA00014711

=== Page 3 ===
Regards,
Nicole
Nicole Simmons
Haddon, Morgan and
Foreman, P.C.
150 East 10th Avenue
Denver, Colorado
<image001.jpg>80203
PH
FX
DIRECT:
www.hmflaw.com
CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening attachments or
clicking on links.
EFTA00014712


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=== Page 1 ===
10/6/21, 12:40 PM
III/FBI/State Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
III Information
THE RECORD(S) CAN BE OBTAINED THROUGH THE INTERSTATE IDENTIFICATION
INDEX BY USING THE APPROPRIATE NCIC TRANSACTION.
END
1/1
EFTA00015150


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=== Page 1 ===
11/28/21, 9:12 PM
Mail
(NY) (FBI) - Outlook
CA photos
(NY) (FBI)
Tue 1/26/2021 12:10 PM
To:
(NY) (FBI)
>
4 attachments (61 KB)
photo 1.jpg; Photo 2.jpg; Photo 3.jpg; Photo 5.jpg;
<< photo 1.jpg >> << Photo 2.jpg >> << Photo 3.jpg >> << Photo 5.jpg
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
U
ttps://culok.office35.us/mailinboxid/AAQkADkwOTA4M2JkLTZjNzYNDA0Yy05NTFiLWE3MDM4MDY5NzQxYwAQAKd35X9Ok8Utb0wicWxwno
1/1
EFTA00014980


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=== Page 1 ===
From: "spamcontrol@usdoj.gov" <spamcontrol@usdoj.gov>
To:
Subject: End User Digest: 1 New Message
Date: Tue, 25 Aug 2020 10:10:30 +0000
Inline-Images: logo.jpeg
End User Digest: 1 New Message
DEPARTMENT JUSTICE
For
The emails listed below have been placed in your personal Quarantine since you received your last End User Digest. They will
be deleted after 14 days. To deliver an e-mail to your inbox, click on Release. To deliver an e-mail to your inbox and add the e-
mail sender to your Safe Senders List, click on Release and Allow Sender. This ensures that no emails from that sender will be
blocked in the future. To report messages that are not spam but are reported in the digest, click on Not Spam.
Request New End User Digest Request Safe/Blocked Senders List Manage My Account Questions about digesting?
The emails listed in this section have been placed in your personal Quarantine. Click Release to deliver the email to your inbox.
To continue to receive future emails from the sender, click Allow Sender. To report messages that are not spam but are included
in the Spam - Quarantined section, click Not Spam.
Spam - Quarantined
Score
From
Subject
Date
Action
100
srs0=e1mvhd=cc=moraloutrage.org=chris@srs.bis7.eu.blackberry.com Epstein's 2020-
Release
Buddy 08-24
and
Not
Clinton 13:50:36
Release
Allow
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For more information contact your System Administrator.
Powered by Proofpoint Protection Server
EFTA00016972


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=== Page 1 ===
rom: Jeffery Edwards <jeevacation@gmail.com>
Date: 3 September 2008 at 10:48:50 GMT-7
To:
Subject: Re: i hear you've had a spot of bother
guess
On 9/3/08 1:06 PM,
wrote:
Ok will send pics later today or tomorrow. Anything in mind ?
Sent via BlackBerry by AT&T
From: Jeffery Edwards <jeevacation@gmail.com>
Date: Wed, 03 Sep 2008 12:19:06 -0400
To:
Subject: Re: i hear you've had a spot of bother.
Making the best,, send photos please
On 9/2/08 8:41 PM,
wrote:
So how are you ?
Sent via BlackBerry by AT&T
From: Jeffery Edwards <jeevacation@gmail.com>
Date: Tue, 02 Sep 2008 19:27:29 -0400
To:
Subject: Re: i hear you've had a spot of bother
Tell
I appreciate the advice, but that would be contraband, and
the punishment would be vaseline
On 9/2/08 6:56 PM,
wrote:
Well I suppose I will not be seeing you while I am in
New York to my great disappointment.
How are you? I suppose you are making the most of
the opportunity to read and observe human behavior
under duress and confinement ! If there is anyone who
would maximize on such a "vacation" it's you !
1
EFTA00015074

=== Page 2 ===
I am with
and he is asking if you would
like him to send you some Vaseline I
Seriously though sweetheart, If I can do anything let
me know. I hope you are keeping a diary
and I am sure you are keeping fit !
Anyway,
best love always
XXXXX
P.S.If you would like me to come and visit sometime it
would be my pleasure
2
EFTA00015075


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=== Page 1 ===
From:
"
)"
To:
(USANYS)"
Cc:
)"
,
)"
=
Subject: SW Affidavit
Date: Thu, 02 Jul 2020 03:19:30 +0000
Attachments: New_Hampshire_Premises_SW_Affidavit_v2.docx.
Attached is the revised affidavit.
Thanks,
EFTA00016161


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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: RE: Epstein/
and US/French international justice (journalist question)
Date: Thu, 06 Feb 2020 17:45:17 +0000
I see. I'll handle this, thanks.
From:
Sent: Thursday, February 6, 2020 12:45 PM
To:
Cc:
is
Subject: Fwd: Epstein/
and US/French international justice (journalist question)
Hi Nick- just passing this on, I haven't responded, but for what it's worth this reporter contacted me at the
email address for the law school where I teach a small class, which I didn't appreciate.
Sent from my iPhone
Begin forwarded message:
Begin forwarded message:
From: Philippe BERRY
Date: February 6, 2020 at 4:58:20 PM GMT+1
To:
Subject: Epstein
and US/French international justice (journalist question)
Hi
I'm the US correspondent for 20 Minutes, a French newspaper.
I'm working on a Epstein/
piece, and I had some questions (it can be 100% of the record or
purely for background) about how such a case work between US/French judicial authorities when key events
and players are linked to several countries.
Could I call you to talk about it?
Thank you so much,
Philippe
Philippe Berry Correspondant aux Etats-Unis(
EFTA00017057


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=== Page 1 ===
From:
To:
Subject: more printing?
Date: Tue, 23 Nov 2021 20:13:51 +0000
Attachments: GX-602 - IMG-4468.pdf; GX-603 - IMG-4466_&_IMG-4467.pdf; GX-604 - IMG-
4464 & IMG-4465.pdf;
cross_outline.docx;
Direct_Examination_v4.docx
Would you mind printing the attached for me?
EFTA00016617


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=== Page 1 ===
From: "postmaster@voip.usa.doj.gov" <postmaster@voip.usa.doj.gov>
To:
Cc: USANYS-EpsteinVictims <USANYS.EpsteinVictims@usa.doj.gov>
Subject: Voice Message Attached from
Date: Thu, 08 Aug 2019 18:29:40 +0000
Attachments:
vav
Time: Aug 8, 2019 2:29:40 PM
Click attachment to listen to Voice Message
EFTA00015702


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=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
,
Subject: A further request
Date: Mon, 01 Jul 2019 18:50:36 +0000
Importance: Normal
Team,
DAG's office requested an update to the Urgent Report on Epstein reporting the indictment.
This should require no more than adding a sentence or two at the end of the prior report.
Thanks.
Deputy United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00014523


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=== Page 1 ===
From:
To:
Subject: Accepted: Epstein Press Meeting
Date: Fri, 28 Jun 2019 15:09:08 +0000
Importance: Normal
Attachments: unnamed
EFTA00014284


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=== Page 1 ===
From:
To:
Cc:
Subject: RE: [EXTERNAL] Re: SDNY PRESS GUIDANCE I U.S. V. GHISLAINE MAXWELL,
FRIDAY, NOVEMBER 26, 2021
Date: Fri, 26 Nov 2021 15:25:43 +0000
Inline-Images: image001.png
Ah, good to know - thanks!
From:
Sent: Friday, November 26, 2021 10:24 AM
To:
Cc:
Subject: RE: [EXTERNAL] Re: SDNY PRESS GUIDANCE I U.S. V. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021
Thanks
I don't think you need to say any more regarding the below, but for your knowledge,
will
testify under her own name (and has testified under her own name at the prior bail hearings).
From:
Sent: Friday, November 26, 2021 10:19 AM
To:
Cc:
Subject: FW: [EXTERNAL] Re: SDNY PRESS GUIDANCE I U.S. V. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021
We circulated Tuesday's guidance to some additional UK reporters this morning. The additional guidance we drafted on
Wednesday will go out shortly, we'll blind copy you.
From:
Sent: Friday, November 26, 2021 10:14 AM
To: Gadher, Dipesh <dipesh.gadher@sunday-times.co.uk>
Cc:
Subject: RE: [EXTERNAL] Re: SDNY PRESS GUIDANCE I U.S. V. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021
In accordance with the previously provided court order, any victim or witness testifying under a pseudonym should not
be identified, and should be referred to under their pseudonym, regardless of any previous identifications or waivers that
might have been made.
Best,
Nick
From: Gadher, Dipesh <dipesh.gadher@sunday-times.co.uk>
Sent: Friday, November 26, 2021 9:58 AM
To:
Subject: [EXTERNAL] Re: SDNY PRESS GUIDANCE I U.S. V. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021
EFTA00016489

=== Page 2 ===
Hi - can I please clarify if I'm allowed to identify
by name as she has previously waived her right to
anonymity? How will she be identified in future proceedings? Thanks.
Best
Dipesh
The Sunday Times
1 London Bridge Street
London SE1 9GF
Tel: +44 (0)20 7782 5745
Mob: +44 (0)7956 142 227
On Fri, 26 Nov 2021 at 14:48, Biase, Nicholas (USANYS) <Nicholas.Biase@usdoj.gov> wrote:
In order meet the demand for the high volume of media requests we are already receiving, the following guidance is
being provided in advance of the trial to ensure efficient communications. Please take careful note.
QUI PRO OF JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
JUSTITIA
SOFFICE
OF
PRESS GUIDANCE
Friday, November 26, 2021
*OFF-THE-RECORD, AND FOR GUIDANCE ONLY: Several of the government's anticipated witnesses will be testifying in
this trial using a pseudonym or first name. The Court granted a Government motion [attached] requesting that they
be able to do so, because the victim witnesses are expected to describe alleged sensitive, explicit and personal events
concerning illegal sexual abuse, sexual contact and other acts of which they have been victims. I believe most, if not
all, news media outlets have a policy against identifying sex crime victims without their consent, and urge you to
abide by that policy with our witnesses and respect their privacy.
9:30 a.m. - Final pretrial conference U.S. V. Ghislaine Maxwell - the defendant is charged in connection to conspiring
with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity - before Judge Alison Nathan
(Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S.
Courthouse]).
EXHIBITS: Government exhibits will be provided exclusively through the SDNY file share. If you are unable to access
this link to the file share (USAFx), you must establish an account to access the files. To establish an account, request
access by email to me or my colleague, Jim Margolin, Cc'd here, prior to Wednesday, November 29, 2021.
EFTA00016490

=== Page 3 ===
Please also note that all case filings in U.S. V. Maxwell are available in the Court's electronic filing system; we encourage
media representatives to establish a free PACER account, if they have not done so already. Credentialing and other
matters relating to in-person attendance for the trial are handled by the SDNY District Executive's Office.
Periodic updates to follow.
Follow us on Facebook I Follow us on Twitter I SDNY website I YouTube
*** FOR PLANNING PURPOSES ONLY
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE AT (212) 637-2600.
"Please consider the environment before printing this e-mail"
This e-mail and any attachments are confidential, may be
legally privileged and are the property of News Corp UK & Ireland
Limited on whose systems they were generated. News Corp UK
& Ireland Limited is the holding company for the News UK group,
is registered in England & Wales under number 81701, has its
registered office at 1 London Bridge Street, London, SE1 9GF and
is registered with VAT number GB 243 8054 69. If you have received
this e-mail in error, please notify the sender immediately and do not
use, distribute, store or copy it in any way. Statements or opinions in
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necessarily agreed or authorised by News Corp UK & Ireland Limited
or any member of its group. News Corp UK & Ireland Limited may
monitor outgoing or incoming emails as permitted by law. It accepts
no liability for viruses introduced by this e-mail or attachments.
News Corp UK & Ireland Limited and its titles are committed to abiding by
IPSO's regulations and the Editors' Code of Practice that IPSO enforces.
EFTA00016491


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=== Page 1 ===
From:
)"
To:
Subject: RE:
- Following up re proffers
Date: Wed, 15 Jan 2020 22:12:37 +0000
I just called and she picked up - either / both of you want to call my desk
and I can conference you in? She's
tracking down her colleagues also
From:
)
Sent: Wednesday, January 15, 2020 17:11
To:
is
Subject: RE:
- Following up re proffers
I've been running around since 4, so just saw this - hopefully we can still chat with her.
From:
Sent: Wednesday, January 15, 2020 16:37
To:
Subject: Fwd:
- Following up re proffers
I can join a call from my cell.
Begin forwarded message:
From:
"
Date: January 15, 2020 at 4:10:54 PM EST
To:
)"
Cc:
Subject: RE:
- Following up re proffers
Are you available for a call at 4:45 pm today? Please let us know.
Thank you,
Original Message
EFTA00016975

=== Page 2 ===
From:
Sent: Wednesday, January 15, 2020 12:54 PM
To:
Cc:
Subject: RE:
- Following up re proffers
Great -- received, thank you.
Original Message
From:
Sent: Wednesday, January 15, 2020 09:01
To:
Cc:
Subject: Re:
- Following up re proffers
Thanks,
Confirmed for Friday, January 24, at 3:30.
We will also be in touch about scheduling another call with you later this week.
On Jan 14, 2020, at 7:28 PM,
)
wrote:
,
I apologize, but we've been advised that due to a scheduling issue the office leadership is able to do Friday,
January 24, at 3:30 p.m. (rather than Thursday). We've also asked to convey that the leadership will block out
at least a full hour, should you want that much time, with the potential for a short amount of additional time if
necessary for questions, follow-up, etc. But they wanted to make sure to provide at least that amount of time,
which is possible on Friday (but not Thursday).
EFTA00016976

=== Page 3 ===
Could you please confirm, and we'll finalize it on the various calendars?
Thanks very much,
Original Message
From:
)
Sent: Tuesday, January 14, 2020 12:32
To:
Cc:
Subject: RE:
- Following up re proffers
,
Thanks very much. We've confirmed with our office leadership that they are able to do Thursday, January 23 at
4:00 p.m.
You should also feel very free, though not obligated, to submit in advance any written materials you believe
would be useful. We will pass up the chain anything you convey, written or oral, in between now and the
meeting -- and as we mentioned previously, we would be happy to (and hope to) speak with you again in
advance of the meeting, particularly about the topics I mentioned in my email from yesterday (the incident
described in the complaint, as well as Ms.
recollection, if any, of other instances in which she
observed Epstein engaged in any sexual activity, or observed other women or girls in sexually-suggestive
circumstances), but also about anything else you think could be helpful.
thank you,
Original Message
EFTA00016977

=== Page 4 ===
From:
Sent: Tuesday, January 14, 2020 08:15
To:
)
Cc:
Subject: Re:
- Following up re proffers
We will be able to make the changes needed to do the meeting on the dates referenced below. Please let us
know if either of those dates. Thanks.
EFTA00016978

=== Page 5 ===
On Jan 13, 2020, at 1:59 PM,
wrote:
The following is conceivably possible for next week, if we can make certain changes to international travel that
was booked earlier with respect to a firm-related matter:
January 23 - any time after 2 pm
January 24 - any time after 10 am
Original Message
From:
Sent: Monday, January 13, 2020 12:18 PM
To:
Cc
EFTA00016979

=== Page 6 ===
Subject: RE:
- Following up re proffers
,
Please let us know what days and time ranges would be even conceivably possible next week, and also if your
schedule changes at for later this week. On our end, we need to coordinate at least 10 people's schedules so
we'll need some ranges to make sure everyone who you will want to hear your presentation can attend.
As we mentioned on the phone, there is a strong view that there are offenses that can be charged now, so it is
also possible to have this discussion post-charge, but we certainly would prefer to have the conversation before
that, and while the issues are very fresh in everyone's minds here. Our supervisor's view is that the 30th/3 st is
a long way off.
thanks,
Original Message
From:
Sent: Monday, January 13, 2020 12:10
To:
)
Cc:
Subject: RE:
- Following up re proffers
Understood. This week doesn't work at all. The 21st and 22nd also don't work, but if the 30th and 31st don't
work on your end, I will see if I can move some things around in order to make next week work.
EFTA00016980

=== Page 7 ===
Original Message
From:
)
Sent: Monday, January 13, 2020 12:05 PM
To:
Cc
Subject: RE:
- Following up re proffers
,
We were asked to inquire regarding your availability later this week (15th to 17th) and early next (21st and
22nd), and I know the brass feels that the issues are teed up and they want to provide an opportunity to hear
from you as soon as possible. Are you available on any of those days, of it not, some other time next week?
thanks,
EFTA00016981

=== Page 8 ===
Original Message
From:
Sent: Monday, January 13, 2020 11:59
To:
)
Cc:
Subject: RE:
- Following up re proffers
All - Thank you for your time on the phone last week. We are following up with regard to scheduling the
meeting referenced in your earlier email. Would January 30th or 31st work (with a preference for the 31st)?
Original Message
From:
)
Sent: Thursday, January 9, 2020 11:00 PM
To:
Cc:
EFTA00016982

=== Page 9 ===
Subject: RE:
- Following up re proffers
Understood, thanks. We'll be reachable in the interim via email.
Original Message
From:
Sent: Thursday, January 09, 2020 22:57
To:
)
Subject: Re:
- Following up re proffers
I'm trying to rearrange some things in order to call you at 11 am. Thanks.
EFTA00016983

=== Page 10 ===
On Jan 9, 2020, at 10:03 PM,
wrote:
,
We are all available just slightly later, at 11:00 a.m. - we'll be reachable a
or we can call you at
any number that would be convenient for you then. We'll plan to speak with you then, and no hard stop.
thanks,
From:
Sent: Thursday, January 09, 2020 19:45
To:
)
Cc:
Subject: RE:
- Following up re proffers
We can also do any time after 9 am, if that is better for you. Please let us know. Thanks.
EFTA00016984

=== Page 11 ===
From:
Sent: Thursday, January 9, 2020 7:25 PM
To:
)'
Cc:
EFTA00016985

=== Page 12 ===
Subject: RE:
- Following up re proffers
Thank you for the update. Are you available to speak tomorrow at 10 am?
From:
)
Sent: Thursday, January 9, 2020 6:09 PM
To
Cc:
EFTA00016986

=== Page 13 ===
Subject: RE:
- Following up re proffers
,
As we flagged for you a week ago, and as expected, we had a meeting with the office leadership today to
discuss the status of the case in general and Ms.
in particular. We continue to believe that it would be
helpful to receive any clarifications, as well as any response to the complaint originally sent on December 4, as
soon as possible; we are available tomorrow or over the weekend if there is a time that works for you. If it
remains impossible to talk before Tuesday, we have 2:30 in our calendar for then, but with a hard stop at 3:30
so please let us know if you'd like to start the discussion earlier if you expect it might be useful to have
additional time.
More generally, you had requested the opportunity to present to the ultimate decision-makers in the case if it
appeared that charges were likely, and based on our meeting today, the Office would like to provide you that
opportunity. If you could please let us know what dates and times you are available in the ranges of January
15-17 and 21-22, we will figure out a time when all the relevant supervisors here are available. I expect that
meeting will include at least the U.S. Attorney, the Deputy U.S. Attorney
), and the Chief of the
Criminal Division
), and some combination of the Chief Counsel
), the Counsel
(
), the two Public Corruption Unit chiefs
(
), the line assistants, and/or
FBI investigative and supervisory personnel. We will be prepared to discuss that meeting with you via phone
when we speak as well, which is one reason I note that we can begin our discussion earlier than 2:30 on
Tuesday (or block off significant time to talk before then) if that would be useful.
thank you,
EFTA00016987

=== Page 14 ===
Assistant U.S. Attorney
Southern District of New York
Original Message
From:
)
Sent: Sunday, January 05, 2020 18:15
To:
Cc:
Subject: RE:
- Following up re proffers
EFTA00016988

=== Page 15 ===
We'll block off that time in the calendar and plan to talk with you then.
thanks,
Original Message
From:
Sent: Saturday, January 04, 2020 22:30
To
Cc:
EFTA00016989

=== Page 16 ===
Subject: Re:
- Following up re proffers
Sorry for the delay in my response. Unfortunately, I won't be able to address this until my return to the office.
Apologies. Of course, I will consult with
and try to get back to you as quickly as possible following my
return. In anticipation of being able to do that, do you want to "pencil in" a call for Tuesday, January 14 at
2:30?
EFTA00016990

=== Page 17 ===
F:
Bio<
On Jan 2, 2020, at 3:07 PM,
wrote:
EFTA00016991

=== Page 18 ===
Thanks very much for being in touch. We had actually planned to be in touch today-we expect that next week
we'll be having meaningful conversations internally with supervisors about the possible / likely paths forward
for aspects of the case including Ms.
In connection with that expectation, we wanted to ask if you
were prepared (and willing) to convey to convey your client's recollection regarding the incident described in
the complaint
sent on December 4 (re-attaching here, specifically at page seven). To the extent you
have additional information that would be helpful to convey, even minor, we would be available anytime in the
coming days to do a call. If that isn't possible until you come back, obviously we understand the challenges of
scheduling, but we had anticipated trying to see if we could schedule a call in the coming days. Please let us
know?
thanks,
Original Message
From:
Sent: Wednesday, January 01, 2020 21:50
To:
EFTA00016992

=== Page 19 ===
Cc:
Subject:
- Following up re proffers
All - Happy new year. Wishing you and your families a happy, healthy, and peaceful 2020. We wanted to let
you know that there are a few minor clarifications/corrections we want to share with respect to
proffers.
I will be out of the country and not returning to the office until January 10<x-apple-data-detectors://0> (or
possibly January 13<x-apple-data-detectors:/1>). We will contact you then about scheduling a call to discuss.
Many thanks.
Best,
EFTA00016993

=== Page 20 ===
EFTA00016994

=== Page 21 ===
F

=== Page 22 ===
The contents of this message may be privileged and confidential. If this message has been received in error,
please delete it without reading it. Your receipt of this message is not intended to waive any applicable
privilege. Please do not disseminate this message without the permission of the author. Any tax advice
contained in this email was not intended to be used, and cannot be used, by you (or any other taxpayer) to avoid
penalties under applicable tax laws and regulations.
EFTA00016996


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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 19:09:34 +0000
Inline-Images: image001.png
Thanks very much.
From:
Sent: Thursday, July 2, 2020 2:46 PM
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN
TO SEXUALLY ABUSE MINORS
Awesome work.
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA JUSTITIA OF TOFFICE SESTICE
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,
EFTA00017726

=== Page 2 ===
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
EFTA00017727

=== Page 3 ===
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00017728


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=== Page 1 ===
From: USDOJ-Office of Public Affairs <USDOJ-OfficeofPublicAffairs@public.govdelivery.com>
To:
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING
WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 19:52:29 +0000
seal - centered header for gov delivery
The United States Department of Justice
Audrey Strauss
Acting United States Attorney
Southern District of New York
FOR IMMEDIATE RELEASE
THURSDAY, JULY 2, 2020
WWW.JUSTICE.GOV/USAO-SDNY
CONTACT: JIM MARGOLIN
PHONE: (212) 637-2600
EFTA00016166

=== Page 2 ===
GHISLAINE MAXWELL CHARGED IN MANHATTAN
FEDERAL COURT FOR CONSPIRING WITH JEFFREY
EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016
Depositions
NEW YORK CITY - Audrey Strauss, the Acting U.S. Attorney for the Southern
District of New York, William F. Sweeney Jr., the Assistant Director in Charge of
the New York Field Office of the Federal Bureau of Investigation (FBI), and
Dermot Shea, Commissioner of the New York City Police Department (NYPD),
announced that Ghislane Maxwell was arrested this morning and charged with
enticing a minor to travel to engage in criminal sexual activity, transporting a
minor with the intent to engage in criminal sexual activity, conspiracy to commit
both of those offenses, and perjury in connection with a sworn deposition.
The indictment unsealed today alleges that between at least in or about 1994
through 1997, Maxwell and co-conspirator Jeffrey Epstein exploited girls as young
as 14, including by enticing them to travel and transporting them for the purpose
of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference
for young girls, Maxwell played a critical role in the grooming and abuse of minor
victims that took place in locations including New York, Florida, and New
Mexico. In addition, as alleged, Maxwell made several false statements in sworn
depositions in 2016. Maxwell is expected to be presented this afternoon in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J.
Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell
facilitated, aided, and participated in acts of sexual abuse of minors. Maxwell
enticed minor girls, got them to trust her, and then delivered them into the trap
that she and Jeffrey Epstein had set. She pretended to be a woman they could
trust. All the while, she was setting them up to be abused sexually by Epstein and,
in some cases, Maxwell herself. Today, after many years, Ghislaine Maxwell
finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of
children is among the most important responsibilities we carry as adults. Like
Epstein, Ms. Maxwell chose to blatantly disregard the law and her responsibility
as an adult, using whatever means she had at her disposal to lure vulnerable
youth into behavior they should never have been exposed to, creating the
potential for lasting harm. We know the quest for justice has been met with great
disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered
EFTA00016167

=== Page 3 ===
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, Ghislane Maxwell assisted, facilitated,
and participated in Jeffrey Epstein's abuse of minor girls by, among other things,
helping Jeffrey Epstein to recruit, groom, and ultimately abuse victims known to
Maxwell and Epstein to be under the age of 18. The victims were as young as 14
years old when they were groomed and abused by Maxwell and Epstein, both of
whom knew that their victims were in fact minors. As a part and in furtherance of
their scheme to abuse minor victims, Maxwell and Epstein enticed and caused
minor victims to travel to Epstein's residences in different states, which Maxwell
knew and intended would result in their grooming for and subjection to sexual
abuse.
As alleged, Maxwell enticed and groomed minor girls to be abused in multiple
ways. For example, Maxwell attempted to befriend certain victims by asking them
about their lives, taking them to the movies or taking them on shopping trips, and
encouraging their interactions with Epstein. Maxwell also acclimated victims to
Epstein's conduct simply by being present for victim interactions with Epstein,
which put victims at ease by providing the assurance and comfort of an adult
woman who seemingly approved of Epstein's behavior. Additionally, to make
victims feel indebted to Epstein, Maxwell would encourage victims to accept offers
of financial assistance from Epstein, including offers to pay for travel or
educational expenses. Maxwell also normalized and facilitated sexual abuse by
discussing sexual topics with victims, encouraging them to massage Epstein, and
undressing in front of a victim.
As Maxwell and Epstein intended, these grooming behaviors left minor victims
vulnerable and susceptible to sexual abuse by Epstein. Maxwell was then present
for certain sexual encounters between minor victims and Epstein, such as
interactions where a minor victim was undressed, and ultimately Maxwell was
present for sex acts perpetrated by Epstein on minor victims. That abuse included
sexualized massages during which a minor victim was fully or partially nude, as
EFTA00016168

=== Page 4 ===
well as group sexualized massages of Epstein involving a minor victim where
Maxwell was present.
As alleged, minor victims were subjected to sexual abuse that included, among
other things, the touching of a victim's breasts or genitals, placing a sex toy such a
vibrator on a victim's genitals, directing a victim to touch Epstein while he
masturbated, and directing a victim to touch Epstein's genitals. Maxwell and
Epstein's victims were groomed or abused at Epstein's residences in New York,
Florida, and New Mexico, as well as Maxwell's residence in London, England.
Additionally, in 2016, while testifying under oath in a civil proceeding, Maxwell
repeatedly made false statements, including about certain specific acts and events
alleged in the indictment.
*
*
*
Ghislaine Maxwell, 58, is charged with one count of enticing a minor to travel to
engage in illegal sex acts, which carries a maximum sentence of five years in
prison, one count of conspiracy to entice a minor to travel to engage in illegal sex
acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which
carries a maximum sentence of 10 years in prison, one count of conspiracy to
transport a minor with the intent to engage in criminal sexual activity, which
carries a maximum sentence of five years in prison, and two counts of perjury,
each of which carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided
here for informational purposes only, as any sentencing of the defendant would be
determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S.
Attorneys
,
, and
are in charge of the
prosecution.
The charges contained in the Indictment are merely accusations. The defendant
is presumed innocent unless and until proven guilty.
[1] As the introductory phrase signifies, the entirety of the text of the Indictment,
and the description of the Indictment set forth herein, constitute only allegations,
and every fact described therein should be treated as an allegation. The defendant
is presumed innocent unless and until proven guilty.
###
Do not reply to this message. If you have questions, please use the contacts in the
message or call the Office of Public Affairs at 202-514-2007.
EFTA00016169

=== Page 5 ===
Twi Fac You Ins
Follow us:
the
oR
Tub
tax
This email was sent to
using GovDelivery, on behalf of U.S. Department of Justice Office of Public Affairs - 950 Pennsylvania Ave., NW
Washington, DC 20530 202-514-2007 TTY (866) 544-5309. GovDelivery may not use your subscription information for any other purposes. Click here to
unsubscribe.
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EFTA00016170


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=== Page 1 ===
Event: Accepted: Call/Meeting on Epstein
Start Date: 2018-12-07 16:00:00 +0000
End Date: 2018-12-07 17:00:00 +0000
Organizer:
(USANYS)
Class: X-PERSONAL
Comment:
Date Created: 2018-12-07 11:40:27 +0000
Date Modified: 2018-12-07 11:40:27 +0000
Priority: 5
DTSTAMP: 2018-12-07 11:31:33 +0000
EFTA00016610


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=== Page 1 ===
From: "postmaster@voip.usa.doj.gov" <postmaster@voip.usa.doj.gov>
To:
Cc: USANYS-EpsteinVictims <USANYS.EpsteinVictims@usa.doj.gov>
Subject: Voice Message Attached from
- WIRELESS CALLER
Date: Fri, 02 Aug 2019 19:29:37 +0000
Attachments:
wav
Time: Aug 2, 2019 3:29:37 PM
Click attachment to listen to Voice Message
EFTA00015705


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=== Page 1 ===
From:
(USANYS)"
To:
)"
Subject: Automatic reply: Jeffrey Epstein Bourget Airport - Journalist in France
Date: Sun, 29 Sep 2019 20:56:37 +0000
I will be out of the office Thursday and Friday but will return Monday morning. If you need immediate
assistance, please call the main public affairs phone number at
EFTA00014283


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=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: RE: subpoena of
Date: Mon, 29 Jul 2019 14:25:28 +0000
Let me know when would be a good time for a call to further discuss the
subpoena.
Thanks,
From:
Sent: Tuesday, July 16, 2019 12:53 PM
To:
Cc:
)
Subject: RE: subpoena of
Following up on our phone conversation earlier today, thank you for being in touch and advising us of your representation
of
in connection with
receipt of a grand jury subpoena. So you have contact info for our full team,
we're all reachable anytime at the copied emails or by phone at:
As we briefly discussed, the documentary materials we are seeking from
in the first instance are any flight
manifests, flight plans, or other documents reflecting passengers and/or travel records, dating back to 2000. And we
would like to hear from
about
observations, if any, of young women or girls on flights, as well as any discussions
with Mr. Epstein about his relationships with young women or girls, or his legal issues relating to those relationships. We
are also interested to know the identities of Epstein's employees and staff whom
is aware of, current and
previous.
As I mentioned on the phone, given the prospect of attorney proffer information and/or a possible voluntary interview,
we are prepared to hold in abeyance the current subpoena return date of July 22, 2019.
thank you,
EFTA00014524

=== Page 2 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00014525


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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 16, 2019
VIA ECF
REQUEST TO FILE PARTIALLY
UNDER SEAL
The Honorable Richard M. Berman
United States District Judge
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 Berman:
The Government respectfully submits this letter to provide the Court with additional
information in response to the Court's questions at the detention hearing held on July 15, 2019
(the "Detention Hearing").
I. Payments to Potential Witnesses
In a July 12, 2019 letter, the Government informed the Court that the Government had
recently obtained records from a financial institution ("Institution-1") that appeared to show the
defendant had made suspicious payments shortly after the Miami Herald began publishing, on
approximately November 28, 2018, a series of articles relating to the defendant, his alleged sexual
misconduct, and the circumstances under which he entered into a non-prosecution agreement
("NPA") with the U.S. Attorney's Office for the Southern District of Florida in 2007. The same
series highlighted the involvement of several of Epstein's former employees and associates in the
alleged sexual abuse. At the Detention Hearing, the Court asked the Government to provide
additional information about the individuals to whom these payments appear to have been made.
First, records from Institution-1 show that on or about November 30, 2018, or two days
after the series in the Miami Herald began, the defendant wired $100,000 from a trust account he
controlled to
, an individual named as
a potential co-conspirator-and for whom Epstein obtained protection in-the NPA. This
individual was also named and featured prominently in the Herald series.
Second, the same records show that just three days later, on or about December 3, 2018,
the defendant wired $250,000 from the same trust account to
, who was
1 For the reasons set forth at the Detention Hearing, and with the consent of the Court, the
Government is redacting the identities of these individuals in the publicly filed version of this
letter.
EFTA00016748

=== Page 2 ===
Hon. Richard M. Berman
United States District Judge
July 16, 2019
Page 2
also named as a potential co-conspirator-and for whom Epstein also obtained protection in-the
NPA. This individual is also one of the employees identified in the Indictment, which alleges that
she and two other identified employees facilitated the defendant's trafficking of minors by, among
other things, contacting victims and scheduling their sexual encounters with the defendant at his
residences in Manhattan and Palm Beach, Florida. This individual was also named and featured
prominently in the Herald series.
II. Police Report
During the Detention Hearing, the parties referenced a redacted copy of a Palm Beach
police report, which was annexed to the Government's July 12, 2019 detention memorandum. At
the Court's request, the Government has provided a supplemental copy of the police report
previously filed, with information referred to in open court unredacted. The updated copy of the
police report is attached as Exhibit A.
III. Foreign Passport
During the Detention Hearing, the Government informed the Court that it had recently
learned that law enforcement agents had seized what appears to be an expired foreign passport (the
"Foreign Passport") from a safe in the defendant's Manhattan residence during the execution of a
search warrant on or about July 6, 2019. The Foreign Passport has a photograph that appears to
depict the defendant, but lists a different name. Photographs of that passport are annexed hereto
as Exhibit B. In the same safe, agents discovered what appears to be an expired United States
passport issued to the defendant, in his true name, within three years of the date on the Foreign
Passport. A photograph of that United States passport is annexed hereto as Exhibit C, so that the
Court may compare the passports, both of which appear to depict the defendant. Because Exhibits
B and C contain personally identifiable information and sensitive information relevant to the
ongoing investigation, the Government respectfully requests that Exhibits B and C be filed under
seal.
The Government is attempting to obtain additional information about the Foreign Passport,
including how it was obtained and whether the passport is genuine or fabricated. But the
defendant's possession of what purports to be a foreign passport issued under an alias gives rise to
the inference the defendant knows how to obtain false travel documents and/or assume other,
foreign identities. This adds to the serious risk of flight posed by the defendant.²
2 The Government has asked defense counsel to advise whether the defendant is currently, or has
been in the past, a citizen or legal permanent resident of a country other than the United States. To
date, defense counsel has declined to respond. Certainly if the defendant is, or has been, a citizen
or permanent resident of another country, that would add significantly to the overwhelming
evidence of risk of flight.
EFTA00016749

=== Page 3 ===
Hon. Richard M. Berman
United States District Judge
July 16, 2019
Page 3
IV. Cash and Diamonds
At the Detention Hearing, the Government informed the Court that diamonds and cash
were seized from a safe in the defendant's Manhattan residence. The Court inquired as to the value
of these items. After conferring with law enforcement agents who have reviewed the materials
from the safe, the Government has learned that the safe contained more than $70,000 in cash. In
addition, the safe contained 48 loose diamond stones, ranging in size from approximately 1 carat
to 2.38 carats, as well as a large diamond ring. The Government is currently unaware of whether
the defendant maintains similar stashes of cash and/or jewels at his multiple properties, or in other
locations. Such ready cash and loose diamonds are consistent with the capability to leave the
jurisdiction at a moment's notice.
V. Conclusion
For the reasons set forth herein, in the Government's July 8, 2019 and July 12, 2019
detention memoranda, and on the record at the Detention Hearing, the Court should order that the
defendant be detained pending trial. The defendant 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.
Respectfully submitted,
United States Attorney
By:
/s
/
/
Assistant United States Attorneys
Southern District of New York
Tel:
Cc:
counsel for defendant
EFTA00016750


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=== Page 1 ===
From:
To:
Subject: Excerpt
Date: Wed, 18 Sep 2019 20:04:31 +0000
Attachments: 09172019KMKTartaglioneExcerpt.pdf
there is no title sheet on this.
Thanks so much
EFTA00017108


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=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
)"
)"
Subject: RE: Epstein tips / communications
Date: Wed, 04 Sep 2019 21:04:19 +0000
Importance: Normal
Attachments: 2019.08.05_Letter_to
pdf; 2019.07.28_Letter_w_Photo.pdf
Team,
For obvious reasons I don't think the attached communications are meaningful for the investigation, but in the interest of
passing along anything we receive into our office, please see the attached. And mailing over the hard copies.
thanks,
EFTA00016799


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=== Page 1 ===
From:
To:
Cc:
Subject: Tartaglione
Date: Thu, 19 Dec 2019 15:38:44 +0000
Embedded: Re_Fwd:_Preservation_request.msg
Here is the email we spoke about.
I
EFTA00016909


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=== Page 1 ===
From:
To:
Subject: scheduling order
Date: Wed, 07 Oct 2020 16:29:59 +0000
Attachments: 2020.07.15,_GM,_20_Cr_330_(AJN)_Scheduling_Order.pdf
Attached, thanks.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00014589


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=== Page 1 ===
From:
)"
To:
)"
Subject: FW: subpoena of
Date: Tue, 30 Jul 2019 14:39:35 +0000
The more the merrier, of course, but I'm happy to deal with this
From:
Sent: Tuesday, July 30, 2019 10:39
To:
<KCassidy@hafetznecheles.com>
Cc:
Subject: RE: subpoena of
Sure - you can call
or let us know if there's a number we can reach you at if you prefer we call you.
thanks,
From:
Sent: Tuesday, July 30, 2019 07:16
To:
Cc:
)
)
Subject: Re: subpoena of
Would 4:30 work?
Sent from my iPhone
On Jul 29, 2019, at 11:22 PM,
wrote:
Is there a good time for you tomorrow afternoon, 2:00 or later?
thanks,
From:
Sent: Monday, July 29, 2019 10:25
To:
Cc:
)
Subject: RE: subpoena of
Let me know when would be a good time for a call to further discuss the
subpoena.
Thanks,
EFTA00014558

=== Page 2 ===
From:
Sent: Tuesday, July 16, 2019 12:53 PM
To:
Cc:
Subject: RE: subpoena of
Following up on our phone conversation earlier today, thank you for being in touch and advising us of your
representation of
in connection with
receipt of a grand jury subpoena. So you have contact info
for our full team, we're all reachable anytime at the copied emails or by phone at:
As we briefly discussed, the documentary materials we are seeking from
in the first instance are any flight
manifests, flight plans, or other documents reflecting passengers and/or travel records, dating back to 2000. And we
would like to hear from
about
observations, if any, of young women or girls on flights, as well as any discussions
with Mr. Epstein about his relationships with young women or girls, or his legal issues relating to those relationships.
We are also interested to know the identities of Epstein's employees and staff whom
is aware of, current
and previous.
As I mentioned on the phone, given the prospect of attorney proffer information and/or a possible voluntary interview,
we are prepared to hold in abeyance the current subpoena return date of July 22, 2019.
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00014559


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=== Page 1 ===
From:
To:
Subject: Re:
Date: Mon, 13 Jan 2020 23:14:40 +0000
Hey sorry. I've been out sick today and don't have access to everyone's calendars from my phone. Hopefully I'll
be in tomorrow and can give you an answer for this and
On Jan 13, 2020, at 4:19 PM,
wrote:
- what is full brass availability on Friday January 24 for a presentation by defense counsel for
? I would
block off 90 minutes but could be done in 60.
EFTA00016734


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 7, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These discovery materials
are stamped with control numbers SDNY_GM_02762507 through SDNY_GM_02763017.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. 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.
EFTA00015186

=== Page 2 ===
Page 2
An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential Designation
SDNY GM 02762507
SDNY GM 02762567
SDFL files¹
SDNY GM 02762568
SDNY GM 02762569
JPMC documents²
SDNY GM 02762570
SDNY GM 02762637
Database files (Ghislaine Maxwell)
SDNY GM 02762638
SDNY GM 02762663
Database files (Jeffrey Epstein)
SDNY GM 02762664
SDNY GM 02762775
FAA records
Confidential
SDNY GM 02762776
SDNY GM 02762776
FedEx records
Confidential
SDNY GM 02762777
SDNY GM 02762831
Miscellaneous
SDNY GM 02762832
SDNY GM 02763004
Miscellaneous
Confidential
SDNY GM 02763005
SDNY GM 02763007
Photographs
SDNY GM 02763008
SDNY GM 02763016
Photographs
Confidential
SDNY GM 02763017
SDNY GM 02763017
Photos of Palm Beach House
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials.
Very truly yours,
AUDREY STRAUSS
United States Attorney
by:
s/
Assistant United States Attorneys
1 We are unable to view these files, as they are either corrupt or we do not have the requisite
software to view them, but we are producing these files to you in an abundance of caution.
2 We are unable to view the JPMC files, which we understand to be from FBI in Florida. The two
files are password protected, but we are producing these files to you in an abundance of caution.
EFTA00015187


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=== Page 1 ===
From:
To:
Subject:
Sharts
Date: Mon, 26 Aug 2019 21:24:15 +0000
I am currently on trial before the Honorable Ronnie Abrams. I will be checking email at the end of each trial day. If you need immediate
assistance in connection with United States V. Epstein, 19 Cr. 490 (RMB), please contact AUSA
For all other matters,
please contact AUSA
Thank you.
EFTA00014376


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=== Page 1 ===
From:
To:
Subject: RE: Epstein
Date: Mon, 10 Dec 2018 20:31:10 +0000
Importance: Normal
Got it
From:
Sent: Monday, December 10, 2018 3:23 PM
To:
is
Subject: RE: Epstein
He told us he sent
a brief write up and told her we were open on it - he hasn't heard back yet.
From:
Sent: Monday, December 10, 2018 3:20 PM
To:
is
Subject: Epstein
Do you know whether
mentioned it to ODAG?
EFTA00015291


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=== Page 1 ===
10/6/21, 12:18 PM
III/FBI/State Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
III Information
The following information is provided in response to your request for a search of the III based on:
THE RECORD(S) CAN BE OBTAINED THROUGH THE INTERSTATE IDENTIFICATION
INDEX BY USING THE APPROPRIATE NCIC TRANSACTION.
END
1/1
EFTA00015157


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=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
(USANYS)"
Cc:
(USANYS)"
Subject: RE: Voice Message Attached from
- WIRELESS CALLER
Date: Tue, 23 Nov 2021 18:19:42 +0000
Hi
,
Thanks very much for flagging. Our protocol in this case has been to forward all tips to the FBI-- our case agents
have been logging tips through a specific protocol. We'll pass this on.
Thanks,
Original Message
From:
(USANYS) [Contractor]
Sent: Tuesday, November 23, 2021 1:15 PM
To:
(USANYS)
Cc:
(USANYS)
)
Subject: FW: Voice Message Attached from
- WIRELESS CALLER
Hi
,
, and
- attached is a voice message from an individual claiming they have information
about Ghislaine Maxwell and that they are a friend of George Soros.
,
- not sure if this is something you want to follow up on.
,
if not can you send this individual
the crime reporting materials? Her number is
She was transferred to my line from the tent CSOs.
Original Message
From:
Sent: Tuesday, November 23, 2021 12:53 PM
To:
(USANYS) [Contractor]
Subject: Voice Message Attached from
- WIRELESS CALLER
Time: Nov 23, 2021 12:53:29 PM
Click attachment to listen to Voice Message
EFTA00014717


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=== Page 1 ===
From:
"
)"
To: Nathan NYSD Chambers
Cc:
)"
(USANYS)"
)"
bcsternheim_mac.com
, Jeff Pagliuca
,
Laura Menninger
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Motion to Preclude
Date: Sun, 28 Nov 2021 03:35:33 +0000
Attachments: 2021-11-27_GM_mot_to_preclude_cross_final.pdf
Chambers,
Attached please find a letter motion to preclude cross-examination. The Government respectfully submits this filing
under seal.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
EFTA00016509


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=== Page 1 ===
11/26/21, 7:16 PM
Mail - Meder, Kimberly R. (NY) (FBI) - Outlook
Accepted: Call re: GM photo project
Tue 8/10/2021 1:05 PM
To:
https://outlook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
1/1
EFTA00014958


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=== Page 1 ===
From:
To:
Subject: Filed version of Epstein papers
Date: Wed, 17 Jul 2019 13:47:19 +0000
Attachments: 2019.07.16_Defense_Letter.pdf 23-1.pdf; 23.pdf
Here are the papers filed yesterday by defense and by us in Epstein.
United States Attorney's Office
Southern District of New York
EFTA00016746


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=== Page 1 ===
Event: Call/Meeting on Epstein
Start Date: 2018-12-07 16:00:00 +0000
End Date: 2018-12-07 17:00:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2018-12-07 02:50:51 +0000
Date Modified: 2018-12-07 02:50:51 +0000
Priority: 5
DTSTAMP: 2018-12-07 02:48:09 +0000
Attendee:
EFTA00014304


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=== Page 1 ===
From:
"
To:
Subject: Interesting
Date: Thu, 28 May 2020 18:00:53 +0000
Attachments: In_re_Wild,_955_F.3d_1196_(11th_Cir_2020).pdf
Last month, the 11th Circuit, in a case arising from the failure to prosecute Jeffrey Epstein,
decided that rights under the Crime Victims' Rights Act (the "CVRA") "do not attach until
criminal proceedings have been initiated against a defendant, either by complaint, information, or
indictment." In re Wild, 955 F.3d 1196, 1198 (11th Cir. 2020). Accordingly, "[b]ecause the
government never filed charges or otherwise commenced criminal proceedings against Epstein,"
but simply entered into a non-prosecution agreement with him, "the CVRA was never triggered."
Id.
EFTA00016451


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=== Page 1 ===
10/6/21, 12:40 PM
III/FBI/State Delayed Response
Additional Inquiry Response
ORI: NYFBINY00
Federal Bureau of Investigation - New York
New York State Division of Criminal Justice Services
Alfred E. Smith Building, 80 South Swan St.
Albany, New York 12210. Tel:1-800-262-DCJS
Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
III Information
END
1/1
EFTA00015125


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=== Page 1 ===
Event: Call w/ DOJ re. Epstein SDNY Investigation
Start Date: 2020-10-05 18:45:00 +0000
End Date: 2020-10-05 19:15:00 +0000
Organizer:
Location:
4279915#
Class: X-PERSONAL
Date Created: 2020-10-05 12:29:23 +0000
Date Modified: 2020-10-05 12:29:23 +0000
Priority: 5
DTSTAMP: 2020-10-05 12:19:09 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
Confidential & Privileged
Unless otherwise indicated or obvious from its nature, the information contained in this
communication is attorney-client privileged and confidential information/work product. This
communication is intended for the use of the individual or entity named above. If the reader of
this communication is not the intended recipient, you are hereby notified that any dissemination,
distribution or copying of this communication is strictly prohibited. If you have received this
communication in error or are not sure whether it is privileged, please immediately notify us by
return e-mail and destroy any copies--electronic, paper or otherwise--which you may have of this
communication.
EFTA00014587


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=== Page 1 ===
From: Bruce Barket <bbarket@barketepstein.com>
To:
, Aida Leisenring
<aleisenring@barketepstein.com>
Cc:
)"
Subject: RE: Follow Up on July 23 Incident Sensitive Disclosure Materials
Date: Tue, 17 Dec 2019 16:59:44 +0000
Thanks for look into this for us.
As part of our work, we routinely examine physical evidence of any relevant event. The incident on the 22ⁿᵈ-23ʳᵈ may be
relevant to the penalty phase. We would like to examine the "rope" and be permitted to take measurements of it. Please
let us know your position.
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
(516) 745 1500 [P] (516) 745 1245 [F]
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments
From:
[mailto:
Sent: Tuesday, December 17, 2019 6:47 AM
To: Aida Leisenring
Cc:
); Bruce Barket
Subject: Re: Follow Up on July 23 Incident Sensitive Disclosure Materials
Aida,
To confirm, we are looking into whether video of the hallway, and videos and/or photos of the cell exist. We likely would
make those available for review in the same manner as the report. We are also looking into whether the orange rope was
preserved and if it was, we will let you know our position on whether it can be made available for inspection. As discussed
briefly, since you have reviewed a photograph of the rope, we are not sure the basis for a physical inspection and would
ask you to articulate one for our consideration.
Co-Chief, Narcotics Unit
212-637-1023
On Dec 16, 2019, at 16:52, Aida Leisenring <aleisenring@barketepstein.com> wrote:
Hello
Thank you for taking the time to let us review sensitive disclosure materials in your office on Friday. We appreciate it. I
just wanted to memorialize a few follow-up questions we had.
EFTA00016907

=== Page 2 ===
1. It is our understanding that there is video surveillance in the hallway in or near the tier that was preserved in
reference to the July 23 incident. We would like to see a copy of it.
2. It is our understanding that there may be photographs or a video recording of cell 124 that would have been
taken shortly after the incident. If so, we would like to see them.
3. If the orange rope was preserved, we would like to view it in person.
Jason, I understand that you were not aware of the availability of the above and that you would look into this additional
discovery. I just wanted to memorialize our follow up inquiries for your records.
Lastly, if the items above are available, does your office take a position with respect to our request to view them? We
just need to know so we can plan our next course of action.
See you in Court, and thank you again for your time.
Aida Ferrer Leisenring, Esq.
Barket, Epstein, Kearon, Aldea & LoTurco LLP
666 Old Country Road, Ste 700
Garden City, NY 11530
T(
F
(
Please note that my emailed has changed to:
aleisenring@barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments.
EFTA00016908


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=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
"Berman, Geoffrey (USANYS)"
(USANYS)"
USANYS)"
(USANYS)"
)"
)"
)"
Cc:
(USANYS) [Contractor]"
(USANYS)"
Subject: RE: Epstein PR Final review
Date: Mon, 08 Jul 2019 13:56:57 +0000
Importance: Normal
Got it. Yes, they meant 'where.' I made the edit (and corrected the spelling).
From:
(USANYS)
Sent: Monday, July 8, 2019 9:55 AM
To:
(USANYS)
>; Berman, Geoffrey (USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
is
is
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: RE: Epstein PR Final review
Also in
quote: Are we trying to say no matter where the incident took place?
FBI Assistant Director
said: "We are asking anyone who may have been victimized
by Jeffery Epstein, or anyone who may have information about his alleged criminal behavior, to please call us.
The number is 1-800-CALL-FBI. We want to hear from you, regardless of the age you are now, or whatever age
you were then, no matter the incident that took place. The bravery it takes to call us might empower others to
speak out about the crimes committed against them. It is important to remember there was never, nor will
there ever be an excuse for this type of behavior. In the eyes of the FBI, the victims will always come first."
From:
(USANYS)
Sent: Monday, July 8, 2019 9:39 AM
To: Berman, Geoffrey (USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
(USANYS)
is
is
is
Cc:
(USANYS) [Contractor]
is
(USANYS)
Subject: Epstein PR Final review
Importance: High
EFTA00014641

=== Page 2 ===
Attached is the final PR for review. Please note that
quote includes the number to call, so we need to
finalize that as soon as possible. Thanks.
Public Affairs
U.S. Attorney's Office for the Southern District of New York
Facebook: https://www.facebook.com/usaosdny.
Follow us on Twitter: @SDNYnews
EFTA00014642


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=== Page 1 ===
From:
To:
Cc:
Subject: Re: quick Epstein update?
Date: Wed, 03 Apr 2019 15:35:16 +0000
Importance: Normal
We're in
office.
Sent from my iPhone
On Apr 3, 2019, at 11:25 AM,
wrote:
Works for me if that's good for
From:
Sent: Wednesday, April 03, 2019 11:17
To:
is
Subject: RE: quick Epstein update?
Just finishing up a SW. Would 11:30 work?
From:
Sent: Wednesday, April 3, 2019 11:16 AM
To:
is
Subject: quick Epstein update?
Could I grab you guys for just 5-10 minutes on Epstein sometime today? I'm free now until noon, and then in and out of
proffers / meetings but generally around. No emergency at all just want to run a few things by you.
Assistant U.S. Attorney
Southern District of New York
EFTA00017754


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=== Page 1 ===
sa his car- his driver netually took us to
be so moving had seen it before but still
Phantom | didn't know any play could
couldn 4 believe it / bulled it was tantastic
After the play we walked around the
Plaza and went home. it was so much fun
/ met
he was diffurent boyfriend than / expected pretty
mAr, nice, but they didn 4 get along
very well took at the beg. which made
me annoyed W / him. he turned out
to be pretty 1001 once he chilled out
His brother
was 25 and we
hung out wl him a lot. at 157 / didn't
think he was as cute as She had said
but We quickly fuand him really cute
than the 4 of us went to their cakin
hung out for the 1st the uple days
We had a lot of tun- X-country skild, watched
Shuth movie) # hung out. We had to
forareally long time kind of wanted
sleep in the same bed f ended up talking
/ just thought he was nite + tun, Ididn't
something to happen- but didn't know
See to him again until Friday we wht
t then
a club to watch some bands, to a bar
Jethneys + asked announced she was staying at
to think had wanted her to do this him so
secretly happy but clidn It want was
tostay w/me
acticl kind wl of upset, They lett us at
I
wondered if he hanted


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=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc: Christian Everdell
P, Laura Menninger
, Jeff Pagliuca
Subject: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Wed, 03 Nov 2021 16:48:37 +0000
Attachments: Disclosure_of_Juror_Names_to_Counsel_Only_upon_completion_of_Questionnaire.pdf
Courtesy copy of today's ECF filing.
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
EFTA00016203


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=== Page 1 ===
From:
)"
To:
)"
Subject: Accepted: Epstein discovery deadline
Date: Wed, 31 Jul 2019 16:08:35 +0000
Importance: Normal
Attachments: unnamed
EFTA00014556


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=== Page 1 ===
From:
)"
To: "gldc@att.com" <gldc@att.com>
Cc:
)"
)"
)"
Subject: Certification Request
Date: Thu, 30 Sep 2021 18:59:27 +0000
Importance: Normal
Attachments: 229703-3363-0504.pdf; Scan_1.pdf
Good afternoon,
I'm writing to request certification of the attached AT&T record. I have also attached a cover letter that is attached to the
CD containing the record. The CD itself has a file code of 229703 and a date of 8/23/2006.
If you have any questions, or if you have difficulty certifying the record, please give me a call at the below number.
Thank you,
Andrew
Assistant United States Attorney
Southern District of New York
EFTA00015188


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=== Page 1 ===
From:
To:
Subject: Automatic reply: Rossmiller opens U.S. V. Cordell Fitts
Date: Mon, 26 Aug 2019 20:03:19 +0000
I am currently on trial before the Honorable Ronnie Abrams. I will be checking email at the end of each trial day. If you need immediate
assistance in connection with United States V. Epstein, 19 Cr. 490 (RMB), please contact AUSA
at
For all other matters,
please contact AUSA
at
Thank you.
EFTA00014378


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=== Page 1 ===
From:
)"
To:
)"
Subject: Automatic reply: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to
Date: Sat, 03 Aug 2019 22:31:51 +0000
I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses may be
delayed. For urgent matters, please contact the other AUSA(s) on the case, or
or
EFTA00014580


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=== Page 1 ===
From:
To:
)"
)"
Cc:
(USANYS)"
Subject: RE: Wednesday's WebEx
Date: Tue, 17 Nov 2020 13:21:22 +0000
Attachments: 2020.11.12_Proffer_Agreement_Executed.pdf
sorry for the delay. Here is the executed proffer agreement from our last meeting.
Best,
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Wednesday, November 11, 2020 1:43 PM
To:
is
Cc:
is
is
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
We will be joined by two FBI agents who are focusing on the CBP topics that we have previously discussed. I expect one
of those agents will take the lead on questioning Mr.
The topics we expect to cover include:
The identities of any CBP employees Mr.
recalls interacting with Jeffrey Epstein in the Virgin Islands.
Any steps Mr.
recalls any CBP employees in the Virgin Islands taking to help Epstein and those traveling with
Epstein to enter the country, including any steps that allowed Epstein or those traveling with him to avoid
processing that travelers would normally undergo.
Any favors Mr.
recalls Epstein doing for CBP employees in the Virgin Islands, such as trips to Epstein's island.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00015006

=== Page 2 ===
From:
Sent: Tuesday, November 10, 2020 1:16 PM
To:
>;
Cc:
is
>;
(USANYS)
Subject: RE: Wednesday's WebEx
just wanted to circle back with you in advance of Thursday's meeting. We want
to be fully prepared, so
if there is any more granularity on this topic (or any additional topic or topics), please let us know.
Thanks,
I
Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Monday, October 26, 2020 6:19 PM
To:
in
Cc:
is
>;
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
Thanks very much,
Let's plan for 1pm on Thursday, 11/12. I will circulate a WebEx invitation shortly.
We expect to ask Mr.
about his interactions with
the U.S. Customs and Border Protection
employee who worked in Saint Thomas and who had Mr.
listed as a contact in his phone. I expect we will ask for
an approximate timeline of when Mr.
met and interacted with
the nature of those interactions, and any
interactions
may have had with Epstein (to the best of Mr.
knowledge).
Best,
Assistant United States Attorney
Southern District of New York
EFTA00015007

=== Page 3 ===
From:
Sent: Monday, October 26, 2020 11:58 AM
To:
is
Cc:
V.
i
(USANYS)
Subject: RE: Wednesday's WebEx
-
Sorry for the delay. Looks like we can do between 11 a.m. and 2 p.m. on Tuesday, 11/10, or any time on Thursday, 11/12.
Let us know if anything in that range will work.
So as to make sure Mr.
is prepared, can you give us an overview of what you expect to cover?
Thanks,
I
Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Thursday, October 22, 2020 10:33 AM
To:
is
Cc:
is
i
(USANYS)
Subject: RE: Wednesday's WebEx
External Email
As I believe we mentioned when we last spoke, we would like to schedule time for a second interview with Mr.
via
WebEx. Are there any days the week of November 9th when your team and Mr.
would be available? We would
expect this proffer to be much shorter than our first, and certainly no more than two hours at most.
Thanks,
EFTA00015008

=== Page 4 ===
Assistant United States Attorney
Southern District of New York
From:
Sent: Friday, October 9, 2020 4:42 PM
To:
Cc:
is
i
(USANYS)
is
Subject: RE: Wednesday's WebEx
Hi
Thanks very much. I'm attaching the fully executed copy.
Thanks,
From:
Sent: Thursday, October 8, 2020 9:31 AM
To:
Cc:
is
>;
(USANYS)
is
Subject: RE: Wednesday's WebEx
Hi all.
Attached please find the signed proffer agreement. It was nice seeing everyone yesterday.
Thanks,
I
Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
From:
Sent: Monday, October
2020 4:14 PM
To:
Cc:
is
i
(USANYS)
EFTA00015009

=== Page 5 ===
is
Subject: RE: Wednesday's WebEx
External Email
Hi
Not a problem at all -- I've added everyone to the calendar invitation. Please let us know if any other tech issues crop up,
and we'd be happy to work through them.
Thanks,
From:
Sent: Monday, October
2020 12:48 PM
To:
is
is
(USANYS)
Cc:
is
;
>;
Subject: Wednesday's WebEx
Thanks for sending the WebEx invitation for Wednesday's meeting to me. For whatever reason, the system is not
permitting me to forward the invite, so I would ask that you separately invite those copied on this e-mail:
and Mr.
but also Josh Morrissey who is in our IT group and will make sure we are good to go for our meeting.
Thanks,
I
Crowell & Moring LLP
Managing Partner, New York Office
www.crowell.com
Web
Bio
Privileged and Confidential Attorney-Client Communication Attorney Work Product
This message contains privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT.
Instead, please notify the sender (or postmaster@crowell.com) by reply e-mail, and delete this e-mail.
Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
COVID-19 Questions or Concerns? See Crowell & Moring's COVID-19 Resource Center
EFTA00015010


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=== Page 1 ===
From:
To:
Subject: quick Epstein update?
Date: Wed, 03 Apr 2019 15:16:10 +0000
Importance: Normal
Could I grab you guys for just 5-10 minutes on Epstein sometime today? I'm free now until noon, and then in and out of
proffers / meetings but generally around. No emergency at all just want to run a few things by you.
Assistant U.S. Attorney
Southern District of New York
EFTA00017753


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=== Page 1 ===
La
Jan. 25, 1996
It has been a Co uple of weeks since / got
back + / have gaten back into the swing ot
things A couple of quick details about NY
Idian't mention canier- went to See The Dulhess-
advent play, t Blue-Man group Tubes- oH boadway
really we / production went to the theamanket
where / got some 1001 stutt, went to dettrey
Epstein's Mansion, went to the Met, a
pretty tun NewYear's Eve party, went to twift
stores where / got an amazing dress for
prom, it's from the fifties, lace with pink howers
wl rhinestones in the middle allover it, it is
my dream dress, One night we went to
the movies Jettrey Epstein It was white
weird one ot mose things that is wer hand
to explain we were sitting next to ealn other
+ he put out his hand for me to hold we
wine ho Icling hands Enotweins normalt fined
then he kind of caressed/mbbbld my am +
SAMON/foot - It was one of those things that
just your me a wei rd fulling but wasn
that Vind of winded me out about it was he
that weive + probably normal - the one thing
let go of my hand when he was talking to
I Q lowell / decided it was no big
deal It just made me mad because he
is being 80 amazing - paying for a summer
program for me thelping me w/colege- + -
he is 50 hiu t so generous w leveryone
/ just didn't want to have any werrethings
about it - / say anything.
EFTA00017025


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=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
November 22, 2021
BY E-MAIL
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully requests permission to file the attached reply brief in support
of the Government's motion to preclude the testimony of Dr. Ryan Hall. Among other issues, the
defendant's opposition brief raises new arguments about hearsay exceptions that the defendant
argues apply to information contained in Dr. Hall's report and further elaborates on the defendant's
theory of the report's relevance.
Respectfully submitted,
United States Attorney
By:
s/
Assistant United States Attorneys
Southern District of New York
Cc: Defense Counsel (By E-Mail)
EFTA00014697


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=== Page 1 ===
From: Christian Everdell <CEverdell@CohenGresser.com>
To: 'Laura Menninger' <lmenninger@hmflaw.com>.
(USANYS)"
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>, 'BOBBI C STERNHEIM'
<bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Thu, 08 Apr 2021 21:05:54 +0000
Inline-Images: image001.jpg
-
I plan to arrive at the warehouse on April 12 with an investigator and a paralegal at around 9:30am. Does that work?
Thanks,
Chris
From: Laura Menninger [mailto:Imenninger@hmflaw.com]
Sent: Wednesday, April 07, 2021 4:23 PM
To:
)';
);
(USANYS)
Cc: Jeff Pagliuca; Christian Everdell; 'BOBBI C STERNHEIM'
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
-
My apologies, I meant to include in my previous email that we could have the Bronx view on Monday, April 12. Thank you
for the logistics.
Regarding the spreadsheets you provided, I have several issues.
First, there are a couple of items that you have noted for the Bronx Warehouse but will in fact need to be brought to 500
Pearl for review because you labeled them as "Highly Confidential" and not "bulky." These appear to include:
NY Evidence List
Items 1B127-130 (4 boxes).
Item 1B13 (1 box)
Florida Evidence List
Item 1, Subitem 26 - one large framed photo from Master Bedroom.
Second, with regard to the "Bulky" photos (Florida Items 1, Subitems 8, 15a, 15b and 15c), are we permitted to
photograph those or not? If not, we will need them transported to 500 Pearl.
Third, Florida Item 8, Subitem 8, says it is Sixteen DVD-R Discs from PBSO but you do not indicate that we can review
those. Why? We need to address with the Court promptly any issues related to our request to view all evidence.
Fourth, Electronic surveillance - Your email yesterday stated that these were all "electronic files" with no corresponding
physical item. However, for several, the chart indicates "Blu-Ray Disks;" is there a reason we cannot inspect these?
Another Florida item is listed as "one original recording of an interview dated 4/24/07"; I am suspicious that "one original
EFTA00015770

=== Page 2 ===
recording of an interview" is not truly only an "electronic" file? I was practicing law in 2007 and do not recall "electronic
files" being the standard then. Can you please confirm? I know that Chris has written separately about the many files for
which the metadata has apparently been stripped, so we will have to address purely electronic information at another
date.
Shredded Paper - Yes, we need to review that as well.
"Missing from Assigned Box" items - can you please provide more of an explanation for all "missing items"?
I will let you know any other issues as I see them. However, now that we have made travel plans in reliance on your
agreement to produce all evidence items, I am hoping that you can promptly answer these questions so that we can
resolve any of them as needed this week.
Thank you,
-Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Wednesday, April 7, 2021 1:44 PM
To: Laura Menninger <lmenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Hi Laura,
The Bronx warehouse is located at 2350 Lafayette Ave, Bronx, NY. There is plenty of street parking outside of the
building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the
attorney, investigator, and paralegal at the warehouse to escort them into the building to the evidence review room. The
AUSA will remain present at the warehouse to answer any questions that may arise.
The FBI has informed me that they can make the evidence available for review at the warehouse any day next week or the
week of April 19th. Please just let me know what day you prefer, and we will coordinate with the FBI to arrange for the
review.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00015771

=== Page 3 ===
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Wednesday, April 7, 2021 3:30 PM
To:
)
is
)
i
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for the updated spreadsheets and the information regarding the timing of the review at 500 Pearl.
I believe we will be able to have an attorney, investigator and paralegal present at the Bronx warehouse to take photos of
the "excluded from transportation" items. Please let us know the particulars for that visit when you have a moment.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
)
Sent: Wednesday, April 7, 2021 10:06 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
i
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
Attached please find the revised spreadsheets, which reflect designations under the Protective Order for the three mini-
VHS tapes that I referenced below.
I learned this morning that the Marshals intend to bring Ms. Maxwell back to the MDC each review day at 4:30pm. So we
can plan for the review to take place at 500 Pearl Street from 9:30am to 4:30pm each day beginning on April 13th.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00015772

=== Page 4 ===
From:
Sent: Wednesday, April 7, 2021 12:09 AM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: 'Jeff Pagliuca' <jpagliuca@hmflaw.com>; 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good evening,
Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day
thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street
at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer rooms on the 5th floor of
the 500 Pearl Street courthouse beginning at 9:30am on April 13th. I will plan to be present and to continue assisting with
logistics. If any questions or concerns arise, please feel free to call my cellphone at
To assist in preparing for this review, attached please find annotated versions of the three evidence spreadsheets I
previously emailed to you: (1) a spreadsheet of New York evidence; (2) a spreadsheet of Florida evidence; and (3) a more
detailed spreadsheet of the sub-items contained in the Florida evidence spreadsheet. A couple things to note:
These spreadsheets now indicate the Protective Order designation, if any, for each item to be reviewed. As you will
see, there are three mini-VHS tapes that I need to double check before assigning a final designation. I expect to be
able to access a mini-VHS cassette player later this week, at which point I will be able to provide an updated
spreadsheet with a confirmed designation for those three items. Additionally, please note that there is one item
about which we plan to provide you with a letter later this week.
These spreadsheets also indicate where each item will be made available for the defense to review. As you will see,
we have now learned that one item (consisting of shredded paper) is currently at FBI headquarters and will not be
available for review next week. Please let me know if you believe you need to review that item, and I will inquire as
to whether and how it can be relocated to New York. Additionally, all 1D items consist of electronic data (as
opposed to 1B items, which are physical items). As is noted in the spreadsheets, the electronic data that constitute
the 1D items in this case have either already been produced to you in discovery (e.g., pen register data, GPS data,
and aerial footage), or are digital recordings of interviews that will be produced as non-testifying witness
statements. Because these 1D items are data files stored in the FBI system, there is no corresponding physical item
to produce for you to review.
Please let me know when you would like to schedule a time for a smaller group from the defense team to review evidence
at the Bronx warehouse.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
)
Sent: Monday, April 5, 2021 10:48 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
EFTA00015773

=== Page 5 ===
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Laura,
Thank you for your email and for your understanding as we work through the logistics of arranging this review. Your
modifications and clarifications are acceptable to us. Below I address each specifically:
The FBI can arrange for a lawyer, investigator, and paralegal to inspect and photograph the precluded items at the
Bronx warehouse either next week or the week after. Please let us know what day you would like to arrange for
that inspection, and I will coordinate with the FBI accordingly. I would suggest trying to schedule this visit early
next week if possible so that if there are items that you believe need to be produced to 500 Pearl Street, we will
have time to do so during a subsequent day of review at 500 Pearl if the FBI agrees to transport the item(s).
Tomorrow, I will send you evidence spreadsheets with annotations of which items the FBI will not be producing to
500 Pearl Street, and which items we are designating under the Protective Order. Please note that certain items
will be designated "Confidential," in which case they may be photographed, but the photographs should be treated
as Confidential under the Protective Order. Other items will be designated "Highly Confidential," in which case they
may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to
photograph this latter category because some Highly Confidential evidence items include both nude and non-nude
portions, in which case we would permit photography of the non-nude portions.
In light of our decision to produce non-testifying witness statements beginning on April 12, 2021, we are no longer
segregating any electronic media that contain witness statements during this review. This is because all of the
witness statements on the electronic media in the FBI's possession are from witnesses whom the Government does
not expect to call at trial in this case. Please note that we intend to produce digital audio files to you containing the
contents of the electronic media with these non-testifying witness statements, but you are of course welcome to
review the original recordings themselves.
In terms of space, I have been informed that we will not be permitted to conduct this review in a courtroom and
will instead be required to do so in the proffer rooms. I have reserved the two largest proffer rooms available at
500 Pearl. We can use the largest proffer room for evidence review, and the slightly smaller proffer room as a
private meeting space for the defense team.
Confirmed, I will ask the FBI to bring all electronic highly confidential images to 500 Pearl Street, including the
2,100 that were not previously reviewed and the electronic images that were previously provided for review at the
MDC.
Confirmed, I will ask the FBI to bring the 7 hard-copy highly confidential materials to 500 Pearl Street.
As I mentioned earlier today in a separate email, the FBI and AUSAs are prepared to facilitate this review beginning April
13th and continuing every day thereafter until your review is complete. I have also formally requested that the Marshals
produce Ms. Maxwell to 500 Pearl Street on April 13th and every day thereafter until the review is complete. The
Marshals previously confirmed their willingness to produce Ms. Maxwell for such a review in general, but they have not
yet confirmed their ability to do so on any particular dates. I will let you know as soon as the Marshals inform me
whether they can accommodate these specific dates.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00015774

=== Page 6 ===
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Friday, April 2, 2021 5:36 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you for your email. Your proposal is largely acceptable to us, with the following modifications and clarifications.
For the items that you propose below to exclude from the evidence transported to 500 Pearl Street (with the
exception of the cash held at 26 Federal Plaza), we will need to have access for a lawyer, investigator and paralegal
to inspect and photograph those items at the Bronx warehouse. This seems to include the bulky items, electronic
devices and "fragile" items.
Once they are photographed and shared with the team and our client, we can decide whether a separate
inspection by our client and/or any expert is necessary at a later time. To be clear, the government's photos
of these same items are insufficient.
If there are any items we are not permitted to photograph (and perhaps you will be able to tell us by April 5
which those are), we likely will need to have those transported because there is no way for our client to
inspect the evidence. We can wait to finalize this issue until you have finished deciding what items you
consider non-photographable, and if we can't agree, then discuss next steps.
Please let us know when these "non-transportable" items can be inspected and photographed at the Bronx
warehouse. It makes sense that it would be done soon so that we can raise any issues as necessary with the
Court.
For playing any of the electronic media, we will obtain the necessary equipment to play at 500 Pearl Street and
seek permission to bring those devices into the Courthouse. You can segregate out the section of recordings that
contain "witness statements" and advise us then which ones cannot be played, but we still need to inspect the
outside of those recordings.
As far as space, can you please advise whether the largest proffer room will be available for review of evidence? It
is my understanding that it can accommodate a large number of the team members at one time. If not, is a locked
courtroom available for us to review the evidence? The agents could bring out a limited number of boxes at a time
for inspection.
We understand that the evidence will not be taken outside of the monitoring of the agents or your staff and
appreciate that you will have a separate room for us to consult with our client privately (without the evidence).
We understand that all of the highly confidential materials, including not only the 2,100 images not previously
disclosed as well as the electronic images that were only shown to NY counsel and the client at the MDC, will be
available for review on a singular laptop at 500 Pearl Street.
We also understand the 7 hard-copy highly confidential materials will also be available for inspection at 500 Pearl
Street.
Please let me know if you have any questions or disagree with my understanding. If you agree, we can then proceed as
scheduled on April 12 and continue day to day until we are finished, with a break if necessary for the arraignment.
Laura A. Menninger Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
EFTA00015775

=== Page 7 ===
From:
Sent: Saturday, March 27, 2021 4:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
>;
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell 20 Cr. 330 (AJN) Request to view evidence, highly confidential materials, scenes
Counsel,
Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with
arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will
also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12th.
Physical Evidence
It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are
certainly willing to work with you to ensure that your client can review any physical items that are material to the
preparation of her defense.
We would propose excluding the below items from production to 500 Pearl:
We appreciate your note that the massage tables are not needed, which will certainly help with the logistics
of transport.
We also appreciate your indication that the cash items from 26 Federal Plaza do not need to be produced.
Those are the only items not located in the Bronx warehouse.
The FBI has seized dozens of electronic devices, including desktop computers, servers, and laptops, from
Jeffrey Epstein's residences in 2019. Photographs of those devices were produced in our August 2020
productions as part of the search warrant photographs, and you have received copies of the data that was
seized from those devices pursuant to a warrant. The production of these devices would be very
cumbersome, and we do not see any value in looking at an electronic device that cannot be turned on.
The framed pictures are bulky and cumbersome to transport. These are also very delicate and are difficult
to transport. Photographs of those seized images were already provided to you as part of the photographs
from the searches of Epstein's residences.
Certain items seized from the New York residence are bulky, fragile, and/or difficult to transport. These
include plaster busts of female torsos and a stuffed dog. Photographs of these items were already provided
to you from the search of the New York residence.
The remaining physical items of evidence would fit into approximately 15 to 20 boxes. The FBI has indicated that it
would be feasible to transport those boxes to 500 Pearl Street.
Regarding your request for equipment that can play the recordings, we believe they would require a VCR, a cassette
player, a CD player, an adapter for a micro VHS tape, and a microcassette player. If you wish to play these
recordings at 500 Pearl, you will need to provide that equipment. We have asked the FBI whether any other
equipment would be necessary and will let you know if that is the case prior to the date of your review. It is our
understanding that any recordings that are not witness statements and that are not highly confidential have been
produced to you in discovery. We are not aware of any discoverable, non-highly confidential, recordings that were
not produced to you as part of the Government's discovery productions in the fall. To confirm that understanding,
we are working with the FBI to physically doublecheck each recording. If we identify any discoverable recordings
that have not already been produced, we will promptly provide them to you.
The segregation of highly confidential material will require the FBI and an AUSA to physically review each item to
confirm the item's status. We will endeavor to do so by your requested date of April 5, 2021.
EFTA00015776

=== Page 8 ===
We can confirm that neither the AUSA(s) nor the agent(s) will record or attempt to record any part of the evidence
review or conversations among the defense team or with the defendant during this review. Although the evidence
cannot be left outside of the presence of an agent, we will ensure that a room is available for the defense team and
the defendant to confer privately away from the agent(s) and the AUSA(s) without monitoring.
As for your request for a space large enough to fit 8 members of the defense team, the defendant, an agent, an
AUSA, and the evidence, my office cannot control the space that the Marshals allow us to use at 500 Pearl outside
of the proffer rooms. We will certainly request as large a space as possible, but if we are required to use the
proffer rooms, then members of the defense team may need to rotate in and out of the room. I know members of
the defense team have been in those proffer rooms before, and they can hopefully provide some thoughts on how
we might use the proffer room space effectively for your purposes. If the Court grants authorization for the
defense to bring electronic devices into 500 Pearl, that is certainly fine with the Government, and you may note our
consent in your request to Judge Nathan for such authorization.
Highly Confidential Electronic Images
The 2,100 electronic images were recovered during the responsiveness review of images and videos seized from
Jeffrey Epstein's devices, which review was not complete until early November 2020. We indicated on page 4 the
cover letter to our November 9, 2020 production, which included all other images and videos from those devices,
that "the Federal Bureau of Investigation ('FBI') seized multiple nude and partially nude images from several for the
above-listed electronic devices. All such images have been designated Highly Confidential. The FBI will make these
images available for review by the defense upon request." We did not receive a request from the defense to review
these images until your March 8, 2021 letter, which requested to "view and inspect all materials designated by your
office as 'Highly Confidential' under the terms of the Protective Order".
We did not ask the FBI to bring the 7 hard copy images to the MDC in the fall because we did not understand you to
be requesting a review of physical, non-electronic evidence during those meetings. Our understanding of the
defense request at that time was to review the electronic highly confidential images that were recovered from CDs
from Epstein's residence. We will ensure that the 7 hard copy images are available to you for review at 500 Pearl.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 22, 2021 5:19 PM
To:
is
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
We have considered your proposal. Unfortunately, it does not permit us an adequate ability to review the evidence in the
case and does not permit our client to meaningfully participate in her own defense.
EFTA00015777

=== Page 9 ===
First, we are unable to meaningfully review the evidence without the benefit of our laptops and other electronic devices
which are needed to take notes of our review. We also need access to our devices during the review to compare the
physical evidence with the electronic discovery and with our work product.
Second, we need to provide our client the ability to review all discovery, including any recordings, in order to assist in her
own defense. Presuming that she will not be taken to the FBI downtown office, then your proposal offers no means by
which she can both inspect a recording in its physical form and listen to the recording at the same time.
In order to address the deficiencies in your proposal, we believe the following are necessary:
Physical Evidence
All of the physical evidence currently located in the FBI Bronx warehouse will be transported to 500 Pearl Street
and made available during the week of April 12, with our client present, in a room sufficiently large to
accommodate 8 attorneys and investigators.
We do not need the "bulky" massage tables transported; if there are any other extremely large evidence
pieces, let us know what they are and we can consider whether we can have someone review and
photograph those at the Bronx warehouse at an earlier time.
From your email, it appears that only two items are not located at the Bronx warehouse - both envelopes
with cash. Please confirm this. We do not need the two "cash" evidence items transported to 500 Pearl.
If there are other evidence items housed somewhere other than the Bronx, please let us know what they are
and where they are.
We will be permitted to bring our laptops, and a camera, into 500 Pearl Street; we are happy to seek permission
from Judge Nathan to do so.
Either the FBI can provide the equipment necessary to listen to any of the recordings at 500 Pearl Street or we can
bring the necessary equipment. If we are to provide the equipment, we will need to know in advance the formats
of each recording so that we can be prepared. You can note that on your Excel spreadsheet by the item number by
March 29 to give us adequate time to secure the necessary equipment.
The FBI can segregate any physical evidence that you deem "highly confidential." You can identify any "highly
confidential" physical evidence items on your Excel spreadsheets by April 5 (one week before the evidence view). If
we need to photograph or reproduce any such item for expert evaluation, we will seek leave of court. Otherwise,
we will not photograph any such items during the review during the week of April 12. This will ensure the evidence
review proceeds smoothly and there will not be any need to ask permission to photograph on an item by item
basis.
The FBI also can segregate any recordings which we will be able to inspect, but not listen to, during the evidence
view the week of April 12. You can note such designation on your Excel spreadsheet. If we disagree, we can seek
leave of the Court in advance.
We understand that an FBI Agent and/or AUSA may be present during our physical evidence review at 500 Pearl
Street but of course must ensure that no recordings are made of our conversations and also ensure that there is a
separate, secure room in which we can confer with our client during the evidence view without monitoring by the
government.
Please confirm whether all electronic recordings (other than the highly-confidential images and videos described
below) have previously been produced to us, and if not, please explain which ones were not produced by the
discovery deadlines last fall and why.
Highly Confidential Electronic Evidence
Can you please explain why 2,100 + 7 "highly confidential" images have not been shared with us yet? It was our
understanding that you previously provided all "highly confidential" images to our client - and to defense counsel -
for review at the MDC in November. We are confused about where these previously undisclosed items were
located and why they have not yet been made available for inspection and review.
During the week of April 19, Ms. Maxwell should be produced to 500 Pearl Street to review (with counsel and a
defense staff member, on the 1 laptop provided) all of the 5,507 electronic images and video marked "highly
confidential". These should be segregated into the three categories you describe (never-before produced,
previously produced, and the 7 hard-copy images).
EFTA00015778

=== Page 10 ===
Please let us know if you will not agree to any of these steps so that we can address the issues with the Court.
Thank you.
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
)
Sent: Tuesday, March 16, 2021 4:40 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
All,
Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding
discovery cover letter. We are sending a copy of these files to the MDC for your client as well.
In response to your questions, the FBI has informed me of the following:
Regarding the Highly Confidential nude/partially nudge images to be reviewed at 500 Pearl:
There are three categories of these images:
Approximately 2,100 electronic images and videos seized from Epstein's electronic devices (which have not
been previously provided to you)
Approximately 3,400 electronic images from discs seized from Epstein's residences in 2019 (which have
previously been provided to you and your client for review at the MDC)
Approximately 7 hard copy nude images located in the file from the FBI Florida office's investigation of
Epstein (which have not been previously provided to you)
The FBI will make all three of those categories available to you. The electronic files will be provided on hard drives,
and the FBI will provide you with the hard copy images for review as well.
All electronic images should be viewable as thumbnails, except those seized from Apple devices, which must
be viewed using Cellebrite.
The Cellebrite software will be provided on the drive for your review of images and videos seized from Apple
devices.
The electronic files have the same metadata on the hard drive that was available when the FBI seized each
image. For images that were carved or deleted, no metadata was recovered, so none is viewable. For all
other images, the metadata recovered should be viewable on the hard drive.
The approximately 2,100 electronic images and videos seized from Epstein's devices are separated by folder
to indicate which device each image was seized from.
Because these images are considered obscene material, the FBI is not permitted to make duplicates of them, and
there is a limited number of clean laptops on which these images can be reviewed. As a result, the FBI is only able
to provide a single laptop for review of these images.
Regarding the physical evidence:
Attached are two lists of all physical items in the FBI's custody relating to this case. The first list relates to items
associated with the FBI Florida office's investigation of Epstein. The second list relates to items associated with the
FBI New York office's current investigation.
The vast majority of physical evidence in the FBI's custody is located at the FBI's warehouse in the Bronx. Two
items (1B 77 & 1B 79) are located at 26 Federal Plaza, but the case agents can check those items out from 26
EFTA00015779

=== Page 11 ===
Federal Plaza and bring them to the Bronx warehouse on whatever day you choose to conduct your review so that
you will have all evidence in one place.
The FBI is able to arrange for the defense team to review all physical evidence at the Bronx warehouse under the
following conditions:
The warehouse requires at least two weeks' notice in order to pull all of the items for the entire case and
place them in a location where a large group of people can view them.
The warehouse is open during normal business hours between 9am and 5pm on weekdays.
At least two FBI agents and an AUSA will be present at the Bronx warehouse to assist and answer questions.
The evidence will be placed in a loading dock at the warehouse to provide additional space for the review.
To ensure that there is sufficient space, please let me know how many members of the defense team intend
to be physically present for this review.
Electronic devices such as cellphones and laptops are not permitted in the warehouse. The defense team
may bring a digital camera that is not connected to the Internet or a cellular network into the warehouse. If
the defense team wishes to photograph an item of evidence, the defense will need to inform the agents who
are present, so that they may confirm that the photographed item is not Highly Confidential based on the
presence of nudity.
Electronic media such as VHS tapes, cassette tapes, and CDs will not be playable at the warehouse.
To the extent the defense requests that the FBI bring any physical items to 500 Pearl Street for your client to review,
the FBI is prepared to bring items that are reasonably sized to 500 Pearl Street. With respect to bulky or large
items, the defense team should be able to photograph those for your client to review, unless they are deemed
Highly Confidential, in which case the FBI can make arrangements to transport the item to 500 Pearl Street if
necessary.
The FBI is in the process of confirming that it can provide devices to play all of the electronic media in the case in a
single location at the FBI's offices in downtown Manhattan. We are also double-checking to confirm that all media
that does not contain witness statements have already been produced to you and your client in discovery. The FBI
anticipates that we can arrange for you to review all non-witness statement electronic media at the FBI's office in
downtown Manhattan in approximately three weeks.
To the extent you wish to review all of the discs containing photographs, which were seized from Epstein's
residences in 2019, we note that all of those images have already been produced to you in discovery. For
your awareness, the FBI has informed me that it took their team several weeks to review all of the images on
all of those discs.
Please let me know how you wish to proceed.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Monday, March 15, 2021 6:00 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
-
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
EFTA00015780

=== Page 12 ===
Laura,
I expect to be able to answer all of your questions about the evidence review by tomorrow.
We have been looking into the discovery request you made last week, and we hope to have a response ready to provide
to you by next week.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 15, 2021 3:01 PM
To:
is
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: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of
when you would have answers, it could help me answer your question.
At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the
attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their
evidence when they seized it from NY and LSJ, so I don't think we need to wait for them to now prepare an inventory
before we start reviewing evidence.
Also, when do you believe you will have a response regarding the discovery I requested last Monday?
Thanks,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
lmenninger@hmflaw.com
From:
Sent: Friday, March 12, 2021 11:44 AM
To: Laura Menninger <lmenninger@hmflaw.com>;
is
(USANYS)
EFTA00015781

=== Page 13 ===
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you
asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait
until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review
the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those
highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all
of your questions about those images before that date, and I do not know whether you will also be able to visit the
evidence vault that same week.
Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
Thank you,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, March 9, 2021 4:56 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does
not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020
discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office
during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range
SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the
physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00015782

=== Page 14 ===
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 3:44 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Thank you. Is that the only index of physical evidence available?
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue | Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
Sent: Tuesday, March 9, 2021 1:38 PM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel,
In advance of our call tomorrow, I wanted to send a copy of the attached index of physical items in FBI custody from the
FBI-Miami office, which we previously produced to you as part of our August 21, 2020 discovery production. Also
included in that August 21, 2020 production were scans of numerous items listed on the index. Those scans can be found
within Bates range SDNY_GM_00172218-SDNY_GM_00173007. It may be useful to reference some of those items during
our conversation tomorrow, so I wanted to make sure you were aware of them.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00015783

=== Page 15 ===
From:
Sent: Tuesday, March 9, 2021 2:03 PM
To: 'Laura Menninger' <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Yes, that works for us, thank you very much. We can use the below dial-in:
Dial-in:
Code:
Best,
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Tuesday, March 9, 2021 11:19 AM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
We are free at 1:30 p.m. ET / 11:30 a.m. MST tomorrow. Would that work? We are generally free thereafter, so please
suggest another later time if not.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+1 303 831 7364 (Office)
Imenninger@hmflaw.com
From:
)
Sent: Tuesday, March 9, 2021 8:36 AM
To: Laura Menninger <Imenninger@hmflaw.com>;
)
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: RE: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Good morning,
It would be helpful to have a call to discuss the requests contained in this letter. Are there times tomorrow when you
would be available to speak, please?
Thank you,
EFTA00015784

=== Page 16 ===
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: Laura Menninger <Imenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
is
V.
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00015785


c1: EFTA00016204
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016204.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: FW: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Wed, 03 Nov 2021 20:12:00 +0000
Attachments: Bail_Application_11321.pdf.
From: BOBBI c STERNHEIM
Sent: Wednesday, November 3, 2021 4:08 PM
Cc: Christian Everdell
; Laura Menninger
; Jeff Pagliuca
Subject: [EXTERNAL] U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Courtesy copy of this afternoon's ECF filing-
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be
confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
On Nov 3, 2021, at 12:48 PM, BOBBI C STERNHEIM
> wrote:
Courtesy copy of today's ECF filing.
<Disclosure of Juror Names to Counsel Only upon completion of Questionnaire.pdf>
EFTA00016204

=== Page 2 ===
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be
confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
EFTA00016205


