# docs_fts_content

c1: EFTA00032809
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032809.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Jeff Jocks <jjocks@sondeeracine.com>
To:
)"
Subject: [EXTERNAL] Re: Subpoena to Interlochen Center for the Arts
Date: Mon, 25 Oct 2021 14:08:43 +0000
That works.
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, October 22, 2021 at 2:45 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Thanks very much. Let's plan to talk at 1 p.m. on Monday, if that works.
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 22, 2021 1:55 PM
To:
Subject: [EXTERNAL] Re: Subpoena to Interlochen Center for the Arts
Monday afternoon works. Today is shot.
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
EFTA00032809

=== Page 2 ===
From:
)"
Date: Friday, October 22, 2021 at 1:25 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Are you available for a call today or Monday to follow up on our conversation about a records
custodian testifying at trial?
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, May 14, 2021 10:50 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
I just reached out to Interlochen and they do not have a color version.
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, May 14, 2021 at 10:38 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Received, thanks very much Jeff. Do you have a color copy of the photograph on page 87?
Best,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, May 13, 2021 4:41 PM
EFTA00032810

=== Page 3 ===
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
Attached is what went in the mail today.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Wednesday, May 12, 2021 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
II
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on this.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Monday, April 26, 2021 10:32 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm working on it and hope to have it complete and ready in the next couple of days.
Thanks,
Jeff
EFTA00032811

=== Page 4 ===
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Monday, April 26, 2021 at 9:28 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Could you please let us know when you expect to produce these materials?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, March 26, 2021 5:33 PM
To:
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Just confirming receipt. Also, I'm hopeful that we can have everything gathered by April 12th. However, l'll be out of the
office for the next week so it might be delayed. Will that be a problem?
In addition, and just for confirmation's sake, you are ok that we will make reasonable efforts to notify the
parents/students of the subpoena prior to compliance with the subpoena correct?
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
EFTA00032812

=== Page 5 ===
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, March 26, 2021 at 3:37 PM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
Thanks again for taking the time to speak with me this morning. As we discussed, I'm attaching a subpoena for additional
student records.
Thank you,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:41 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Sounds good. Yes, that is the best number.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Thursday, March 25, 2021 at 4:40 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
EFTA00032813

=== Page 6 ===
Thanks so much-let's plan to talk at 9:30 tomorrow morning, if that works for you. Is this the best number to reach you
then: 231-947-0400
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, March 25, 2021 4:32 PM
To:
)
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
I'm available between 9am and 10am, and then again after 11am.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, March 25, 2021 at 3:41 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. Are you available for a quick call tomorrow morning?
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, January 7, 2021 11:10 AM
To:
Cc:
)
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
EFTA00032814

=== Page 7 ===
231-947-0400
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you are
not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, January 7, 2021 at 10:37 AM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff- what is the best number to reach you this morning? Thanks.
Sent from my iPhone
On Jan 5, 2021, at 3:21 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
That works for me.
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
II
)"
Date: Monday, January 4, 2021 at 8:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
EFTA00032815

=== Page 8 ===
Subject: Re: Subpoena to Interlochen Center for the Arts
That would be great, thanks. Would Thursday at 11:30 work for you?
Sent from my iPhone
On Jan 4, 2021, at 3:50 PM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Sure. Does Wednesday or Thursday morning work?
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, January 4, 2021 at 1:02 PM
To: Jeff Jocks <jjocks@sondeeracine.com
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Are you available for a call sometime in the next few weeks? We have one or two follow up
questions that would be helpful to talk through.
Thanks,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, December 30, 2020 2:37 PM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
Sorry about the delay. Interlochen doesn't have any other documents regarding tuition payment information or
payments by Epstein or Epstein entities.
Let me know if you have any other questions.
EFTA00032816

=== Page 9 ===
Thanks,
Jeff Jocks
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Monday, December 7, 2020 at 11:27 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Just checking in on the below.
Thanks,
From:
Sent: Monday, November 16, 2020 3:28 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
is
(USANYS)
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Hope you're doing well. I'm following up on our conversation from earlier this month to see if you have any updates on
the categories of documents we discussed.
Thanks very much,
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Friday, October 30, 2020 11:15 AM
To:
Cc:
is
(USANYS)
Subject: Re: Subpoena to Interlochen Center for the Arts
That works for me. I will call in at 10am Monday.
EFTA00032817

=== Page 10 ===
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of the
addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law. If you
are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Friday, October 30, 2020 at 11:13 AM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
(USANYS)"
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi Jeff,
Thanks very much. Would a call on Monday at 10 a.m. work for you? If so, we can use this conference line:
Thanks,
Sent from my iPhone
On Oct 30, 2020, at 9:06 AM, Jeff Jocks <jjocks@sondeeracine.com> wrote:
Hi
I'm happy to have a call. I'm available Monday all morning, Tuesday until 10:30am and Wednesday all morning.
I apologize about not getting back with you. I thought the other attorney that filed the response was going to do so.
Regardless, the response included everything that Interlochen has. They only keep tuition payment information for 7
years and nothing in their files reflects any payments by Epstein or Epstein entities.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
EFTA00032818

=== Page 11 ===
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
)"
Date: Thursday, October 29, 2020 at 6:20 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
II
>,
(USANYS)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff,
I hope you are doing well. We still have not received a response to our inquiry from April of 2020. Would you be
available for a call with our team next week to discuss, please?
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From:
Sent: Wednesday, April 8, 2020 1:46 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Subject: RE: Subpoena to Interlochen Center for the Arts
Hi Jeff,
No, I don't think you responded. Totally understandable given everything that has gone on in the last month. I'd still
be grateful if you could get back to me on this point, please.
Hope you are also staying safe and healthy.
Thanks,
Assistant United States Attorney
EFTA00032819

=== Page 12 ===
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Wednesday, April 8, 2020 1:20 PM
To:
)
Subject: Re: Subpoena to Interlochen Center for the Arts
Hi
-
Did we ever respond to you on this question? Things have gotten so complicated that I can't remember or
determine.
Hope you are staying safe and healthy.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
"
)"
Date: Sunday, March 8, 2020 at 3:04 PM
To: Jeff Jocks <jjocks@sondeeracine.com>, "Donnini, George B." <donnini@butzel.com>
Cc:
)"
>,
)"
Subject: RE: Subpoena to Interlochen Center for the Arts
Jeff and George,
Thank you both very much for your assistance in response to our subpoenas seeking records from Interlochen. In
reviewing the documents you produced in response to the attached subpoena, a follow-up question arose. Would
you please confirm that your production included all records of any tuition payments that Epstein (or his entities)
made for any students at Interlochen?
Our team is also happy to discuss this inquiry over the phone if that would be useful. I am starting a trial tomorrow
and will have limited availability this week, but my colleagues
and
(both cc'd) should be
able to coordinate with you as needed.
EFTA00032820

=== Page 13 ===
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
From: Jeff Jocks <jjocks@sondeeracine.com>
Sent: Thursday, February 6, 2020 2:46 PM
To:
)
>
Cc:
>;
Subject: Re: Subpoena to Interlochen Center for the Arts
-
Receipt confirmed.
Thanks,
Jeff
Jeffrey L. Jocks
Sondee, Racine & Doren, PLC
310 West Front Street, Suite 300
Traverse City, Michigan 49684
231-947-0400
jjocks@sondeeracine.com
www.sondeeracine.com
CONFIDENTIALITY NOTICE: The information contained in this email and any attachments is intended for the use of
the addressee only. Its contents may be privileged, confidential, and exempt from disclosure under applicable law.
If you are not the named addressee, please delete it immediately. Thank you.
From:
II
)"
Date: Thursday, February 6, 2020 at 1:51 PM
To: Jeff Jocks <jjocks@sondeeracine.com>
Cc:
)"
>,
)"
Subject: Subpoena to Interlochen Center for the Arts
Jeff,
As discussed, attached please find a subpoena addressed to Interlochen seeking information regarding Jeffrey
Epstein and Ghislaine Maxwell. Per our conversation, we understand that Interlochen will keep this request
confidential.
EFTA00032821

=== Page 14 ===
Please let me know if you have any questions or would like to discuss further.
Best,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
212-637-2324
EFTA00032822


c1: EFTA00033469
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00033469.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
U.S. Department of Justice
TENANT
Federal Bureau of Prisons
Metropolitan Correctional Center
New York, NY 10007
Institution
OPI: Correctional Services
NUMBER: NYM 5500.14b
Supplement
DATE: November 13, 2014
SUBJECT: Inmate Accountability
1.
PURPOSE: To outline the responsibility of all employees in the area of inmate accountability.
Additionally, it is to establish and implement specific supervision and count procedures which will
ensure the accountability of all inmates at all times. It will also explain the pass system which is
designed to assist the employee in carrying out that responsibility. This institution supplement must be
read in conjunction with national policy.
2.
DIRECTIVES AFFECTED: Institution Supplement 5511.06G dated June 18, 2007, is rescinded.
P.S. 5500.14 Correctional Services Procedures Manual, dated 10/19/2012 is referenced.
3.
POLICY: To ensure that all inmates are supervised and accounted for according to their custody
classification.
IMPLEMENTATION AND PROCEDURES:
4.
RESPONSIBILITY: Employees will be knowledgeable of proper inmate accountability procedures.
Accountability will be maintained by census checks and accurate counts.
A.
CUSTODY: Refers to the degree of staff supervision required for an individual inmate.
B.
CONTROL CENTER: The records are maintained in the control center. When an inmate arrives
at the institution, R&D staff will be responsible for making picture cards of inmates for the
Control Room records, in addition to the bed book and unit cards. The Control Room Officer
will document records of all inmates in the institution by utilizing a pp30, daily sanitized roster.
A photo of the inmate, with the inmate's name and register number will be on the card from
R&D. Additionally, the following information will also be maintained by using a sentry roster,
PP30 with these codes keyed in this order: reg, In, qtr, wrk, prd, cus, 2. This roster is to be
generated daily and placed in the 30 day file.
A.
job assignment
B.
housing assignment
C.
custody
D.
sentence information
E.
other necessary security and control information, or special conditions.
Sensitive But Unclassified
SDNY_00008371
EFTA00033469

=== Page 2 ===
NYM 5500.14a
Inmate Accountability
Page 2
5.
COUNTS: The utmost precaution should be utilized when staff are conducting a count. Staff are to
ensure they are observing a real person and not a "DUMMY". When conducting a count, the staff
members will ensure that they personally observed breathing human flesh for each inmate
counted. All counts shall be double counted by two staff members and both staff shall print and
sign their names to the count slip. Inmate details of more than five inmates shall also be double
counted. Official counts will be conducted at the following times:
12:00 AM
3:00 AM
5:00 AM
10:00 AM (Weekends and Holidays, only)
4:00 PM
10:00 PM
The 4:00 PM, 10:00 AM and 10:00 PM counts are MANDATORY STAND-UP COUNTS.
The master count sheet is obtained using Sentry transaction PPE1. In the event that SENTRY is
down, the Control Room Officer shall prepare an error free master count sheet (Attachment 1).
At a minimum, two officers will count each unit. One officer will count while the second officer
stands in a position to observe the movements of inmates. Upon the completion of the first
count, the officers will change positions and the second officer will count. At the end of the
second count, the count will be called into the Control Room for acceptance. There will be no
movement of inmates during the count. While counting, officers will not permit anything short
of an emergency to distract them. The officers who conducted the count will remain in the area
until the count has been cleared by Control. When counting at night, flashlights should be used
judiciously, but enough light should be shown on the inmate as to leave no doubt that the officer
is counting a breathing living human body.
A.
LOCK-DOWN ACCOUNTABILITY CHECK: A lock-down accountability check will be
conducted at this institution a minimum of once per month. The accountability check will be
announced over the public address system at a random time and date with no prior notification to
the various departments. This procedure is used to determine if inmates are authorized to be in
the respective areas.
Although not designed to be strictly a head count, every effort should be made to arrive at a total
institution head count. If this is not accomplished within a reasonable length of time, the Warden
may resume normal operations with the understanding there is an accountability problem which
needs to be corrected.
Upon hearing the announcement for an accountability check, staff will secure all entrance and
exits. No inmate movement will be allowed following the announcement. Staff members will
Sensitive But Unclassified
SDNY_00008372
EFTA00033470

=== Page 3 ===
NYM 5500.14a
Inmate Accountability
Page 3
survey their areas of supervisory responsibility and verify that only authorized inmates are
present.
The following information will be gathered from each area and reported to the Lieutenant's
Office. This form is to be reproduced locally from the Correctional Services Manual
(Attachment 2).
1.
Total number of inmates present who are authorized.
2.
Total number of inmates present who are unauthorized, including names and register
numbers.
3.
The total number of inmates who are unauthorized to be missing, including their names
and register numbers.
The above information will be placed on the Lock Down Accountability Check form and the
form will be submitted to the Lieutenant's Office immediately. A Lieutenant will be responsible
for supervising the accountability check and documenting the results (i.e., time involved,
discrepancies noted, action taken, etc.).
DURING A LOCK DOWN ACCOUNTABILITY CHECK, INMATES WILL BE
QUICKLY LOCATED INTO A CENTRAL AREA AND COUNTED. ALL INMATE
MOVEMENT WILL CEASE AT THAT POINT UNTIL THE CENSUS COUNT HAS
BEEN CLEARED.
Inmates on the elevator will be transported to a safe location where no separatee exists.
B.
BED BOOK COUNTS: The Bed Books will be utilized for emergency counts, bad institutional
counts and random Bed Book counts requested by the Shift Lieutenant. When a unit has two
consecutive bad counts, a bed book count must be conducted. In conjunction with the Bed Book
the unit roster will be used to conduct these counts. Upon receiving a new inmate on the unit, the
unit officer will receive two 3 X 5 cards, one to be utilized for the bed book, and the other to use
for inmate movement. The bed book card is not to be removed from the bed book.
C.
OFFICIAL COUNT FORMS/COUNT SLIPS: All official count forms prepared by the Control
Room Officer will be in ink. The count verification on all official count slips and forms will be
in ink. All count slips are to be prepared in ink without error and forwarded to the Control Room
Officer. Completed count slips, out count sheets, and official count sheets will be retained for 30
days. (Attachment 5)
AT LEAST ONE OFFICIAL COUNT ON THE E/W AND M/W SHIFT WILL BE
TAKEN AND VERIFIED BY A LIEUTENANT ON DUTY.
Sensitive But Unclassified
SDNY_00008373
EFTA00033471

=== Page 4 ===
NYM 5500.14a
Inmate Accountability
Page 4
D.
OUT COUNTS: Out counts will be kept to a minimum. Staff who will have inmates out of
quarters at count time must sign their out count sheet prior to submission to the Operations
Lieutenant for approval, the out count (Attachment 4) must be forwarded to Control Room forty-
five (45) minutes prior to the official count time. All out counts of more than five inmates will
require two staff members to conduct the count utilizing detail cards for identification.
The Control Room Officer will check each out-count sheet by verifying the unit assignment as
reported to ensure accuracy, and notify the Operations Lieutenant of any out count which appears
to have discrepancies. All out counts will be approved by the Operations Lieutenant.
(Attachment 6)
E.
CENSUS CHECKS:
All departments must conduct a census of all inmates assigned to their area and/or detail during
each work period (AM and PM). Census checks will be conducted at approximately 8:30 A.M.
and 12:30 P.M., Monday through Friday. The Control Center will announce over all radio
channels to begin conducting the census. The results of the AM and PM census checks will
documented in the unit officer's log book (ex., Unit 5-South AM Census completed with zero
absent and zero unauthorized). Departments not having a log book will document census check
results on the Summary of Daily Census Form (Attachment 4). This procedure is designed to
determine whether or not inmates are authorized to be in a respective area. The Control Center
will report any discrepancies to the Lieutenant's Office immediately.
F.
LOCKDOWN CENSUS COUNTS:
At the Lieutenant's direction, Control Center will announce over all radio channels a Lockdown
Census Count. The results of this count will be called into the Lieutenant's Office. The Internal
Officer will distribute the Lockdown Accountability Census Detail Form (Attachment 2). All
unit officers and detail supervisors will complete Attachment 2 and forward to the Lieutenant's
Office. This procedure is designed to determine whether or not inmates are authorized to be in a
respective area.
6.
DAILY ACCOUNTABILITY CHECKS: It is the responsibility of the Activities Lieutenant to
inspect, a minimum of 25% of all work details must be conducted per week.
All details must be checked within a 30 day period. A detail roster will be utilized to conduct this
inspection. When inspecting the detail cards, the Activities Lieutenant will look for proper identification
and accurate information on the face of the card.
Sensitive But Unclassified
SDNY_00008374
EFTA00033472

=== Page 5 ===
NYM 5500.14a
Inmate Accountability
Page 5
The Activities Lieutenant will ensure that each inmate assigned to the detail has a card and all inmates
are physically accounted for. The Activities Lieutenant will be required to submit all discrepancies in
writing to the Chief Correctional Supervisor's office. (Attachment 7)
7.
DAILY TRANSFER SHEET: The Control Room Officer will be responsible for generating the Daily
Transfer Sheet Change Sheet, Monday through Friday. The procedure to complete this task is done by
performing Sentry Transaction PPF6, followed by Sentry Transaction PP48. This will delete the Call-
Outs, and Changes from the previous day. The Control Center will maintain a running master base count
worksheet (Attachment 8) that will be used to track and edit all movement in the institution.
After the PPF6 and PP48 are completed then proceed to Sentry Transaction PP39. The PP39 will be all
the Call-Outs and Changes for the proceeding date. The following morning at 0001, the Morning Watch
Officer will perform Sentry Transaction PPF6, with the future date, this will program the future changes
in Sentry. If there are no changes for any given day, on the last page of the call-out, the last remark will
be; Transaction Successfully Completed.
8.
CALL-OUTS: Sufficient copies of the master call-out sheet for distribution to all units will be copied
and forwarded to the Control Center Officer so that the Morning Watch Control Center Officer can place
one in each detail pouch. Extra copies of the call-outs will be placed at the detail pouch cabinet. Unit
officers will post the call-out in the housing units.
The employee who places an inmate on call-out must ensure the requested inmate arrives at the specified
time. If the inmate does not arrive as scheduled, the requesting staff member shall contact the staff
member responsible for the inmate's accountability. It is the responsibility of the staff member or
department to prepare an incident report for inmates who fail to report for a call-out or is found to be in
an unauthorized area. If efforts to locate the inmate fail, the inmate shall be immediately reported to the
shift lieutenant as missing and appropriate action initiated to locate the inmate.
9.
PASS SYSTEM: MCC New York does not utilize a pass system for inmate movement. With the
exception of work calls and scheduled mass movement, inmates within the confines of the institution
will be escorted by a staff member with the use of a picture on a 3x5 card.
A.
GATE PASSES: All gate passes must contain the following information: Inmate's picture,
custody classification, work assignment, offense, and sentence. Each card shall be signed by the
Chief Correctional Supervisor and the Associate Warden responsible for Correctional Services,
each card will also be stamped with an imprint seal and laminated for durability. The imprint
shall cover a portion of the inmate's picture to prevent tampering with the gate pass. The Chief
Correctional Supervisor will maintain accountability of blank gate passes. When a decision is
made to permanently remove an inmate's gate pass, the Chief Correctional Supervisor will
forward the gate pass to the Cadre Unit Secretary for proper disposal. The Cadre Unit Secretary
will keep a log accounting for the issuance and disposition of all gate passes.
Sensitive But Unclassified
SDNY_00008375
EFTA00033473

=== Page 6 ===
NYM 5500.14a
Inmate Accountability
Page 6
Gate passes will be maintained at the rear entrance during normal working day operations,
Monday through Friday. After hours and on weekends, the passes will remain in the Control
Center Officer.
If a discrepancy is identified with a gate pass, the gate pass will be removed and forwarded to the
Chief Correctional Supervisor with a written explanation describing the discrepancy.
10.
DETAIL CREW KITS: Detail cards will be maintained by the Control Room Officer. At a minimum,
crew kit cards shall contain the following: inmate's name and register number, current photo (a new
photo must be made whenever an inmate's appearance changes), job assignment, housing assignment,
custody level, and any special conditions. Crew kits will be picked up by all Departments at the
beginning of the shift.
A chit will be used for accountability of crew kits. Detail supervisors are held responsible for inmates
whose cards are included in the respective crew kits, and for accountability of the crew kit while checked
out from the Control Center Officer. A Lieutenant will monitor this procedure for compliance. The
crew kits will include a SENTRY printout of the specific detail roster. All crew kits will be returned to
the Control Center Officer at the end of the work day; all cards must be included in the crew kit. Inmates
shall never be allowed to handle detail/crew kit cards.
The Morning Watch Control Center Officer will receive the SENTRY transactions from the Control
Room Officer; this will include the Daily /Transfer sheet (PP39) and SENTRY Detail Roster.
All inmates' current job, housing, and custody assignments will be updated daily by the Morning Watch
Control Center Officer. The Morning Watch Control Center Officer will place the new detail roster into
the detail pouches daily. This roster will inform the Detail Supervisors of any changes which may affect
an inmate's status on his crew.
The Morning Watch Control Center Officer will perform the following tasks:
a.
Insert any new detail cards into the appropriate kit.
b.
Remove any detail cards of inmates who have transferred out of the institution or have
been removed from that detail. These cards will then be forwarded to the Lieutenant's
Office.
c.
Check each detail to ensure that each inmate on the SENTRY roster has a picture card in
the crew kit.
d.
Audit all detail pouches and note any discrepancies. Submit written report of detail
pouch audit. (Attachment 9)
The morning watch Operations Lieutenant will ensure that the above is accomplished.
Sensitive But Unclassified
SDNY_00008376
EFTA00033474

=== Page 7 ===
NYM 5500.14a
Inmate Accountability
Page 7
11.
CHECKING OF DETAILS: The Detail Foreman will provide supervision of his/her detail at all times.
The Detail Foreman must have a detail card for each inmate assigned to that detail. If a detail card is not
present the Detail Foreman will be responsible for replacing any missing detail card(s). Detail Foremen
will obtain any missing detail card(s) from R&D. Detail Foremen will check their detail cards at the
beginning of the work day and after lunch to determine if all inmates assigned to that detail are
accounted for. When the detail foremen return their crew kits to the Control Center Officer at the end of
the day they are to ensure that all crew kit cards are present. Detail Foremen will be responsible for
obtaining a new crew kit card, through R&D, and ensuring that all correct information is contained on
the card.
A.
LOAN OF INMATES TO OTHER DETAILS: It is permissible for one detail supervisor to loan
an inmate to another detail within the same department, providing the following requirements are
met:
1.
The inmate meets the custody and physical condition requirements.
2.
The loan must be made on a daily basis for that day only.
3.
The detail card is transferred to the detail supervisor assuming responsibility for the
inmate and returned to the proper pouch at the end of the work day.
12.
WORK CALL: Work Call will be announced at 7:00 A.M. for CMS inmates, and 7:30 A.M. and 12:00
P.M. for all other inmates. The Detail Foreman will report to the unit and escort the inmates to their
work detail. During work call, no inmate will be allowed to leave their assigned units without being
escorted by a Detail Foreman.
The Detail Foreman will present a detail work card to the Unit Officer for each inmate assigned to the
detail. At this time, the Unit Officer may release the respective inmates to the Detail Foreman. If the
Detail Foreman cannot present a work detail card to the Unit Officer, the Unit Officer WILL NOT
release the inmate into the custody of the Detail Foreman.
The Internal Security Officer will run the elevator between the floors that are involved in the move. All
inmates must be at their assigned details and accounted for by the supervisor. The Activities Lieutenant
and a Detail Foreman will be responsible for supervising work calls and work recalls.
13.
WORK RECALL: Recall will be announced at 11:00 A.M. and 3:30 P.M. and 2:30 P.M. for CMS
inmates. At which time all work detail inmates will return to their assigned units. Detail foremen must
escort their details back to their assigned units. If any unescorted inmates arrive at the unit the unit
officer will not allow these inmates to enter the housing unit.
14.
CONTROLLED MOVES: A Lieutenant will call a controlled move to halt all general population
Sensitive But Unclassified
SDNY_00008377
EFTA00033475

=== Page 8 ===
movement. The controlled move is conducted to guarantee that the inmate is closely monitored and kept
kept separate from other inmates.
NYM 5500.14a
Inmate Accountability
Page 8
15.
SCHEDULED GROUP MOVEMENTS: Roof recreation, law library, and court are the only scheduled
group movements allowed without the permission of the Operations Lieutenant. These moves are
scheduled in advance and a staff member will directly supervise these moves. No passes are necessary,
but supervising staff must maintain strict accountability of any inmate released from a housing unit.
16.
BED BOOKS: All housing unit officers are primarily responsible for the maintenance and accuracy of
bed books and bed locations on their respective units. Morning watch officers will inventory and update
the bed book cards on their respective units.
INMATE ACCOUNTABILITY IS EVERYONE'S RESPONSIBILITY!
17.
SPECIAL ACCOUNTABILITY: A staff member shall observe any inmate confined in continual
locked status, such as administrative detention or disciplinary segregation, at least every 30 minutes, at
irregular times. All observations made shall be documented.
18.
EFFECTIVE DATE: This Supplement is effective upon issuance.
Approved by:
DISTRIBUTION:
Warden
Associate Wardens
Executive Assistant
Department Heads
Correctional Supervisors
President, AFGE Local 3138
NERO
Master File
Sensitive But Unclassified
SDNY_00008378
EFTA00033476

=== Page 9 ===
Attachment 1
DATE:
TIME:
AM
PM
MCC NEW YORK, NY
(INSTITUTION)
OFFICIAL COUNT FORM
OUT COUNT SECTION
A
F
F
F
F
H
M
R
S
T
V
0C
T
N
N
N
S
0
S
&
A
N
I
UO
T
J
Y
Y
S
D
N
W
S
TU
P
I
D
I
N
Y
E
S
T
V
T
COUNT
R
VERIFY
COUNT
COUNT
AREA
CENSUS
COUNT
AREA
B-A
B-A
C-A
C-A
E-N
E-N
E-S
E-S
G-N
G-N
G-S
G-S
H-A
H-A
I-N
I-N
K-N
K-N
R-A
R-A
Z-A
Z-A
Z-B
Z-B
TOTAL
IIII
IIII
COUNT
VERIFY
Sensitive But Unclassified
SDNY_00008379
EFTA00033477

=== Page 10 ===
Official Preparing Count:
Official Taking Count:
Good Verbal Count Time:
Count Cleared Time:
Attachment 2
LOCKDOWN ACCOUNTABILITY CENSUS DETAIL FORM
Detail or Location:
INMATES UNAUTHORIZED (PRESENT)
NAME
REG NO
UNIT
JOB
REMARKS
Sensitive But Unclassified
SDNY_00008380
EFTA00033478

=== Page 11 ===
Attachment 2b
ASSIGNED INMATES (ABSENT AND UNACCOUNTED)
NAME
REG NO
UNIT
JOB
REMARKS
PRINTED NAME
SIGNATURE
DATE
Sensitive But Unclassified
SDNY_00008381
EFTA00033479

=== Page 12 ===
Attachment 3
METROPOLITAN CORRECTIONAL CENTER
NEW YORK, NY
SUMMARY OF DAILY CENSUS
DATE:
Absent
Unauthorized
Absent
Unauthorized
DEPARTMENT/POST/AREA
DEPARTMENT/POST/AREA
AM
PM
AM
PM
AM PM
AM
PM
UNIT 2
GM WELD
UNIT 3
HOSP
UNIT 5-NORTH
HVAC
UNIT 5-SOUTH
LAUNDRY
UNIT 7-NORTH
ORD CCS
UNIT 7-SOUTH
ORD R/D
UNIT 9-NORTH
PAINTING
UNIT 11-NORTH
PLUMBING
UNIT 11-SOUTH
PM LAUNDRY
A & 0
RECREATION
BARBER
SAFETY
BST
TWN DRIVER
CHAPEL ORD
UNIT 2FS
CMS CLERK
UNIT 5NFS
COMMISSARY
UNIT 5SFS
EDUCATION
UNIT 7NFS
ELECTRIC
UNIT 7SFS
F/S BLDG 4
UNIT 9NFS
FS AM
UNIT 11NFS
FS PM
UNIT 11SFS
FS WAREHOU
WARDEN ORD
GM CARP
WAREHOUSE
AM CENSUS
START
END
PM CENSUS
START
END
TIME
TIME
COMMENTS/DISCREPANCIES:
Sensitive But Unclassified
SDNY_00008382
EFTA00033480

=== Page 13 ===
Attachment 4
METROPOLITAN CORRECTIONAL CENTER
NEW YORK, NY
COUNT SLIPS
Metropolitan Correctional Center
Official Count Slip
Unit:
Date:
Count:
Time:
Print Name:
Signature:
Print Name:
Signature:
Metropolitan Correctional Center
Official Count Slip
Unit:
Date:
Count:
Time:
Print Name:
Signature:
Print Name:
Signature:
Metropolitan Correctional Center
Official Count Slip
Unit:
Date:
Count:
Time:
Print Name:
Signature:
Print Name:
Signature:
Sensitive But Unclassified
SDNY_00008383
EFTA00033481

=== Page 14 ===
Attachment 5
METROPOLITAN CORRECTIONAL CENTER
NEW YORK, NY
OFFICIAL OUT COUNT
DATE:
COUNT TIME:
FROM:
LOCATION:
(Staff Member Preparing Out Count)
APPROVED:
(Operations Lieutenant)
REG #
NAME
UNIT
REG #
NAME
UNIT
1.
13.
2.
14.
3.
15.
4.
16.
5.
17.
6.
18.
7.
19.
8.
20.
9.
21.
10.
22.
11.
23.
12.
24.
OUT-COUNT BY UNIT
B-A
C-A
E-N
E-S
G-N
G-S
H-A
I-N
K-N
K-S
R-A
Z-A
Z-B
Total Out-Counted:
This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count.
Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an
Out-Count. No other form will be accepted in lieu of the Out-Count Form.
Sensitive But Unclassified
SDNY_00008384
EFTA00033482

=== Page 15 ===
Attachment 6
METROPOLITAN CORRECTIONAL CENTER
NEW YORK, NY
UNANNOUNCED AREA/DETAIL CENSUS CHECK
DATE:
DETAIL/AREA:
TIME:
DETAIL SUPERVISOR:
SENTRY DETAIL CENSUS:
INMATES PRESENT ON DETAIL:
LIST INMATES ABSENT FROM DETAIL WITH AUTHORIZATION:
TOTAL:
LIST INMATES ABSENT FROM DETAIL WITHOUT AUTHORIZATION:
TOTAL:
COMPARE THE DETAIL 3X5 CARDS TO THE SENTRY ROSTER
YES
NO
1. The Detail Crew Kit pouch contains a 3x5 Picture ID Card for each assigned
Inmate.
2. Each 3x5 Picture ID Card contains the Inmate's currently Custody Classification.
3. Each 3x5 Picture ID Card contains the Inmate's current housing and work
assignment.
4. Each 3x5 Picture ID Card contains the Inmate's photograph which accurately
reflects the inmate's current appearance.
LIST COMMENTS AND SPECIFIC ACTION TAKEN TO CORRECT DISCREPANCIES
LIEUTENANT'S SIGNATURE
CAPTAIN'S REVIEW
CC: Original - Census Log
Sensitive But Unclassified
SDNY_00008385
EFTA00033483

=== Page 16 ===
Attachment 7
Metropolitan Correctional Center New York, NY
Running Board
Date:
Page:
Starting Count:
Name
Reg.
From To R-A H-A B-A C-A E-N E-S G-N G-S I-N Z-A Z-B K-N K-S TOTAL
Pre Check
Post Check
ISM
HOSP
U2
U3
5N
5S
7N
7S
9N
SHU
10S
IIN
118
End Count
SDNY_00008386
EFTA00033484

=== Page 17 ===
Attachment 8
DEPARTMENT OF JUSTICE
U.S. DEPARTMENT OF JUSTICE
FEDERAL BUREAU OF
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
Insert Date
MEMORANDUM FOR CAPTAIN
FROM:
Lieutenant's Office
SUBJECT:
Detail Pouch Audit
An audit of the institution detail pouches/gate passes were conducted on [Insert Date].
The following discrepancies were noted:
DATE
CURRENT
INMATES
INMATES
DATE INMATE
INMATE
INCORRECT
CORRECTIVE
DETAIL
MISSING DETAIL
MISSING GATE
PLACED ON
W/CARDS NOT
DETAIL
ACTION TAKEN
CARDS
PASSES
DETAIL
ON ROSTER
UNIT/QTR
Sensitive But Unclassified
SDNY_00008387
EFTA00033485


c1: EFTA00033626
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00033626.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES GOVERNMENT
MEMORANDUM
METROPOLITAN CORRECTIONAL CENTER
New York, NY 10007
August 04, 2019
REPLY TO
ATTN OF:
,
M/W Operations Lieutenant
SUBJECT: Daily Activity Report
TO:
, Warden
,
Associate Warden (0)
,
Associate Warden (P)
,
Executive Assistant
, Captain
Lieutenants
Departments Heads
Daily Activity as communicated or documented by the Operations
Lieutenant for August 03, 2019, was received and/or reviewed. The
following information was noted.
Morning Watch Shift:
Lt.
reported no unusual activity on the morning watch
shift.
Day Watch Shift:
Lt.
reported correctional assignments 10 south #2, SHU #4,
and lobby #2 unassigned, due to, a shortage of staff.
Evening Watch Shift:
Lt.
reported correctional assignments 10 South #2 and
SHU #3 unassigned due to a shortage of staff.
CONFIDENTIAL
SDNY_00008928
EFTA00033626

=== Page 2 ===
INMATES IN OUTSIDE HOSPITAL/SUICIDE WATCH/FURLOUGH/DRY CELL:
I/M
on Suicide Watch w/inmate companion
NEW ADMISSIONS TO MCC New York:
(Hospital Return)
RELEASED FROM MCC NEW YORK:
N/A
ADMISSIONS TO THE SPECIAL HOUSING UNIT:
N/A
TOTAL NUMBER OF CELLS IN SHU THAT ARE PRESENTLY TRIPLE BUNKED:
None
MISSING FIRE AND SECURITY REPORT:
None
MISSING EQUIPMENT INVENTORY FORM:
None
CONFIDENTIAL
SDNY_00008929
EFTA00033627

=== Page 3 ===
THE FOLLOWING LEAVE WAS UTILIZED:
FURLOUGH: 00
ANNUAL LEAVE: 02
SICK LEAVE: 08
OFFICIAL TIME: 00
SUSPENSION: 00
FFLA: 01
FMLA: 00
COP: 02
AWOL: 02
ADVANCE LEAVE: 00
LWOP: 01
ADMIN LEAVE: 00
COMP TIME: 00
TRAINING: 00
GLYNCO: 00
LWOP (M) : 01
TOA: 00
EPO: 00
TRAVEL: 00
THE FOLLOWING OVERTIMES WERE HIRED:
E-1 OVERTIME:
Number of staff = 30
Hours = 238.00
E-1 COMPTIME:
Number of staff = 00
Hours = 00.00
60-Q OVERTIME (USM MEDICAL) :
Number of Staff = 00
Hours = 00.00
CONFIDENTIAL
SDNY_00008930
EFTA00033628

=== Page 4 ===
B-2 OVERTIME:
Number of Staff = 00
Hours = 00.00
O9D OVERTIME (SPECIAL) :
Number of Staff = 01
Hours = 08.00
XXX OVERTIME (AIRLIFT) :
Number of Staff = 00
Hours = 00.00
87S OVERTIME (TREATY TRANS) :
Number of Staff = 00
Hours = 00.00
INSTITUTION TOTALS AT THE BEGINNING OF THE MORNING WATCH SHIFT:
08-03-2019 / 12:00 AM
UNIT B-A: 26
UNIT E-N: 87
UNIT E-S: 78
UNIT G-N: 78
UNIT G-S: 82
UNIT H-A: 01
UNIT I-N: 87
UNIT K-N: 88
UNIT K-S: 142
UNIT Z-A: 77
UNIT Z-B: 05
TOTAL:
761
CONFIDENTIAL
SDNY_00008931
EFTA00033629


c1: EFTA00033992
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00033992.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
maybe just screen him and put a note in to be safe
, Psy.D.
Chief Psychologist
U.S. Department of Justice/
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
>>>
8/1/2019 8:46 AM >>>
in R & D stated that yesterday when Epstein came back from court he had to sign a form with the Marshals that he said
noted, "Suicidal tendencies."
denied that it said he was suicidal.
Do I see him? Do I do a SRA?
CONFIDENTIAL
SDNY_00009817
EFTA00033992


c1: EFTA00032014
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032014.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc:
Christian Everdell
Subject: Ghislaine Maxwell 02879-509
Date: Wed, 16 Jun 2021 17:46:52 +0000
Good afternoon-
Despite being subjected to the most unique, restrictive, and invasive conditions
of pretrial confinement, Ms. Maxwell has and continues to be a compliant detainee.
She obeys all orders and commands - often muffled by masks,
uttered behind prison doors, and/or combined with the din of background noise -
as soon as they are audibly discernible.
Erratic enforcement of inconsistent rules and regulations imposed by
revolving teams of guards who exert varying degrees of officiousness
and contempt toward Ms. Maxwell is the fault of the MDC/BOP,
not Ms. Maxwell.
Regards,
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Main:
Cell:
Fax:
**Covid-19 Notice: The
office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
On Jun 16, 2021, at 11:25 AM,
wrote:
Hi Bobbi-
I apologize for the delay in response. I have been out of office sick.
EFTA00032014

=== Page 2 ===
We are looking into the concerns you have brought to our attention
regarding the VTC units. All of the VTC units throughout the
institution are now being stored in this manner as it is a protective
barrier for the equipment. With that said, we will be doing test runs
to investigate concerns you have mentioned.
Furthermore, Ms. Maxwell must oblige by the orders of the Officers. We
offer Ms. Maxwell medical care on a daily basis, which she has
declined.
Additionally, can you please provide me with a photo of the ear buds
you are requesting to bring into the institution?
Best,
BOBBI C STERNHEIM
6/16/2021 10:23 AM
Good morning-
As reported yesterday, the modifications made in the VTC room
are negatively impacting attorney-client communication.
The video is blurry; the audio includes distorting noises.
I am requesting that these problems be remedied immediately.
Also, I am bringing to your attention the inappropriate behavior of the
guards presently on Ms. Maxwell's detail: threatening discipline if
Ms. Maxwell is "off camera" while leaning against a wall to soothe her
aching
back; barking orders regarding the noise emanating from the washing
machine
and the pace of her gait when walking; laughing amongst themselves as
if any of this is funny.
The manner in which some of the guards responded to me on Sunday gives
me reason to be concerned
about how they treat Ms. Maxwell when out of public view.
The courtesy of a response is requested.
Thank you-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Main:
Cell:
Fax:
EFTA00032015

=== Page 3 ===
**Covid-19 Notice: The
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.
EFTA00032016


c1: EFTA00033592
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00033592.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Lieutenant's log and Daily activity report for Sunday, July 28, 2019.
L.
Lieutenant
Federal Bureau of Prisons
Metropolitan Correctional Center
150 Park Row
New York, N.Y. 10007
CONFIDENTIAL
SDNY_00008797
EFTA00033592


c1: EFTA00031912
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00031912.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FBI / SDNY Epstein update mtg
Date: Tue, 07 Jan 2020 21:44:41 +0000
Importance: Normal
Attachments: unnamed
EFTA00031912


c1: EFTA00032303
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032303.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:Access to Justice Law360 <news-alt@law360.com>
To:<
Subject: The $4.3B Question Over What Terrorist Victims Can Recoup
Date:Mon, 24 Feb 2020 12:41:26 +0000
Law36
Access to Justice
0 Access
to
Justice
Getty-A2J-Kenya.jpg
Monday, February 24, 2020
The $4.3B Question Over What Terrorist Victims Can Recoup
LAW FIRMS
BakerHostetler
The U.S. Supreme Court during oral arguments on Monday will be asked to
create a clearer path to punitive damages in certain cases involving state
Boies Schiller
sponsors of terrorism. It's just the latest chapter in a case that highlights the
Castillo Snyder
decadeslong legal battles that terrorist victims and their families often face in
Clark Hill
trying to recoup damages.
Cooper & Kirk
Read full article
Cowles & Thompson
Culhane Meadows
Analysis
DLA Piper
Ex-Felons In Fla. Race Against Clock To Vote In 2020
Dentons
Former felons in the Sunshine State who are fighting a requirement that they
Epstein Becker Green
pay all outstanding fines and fees before being able to vote may have scored a
Fish & Richardson
recent win at the Eleventh Circuit, but with just eight months to go before the
Gibson Dunn
general election and the state vowing to battle on, time may be running out for
Greenberg Traurig
them to cast a ballot in 2020.
Greenspoon Marder
Read full article
Howarth & Smith
Hunton Andrews Kurth
Analysis
Jenner & Block
ABA Says Industry Regs Need A Rethink, But Will It Matter?
Jones Day
The passage of a revised American Bar Association resolution intended to
Kaplan Hecker
encourage a new look at legal industry regulation and increase access to justice
Kellogg Hansen
represents a major step forward, even in the absence of any recommended
Kirkland & Ellis
changes on nonlawyer participation in the market, some experts say.
Latham & Watkins
Read full article
Loeb & Loeb
Martin Clearwater
How Attys Can Help Dismantle The School-To-Prison Pipeline
Mayer Brown
Miller & Chevalier
As the rise of school shootings spurs an increase in spending on school police
officers, experts at a recent conference said students need more due process
Morgan Lewis
protections when those officers handle routine disciplinary matters: Police
Munger Tolles
Neligan LLP
EFTA00032303

=== Page 2 ===
involvement, they said, should mean attorney involvement too.
Patterson Belknap
Read full article
Paul Weiss
Proskauer Rose
Robins Kaplan
Coin Toss: Are Risk-Measuring Tools Accurate Enough?
Skadden
Most of the algorithms used to assess someone's risk of recidivism before they
Sullivan & Cromwell
are released on bail are correct about 60 and 70% of the time - better than a
White & Case
coin flip, but still prone to misclassification, especially in cases that involve
people of color. The tools' potential for error has left stakeholders clashing over
WilmerHale
their use.
Winston & Strawn
Read full article
COMPANIES
3M Co.
Debt-Based License Suspensions Get Fresh Scrutiny In NY
AbbVie Inc.
New York lawmakers are taking a closer look at doing away with driver's license
Acreage Holdings Inc.
suspensions based on debt, which a New York Law School report this month
Allergan PLC
determined disproportionately impacts minority motorists.
Amazon.com Inc.
Read full article
American Bankruptcy
Institute
American Bar Association
All Access
American Civil Liberties
Homeboy Industries' Harati On Giving People A Fresh Start
Union
As the director of legal services for LA-based Homeboy Industries, Donna Harati
American International
helps former gang members and convicted felons rejoin society by working with
Group Inc.
them on expungements, custody disputes and more. Here, Harati discusses
Amgen Inc.
traffic fines, trauma and finding reasons to smile during tough situations.
Read full article
Apple Inc.
Campaign Legal Center
Canopy Growth Corp.
Perspectives
Center for Justice
Justice Denied For A NY Domestic Violence Survivor
Chevron Corp.
New York's Domestic Violence Survivors Justice Act was enacted to reduce
Cognizant Technology
sentences for people like Nicole Addimando, who was just given 19 years to life
Solutions Corp.
in prison for killing her sadistically abusive partner, so the court's failure to apply
Coherus BioSciences Inc.
it here raises the question of whether it will be applied at all, say Ross Kramer
Exxon Mobil Corp.
and Nicole Fidler at Sanctuary for Families.
Facebook Inc.
Read full article
Google Inc.
ImClone Systems Inc.
Perspectives
Johnson & Johnson
Book Review: A Lawyer Reflects On Defending Guilty People
Martha Stewart Living
In her new book, "Guilty People," Abbe Smith successfully conveys that seeing
Omnimedia, Inc.
ourselves in people who commit crime may be the first step to exacting change
Morgan Stanley
in our justice system, says U.S. District Judge Diane Humetewa of the District of
Motorola Solutions Inc.
Arizona.
New Jersey State Bar
Read full article
Association
New York Civil Liberties
Union
EFTA00032304

=== Page 3 ===
New York Law School
New York State Bar
Association
New York University
Nike Inc.
Pennsylvania Bar
Association
Repligen Corporation
San Francisco 49ers
Spotify Technology SA
Teva Pharmaceutical
Industries Ltd.
The Gap Inc.
Twitter Inc.
University of lowa
Validus Holdings Ltd.
YMCA of the USA
GOVERNMENT
AGENCIES
California Supreme Court
Committee on Foreign
Investment in the United
States
Congressional Budget
Office
Congressional Research
Service
European Securities and
Markets Authority
Federal Trade Commission
Florida Attorney General's
Office
Food and Drug
Administration
New Jersey Supreme Court
Ohio Supreme Court
Pennsylvania Supreme
Court
Securities and Exchange
Commission
U.S. Court of Appeals for
the Eleventh Circuit
U.S. Department of
Education
U.S. Department of Justice
U.S. Department of Labor
EFTA00032305

=== Page 4 ===
U.S. Department of State
U.S. District Court for the
District of Arizona
U.S. District Court for the
Northern District of Texas
U.S. Forest Service
U.S. Supreme Court
Not sure if your firm subscribes? Ask your librarian.
We hope you found this message to be useful.
However, if you'd rather not receive future emails of this sort,
you may unsubscribe here.
Please DO NOT reply to this email. For customer support inquiries, please call +1-646-783-7100 or visit our Contact Us page.
Privacy Policy
Law360 I Portfolio Media, Inc, 111 West 19th Street, 5th Floor, New York, NY 10011
EFTA00032306


c1: EFTA00032762
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032762.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Subject: doc review
Date: Fri, 13 Aug 2021 14:25:13 +0000
Hi
Thanks for all your work helping to review documents, it's a big help to the case. As we discussed, there's another set of
emails that we've batched out, and it would be great if you could help by taking a few batches - I'm reviewing as well. The
batches are under the Epstein SW database, but let me know if you have any issues finding them. As before, this review is
just for "hot docs." These items have already been produced in discovery.
Thanks!
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00032762


c1: EFTA00032646
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032646.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS) [Contractor]"
Cc:
(USANYS) [Contractor]"
(USANYS)
[Contractor]"
Subject: RE: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Date: Wed, 07 Apr 2021 21:33:50 +0000
Thank you!
From:
(USANYS) [Contractor]
Sent: Wednesday, April 7, 2021 4:17 PM
To:
)
Cc:
(USANYS) [Contractor]
>;
(USANYS) [Contractor]
Subject: RE: [EXTERNAL EMAIL] - RE: CD with Maxwell files
The files from
have been added to the folder here for your review:
From:
Sent: Wednesday, April 7, 2021 3:45 PM
To:
(USANYS) [Contractor]
is
(NY) (FBI)
Cc:
(USANYS) [Contractor]
>;
(USANYS) [Contractor]
Subject: RE: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Great, thanks to you both!
From:
(USANYS) [Contractor]
Sent: Wednesday, April 7, 2021 3:30 PM
To:
(NY) (FBI)
i
)
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Received, thank you!
I'll let you know when these files have been uploaded to the shared.
From:
(NY) (FBI)
Sent: Wednesday, April 7, 2021 3:28 PM
To:
)
>;
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Just dropped it off.
Special Agent
FBI New York Field Office
EFTA00032646

=== Page 2 ===
On Apr 7, 2021 2:24 PM,
(USANYS) [Contractor]"
wrote:
That's perfect, thank you. Please let me know once you've dropped them off.
From:
(NY) (FBI)
Sent: Wednesday, April 7, 2021 2:22 PM
To:
(USANYS) [Contractor]
is
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Do you want me to just leave it downstairs in a folder? I'll bring it over now. There are four disks to include 1B-14, 1B 8-2,
1B 8-7, and 1D-1.
From:
(USANYS) [Contractor]
Sent: Wednesday, April 7, 2021 11:26 AM
To:
(NY) (FBI)
is
)
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Sounds good, thank you!
From:
(NY) (FBI)
Sent: Wednesday, April 7, 2021 11:09 AM
To:
is
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
>;
(USANYS) [Contractor]
Subject: [EXTERNAL EMAIL] - RE: CD with Maxwell files
Hey
I'm having some issues with my usa fx account. I have to drop some other media off, so I'll put this on another disc and
drop it off. I can drop it all off early afternoon if that's alright.
Special Agent
FBI New York Field Office
On Apr 7, 2021 9:48 AM,
(USANYS) [Contractor]"
wrote:
Hey
Just wanted to follow up on getting the folder "1B 1-14" on USAfx. Please let us know when you've been able to upload it,
thanks!
EFTA00032647

=== Page 3 ===
From:
Sent: Tuesday, April 6, 2021 1:14 PM
To:
(NY) (FBI)
is
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: FW: CD with Maxwell files
Thanks so much,
(cc'd) will make another copy this afternoon and will send it to you via USAfx.
From:
(USANYS) [Contractor]
Sent: Tuesday, April 6, 2021 1:12 PM
To:
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: CD with Maxwell files
Just confirmed with
that we'll need a replacement of the folder called "1B 1-14" since it won't copy for him either,
probably due to the files getting corrupted somehow when the disc was burned. The folder/its contents may be small
enough that the FBI could send it via USAfx rather than having to burn a new disc, but we'll need a replacement of this
folder either way.
From:
Sent: Monday, April 5, 2021 4:27 PM
To:
(USANYS) [Contractor]
Cc:
(USANYS) [Contractor]
is
(USANYS) [Contractor]
Subject: RE: CD with Maxwell files
Great, thank you!
From:
(USANYS) [Contractor]
Sent: Monday, April 5, 2021 4:20 PM
To:
Cc:
(USANYS) [Contractor]
>;
(USANYS) [Contractor]
Subject: RE: CD with Maxwell files
Hi
Four of the five folders from the disc have successfully uploaded to the folder path linked below, but the fifth folder (1B 1-
14) contains at least one file that will not copy off of the disc (not sure if the file is corrupted or what the issue is exactly).
l'll check with the IT folks and
to see if they're able to copy the remaining folder off the disc or if we'll need the FBI
to recopy and resend it. I will keep you posted on the status of this last folder.
Thanks,
From:
(USANYS) [Contractor]
Sent: Monday, April 5, 2021 2:04 PM
To:
(USANYS) [Contractor]
Subject: FW: CD with Maxwell files
Thank you so much!
EFTA00032648

=== Page 4 ===
From:
)
Sent: Monday, April 5, 2021 1:55 PM
To:
(USANYS) [Contractor]
i
(USANYS) [Contractor]
Subject: CD with Maxwell files
H
and
On Friday, the FBI brought me a CD containing additional files that I need to review for Maxwell. It should be sitting in my
office on the 4th floor on my keyboard at my desk. Would one of you (or another paralegal who is in the office) be able to
please grab the CD and load its contents onto the Epstein share? You can save everything from the CD here:
11
Thanks so much,
EFTA00032649


c1: EFTA00032130
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032130.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Subject: RE: question re: flight records
Date: Tue, 31 Mar 2020 17:46:39 +0000
Got it - thanks.
From:
Sent: Monday, March 30, 2020 12:52
To:
Subject: RE: question re: flight records
Yep, the August flights are what I was referring to.
recalled the NM trip was sometime after
returned from
the Africa trip with Epstein and President Clinton. I don't have the records in front of me, but I believe those August
flights are after the Pres. Clinton flights.
From:
Sent: Sunday, March 29, 2020 1:44 PM
To:
Subject: question re: flight records
Hey, just a quick question about this in the CC update memo - "flight records do reflect at least one trip that
took with Epstein to New Mexico during the general time period in 2002 when
recalls the assault
occurring"
Looking at the records from July 2002 through the end of the year, and looking for either ABQ (Albuquerque) or SAF
(Santa Fe), I only see the following:
-
July 17, SAF to TEB (includes
-
August 5, TEB to SAF (includes
and August 17, SAF to TEB (includes
says she met Epstein in 2002, so is one (or both) of those trips what we're referring to? I don't see any other records
of flights to New Mexico in the second half of 2002 at all, and
doesn't show up by name on the jet until December
and then I don't see her again until April 2003 (which is consistent with her being in Spain for the beginning of 2003).
Just wanted to check - extremely possible I'm not seeing something! Or just that the July / Aug. flights are what we're
referencing. Thanks!
Assistant U.S. Attorney
Southern District of New York
EFTA00032130


c1: EFTA00032697
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032697.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: BOBBI C STERNHEIM <bcsternheim@mac.com>
To: Nathan NYSD Chambers
Cc:
)"
, Christian Everdell
<CEverdell@CohenGresser.com>, Laura Menninger <Imenninger@hmflaw.com>, "Jeff
Pagliuca" <jpagliuca@hmflaw.com>
Subject: U.S. V. Maxwell S2 20 Cr. 330 (AJN)
Date: Wed, 14 Apr 2021 01:05:31 +0000
Attachments: Ltr_re_Marshall_Order.pdf; ATT00001.htm; Proposed_order_for_Marshal.pdf;
ATT00002.htm
Good evening-
Please see the enclosed request and proposed order.
Thank you-
Bobbi
EFTA00032697


c1: EFTA00032409
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032409.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: RE: Epstein
Date: Wed, 05 Dec 2018 17:46:21 +0000
Importance: Normal
I came by - let me know when you're around.
From:
(USANYS)
Sent: Wednesday, December 05, 2018 10:14 AM
To:
(USANYS)
Subject: Epstein
Swing by when you have a sec
Associate U.S. Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
EFTA00032409


c1: EFTA00032137
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032137.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
"
,
)
[Contractor]"
Subject: Automatic reply: 3500 Production
Date: Mon, 26 Aug 2019 22:47:09 +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.
EFTA00032137


c1: EFTA00032556
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032556.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: New York Law360 <news-alt@law360.com>
To:
Subject: States 'Stepped Into The Breach' As Crypto Market Exploded
Date: Thu, 27 Jun 2019 08:59:11 +0000
Law360 New York
NEW YORK
Thursday, June 27, 2019
Follow Law360
TOP NEWS
Law360 Pro Say Podcast
Analysis
States 'Stepped Into The Breach' As Crypto Market Exploded
While the eyes of the investing public have been trained on the U.S.
Securities and Exchange Commission's efforts to police the nascent
cryptocurrency market over the past 18 months, New York's attorney general
turned heads in April when she accused digital currency trading platform
Bitfinex of hiding the loss of $850 million by tapping into the reserves of an
affiliated cryptocurrency.
Read full article
2nd Circ. Ponders Lehman 'Mistake' Claim In Safe Harbor Suit
A Lehman Brothers unit pitched the Second Circuit on Wednesday on the
Listen to our new podcast here
idea that contract language relied on by the lower courts to approve financial
crisis-era payments may have been just "stray words" in the paperwork.
LAW FIRMS
Read full article
Akerman
2nd Circ. Iffy On Goldman 'Re-Fight' Of CDO Class Cert. Issues
Baker Botts
Federal appeals court judges piled on Goldman Sachs on Wednesday,
BakerHostetler
asking why it was trying to "re-fight" settled issues before the appeals court in
Ballard Spahr
a securities class action brought by investors who claim the financier lost $1
Barrett & Singal PC
billion after lying to them.
Best Best & Krieger
Read full article
Boies Schiller
2nd Of 5 NY Docs Eyed For Taking Insys Kickbacks Cops Plea
Browne George
A doctor admitted Wednesday to taking cash from Insys Inc. to prescribe its
Buckley Beal
Subsys painkiller to patients, becoming the second of five New York
CKR Law LLP
physicians charged in Manhattan federal court to admit guilt in an anti-
Cahill Gordon
kickback prosecution.
Chapman and Cutler
Opinion attached Read full article
Choate
Feds Are Full Of Lies, Platinum Boss Tells Jury
Cleary Gottlieb
An attorney for Platinum Partners co-founder Mark Nordlicht on Wednesday
Clifford Chance
sought to turn the tables on prosecutors in closing arguments, accusing the
Console Mattiacci
government of peddling more lies at trial than top executives at the defunct
Cooley
hedge fund are alleged to have told to investors.
Cotchett Pitre
Read full article
Covington & Burling
High Court Nixes State Residency Reqs. For Liquor Licenses
Cozen O'Connor
The U.S. Supreme Court on Wednesday struck down a Tennessee law that
Cravath Swaine
requires businesses to maintain residency for two years before receiving a
Davis Polk
Dechert
EFTA00032556

=== Page 2 ===
liquor license, saying the requirement violates the Constitution's commerce
Dorsey & Whitney
clause.
Foley Hoag
Opinion attached Read full article
Ford O'Brien
CYBERSECURITY & PRIVACY
Fried Frank
Fuerst Ittleman
Debt Collector Sued Over Medical Provider Data Breach
Garvey Schubert
Bankrupt collections firm Retrieval-Masters Creditors Bureau Inc. is facing a
Gibbons PC
proposed class action in New York bankruptcy court claiming it knew of a
data breach affecting millions of patients, including 11.9 million Quest
Gibson Dunn
Diagnostics Inc. patients, months before it became public.
Girardi & Keese
Complaint attached Read full article
Goldstein & Russell
Goodwin
INTELLECTUAL PROPERTY
Herrick Feinstein
Lionbridge Slams $300M Trade Secrets Suit As 'Frivolous'
Hodgson Russ
Translation company Lionbridge Technologies fired back at accusations that
Hogan Lovells
it had feigned interest in purchasing rival TransPerfect Global at a court-
Holland & Knight
ordered auction just to lift the company's trade secrets, slamming the lawsuit
Hughes Hubbard
as "frivolous" in Manhattan federal court on Wednesday.
Husch Blackwell
Motion attached Read full article
Jackson Walker
Jones Day
MEDIA & ENTERTAINMENT
Katten Muchin
Picasso Painting Can Stay At The Met, 2nd Circ. Rules
Kay Griffin
The Metropolitan Museum of Art can keep a Pablo Picasso painting sold by a
Kellogg Hansen
Jewish industrialist to raise money to escape Nazi persecution, as the
Kirby Mclnerney
Second Circuit ruled Wednesday that a $100 million suit brought by a relative
Kirkland & Ellis
of the businessman was filed too late.
Kruzhkov Russo
Opinion attached Read full article
Labaton Sucharow
Latham & Watkins
EMPLOYMENT
Lieff Cabraser
Ex-CKR Law Marketer Alleges Sexually Hostile Workplace
Littler Mendelson
The former marketing director for CKR Law LLP was "repeatedly subjected to
Locke Lord
a sexually hostile work environment," and was fired after she caught her
Lovell Stewart
assistant kissing a managing partner at the firm, according to a suit filed
Mayer Brown
Wednesday in New York state court.
McDermott Will
Complaint attached Read full article
McKool Smith
Title VII Protects Us, LGBTQ Workers Tell Supreme Court
Milbank LLP
Monteverde & Associates
The gay and transgender workers behind a trio of U.S. Supreme Court cases
asking whether federal law shields LGBTQ workers from job discrimination
Morrison Cohen
filed their opening briefs Wednesday, arguing that Title VII's ban on gender-
Niedweske Barber
based bias covers them.
Nixon Peabody
3 documents attached Read full article
O'Melveny & Myers
Orrick Herrington
BENEFITS
Patterson Belknap
Express Scripts Calls MTA Prescription Fraud Suit 'Fantasy'
Paul Hastings
The New York City Transit Authority resorted to "fantasy" by fudging contract
Paul Weiss
terms in its lawsuit accusing Express Scripts of failing to root out millions of
Quinn Emanuel
dollars in excessive prescription drug claims, the nation's largest pharmacy
Richards Layton
benefits manager told a Manhattan federal court Tuesday.
Robins Kaplan
1 document attached Read full article
Ropes & Gray
SECURITIES & WHITE COLLAR
Sidley Austin
Simpson Thacher
Skadden
EFTA00032557

=== Page 3 ===
Bribe Go-Between For Billionaire And Diplomat Avoids Prison
Sullivan & Cromwell
A China-born naturalized U.S. citizen who facilitated bribe payments from
Thornton Law Firm LLP
incarcerated Macau real estate billionaire Ng Lap Seng to a former U.N.
Troutman Sanders
diplomat avoided prison Wednesday as a Manhattan federal judge credited
Van Ness Law Firm
her cooperation with prosecutors.
Read full article
Wachtell Lipton
Williams & Connolly
BANKRUPTCY
WilmerHale
Wilson Sonsini
BlueHippo Contempt Ruling Violated Automatic Stay: 2nd Circ.
Wollmuth Maher
The disgraced CEO of alleged consumer lending scam BlueHippo Funding
Wuersch & Gering
LLC bought himself more time Wednesday as he grapples with a $13.4
million judgment, after the Second Circuit found that a lower court violated
Young Conaway
the automatic stay by finding him in contempt just days after he had filed for
Zimmerman Law Offices PC
personal bankruptcy.
Zuckerman Spaeder
Order attached Read full article
COMPANIES
BANKING
Alliance Defending Freedom
Altman Weil Inc.
US Bank Hits BofA With Buyback Suit Over $1.6B RMBS Trust
American Arbitration Association
U.S. Bank said in a New York federal court lawsuit filed Tuesday that a $1.6
American Civil Liberties Union
billion residential mortgage-backed securities trust it oversees is teeming with
Baltimore Orioles
defective loans that Bank of America is liable for and should be forced to
shoulder the responsibility of cleaning up.
Bank of America Corp.
Complaint attached Read full article
Citigroup Inc.
Credit Suisse Group AG
Philly And Citibank Resolve Libor-Rigging Claims In MDL
Deutsche Bank AG
Philadelphia and Citibank got approval for stipulations that would free the
Express Scripts Holding Co.
financial institution from the city's antitrust claims in two lawsuits lodged in the
Facebook Inc.
long-running litigation.
Fannie Mae
2 documents attached Read full article
First Franklin Corp.
SPORTS & BETTING
Fox Corp.
Freddie Mac
Orioles Urge NY Court To Throw Out Nats' Arbitration Award
General Motors
The Baltimore Orioles and Mid-Atlantic Sports Network have asked a New
Goldman Sachs Group Inc.
York state court to throw out an arbitration award in their ongoing fight with
HSBC Holdings PLC
the Washington Nationals over profits, calling the decision from the MLB-run
JPMorgan Chase & Co.
Revenue Sharing Definitions Committee "fundamentally unfair."
Leadership Council on Legal
Memorandum attached
Read full article
Diversity
TELECOMMUNICATIONS
Lehman Brothers Holdings Inc.
Lionbridge Technologies, Inc.
Telecom Co. Hit With $4.2M Judgment In Unpaid Loan Action
Major League Baseball Inc.
A New York federal judge has slapped an American telecommunications
Major Lindsey & Africa
company with a more than $4.2 million judgment after it failed to participate in
Metropolitan Museum of Art
a Swiss investment vehicle's litigation seeking to confirm an arbitral award
New York City Transit Authority
over money owed under a loan agreement.
New York Times Co.
Order attached Read full article
North American Securities
Administrators Association
REAL ESTATE & DEVELOPMENT
Platinum Partners LP
REIT Investor's Atty Fees Denied In Merger Suit
Quest Diagnostics Inc.
Counsel for an investor in Select Income Real Estate Investment Trust
Rivada Networks LLC
cannot collect $350,000 in attorney fees in a proposed class action over a
Select Income REIT
planned merger with Government Properties REIT because their eligibility for
State Bar of California
an award is unclear, a New York federal judge said Tuesday.
State Street Corp.
1 document attached Read full article
EFTA00032558

=== Page 4 ===
Real Estate Rumors: Chess Builders, Stellar, Rieber
SunGard Data Systems
Developer Chess Builders has reportedly landed $65 million in financing for a
Sungard Availability Services LP
South Bronx hotel and residential project, Stellar Management is said to have
Swiss Re
sold a Bronx apartment building for $76.3 million and Rieber Developments
has reportedly scored a $36 million loan for a Florida hotel and office project.
The Walt Disney Co.
Total Wine & More
Read full article
TransPerfect Global Inc.
EXPERT ANALYSIS
Twentieth Century Fox Film Corp.
U.S. Bancorp
The Upside Of The Fastest Chapter 11 Confirmation Ever
UBS AG
Setting the record for fastest confirmation of a Chapter 11 plan in U.S. history,
Washington Nationals
Sungard Availability Services Capital confirmed a prepackaged plan of
reorganization 19 hours after filing for bankruptcy. This and other recent
Wells Fargo & Co.
precedents may enable future debtors to bypass costly, lengthy stays in
Yale University
bankruptcy, say Hugh McDonald and Alissa Piccione of Troutman Sanders.
iFinex Inc.
Read full article
GOVERNMENT AGENCIES
Q&A
California Supreme Court
A Chat With Ballard Spahr Diversity Chief Virginia Essandoh
Delaware Court of Chancery
In the final installment of this monthly series, legal recruiting expert Carlos
Equal Employment Opportunity
Pauling from Major Lindsey & Africa talks with Virginia Essandoh about the
Commission
trends and challenges she sees as chief diversity officer at Ballard Spahr.
Read full article
European Union
Federal Trade Commission
LEGAL INDUSTRY
Internal Revenue Service
Massachusetts Supreme Judicial
Del. Justices Rip Sullivan Atty For Client's Deposition 'Fiasco'
Court
The Delaware Supreme Court has reprimanded a Sullivan & Cromwell LLP
Securities and Exchange
attorney for failing to put an end to his Tony Award-winning client's "flagrantly
Commission
evasive" and "flippant answers" in a deposition, garnering social media
Tennessee Attorney General's
attention from attorneys who marveled at the strongly worded chiding.
Office
Read full article
Texas State Securities Board
U.S. Attorney's Office
This BigLaw Firm Retains Best-To-Work-For Title
U.S. Department of Justice
O'Melveny & Myers LLP has earned recognition as the best law firm to work
for, running the table on Vault.com's quality of life, diversity and summer
U.S. Department of Veterans
Affairs
associate program rankings and garnering praise from associates for its
"exceptional," "friendly" and "laid-back" culture.
U.S. Immigration and Customs
Read full article
Enforcement
U.S. Supreme Court
Stark Gender Pay Gap Remains For Solo Attys, Small Firms
United States Bankruptcy Court for
Male attorneys who either work at small firms or have solo practices on
the Southern District of New York
average earned 56.8% more than their female counterparts in 2018,
United States District Court for the
according to a report by legal services company Martindale-Avvo.
Eastern District of Pennsylvania
Read full article
Do 'Good Old Boys' Get Picked To Be Judges? GOP Sen. Asks
A Republican U.S. senator asked four district court nominees if they think the
judicial selection process puts "good old boys" on the federal bench over
candidates with stronger conservative bona fides, after the senator was
called out by a right-leaning publication for hewing to an "old system."
Read full article
Justices Uphold Deference To Regulators, With Caveats
The U.S. Supreme Court on Wednesday refused to overturn a long-standing
doctrine requiring judges to defer to an agency's interpretation of its
regulations, but said that "Auer deference" should only be used in certain
cases.
Read full article
EFTA00032559

=== Page 5 ===
Fox Corp. GC Stepping Down After 22 Years With Company
The general counsel of Fox Corp., which formed after a $71.3 billion deal
with Disney in March, has announced her plans to step down after more than
two decades with the company's predecessor multinational media
organizations, the company said Wednesday.
Read full article
Facebook, BigLaw Attys Among Calif. Judicial Vetters
California Gov. Gavin Newsom made public for the first time Wednesday the
names of individuals who vet state judicial candidates, a list that includes a
top Facebook lawyer and attorneys from Boies Schiller Flexner LLP and
Cooley LLP, along with more than 100 other lawyers and judges from around
the state.
Read full article
Ex-Gibbons Associate's Sex Bias Claims Sent To Arbitration
A former Gibbons PC associate accusing the firm of gender discrimination
must hash it out with her onetime employer in arbitration, a Pennsylvania
federal judge ruled Wednesday, finding that the lawyer was "well-positioned"
to understand exactly what she was signing when she entered into the
arbitration agreement at the time of her hiring.
Read full article
Labaton Chair Decries 'Unfair' Criticism Of Firm's Political Ties
Scrutiny of campaign contributions and other political connections that may
have helped Labaton Sucharow secure clients has been "extraordinarily
unfair," the firm's chairman testified in Boston federal court Wednesday at a
hearing about allegedly improper practices by it and two other firms in a class
action against State Street.
Read full article
Mass. Justices Urged To Restore Judge's Pay During ICE Case
The attorney for a Massachusetts state judge charged with helping an
immigrant escape U.S. Immigration and Customs Enforcement custody
urged the state's highest court on Wednesday to reinstate her pay while
she's suspended from judicial service, contending that the justices could
avoid a constitutional quandary by doing so.
Read full article
PACER Fees For Court Opinions Are Arbitrary, Fla. Court Told
The government's unwillingness to set guidelines for which court documents
should be designated as free-to-download opinions in the federal PACER
court filing system is "a wide-scale rampant administrative failure," a Florida
attorney challenging the portal's fees said Wednesday.
Read full article
Law Firm Leaders: Baker Botts' John Martin
Baker Botts managing partner John W. Martin speaks to Law360 about his
priorities for his first term, the ways law firms are responding to new
competition and how best to achieve smart growth.
Read full article
JOBS
Search full listings or advertise your job opening
Mid-sized NY LF seeks add'tl up-and-
elite lit boutique II mid level assoc
coming partners PB $1M+
Schoen Legal Search
Schoen Legal Search
New York, New York
New York, New York
EFTA00032560

=== Page 6 ===
Banktcy Boutique Counsel/Partner
Stellar mid-sized firm seeks outstanding
Schoen Legal Search
mid level m&a atty
NYC, New York
Schoen Legal Search
NYC, New York
NYC*Corp*Assoc*Mid-sized*Lifestyle
mid level L&E assoc/40 yr old 50 atty NYC
Schoen Legal Search
firm
NYC, New York
Schoen Legal Search
New York, New York
Private Equity Associate
Capital Markets Associate
Hunton Andrews Kurth LLP
Hunton Andrews Kurth LLP
New York, New York
New York, New York
Contract Trademark Attorney
Mid-Level IP Litigation Associate with Solid
Epstein Drangel LLP
Experience in Trademark and Copyright
New York, New York
Law
Epstein Drangel, LLP
New York, New York
M&A Associate
Perkins Coie LLP
New York, New York
Not sure if your firm subscribes? Ask your librarian.
We hope you found this message to be useful.
However, if you'd rather not receive future emails of this sort,
you may unsubscribe here.
Please DO NOT reply to this email. For customer support inquiries, please call +1-646-783-7100 or visit our Contact Us page.
Privacy Policy
Law360 Portfolio Media, Inc, 111 West 19th Street, 5th Floor, New York, NY 10011
EFTA00032561


c1: EFTA00031969
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00031969.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Call W. SDNY re. USVI Epstein Litigation
Start Date: 2020-12-08 18:30:00 +0000
End Date: 2020-12-08 19:00:00 +0000
Location:
Class: X-PERSONAL
Comment:
Date Created: 2020-12-07 19:54:57 +0000
Date Modified: 2020-12-07 19:54:57 +0000
Priority: 5
DTSTAMP: 2020-12-07 15:01:14 +0000
Attendee: Singer, Linda
EFTA00031969


c1: EFTA00032378
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032378.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
<
>
To:
>,
<
>
Subject: RE: MCC Visit Thursday
Date: Fri, 16 Aug 2019 11:21:02 +0000
Thank you for your guidance during the tour. Please let us know if you have further questions or need anything else. It was
great seeing you again.
>>>
)" <
> 8/15/2019 2:17 PM>>>
Thank you both for everything today - - really appreciate it, and lovely to see you, as always!
From:
Sent: Thursday, August 15, 2019 9:40 AM
To:
is
)
Subject: RE: MCC Visit Thursday
Thanks! I just walked Mr. O'Callahan and
over to meet with the Regional Director and new Warden.
>>>
)" <
> 8/15/2019 9:31 AM >>>
From:
Sent: Thursday, August 15, 2019 8:54 AM
To:
is
)
<
Subject: Re: MCC Visit Thursday
Sorry about the abrupt prior email. I was hoping to get the names so we could ensure we have enough vests for everyone.
>>>
)" <
> 8/14/2019 10:56 PM >>>
I just found out that additional law enforcement agents will be joining but I don't know how many and who. I asked. I'm
sorry!
On Aug 14, 2019, at 12:49 PM,
V
> wrote:
<!--[if mso 9]--> <!--[endif]-->
Resending, I got an error last time.
From:
Sent: Wednesday, August 14, 2019 12:41 PM
To:
is
Cc:
Subject: RE: MCC Visit Thursday
Principal Deputy Attorney General
US Attorney
EFTA00032378

=== Page 2 ===
From:
Sent: Wednesday, August 14, 2019 12:26 PM
To:
V.
Cc:
Subject: RE: MCC Visit Thursday
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 >>>
Adam,
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:
V.
)
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!
>>>
)"
>
8/13/2019 3:58 PM >>>
Yes, thank you. Where should we go?
From:
Sent: Tuesday, August 13, 2019 3:38 PM
To:
V.
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
EFTA00032379

=== Page 3 ===
Metropolitan Correctional Center
150 Park Row
New York, New York 10007
>>>
)" <
>
8/13/2019 2:05 PM>>>
Adam,
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:
EFTA00032380


c1: EFTA00032013
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032013.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Subject: FW: Letter re GM requests for redactions and in camera proceeding
Date: Wed, 02 Dec 2020 15:24:59 +0000
Attachments: 2020-12-
02_GM_letter_regarding_defense_request_for_sealing_in_camera_hearing_v1.rd.docx
One small edit in the attached.
From:
Sent: Wednesday, December 2, 2020 10:14 AM
To:
Cc:
is
Subject: Letter re GM requests for redactions and in camera proceeding
Chiefs,
Attached for review is a draft letter responding to Maxwell's requests for redactions and an in camera proceeding. For
reference, attached are the relevant filings and Judge Nathan's order directing us to respond. This is due today.
Thanks,
EFTA00032013


c1: EFTA00033653
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00033653.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES GOVERNMENT
MEMORANDUM
METROPOLITAN CORRECTIONAL CENTER
New York, NY 10007
August 01, 2019
REPLY TO
ATTN OF:
, M/W Operations Lieutenant
SUBJECT: Daily Activity Report
TO:
, Warden
,
Associate Warden (0)
,
Associate Warden (P)
,
Executive Assistant
, Captain
Lieutenants
Departments Heads
Daily Activity as communicated or documented by the Operations
Lieutenant for July 31, 2019, was received and/or reviewed. The
following information was noted.
Morning Watch Shift:
Lt.
reported I/M Davis #89380-053 placement on Dry
Cell upon being observed by the Sanitation Officer talking on a
cellphone. As the cell door was being unlocked, the inmate
inserted the cellphone up his anus cavity.
Day Watch Shift:
Lt.
reported I/M's Benjamin #86463-054, Darand #86725-054,
Ochoa #86452-054, Robinson #34801-058 (Pend SIS), Barbrow #76157-054
Brissett #76269-054 (Code #108), Santiago #80341-083 (Code #104),
placement on the Special Housing Unit. Correctional assignments
3-Sally Officer, SHU #4, 10-South #2, 11-South unassigned, due to,
a shortage of staff.
Evening Watch Shift:
Lt.
reported I/M Davis #89380-053 (Code #108/Pend. FBI
Ref.), removal from Dry Cell and placed on the Special Housing
Unit. Correctional assignments 10-South #2, SHU #4, unassigned,
due to, a shortage of staff.
CONFIDENTIAL
SDNY_00009037
EFTA00033653

=== Page 2 ===
INMATES IN OUTSIDE HOSPITAL/SUICIDE WATCH/FURLOUGH/DRY CELL:
I/M Melendez #85799-054 at Local Hosp. w/USMS Guards
NEW ADMISSIONS TO MCC New York:
Carrasquillo #87058-054
Sanchez #76122-054
Santana #77575-054
Thompson #86307-054
Vasquez #87056-054
RELEASED FROM MCC NEW YORK:
Blackwell #71246-054
Mahmood #24988-014
Mccaskill #33919-171
Searles #76292-054
ADMISSIONS TO THE SPECIAL HOUSING UNIT:
Davis #89380-053 (Code #108/Pend. FBI Ref.)
Benjamin #86463-054 (Pend SIS)
Darand #86725-054
"
Ochoa #86452-054
"
Robinson #34801-058
"
Barbrow #76157-054 (Code #108)
Brissett #76269-054
"
Santiago #80341-083 (Code #104)
TOTAL NUMBER OF CELLS IN SHU THAT ARE PRESENTLY TRIPLE BUNKED:
None
MISSING FIRE AND SECURITY REPORT:
SIS Office
Video Monitoring
2 Sallyport
Central Tool Room
Computer Services
MISSING EQUIPMENT INVENTORY FORM:
Lobby
2 Sallyport
Roof Recreation
CONFIDENTIAL
SDNY_00009038
EFTA00033654

=== Page 3 ===
THE FOLLOWING LEAVE WAS UTILIZED:
FURLOUGH: 00
ANNUAL LEAVE: 06
SICK LEAVE: 08
OFFICIAL TIME: 01
SUSPENSION: 01
FFLA: 00
FMLA: 00
COP: 03
AWOL: 09
ADVANCE LEAVE: 00
LWOP: 01
ADMIN LEAVE: 00
COMP TIME: 00
TRAINING: 00
GLYNCO: 00
LWOP (M) : 03
TOA: 00
EPO: 00
TRAVEL: 00
THE FOLLOWING OVERTIMES WERE HIRED:
E-1 OVERTIME:
Number of staff = 20
Hours = 150.45
E-1 COMPTIME:
Number of staff = 03
Hours = 24.00
60-Q OVERTIME (USM MEDICAL) :
CONFIDENTIAL
SDNY_00009039
EFTA00033655

=== Page 4 ===
Number of Staff = 01
Hours = 08.00
B-2 OVERTIME:
Number of Staff = 00
Hours = 00.00
O9D OVERTIME (SPECIAL) :
Number of Staff = 00
Hours = 00.00
XXX OVERTIME (AIRLIFT) :
Number of Staff = 00
Hours = 00.00
87S OVERTIME (TREATY TRANS) :
Number of Staff = 00
Hours = 00.00
INSTITUTION TOTALS AT THE BEGINNING OF THE MORNING WATCH SHIFT:
07-31-2019 / 12:00 AM
UNIT B-A: 25
UNIT E-N: 85
UNIT E-S: 84
UNIT G-N: 69
UNIT G-S: 92
UNIT H-A: 00
UNIT I-N: 92
UNIT K-N: 91
UNIT K-S: 138
UNIT Z-A: 69
UNIT Z-B: 05
TOTAL:
760
CONFIDENTIAL
SDNY_00009040
EFTA00033656


c1: EFTA00033682
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00033682.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES GOVERNMENT
MEMORANDUM
METROPOLITAN CORRECTIONAL CENTER
New York, NY 10007
August 15, 2019
REPLY TO
ATTN OF:
, M/W Operations Lieutenant
SUBJECT: Daily Activity Report
TO:
, Warden
,
Associate Warden (0)
,
Associate Warden (P)
,
Executive Assistant
, Captain
Lieutenants
Departments Heads
Daily Activity as communicated or documented by the Operations
Lieutenant for August 14, 2019, was received and/or reviewed. The
following information was noted.
Morning Watch Shift:
Lt.
reported Control Center Fire Panel remains
inoperative.
Day Watch Shift:
Lt.
reported I/M's Outlaw #85875-054 (Pend SIS),
/
(Rtn. Frm. HA), placement on the
Special Housing Unit. Correctional assignments Phone Monitor, 3
Sally Officer, 10-South #2, Rec. Officer #1, Rec. Officer #2
vacated, due to, a shortage of staff.
Evening Watch Shift:
Lt.
reported I/M's Acosta #86640-054, Brown #81131-
053 (Codes #201/307), Nicholas #86923-054 (Pend SIS), placement on
the Special Housing Unit.
CONFIDENTIAL
SDNY_00009102
EFTA00033682

=== Page 2 ===
INMATES IN OUTSIDE HOSPITAL/SUICIDE WATCH/FURLOUGH/DRY CELL:
I/M
on Psych Obs. w/inmate companion
I/M
on Psych Obs. w/inmate companion
I/M
on Psych Obs. w/inmate companion
NEW ADMISSIONS TO MCC New York:
Carlucci #08173-041
Days #76333-054
Gaye #85431-054
Hobdy #87098-054
Levy #76334-054
Parrales #76331-054
Pujols #77125-054
Turner #78236-054
Vasquez #76332-054
RELEASED FROM MCC NEW YORK:
Grayson #70887-054
Palermo #79166-054
Ceruti #78162-054
Espinoza #87086-054
Hall #86988-054
Rodriguez #79168-054
Santana #77575-054
Taylor #64739-037
ADMISSIONS TO THE SPECIAL HOUSING UNIT:
Acosta #86640-054 (Codes #201/307)
Brown #81131-053
"
Nicholas #86923-054 (Pend SIS)
Outlaw #85875-054
"
(Rtn. Frm HA)
"
TOTAL NUMBER OF CELLS IN SHU THAT ARE PRESENTLY TRIPLE BUNKED:
None
MISSING FIRE AND SECURITY REPORT:
Education/Recreation
Central Tool Room
Sallyport 2
Facilities Mgmt. Off.
Trust Fund/Financial Mgmt. Off.
MISSING EQUIPMENT INVENTORY FORM:
Sallyport 2
R&D
Roof Recreation
CONFIDENTIAL
SDNY_00009103
EFTA00033683

=== Page 3 ===
THE FOLLOWING LEAVE WAS UTILIZED:
FURLOUGH: 00
ANNUAL LEAVE: 04
SICK LEAVE: 08
OFFICIAL TIME: 02
SUSPENSION: 00
FFLA: 02
FMLA: 00
COP: 03
AWOL: 11
ADVANCE LEAVE: 00
LWOP: 01
ADMIN LEAVE: 00
COMP TIME: 02
TRAINING: 04
GLYNCO: 00
LWOP (M) : 03
TOA: 00
EPO: 00
TRAVEL: 00
THE FOLLOWING OVERTIMES WERE HIRED:
E-1 OVERTIME:
Number of staff = 23
Hours = 163.00
E-1 COMPTIME:
Number of staff = 03
Hours = 24.00
60-Q OVERTIME (USM MEDICAL) :
CONFIDENTIAL
SDNY_00009104
EFTA00033684

=== Page 4 ===
Number of Staff = 00
Hours = 00.00
B-2 OVERTIME:
Number of Staff = 00
Hours = 00.00
O9D OVERTIME (SPECIAL) :
Number of Staff = 00
Hours = 00.00
XXX OVERTIME (AIRLIFT) :
Number of Staff = 00
Hours = 00.00
87S OVERTIME (TREATY TRANS) :
Number of Staff = 00
Hours = 00.00
INSTITUTION TOTALS AT THE BEGINNING OF THE MORNING WATCH SHIFT:
08-14-2019 / 12:00 AM
UNIT B-A: 24
UNIT E-N: 82
UNIT E-S: 82
UNIT G-N: 80
UNIT G-S: 88
UNIT H-A: 03
UNIT I-N: 86
UNIT K-N: 91
UNIT K-S: 140
UNIT Z-A: 67
UNIT Z-B: 05
TOTAL:
758
CONFIDENTIAL
SDNY_00009105
EFTA00033685


c1: EFTA00032765
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0008/EFTA00032765.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Subject: RE: Epstein Relativity Questions
Date: Tue, 20 Apr 2021 20:46:38 +0000
H
Thank you so much for checking in. Yes, please mark those types of issues as "For Further Review". And please let me
know if any other questions come up.
From:
Sent: Tuesday, April 20, 2021 4:27 PM
To:
Subject: Epstein Relativity Questions
Hi
I just had a quick question about how to mark a couple of these documents. For some reason USPV00341820-26 were
blank. I tried clicking image and extracted text and those didn't help. Also, for the documents USVP00341831-51, skipping
some here and there, they said "Browser does not support this multimedia format". I marked all of these "For further
review", is this how you want them marked or do you want me to change that to something else?
Thank you,
EFTA00032765


c1: EFTA00016901
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016901.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
Cc:
)"
Subject: Re: Epstein report
Date: Fri, 13 Dec 2019 22:04:30 +0000
No worries. Happy holidays and enjoy your trip.
Co-Chief, Narcotics Unit
On Dec 13, 2019, at 15:50,
wrote:
Hi
,
Sorry I wasn't able to come by yesterday. Finishing everything up before a night trip always takes more time
than expected, but I wanted to thank you both again for offering toet me review the report had I been able to
find the time. I spoke to
and he wanted me to express his gratitude as well. If he needs to see the report
while I'm away he'll let you know.
Happy holidays and see you next year!
Best,
Sent from Yahoo Mail on Android
On Thu, Dec 12, 2019 at 8:05 AM,
USANYS)
wrote:
We have considered your request and are willing to let you take the document you reviewed yesterday to
your office for review today on the following conditions:
1 - The report must be returned to our office by 5 pm tonight.
2 - The document will be treated as Attorney Eyes Only.
3 - The document will not be reproduced in any way (e.g. photocopying).
EFTA00016901

=== Page 2 ===
Assuming you are ok with these conditions, please let us know what time you'd like to pick it up. I'll be
around all morning after 9:30 so let me know and I'll have it ready for you.
Co-Chief, Narcotics Unit
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York, New York 10007
Tel:
EFTA00016902


c1: EFTA00014581
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014581.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Marc Fernich
,
Martin Weinberg
"Weingarten,
Reid"
,
"Miller, Michael"
Cc:
)"
)"
)
[Contractor]"
Subject: 19 Cr. 490 (RMB) - Discovery Production
Date: Wed, 31 Jul 2019 22:11:22 +0000
Attachments: 2019.07.31_Epstein_Discovery_Letter.pdf
Counsel,
The Government's first discovery production in this case has been loaded onto the drive you provided this afternoon and
is ready for pickup at our office. If you are sending a runner to pick up the production, he or she should just ask for the
envelope with Michael Miller's name on it. I've also attached a copy of the accompanying discovery and disclosure letter
to this email.
Please let me know if you have any difficulty accessing the discovery on the drive.
Best,
Assistant United States Attorney
Southern District of New York
0007
EFTA00014581


c1: EFTA00017752
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017752.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
Cc:
(USANYS)"
Subject: Epstein
Date: Tue, 02 Apr 2019 18:13:59 +0000
Importance: Normal
FBI Florida wants us to obtain the consent of SDLF for FBI to turn over to us all the grand jury materials they have from the
original Epstein case (we already obtained some files without them raising this issue, but now they have). Sharing grand
jury material between different federal grand juries is specifically approved in Rule 6(e), and we have done this before
with a letter acknowledgement, so this shouldn't be an issue.
The question is whether we should have
contact their crim chief on this issue (since the last contact was Lisa to the
crim chief), or have ODAG coordinate. Let us know what you think?
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaz
-
EFTA00017752


c1: EFTA00014647
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014647.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Christian Everdell
To:
Cc:
"Bobbi C. Sternheim, Esq."
Laura Menninger
, Jeff Pagliuca
Subject: [EXTERNAL] RE: Stip
Date: Sat, 20 Nov 2021 02:03:31 +0000
Attachments: Stipulation
Trial_Testimony.DOCX
Following-up on our conversation today, is the revised stipulation acceptable to the government?
From:
Sent: Tuesday, November 16, 2021 7:03 PM
To: Christian Everdell
Cc:
; Bobbi C. Sternheim, Esq.
; Laura Menninger
>; ; Jeff Pagliuca
Subject: Stip
Hey Chris,
Following up on our conversation today regarding the stip, would you agree to have the sentence say that the document is
a "true and accurate copy of the transcript of one witness's trial testimony, but not the full trial transcript, given on
February 26 "? If so, we are fine with the stip - and, of course, happy to consider other language that makes the same
point.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00014647


c1: EFTA00014696
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014696.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Nathan NYSD Chambers
Cc:
)"
)"
(USANYS)"
Christian Everdell
11
Jeff Pagliuca
, Laura Menninger
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Letter Motion to file Reply Brief
Date: Mon, 22 Nov 2021 15:07:17 +0000
Attachments: 2021-11-22_Letter_Motion_re_Daubert_reply.pdf; Ex._C.pdf;
Mot_to_Exclude_Hall_Reply_Br._final_[unredacted].pdf
Chambers,
Attached please find a letter motion to file a reply in support of the Government's motion to preclude the testimony of Dr.
Ryan Hall. Attached also are the proposed reply brief and exhibit. The Government submits these documents temporarily
under seal.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00014696


c1: EFTA00017024
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017024.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
La to
about it because She worships him
+ it no uld just weete pro blems / couldn't
tell any one else because it is thick not a
big deal t / didn it want to povtray him
in a bad light. / really don't think it is
a big deal. / think he is just a relaxed suy
+ likes to firt, orwes being fatherly or something
/ know this sounds like me try ing to justify
him doing something weivd, but it isn 4.
Right now my big concern is what / am
many cool things to do + amazing places
going to do this summer. there are so
to go Right now / am really thinking about
So different, 80 beautiful, all the different
doing something in Africa. It would be incredible-
people I would / ove it. I trink / will veally
be happy doing almost anything.
/ am entying actually am in a pretty
good period- This could all be over by
fomorrow but I tel pretty happy right
how + excited for the future, ( not
immediate - track & school), this summer, senior
W /
year, + college. / am having a lot of fun
+
we have so much fun
doing things together
some pro blems + kind of alienati ng herself
is having
from every one 18 nope Shegets over it. Things
are also going well
although still not ebough Tmakes me a little
t I've been talking to
with move
sad to think about it + mad because it seems
like she doesn't make much of an effort


c1: EFTA00014922
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014922.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Sent: Monday, November 16, 2020 11:22 AM
To:
Classification: UNCLASSIFIED/FOUO
*
Will continue to work with
and
to review evidence (Epstein
EFTA00014922

=== Page 2 ===
EFTA00014923

=== Page 3 ===
Classification: UNCLASSIFIED
Classification: UNCLASSIFIED//FOUO
EFTA00014924

=== Page 4 ===
From:
Sent:
Monday, September 28, 2020 12:39 PM
Classification: UNCLASSIFIED//FOUO
*
Epstein/Maxwell (50D-NY-3027571
o
Assisting with evidence review
EFTA00014925

=== Page 5 ===
EFTA00014926

=== Page 6 ===
Classification: UNCLASSIFIED
Classification: UNCLASSIFIED//FOUO
EFTA00014927

=== Page 7 ===
From:
Sent: Monday, November 02, 2020 1:51 PM
Classification: UNCLASSIFIED/FOUO
*
Will continue to work with
and
to review evidence (Epstein
EFTA00014928

=== Page 8 ===
Classification: UNCLASSIFIED
Classification: UNCLASSIFIED//FOUO
EFTA00014929

=== Page 9 ===
From:
Sent: Tuesday, September 08, 2020 11:32 AM
Classification: UNCLASSIFIED//FOUO
*
Epstein/Maxwell (50D-NY-3027571
o
Assisting with evidence review
EFTA00014930

=== Page 10 ===
Classification: UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
EFTA00014931

=== Page 11 ===
From:
Sent:
Monday, September 14, 2020 11:32 AM
Classification: UNCLASSIFIED/FOUO
*
Epstein/Maxwell (50D-NY-3027571
Assisting with evidence review
EFTA00014932

=== Page 12 ===
Classification: UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
EFTA00014933

=== Page 13 ===
From:
Sent:
Monday, November 09, 2020 1:01 PM
Classification: UNCLASSIFIED//FOUO
*
Will continue to work with
and
to review evidence (Epstein
EFTA00014934

=== Page 14 ===
EFTA00014935

=== Page 15 ===
Classification: UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
EFTA00014936

=== Page 16 ===
From:
Sent: Tuesday, July 07, 2020 10:05 AM
*
Research/assistance/prep for hearing for the Epstein investigation (SA
and Det
o
Binder Review
EFTA00014937

=== Page 17 ===
Classification: UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
EFTA00014938

=== Page 18 ===
From:
Sent: Tuesday, September 08, 2020 11:32 AM
Classification: UNCLASSIFIED/FOUO
*
Epstein/Maxwell (50D-NY-3027571
0
Assisting with evidence review
EFTA00014939

=== Page 19 ===
Classification: UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
EFTA00014940

=== Page 20 ===
From:
Sent:
Monday, July 13, 2020 3:27 PM
Classification: UNCLASSIFIED//FOUO
*
(U//FOUO) Assisting SA
with the Maxwell investigation (50D-NY-3027571)
(U//FOUO) Last Thursday sos
assisted SA
in the lab to convert DVDs
recovered in evidence to our system to upload for review and analysis (will be ongoing
project to review)
EFTA00014941

=== Page 21 ===
Classification: UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
EFTA00014942

=== Page 22 ===
From:
Sent: Tuesday, July 21, 2020 11:17 AM
Classification: UNCLASSIFIED//FOUO
*
(U//FOUO) Evidence review in CAIR for Epstein/Maxwell (50D-NY-3027571) [Priority]
EFTA00014943

=== Page 23 ===
Classification: UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
EFTA00014944

=== Page 24 ===
From:
Sent:
Tuesday, July 28, 2020 7:31 AM
Classification: UNCLASSIFIED//FOUO
*
(U//FOUO) Evidence review in CAIR for Epstein/Maxwell (50D-NY-3027571) [Priority]
EFTA00014945

=== Page 25 ===
Classification: UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
EFTA00014946

=== Page 26 ===
From:
Sent:
Monday, August 03, 2020 11:38 AM
Classification: UNCLASSIFIED//FOUO
*
(U//FOUO) Assisting SA
with the Maxwell investigation (50D-NY-3027571)
(U//FOUO) Evidence Review
EFTA00014947

=== Page 27 ===
EFTA00014948

=== Page 28 ===
Classification: UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
EFTA00014949

=== Page 29 ===
From:
Sent:
Monday, August 24, 2020 1:46 PM
Classification: UNCLASSIFIED//FOUO
*
Epstein/Maxwell (50D-NY-3027571
Assisting with redacting images for Discovery purposes/evidence review
EFTA00014950

=== Page 30 ===
EFTA00014951

=== Page 31 ===
Classification: UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
EFTA00014952

=== Page 32 ===
From:
Sent:
Monday, December 09, 2019 11:40 AM
Classification: UNCLASSIFIED//FOUO
-Photo scrub for SA
for the Epstein case
EFTA00014953

=== Page 33 ===
Classification: UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
EFTA00014954

=== Page 34 ===
From:
Sent:
Monday, August 31, 2020 12:29 PM
Classification: UNCLASSIFIED//FOUO
*
Epstein/Maxwell (50D-NY-3027571
Assisting with redacting images for Discovery purposes/evidence review
EFTA00014955

=== Page 35 ===
EFTA00014956

=== Page 36 ===
Classification: UNCLASSIFIED//FOUO
Classification: UNCLASSIFIED//FOUO
EFTA00014957


c1: EFTA00015299
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015299.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USMS)"
To: "Berman, Geoffrey (USANYS)"
Subject: BOP Press Release
Date: Sat, 10 Aug 2019 16:02:40 +0000
Geoff - I just received this. U.S. Department of Justice
Federal Bureau of Prisons Metropolitan Correctional Center New York, New York
For Immediate Release Contact:
August 10, 2019 Public Information Officer
Inmate Death at the MCC New York
New York, NY: On Saturday, August 10, 2019, at approximately 6:30 a.m., inmate Jeffrey Edward Epstein was
found unresponsive in his cell in the Special Housing Unit from an apparent suicide at the Metropolitan
Correctional Center (MCC) in New York, New York. Life-saving measures were initiated immediately by
responding staff. Staff requested emergency medical services (EMS) and life-saving efforts continued. Mr.
Epstein was transported by EMS to a local hospital for treatment of life-threatening injuries, and subsequently
pronounced dead by hospital staff. The FBI is investigating the incident.
Mr. Epstein was a 66-year-old male who arrived at MCC New York on July 6, 2019 under pretrial status after
being indicted for sex trafficking of minors and conspiracy.
MCC New York is an Administrative security facility that currently houses 763 male offenders in New York,
New York.
Additional information about the Federal Bureau of Prisons can be found at www.bop.gov. ###
Sent from my iPhone
EFTA00015299


c1: EFTA00016618
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016618.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
sa I'm
Eas to out
W which too
+ See
We Thesher clonox xady
as way wattery + VMI put nelso
into or pay for Willage
100 because / hate as 550 po atment
ment to jit my wes
but j+ would be really Cool it
it na prened + even it It doesn
17
my, 13 80 effect / get to go se e
GOVERNMENT
EXHIBIT
602
$2 20 Cr. 330 (AJN)
EFTA00016618


c1: EFTA00017058
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017058.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
)"
Cc:
(NY) (FBI)"
)"
)"
(NY) (FBI)"
) [Contractor]"
Subject: RE: Epstein search warrant materials
Date: Tue, 12 Nov 2019 20:24:19 +0000
Drive is ready for pickup in room 307.
From:
Sent: Tuesday, November 12, 2019 3:13 PM
To:
(USANYS)
Cc:
(NY) (FBI)
>;
is
)
>;
>;
(NY) (FBI)
>;
[Contractor]
Subject: RE: Epstein search warrant materials
Great, thanks very much - and the USAO is 2018R01618 (Epstein).
From:
(USANYS)
Sent: Tuesday, November 12, 2019 15:12
To:
Cc:
(NY) (FBI)
>;
>;
is
>;
(NY) (FBI)
i
)
[Contractor]
Subject: RE: Epstein search warrant materials
No problem I just need the usao number.
From:
Sent: Tuesday, November 12, 2019 2:44 PM
To:
(USANYS)
Cc:
(NY) (FBI)
is
)
is
)
is
is
(NY) (FBI)
i
[Contractor]
Subject: RE: Epstein search warrant materials
The FBI has a large amount of search warrant return files (primarily though not exclusively emails) that they need to
transmit to us for loading to Relativity.
Could we please borrow a 1TB hard drive just for the purpose of transferring the data from them to us? We can get it
back to you as quickly as the data is loaded through our folks.
thanks very much,
EFTA00017058

=== Page 2 ===
From:
(NY) (FBI)
Sent: Tuesday, November 12, 2019 14:41
To:
Cc:
is
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant materials
A 1TB should do it. There are a ton of emails, but they don't take up much space.
Senior Forensic Examiner
cell
desk
On Nov 12, 2019 2:39 PM,
)"
wrote:
Okay thanks. We can circle back in a week or so on exactly what's being processed (in terms of number of devices and
what they are), because we have no idea what it is.
More immediately, please let us know how big of a hard drive you need for later this week.
From:
(NY) (FBI)
Sent: Tuesday, November 12, 2019 14:37
To:
Cc:
is
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant materials
I've got everything here with me. Once I've cleared these load files, that stuff will all be processed. Already have
our HQ working on the Island DVR system.
Senior Forensic Examiner
cell
desk
On Nov 12, 2019 2:34 PM, "
)"
wrote:
Thanks, and we do understand it's a heavy lift so we appreciate the help. Could you let us know the size of the materials
so we can get an appropriate hard drive for you?
And separately, I'm not sure what the status is of the island materials - are those with you, or still being preliminarily
checked for any CP images? Or somewhere else??
thanks again,
From:
(NY) (FBI)
Sent: Tuesday, November 12, 2019 14:15
To:
Cc:
is
is
is
(NY) (FBI)
Subject: RE: Epstein search warrant materials
EFTA00017059

=== Page 3 ===
I am generating the load files for such stuff as we speak. Apologies for the delays, this is a long and complex
process that I had to come up with a procedure for. I anticipate the files being ready by the Thursday COB. If you
could forward a drive to me to copy the files onto, I would appreciate it.
Senior Forensic Examiner
cell
desk
On Nov 12, 2019 2:11 PM,
)"
wrote:
Steve,
Wanted to follow up on our phone conversation from about six weeks ago - I think we had anticipated that the electronic
evidence that was being processed by CART from the New York residence search (which I believe was whittled down to
approximately 5-6 iMacs and 5 laptop computers) would be completed for upload with load files for Relativity sometime
in late October. We're concerned about timing particularly because I think that's just the tip of the iceberg - I don't think
FBI has even started on the island materials, for example - so wanted to check on timing. Could you please let us know
what the status is of those materials, and also what the materials are from the island that need to be processed, and
whether there's an estimated time of completion for those as well?
thanks very much,
Assistant U.S. Attorney
Southern District of New York
EFTA00017060


c1: EFTA00015593
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015593.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Travel approval request
Date: Wed, 10 Jul 2019 11:44:45 +0000
Importance: High
do you have a specific time you would like to return? Most of the non-stop, government fares are early morning on
7/14. Let me know. Thanaks.
U.S. Attorney's Office (SDNY)
Legal Assistant, Public Corruption
From:
Sent: Tuesday, July 09, 2019 10:11 PM
To:
Subject: FW: Travel approval request
Hi
It's still up in the air whether l'll be on this trip to Florida later this week, but could you please create a travel authorization
just in case? Thank you!
From:
Sent: Tuesday, July 09, 2019 19:38
To:
Subject: Travel approval request
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
EFTA00015593

=== Page 2 ===
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:
V.
Cc:
is
Subject: RE: travel approval request
Thanks!
From:
Sent: Tuesday, July 9, 2019 2:08 PM
To:
is
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
EFTA00015594

=== Page 3 ===
To:
Cc:
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,
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
EFTA00015595

=== Page 4 ===
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.
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
EFTA00015596


c1: EFTA00016457
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016457.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc: M
Subject: RE: New drive for Maxwell
Date: Fri, 04 Dec 2020 21:37:43 +0000
Attachments: Ltr_to_Hon_Nathan_12.04.20.pdf
See attached. I apologize for the inconvenience!
)"
12/4/2020 3:21
PM
In particular, there appears to be a track change that is included in
the second page, which we are hoping you could fix before we submit this
to Judge Nathan.
We also were hoping to chat about some other issues, but even if that's
not possible, we're hoping we can provide the court with a clean copy
without the track change.
Thanks,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
Original Message
From:
)
Sent: Friday, December 4, 2020 2:20 PM
To:
i
Subject: RE: New drive for Maxwell
Thank you very much. Would you have time for a quick call to discuss,
please?
EFTA00016457

=== Page 2 ===
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
Original Message
From:
Sent: Friday, December 4, 2020 2:04 PM
To:
Subject: RE: New drive for Maxwell
Attached please find the letter to Hon. Nathan.
Best,
Staff Attorney
Department of Justice
Federal Bureau of Prisons
Metropolitan Detention Center Brooklyn
Brooklyn, New York 11232
E:
SENSITIVE/PRIVILEGED COMMUNICATION
The information contained in this electronic message and any and all
accompanying documents constitutes sensitive information. This
information is the property of the U.S. Department of Justice. If you
are not the intended recipient of this information, any disclosures,
copying, distribution, or the taking of any action in reliance on this
information is strictly prohibited. If you received this message in
error, please notify us immediately to make arrangements for its return
EFTA00016458

=== Page 3 ===
to us.
)"
12/4/2020 9:39
AM
Thank you very much.
Original Message
From:
Sent: Friday, December 4, 2020 7:41 AM
To:
Cc:
Subject: Re: New drive for Maxwell
Not a problem.
Best,
)"
12/3/2020 5:24
PM
Hi all,
Today our office is sending via FedEx a replacement drive for Ghislaine
Maxwell, which should arrive at the MDC tomorrow. This drive will
replace the drive that Maxwell recently dropped and broke, and the
accompanying cover letters are attached. Would you please make sure
Maxwell is given access to this drive?
Would you please mail the broken drive back to our office? It can be
mailed to the below address:
Paralegal Specialist
U.S. Attorney's Office, SDNY
New York, NY 10007
Thanks very much, as always, for your help.
Best,
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00016459

=== Page 4 ===
<mailto:
EFTA00016460


c1: EFTA00014302
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014302.pdf
c6: pdf
c7: images
c0:
=== 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
Class: X-PERSONAL
Comment:
Date Created: 2018-12-07 02:59:37 +0000
Date Modified: 2018-12-07 02:59:37 +0000
Priority: 5
DTSTAMP: 2018-12-07 02:48:09 +0000
Attendee
EFTA00014302


c1: EFTA00016036
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016036.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Sent:
Tuesday, August 11, 2020 5:52 PM
To:
Subject:
FW: MAXWELL: Transfer Recap
From:
Sent: Thursday, February 27, 2014 3:35 PM
To:
Cc:
Subject: MAXWELL: Transfer Recap
Here is a recap of the transfer:
BANKING ACCOUNTS
Account Title
UBS A/C
JPM Mkt
Value
Notes
Value
at UBS
a/o 12/31/13
Ghislaine Maxwell
16,872.07
27,047.74
Completed
Ghislaine Maxwell
3,122,468.82
In process
Max Foundation
3,517.72
3,517.75
Completed
Max Foundation
17,213.42
In process
116 East 65th Street LLC
10,731.50
30,265.73
Completed
Pot and Kettle LLC
5,838.70
5,838.70
Completed
Ellmax LLC
87,974.09
87,974.09
Completed
TerraMar Project, Inc.
50,989.28
35,749.95
Completed
TerraMar Project, Inc.
0.00
0.00
Max Hotel Services Corp.
2,399.64
2,360.13
Completed
Total Banking Assets
3,318,005.24
192,754.09
INVESTMENT ACCOUNTS
Account Title
UBS A/C
JPM Mkt
Value
Notes
Value
at UBS
a/o 12/31/13
Ghislaine Maxwell
$5,259,275.95
Waiting to submit once international
positions are transferred out of JPM A/C
Ghislaine Maxwell
$
0.00
Zero Balance @ JPM
430.00
Ghislaine Maxwell - OAP IHD
$1,967,979.33
1,793,384.45
ACAT Completed - Equity Positions
Ghislaine Maxwell - TAP DYS
$1,036,516.92
1,031,614.80
ACAT Completed - Mutual Funds
1
SDNY_GM_02742189
EFTA00016036

=== Page 2 ===
Ghislaine Maxwell - TAP ARFI
$1,003,477.16
991,783.20
ACAT Completed - Mutual Funds
Ghislaine Maxwell - HY
$
3.00
0.00
Zero Balance @ JPM
Ghislaine Maxwell - OAP FDG
$2,045,944.92
1,966,430.85
ACAT Completed - Equity Positions
Ghislaine Maxwell - IRA
$ 56,821.46
56,278.66
ACAT Completed - Mutual Fund
Total Investment Assets
11,370,448.74
5,839,491.96
TOTAL ASSETS
14,688,453.98
6,032,246.05
2
SDNY_GM_02742190
EFTA00016037


c1: EFTA00016508
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016508.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
(USANYS)"
(USANYS)"
Cc:
(USANYS)"
)"
Subject: FW: Supplemental letter regarding
testimony
Date: Sun, 28 Nov 2021 02:44:47 +0000
Attachments:
Letter re Flatley and their rebuttal expert
From: Laura Menninger
Sent: Saturday, November 27, 2021 9:42 PM
To:
)
is
)
is
(USANYS)
is
Cc: Jeff Pagliuca
>;c
; Ann Lundberg
>; ; Nicole Simmons
Subject: [EXTERNAL] Supplemental letter regarding
testimony
Counsel -
Please see attached letter regarding Mr.
anticipated testimony.
Thank you,
Laura
Laura A. Menninger I Partner
Haddon, Morgan & Foreman, P.C.
EFTA00016508


c1: EFTA00017729
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017729.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Date: Thu, 02 Jul 2020 17:24:53 +0000
Inline-Images: image001.png
Congratulations!
From:
Sent: Thursday, July 2, 2020 1:22 PM
Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO
SEXUALLY ABUSE MINORS
UNITED QUI PRO DOMINA JUSTITIA OF SOFFECE JESTICE
UNITED STATES ATTORNEY'S OFFICE
Southern District of New York
STATES
GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS
Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse
Additionally Charged With Perjury in Connection With 2016 Depositions
-
Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F.
Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of
Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"),
announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel
to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity,
conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment
unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator
Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the
purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls,
MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations
including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false
statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal
court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan.
Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and
participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then
EFTA00017729

=== Page 2 ===
delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust.
All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself.
Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes."
FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the
most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the
law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into
behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for
justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The
example set by the women involved has been a powerful one. They persevered against the rich and connected,
and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery
exhibited by the women involved here has empowered others to speak up about the crimes of which they've been
subjected."
NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will
be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement
partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere."
If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact
the FBI at 1-800-CALL FBI, and reference this case.
According to the Indictment [1] unsealed today in Manhattan federal court:
From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated
in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and
ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as
young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew
that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims,
MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states,
which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse.
As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example,
MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or
taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated
victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at
ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior.
Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of
financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also
normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage
Epstein, and undressing in front of a victim.
As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and
susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between
minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL
was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages
during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein
involving a minor victim where MAXWELL was present.
As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching
of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to
touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and
Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as
well as MAXWELL's residence in London, England.
EFTA00017730

=== Page 3 ===
Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made
false statements, including about certain specific acts and events alleged in the Indictment.
GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal
sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to
travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of
transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of
10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual
activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which
carries a maximum sentence of five years in prison.
The statutory maximum penalties are prescribed by Congress and are provided here for informational
purposes only, as any sentencing of the defendant would be determined by the judge.
Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD.
This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys
, and
are in charge of the prosecution.
The charges contained in the Indictment are merely accusations. The defendant is presumed innocent
unless and until proven guilty.
20-138
###
DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE
AT (212) 637-2600.
Follow us on Facebook Follow us on Twitter SDNY website YouTube
[1]
As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein,
constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent
unless and until proven guilty.
EFTA00017731


c1: EFTA00014959
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014959.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
11/26/21, 7:10 PM
Mail - Meder, Kimberly R. (NY) (FBI) - Outlook
Accepted: GM Physical Evidence Review
>
Fri 4/9/2021 11:26 AM
To:
https://outook.office365.us/mail/deeplink?popoutv2=1&version=20211025002.13
1/1
EFTA00014959


c1: EFTA00017107
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017107.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Zach Jones
Cc: Clara Moran
Subject: RE: Continued investigation into possible collaborators of Jeffrey Epstein
Date: Tue, 17 Sep 2019 21:18:41 +0000
Received, thank you very much.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From:
Sent: Tuesday, September 17, 2019 2:05 PM
To:
)
Cc: Clara Moran
Subject: Continued investigation into possible collaborators of Jeffrey Epstein
Ms.
Please see the attached correspondence from Chief Deputy Attorney General Clara Moran.
You can access the materials referenced in the letter by following this link and entering this password:
NMAG files
Password (without quotes) -- "7e4DzyfvYC"
Note that this link will expire on October 16, 2019.
A CD containing this correspondence and the attached materials will also be arriving shortly via U.S. Mail.
Have a good day.
Assistant Attorney General
EFTA00017107


c1: EFTA00016747
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016747.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: NY Mag piece
Date: Wed, 17 Jul 2019 15:32:29 +0000
Attachments: 2019-07-16_JE_detention_submission_Redacted.pdf
I think I neglected to pass along our filing from last night-it's attached here in case that's helpful. Thanks!
From:
Sent: Wednesday, July 17, 2019 11:12 AM
To:
Cc:
Subject: NY Mag piece
https://www.thecut.com/2019/07/jeffrey-epstein-donald-trump-mar-a-lago-video.html?
utm_source=tw&utm_campaign=nym&utm_medium=s1
Public Affairs
U.S. Attorney's Office for the Southern District of New York
Website: www.justice.gov/usao-sdny.
Facebook: https://www.facebook.com/usaosdny
Follow us on Twitter: @SDNYnews
EFTA00016747


c1: EFTA00014473
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014473.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Cc:
Subject: RE: Correction on
and here is your other bomb
Date: Tue, 16 Jul 2019 18:52:08 +0000
Importance: Normal
I called her, you should not be receiving any more calls or emails. She refuses to call the tip line or the FBI office.
Special Agent
United States Attorney's Office
Southern District of New York
Office
Cell
From:
Sent: Tuesday, July 16, 2019 2:36 PM
To:
is
Subject: RE: Correction on
and here is your other bomb
Yep - voicemail with cell phone number attached (and email address below). Thanks.
From:
Sent: Tuesday, July 16, 2019 14:34
To:
)
is
Subject: FW: Correction on
and here is your other bomb
Do you guys have any other contact information for this person so we can reach out to her?
Special Agent
United States Attorney's Office
Southern District of New York
Office
Cell
From:
Sent: Tuesday, July 16, 2019 1:21 PM
To:
Subject: Fwd: Correction on
and here is your other bomb
EFTA00014473

=== Page 2 ===
See below
Begin forwarded message:
From:
)"
Date: July 16, 2019 at 12:19:03 EDT
To:
Cc:
Subject: FW: Correction on
and here is your other bomb
Hey
and I have gotten a few emails from Ms. Harriman since the indictment (for example, the below)-
would it be possible for someone to respond to her and ask that she contact the FBI tip line with any
information she believes she has about the case? Or I'm also happy to politely do that, but wasn't sure if it'd
be a bad idea to respond directly.
thanks,
From: Susan Harriman
Sent: Tuesday, July 16, 2019 12:06
To:
>;
Subject: Correction on
and here is your other bomb
Mistake on
not on board with Ilian
See following email from Stifel
Sent from my iPhone
On Jul 14, 2019, at 11:52 AM, Susan Harriman
wrote:
1) Look at last page 17 of one of Epstein's Form 990 reports--see the concentration purchase and flip in
TenCent and Western Digital?--More than half the proceeds are bet on these two companies:
http://990s.foundationcenter.org/990pf_pdf_archive/660/660789697/660789697_201712_990PFpdf
2) On the AUDIT COMMITTEE of TenCent is accountant Iain Ferguson Bruce:
https://www.tencent.com/en-us/articles/13006381526480930.pdf
ard committees:- Audit Committee Corporate Governance Committee Investment Committee Nomination
Committee Remuneration Committee Ma Huateng MC Lau Chi Ping Martin C Jacobus Petrus (Koos)
Bekker M Charles St Leger Searle M C M M Li Dong Sheng M M Iain Ferguson Bruce M MM Ian Charles
Stone MM
EFTA00014474

=== Page 3 ===
3) Now, let's see who else Iain knows? My, my! None other than
wife!!!!
My, my, he's on the board of Blue Chip Fund with
Blue Chip Growth Fund - SEC.gov
https://www.sec.gov/Archives/edgar/data/902259/./bcg_811-07059.htm
1.
1.2, Elect Director Leslie A. Brun, Management, For, For. 1.3, Elect
3, Elect Director
Management, For, For. 4, Ratify Auditors
3a2, Reelect Iain Ferguson Bruce as
Director, Management, For, For. 3b, Authorize Board
<SEC-DOCUMENT>0001193125-15-308249.txt : 20150831 <SEC
https://www.sec.gov/Archives/edgar/data/822977/./0001193125-15-308249.xt
94 as Non-independent Director 6.3 Elect Lee, Jong-Fa with Shareholder No.
Director For Against
Management 3.1b Elect Iain Ferguson Bruce as Director
For Management 1.4 Elect Director
For For Management 2
I do not have time to run Western Digital's traps, but this is more than enough for you to take a look.
EFTA00014475


c1: EFTA00016822
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016822.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
Subject: DAILY BEAST: Prince Andrew: I'm Ready to Talk. The FBI Never Asked. Feds: Oh Yes, We Did
Date: Wed, 05 Feb 2020 18:24:46 +0000
Prince Andrew and the FBI were involved in a furious war of words Tuesday, after he
denied claims made by the U.S. attorney for Manhattan, Geoffrey Berman, that he
has refused to cooperate with American authorities investigating Jeffrey Epstein's
alleged sexual abuse.
Andrew said no request had been received, and he was
ready to talk.
However a spokesperson for Berman's office told The
Daily Beast they stood by the prosecutor's comments,
EFTA00016822

=== Page 2 ===
specifically the claim that they had "made several
attempts to contact" Andrew's representatives.
Andrew, 59, however, was said to be "angry and
bewildered," according to The Daily Telegraph,
at allegations made by Berman.
On Monday, Berman called out Andrew for giving "zero
co-operation" to the investigation into Epstein at a
press conference held outside Epstein's infamous front
door.
EFTA00016823

=== Page 3 ===
"Nothing could be further from the truth," a source
described as "close to" Andrew told The Telegraph,
"The Duke is more than happy to talk to the FBI but he
hasn't been approached by them yet.
"He is angry about the way this is being portrayed and
bewildered as to why this was said in New York. It
seems certain people are jumping the gun."
However law-enforcement sources were adamant that
EFTA00016824

=== Page 4 ===
they "stood by" Berman's remarks.
Berman said he was taking the rare step of calling
Andrew out by name because Andrew himself, in his
disastrous Newsnight interview, had said: "I am willing
to help any appropriate law-enforcement agency with
their investigations, if required."
While many observers saw Berman's remarks as a
desperate (and likely unsuccessful) attempt to shame
Prince Andrew into living up to his earlier vow, Duncan
Levin, a former federal and New York state prosecutor
in the Manhattan DA's office, saw something else:
evidence of the authorities' determination to leave no
EFTA00016825

=== Page 5 ===
stone unturned as they go after the rich and powerful
global network which Epstein cultivated.
Levin, who is now a managing partner at Tucker Levin,
PLLC, told The Daily Beast that while it was "highly
unusual for a prosecutor to make a public statement
about a witness's reluctance to cooperate with law
enforcement" there is "nothing usual about this case, in
any way. Prince Andrew is not your typical witness, by
any stretch of the imagination."
Public Affairs
United States Department of Justice
U.S. Attorney's Office I Southern District of New York
I
Mobile:
Press Office: (212) 637-1020
EFTA00016826


c1: EFTA00015937
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015937.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Akin Gump
STRAUSS HAUER & FELD LLP
November 19, 2019
CONFIDENTIAL PURSUANT TO FED. R. CRIM. P. 6(e)
VIA ELECTRONIC DELIVERY
Assistant U.S. Attorney
U.S. Attorney's Office
Southern District of New York
New York, NY 10007
Re: July 11, 2019 Subpoena to Deutsche Bank
Dear
On behalf of our client, Deutsche Bank AG, New York Branch and its affiliates ("Deutsche
Bank" or the "Bank"), we write in further response to the grand jury subpoena dated July 11, 2019
(the "Subpoena"). This letter and the enclosed document production represent the eleventh
submission in our client's rolling response to the Subpoena.
Enclosed with this letter is an encrypted file labeled DB-SDNY-PROD011 containing
documents responsive to items 1, 4, 7, 9, 12, 19, 20, and 27 of the Subpoena. As described in the
enclosed production index, labeled Appendix A, today's production contains the following
categories of documents responsive to the Subpoena:
DB-SDNY-0028783 to 0031309: Bank records and electronic
communications related to the following topics:
The Bank's decision to onboard the Epstein Relationship
(designated as "Onboarding" in Appendix A);
In-person meetings between Bank personnel, Jeffrey Epstein, and/or
his associates (designated as "Meetings" in Appendix A);
The transfer of Jeffrey Epstein's assets from JP Morgan to Deutsche
Bank from 2013 through 2014 (designated as "Transfer" in
Appendix A);
EFTA00015937

=== Page 2 ===
November 19, 2019
Page 2
The Bank's policies and procedures related to its Americas
Reputational Risk Committee from 2013 to 2018 (designated as
"ARRC" in Appendix A);
Certain revenue-sharing accounts opened by the Bank in connection
with the Epstein relationship (designated as "Revenue Sharing
Accounts" in Appendix A).
DB-SDNY-0031310 to 0031643: Bank records related to wire transfers
from Jeffrey Epstein's charitable entity, Gratitude America, Ltd., to the
Foundation (designated as
in
Appendix A).
DB-SDNY-0031644 to 0033038: Bank records, including emails, related
to large, routine cash withdrawals made by Jeffrey Epstein's attorney,
and accountant,
,
(designated as "Cash
Transactions" in Appendix A).
DB-SDNY-0033039 to 0033067: Bank records, including emails, related
to certain large wire transfers involving Jeffrey Epstein's U.S. Virgin
Islands-based attorney,
(designated as
in
Appendix A).
DB-SDNY-0033068 to 0033069: A September 2013 email from Jeffrey
Epstein's accountant,
, to
S assistant,
,
attaching a list of Epstein's JP Morgan accounts (designated as "JPM
Accounts" in Appendix A).
DB-SDNY-0033070 to 0037559: Check images written from over twenty
Epstein-affiliated accounts (designated as "Checks" in Appendix A).
Today's production also encloses as Appendix B a set of five supplemental exhibits that
we have prepared in response to questions raised in our prior discussions. The supplemental
exhibits relate to the following issues:
Wire Transfers Related to Epstein Investments: Supplemental Exhibit
A identifies wire transfers to third party bank accounts that appear to relate
to investments in hedge funds and other private investment vehicles.
EFTA00015938

=== Page 3 ===
November 19, 2019
Page 3
List of Payees of LSJE, LLC Account: Supplemental Exhibit B provides
background information on the recipients of payments from an Epstein-
controlled account, LSJE, LLC. KYC records indicate that Epstein planned
to use the LSJE account as a "[c]hecking account for the daily expenses
associated with running one of Jeffrey Epstein's private homes." KYC
records do not specify which private home. The transactions reflected in
Exhibit B suggest that LSJE was used, at least in part, to manage Epstein's
Palm Beach estate.
Butterfly Trust Account Transactions: Supplemental Exhibit C
identifies all incoming and outgoing transactions involving the Butterfly
Trust money market account.
Timeline of Active/Capitalized Accounts: Supplemental Exhibit D
provides a timeline of the openings and closings of Epstein's capitalized
Wealth Management accounts.
Payments to Certain Beneficiaries of the 2013 Butterfly
Trust: Supplemental Exhibit E identifies payments to or on behalf of
certain beneficiaries of the 2013 Butterfly Trust, as well as their family
members. The Bank did not open an account for this entity, but received
trust documents in the course of its due diligence on a separate Epstein-
settled trust, "The 2017 Caterpillar Trust." The Bank previously briefed the
SDNY on payments to the majority of the beneficiaries of the 2013
Butterfly Trust, with the exceptions being
, and
Supplemental Exhibit E contains
this additional information.
The decryption password for the production will be provided by separate email. As we
have discussed, we continue to collect relevant information related to the Subpoena, and expect to
make additional productions shortly.
*
*
Because we are producing these materials pursuant to a grand jury subpoena, it is our
understanding that this production will be treated as confidential consistent with Federal Rule of
Criminal Procedure 6(e). Notwithstanding the confidentiality of the enclosed materials and
EFTA00015939

=== Page 4 ===
November 19, 2019
Page 4
information, should you receive any request for disclosure of such information, pursuant to the
Freedom of Information Act or otherwise, we ask to be notified in a timely fashion and given the
opportunity to object to such disclosure. Further, should you determine to disclose any materials
to any third party, we ask to be given reasonable advance notice in order to allow us to pursue any
available remedies. In such event, we request that you contact the undersigned by email or
telephone rather than rely on regular mail or facsimile transmission to provide such notice. Please
advise us if you object to or disagree with the foregoing requests.
For the avoidance of doubt, no response or document provided in response to the Subpoena
shall be construed as a waiver of any applicable privilege or doctrine available to Deutsche Bank
under state or federal law. If it were found that production of any of the enclosed materials
constitutes disclosure of otherwise privileged matters, such disclosure would be inadvertent. By
the production of such documents, Deutsche Bank does not intend to waive and has not waived
the attorney-client privilege or any other protections.
Please do not hesitate to contact us at
or pmoyne@akingump.com if you
have any questions. We look forward to continuing to work with you in a cooperative manner.
Sincerely,
Enclosures
EFTA00015940


c1: EFTA00014305
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014305.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein
Date: Fri, 07 Dec 2018 16:03:09 +0000
Importance: Normal
We'll walk over to
?
From:
Sent: Friday, December 7, 2018 11:00 AM
To:
Cc:
is
Subject: RE: Epstein
Meeting in my office? Or
?
From:
(USANYS)
Sent: Thursday, December 06, 2018 9:25 PM
To:
Cc:
is
is
Subject: Re: Epstein
I can call in at 11:00.
Sent from my iPhone
On Dec 6, 2018, at 9:22 PM,
wrote:
Ok for me.
Sent from my iPhone
On Dec 6, 2018, at 7:12 PM,
wrote:
Good for me.
From:
Sent: Thursday, December 6, 2018 7:08 PM
To:
Cc:
(USANYS)
i
is
Subject: Re: Epstein
How about 11:00?
Sent from my iPhone
EFTA00014305

=== Page 2 ===
On Dec 6, 2018, at 7:04 PM,
> wrote:
In case you haven't seen, various lawmakers are now calling on DOJ to explain the Epstein NPA. If you have a few
minutes tomorrow, would be helpful to touch base.
https://www.nbcnews.com/news/us-news/lawmakers-demand-probe-sex-ofender-jeffrey-epstein-s-sweetheart-
deal-n944516
EFTA00014306


c1: EFTA00016796
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016796.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Social Media Posts tha
is receiving
Date: Sun, 08 Dec 2019 18:30:49 +0000
Inline-Images: image001.png; image002.png
Very helpful. Thank you.
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
From:
Sent: Sunday, December 8, 2019 1:28 PI
To:
Cc:
Subject: RE: Social Media Posts
I don't know if you've had the opportunity to google
or to review his Twitter account, but it's difficult to
believe he's acting in good faith on this, or that he has
or other victims') best interests at heart. He appears to
be attempting to "troll" people to get attention by exploiting the Epstein case, e.g. -
https://twitter.com
I would be concerned for
about putting faith in people who don't actually have an interest in the truth or in good-
faith investigations, though of course up to you and her how she engages with anyone who contacts her.
thanks,
From:
Sent: Saturday, December 07, 2019 12:10
Subject: Social Media Posts that
is receiving
asked me to pass this along to you in case it is helpful to the FBI. These are additional posts from
that she continues to receive and he keeps asking her for "help". I informed her of your suggestion before that she can
EFTA00016796

=== Page 2 ===
always block a person if they continue to harass her in any way. Thank you for your attention to this.
Best,
8:22 #
Delete
Accept
EFTA00016797

=== Page 3 ===
8:22 8
i
Do you want to let
message you? They
won't know you've seen their message until you accept.
Report
Delete
Accept
4
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that,
among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF
EFTA00016798


c1: EFTA00016031
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016031.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: US V. Maxwell, 20 CR. 330 (AJN) - replacement discovery materials
Date: Fri, 18 Dec 2020 21:29:01 +0000
Attachments: 2020.12.18_Maxwell_Discovery_Letter_(final).pdf;SDNY_GM_02742184.xlsx,;
SDNY_GM_02742185-SDNY_GM_02742186.pdf; SDNY_GM_02742187-
SDNY_GM_02742188.pdf,SDNY_GM_02742189-SDNY_GM_02742190.pdf;
SDNY_GM_02742191-SDNY_GM_02742236.pdf;SDNY_GM_02742237-
SDNY_GM_02742268.pdf; SDNY_GM_02742269-SDNY_GM_02742302.pdt
Counsel,
Today, our team realized that a handful of documents from recent productions were inadvertently labeled with incorrect
Bates numbers. Attached please find copies of those documents with corrected Bates numbers, as well as an
accompanying cover letter. We are also sending a copy of these materials on a disc to the MDC for your client.
Best,
Assistant United States Attorney
Southern District of New York
New York NY 10007
EFTA00016031


c1: EFTA00016906
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016906.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "erica.dubno@fahringerlaw.com"
To:
, 'Aaron
Mysliwiec' <am@fmamlaw.com>
Cc:
Subject:
submission
Date: Fri, 13 Dec 2019 22:09:15 +0000
Attachments:
As per our conversation, attached is our submission regarding
We very much appreciate your consideration and look forward to answering any questions or discussing this further.
Very truly yours,
Erica and Aaron
Erica T. Dubno, Esq.
Fahringer & Dubno
767 Third Avenue, Suite 3600
New York, New York 10017
www.fahringerlaw.com
IMPORTANT: This email (and any attachment) is exclusively for the intended recipient and likely contains information that is
proprietary, privileged, confidential or exempt from disclosure under law. If you are not the intended recipient, viewing, copying, use,
disclosure or distribution of this information may be subject to legal restriction or sanction, and is not intended to waive any privilege.
Please notify the sender of any unintended recipients and immediately delete the original message and any copies.
EFTA00016906


c1: EFTA00014586
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014586.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "Singer, Linda"
To:
Subject: Call w/ DOJ re. Epstein SDNY Investigation
Date: Mon, 05 Oct 2020 12:19:10 +0000
Importance: Normal
Attachments: unnamed
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.
EFTA00014586


c1: EFTA00017755
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017755.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
)"
)"
)"
Cc:
(USANYS)"
(USANYS)"
Subject: FW: CONFIDENTIAL: Coordinating Victim Interviews Against Jeffrey Epstein, 19 Cr. 490
(RMB)
Date: Tue, 13 Aug 2019 21:38:10 +0000
What case am I using to bring witnesses into SDNY. I can only bring people in for GJ, pretrial, trial and sometimes pre GJ.
For the last three witnesses it was pre-trial. But that was when we had an open indictment.
If you are interviewing more people in an investigation you are going to have to travel to them.
I am not giving anyone a hard time I just need to follow the rules.
Please let me know.
From: Colleen Mullen
Sent: Tuesday, August 13, 2019 5:20 PM
To:
(USANYS)
Cc: Teri Gibbs
>; Arick Fudali
Subject: CONFIDENTIAL: Coordinating Victim Interviews Against Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear
I spoke to
yesterday and she confirmed that she is still interested in speaking with our clients.
is still available to meet with prosecutors on August 26, 2019 at 12:00 p.m. in New York.
Please let me know what information you need from me to arrange flights/hotel stay for Ms.
Additionally, you previously mentioned that there may be counseling resources available for our clients. Could
you send me that information as well?
Thank you,
Best,
Colleen
Colleen M. Mullen, Esq.
EFTA00017755

=== Page 2 ===
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.
EFTA00017756


c1: EFTA00017023
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017023.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
sa
January 7, 1996
I got back from my trip to NY today I had
such a great time it is really depressing to be
back home. / ful like it was a trip that
changed my whole out look on life. Ll guess /
always hel that way a little bit when I get
back from trips but it is overnhelming this
time. I am So ready to be out of high school I and
in college. Everything seems so silly; going
out, etc. -it did a 11 Hu be tove any way- / even
feel a little isolated from my friends Be fore I
left I was on a high of how great my
triends were I still realize how wonderful
they are but I feel more independent
like they aven't necessary. I felt like this when
1 got back from mexico and it taded
quickly but 1 have a feling it is
different this time. New York is such an
amazing ty. / telt really wm fortable
there like / know that / belonged
them r would live there at some point
Chopefully soon. / miss
so much already
it seems un fair that / can't see her
more other / feellike im missing so much.
There is 80 much to tell about the
tnp / don't know where to bugin.
The best hight was when
+ / sun
Phantom of the Opera We went to Jett. Epstein's
house + had champuque w/him / tound him
down to earth + easy to talk to. I thanked him
So much for the tmp, etc. We then took


c1: EFTA00014557
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014557.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Epstein discovery deadline
Start Date: 2019-10-31 21:00:00 +0000
End Date: 2019-10-31 21:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2019-07-31 16:48:30 +0000
Date Modified: 2019-07-31 16:48:30 +0000
Priority: 5
DTSTAMP: 2019-07-31 16:08:35 +0000
Attendee:
EFTA00014557


c1: EFTA00015189
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015189.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
cingular
National Compliance Center
RESPONSE COVER SHEET
PO BOX 24679
WEST PALM BEACH, FL 33416-4679
Phone 1-800-635-6840 Facsimile 1-888-938-4715
To:
SA
File Code: 227815
FBI 33401
STE 500
WEST PALM BEACH FL 33401
From: YAB
Phone Number:
Request Dated: 8/1/2006
Number of Pages:
Fax Number:
Received On: 8/1/2006
Date: 8/24/2006
If you are not already doing so, please begin addressing all legal requests to Cingular Wireless.
Additionally, effective immediately, please fax all legal requests to Cingular Wireless at 1-888-938-4715.
- The requested information is enclosed.
- Cell site location information is provided upon receipt of a Search Warrant, a Court Order pursuant
to "Specific & Articulable Facts" or Federal Statute 18 USC §2703 (d).
- There are four (4) folders in the CD that represent the four target numbers. All available information
for the time frame of January 1, 2004 to present has been provided.
CONFIDENTIALITY NOTICE
This cover sheet, and any document which may accompany it, contains information from the National Compliance Center which is intended for use
only by the individual to whom it is addressed, and which may contain information that is privileged, confidential and/or otherwise exempt from
disclosure under applicable law. If the reader of this message is not the intended recipient or the person responsible for delivering this message to the
intended recipient, any review, disclosure, dissemination, distribution, copying or other use of this message or its substance is strictly prohibited. If
you have received this communication in error, please notify us immediately by telephone to arrange for the return of this communication to us at our
expense. Thank you.
NCC Official Use Only
U
R
C
0
227815
EFTA00015189


c1: EFTA00014379
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014379.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Bcc:
Subject: RE: US V. Epstein (SW database)
Date: Fri, 13 Nov 2020 20:07:14 +0000
Embedded: RE:_US_v._Epstein_(SW_database).msg
Sender:
Subject: RE: US V. Epstein (SW database)
Message-Id:
<BN3P110MB026018BCA88B68BCC7A8C34CE3E60@BN3P110MB0260.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
EFTA00014379


c1: EFTA00014718
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014718.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
ACCOUNT NAME
ACCOUNT NUMBER
BILL DATE PAGE 1.0
JEFFREY E EPSTEIN &
AUG 14, 2003
SUMMARY OF MONTHLY CHARGES FOR ACCOUNT
Wireless Number Multi-Line Account
Previous
Payments
Late Payment
Adjustments
Balance
Current
Balance
Received
Charge
Forward
Charges
1,378.12
1,378.12CR
.00
.00
.00
2,451.88
Your billing cycle began on 07/13 and ended on 08/12.
Total Amt Due
2,451.88
Current Monthly Charges
of Individual Number Charges
GUEST GUEST
121.69
67.96
G MAXWELL
672.26
56.49
1,533.48
Total Current Monthly Charges
DUE UPON RECEIPT
2,451.88
TOTAL AMOUNT DUE
2,451.88
PAYMENT DUE UPON RECEIPT
AMOUNT DUE:
2,451.88
AT&T WIRELESS
Acct Name: IREEREV - ERSTEIN & CO
P.O. BOX 8220
Account:
AURORA IL 60572-8220
Wireless:
IRRUDRV = ERSTEIN & CO
000000030002500000005592276997160002451888
EFTA00014718

=== Page 2 ===
ACCOUNT NAME
ACCOUNT
NUMBER
BILL DATE PAGE 3.0
JEFFREY E EPSTEIN &
AUG 14, 2003
We have important information on your wireless account.
Your AT&T Wireless coverage map for the mLife National Plans may reflect an err
or. Puerto
Rico is not part of the Digital National Service Area. Domestic Long Distance
charges will
apply for calls that are made to Puerto Rico. You will also incur roaming and
domestic long
distance charges for calls placed from Puerto Rico. For more information about
your coverage
area, visit www.attwireless.com.
PAYMENTS AND ADJUSTMENTS
DETAIL OF PAYMENTS
8/04/03 PAYMENT RECEIVED THANK YOU!
1,378.12CR
TOTAL OF PAYMENTS RECEIVED THROUGH 8/14/03
1,378.12CR
EFTA00014719

=== Page 3 ===
ACCOUNT NAME
ACCOUNT
NUMBER
NUMBER
BILL DATE PAGE
5.0
JEFFREY E EPSTEIN &
AUG 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
7/13/03 Through 8/12/03
MONTHLY SE - AT&T DIGITAL ONE RATE $99
99.99
CALL WAITING
.00
INTL DIALING
.00
PCS VOICEMAIL
.00
CALLER ID
.00
DETAIL BILLING
.00
TOTAL MONTHLY SERVICE CHARGES
99.99
HOME AIRTIME CHARGES
7/13/03 Through 8/12/03 - AT&T DIGITAL ONE RATE $99.99
Category
Minutes
Rate
Charge
INCLUDED IN PLAN
3
.000
.00
TOTAL HOME AIRTIME CHARGES
.00
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
3.27
STATE TAX
4.57
LOCAL TAX
4.71
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
2.04
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
2.09
GROSS RECEIPTS SURCHARGE
3.52
TOTAL TAXES, SURCHARGES & REGULATORY FEES
21.70
TOTAL CURRENT MONTHLY CHARGES
121.69
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0001 8/03 10:31A
MCLEAN
VA
0002 8/03 10:32A
MCLEAN
PH
1
VA
1
EFTA00014720

=== Page 4 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER
BILL DATE PAGE
6.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0003 8/03 10:33A
MCLEAN
VA
1
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
3
.00
.00
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
EFTA00014721

=== Page 5 ===
ACCOUNT NAME
ACCOUNT
NUMBER
NUMBER
BILL DATE PAGE
7.0
JEFFREY E EPSTEIN &
AUG 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
7/13/03 Through 8/12/03
MONTHLY SE - LOCAL PLAN $39.99
39.99
CALL WAITING
.00
INTL DIALING
.00
CALLER ID
.00
PCS VOICEMAIL W/NUMERIC MSG
.00
DETAIL BILLING
.00
AT&T 2 WAY TEXT MSG $0.00
.00
AT&T TOLL FREE NATIONWIDE
4.99
AT&T TOLL FREE CREDIT
4.99CR
REGULATORY PROGRAMS FEE
1.75
TOTAL MONTHLY SERVICE CHARGES
41.74
HOME AIRTIME CHARGES
7/13/03 Through 8/12/03 - LOCAL PLAN $39.99
Category
Minutes
Rate
Charge
UNLIMITED NIGHT & WKND
686
.000
.00
300 ADDITIONAL MINUTES
300
.000
.00
INCLUDED IN PLAN
201
.000
.00
1187
.00
TOTAL HOME AIRTIME CHARGES
.00
MESSAGING, CONTENT & APPLICATION CHARGES
7/13/03 Through 8/12/03
Category
Messages
Rate
Charge
SENT MESSAGES
11
.10
1.10
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
1.10
ROAMING CHARGES
ROAMING AIR
9.66
ROAMING LONG DISTANCE CHARGES
2.80
TOTAL ROAMING CHARGES
12.46
EFTA00014722

=== Page 6 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE
PAGE
8.0
JEFFREY E EPSTEIN &
AUG 14, 2003
SUMMARY OF CHARGES (CONTINUED)
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
1.79
STATE TAX
2.53
LOCAL TAX
2.60
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
1.13
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
1.16
GROSS RECEIPTS SURCHARGE
1.95
TOTAL TAXES, SURCHARGES & REGULATORY FEES
12.66
TOTAL CURRENT MONTHLY CHARGES
67.96
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0001
7/13
4:42P
MCLEAN
VA
6
0002
7/13
4:53P
WASHINGTON
MD
6
0003
7/13
5:03P
WESTBURY
NY
3
0004 7/14 10:51A
INCOMING
1
0005 7/14 11:21A
INCOMING
1
0006
7/14
11:33A
LOCAL
1
0007
7/14 11:34A
NEW YORK
NY
1
0008
7/14 11:35A
NEW YORK
NY
1
0009 7/14 11:57A
NEW YORK
NY
1
0010
7/14
11:57A
NEW YORK
NY
1
0011 7/14 12:23P
NEW YORK
NY
3
0012 7/14 12:33P
BERWYN
MD
1
0013 7/14 12:34P
CROFTON
MD
3
0014 7/14 1:11P
INCOMING
2
0015 7/15 10:38A
NEW YORK
NY
2
0016 7/15 10:48A
NEW YORK
NY
2
0017 7/15 10:50A
MCLEAN
VA
2
0018
7/15 10:51A
MCLEAN
VA
1
0019
7/15
12:52P
NEW YORK
NY
1
0020 7/15 12:54P
NEW YORK
NY
1
0021 7/15 12:59P
INCOMING
1
0022 7/15 1:05P
NEW YORK
NY
2
0023 7/15 1:07P
MCLEAN
VA
1
0024 7/15 1:08P
CROFTON
MD
3
0025 7/15 1:11P
FAIRFAX
VA
1
0026 7/15 1:22P
INCOMING
5
0027 7/15 1:49P
INCOMING
1
0028 7/15 10:11P
CROFTON
MD
2
0029 7/15 10:12P
MCLEAN
VA
7
0030 7/16 9:44P
MCLEAN
VA
12
0031 7/16 10:02P
CROFTON
MD
2
0032 7/16 10:03P
CROFTON
MD
15
0033 7/16 10:40P
MCLEAN
VA
6
0034
7/16
10:46P
S
MCLEAN
VA
1
0035
7/16
10:47P
MCLEAN
VA
6
0036
7/17
9:54A
MCLEAN
VA
4
EFTA00014723

=== Page 7 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE
PAGE
9.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0037 7/17 11:14A
WASHINGTON MD
1
0038
7/17
11:15A
ROCKVILLE MD
2
0039 7/17 11:40A
INCOMING
2
0040 7/17 11:46A
NEW YORK
NY
2
0041
7/17
5:12P
NEW YORK
NY
1
0042
7/17
5:20P
BROOKLYN
NY
2
0043
7/17
5:21P
INCOMING
1
0044
7/17
5:24P
NEW YORK
NY
1
0045
7/17
5:31P
BROOKLYN
NY
1
0046
7/17
5:47P
NEW YORK
NY
1
0047
7/17
5:48P
INCOMING
1
0048
7/17
5:49P
NEW YORK
NY
0049
7/17
5:50P
NEW YORK
NY
1
0050
7/17
5:54P
NEW YORK
NY
1
0051
7/17
6:02P
CROFTON
MD
2
0052
7/18
1:45P
NEW YORK
NY
1
0053
7/18
2:19P
MCLEAN
VA
3
0054
7/18
2:33P
NEW YORK
NY
1
0055
7/18
2:34P
INCOMING
1
0056
7/18
2:44P
NEW YORK
NY
2
0057
7/18
3:44P
NEW YORK
NY
0058 7/18 4:03P
INCOMING
2
0059
7/18
4:06P
INCOMING
1
0060
7/18
8:19P
NEW YORK
NY
8
0061 7/18 9:07P
INCOMING
2
0062
7/18
9:52P
215/INCOMNG
LDBRYN MAWR
PA NY
0063
7/18
9:52P
INCOMING
1
0064
7/18
9:56P
BROOKLYN
NY
1
0065
7/18
9:57P
NEW YORK
NY
1
0066
7/18
10:01P
BROOKLYN
NY
1
0067
7/18
10:03P
215/INCOMNG
LDBRYN MAWR
PA
NY
0068
7/18
10:03P
INCOMING
3
0069
7/18
10:07P
FAIRFAX
VA
2
0070
7/18
10:46P
S
NEW YORK
NY
1
0071
7/18
11:25P
FAIRFAX
VA
1
0072
7/18
11:35P
610/INCOMNG
LDBALACYNWYD
PA
NY
0073
7/18
11:36P
INCOMING
3
0074
7/19
1:23A
FAIRFAX-VI VA
2
0075
7/19
9:28A
HYATTVILLE MD
7
0076
7/19
10:44A
HYATTVILLE MD
1
0077
7/19
10:46A
HYATTVILLE MD
1
0078
7/19
11:01A
CAPITOL HE MD
5
0079 7/19 11:10A
FAIRFAX-VI VA
1
0080 7/19 12:51P
GARY
IN
7
0081
7/19
1:07P
TRACY
CA
9
0082
7/19
1:19P
MONMTH JCT
NJ
1
0083
7/19
3:33P
NEW YORK
NY
2
0084
7/19
6:44P
FAIRFAX-VI VA
1
0085
7/19
8:02P
FAIRFAX-VI VA
2
0086
7/19
9:30P
SILVER SPR
MD
2
0087
7/19
9:43P
800 SERV.
64
0088
7/19
11:34P
OAKLAND
CA
1
0089
7/19
11:36P
FREMNTNWRK
CA
1
0090 7/19 11:38P
TORRANCE
CA
3
0091 7/19 11:43P
HAYWARD
CA
1
0092 7/19 11:44P
TRACY
CA
1
0093 7/19 11:45P
NEW YORK
NY
1
0094 7/20 10:31A
SILVER SPR MD
35
0095
7/20
4:02P
FALLS CHUR VA
1
0096
7/20
4:06P
FALLS CHUR VA
1
EFTA00014724

=== Page 8 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE
PAGE
10.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0097
7/20
6:06P
GARY
IN
5
0098
7/20
8:03P
703/INCOMNG
LDARLINGTON
VA NY
0099
7/20
8:04P
INCOMING
3
0100
7/20
8:06P
BROOKLYN
NY
4
0101
7/21
4:05A
703/INCOMNG
LDARLINGTON
VA
NY
0102
7/21
4:07A
INCOMING
1
0103
7/21
6:55A
SILVER SPR MD
1
0104
7/21
6:57A
703/INCOMNG
LDARLINGTON
VA
NY
0105
7/21
6:58A
INCOMING
1
0106
7/21
7:41A
SILVER SPR
MD
1
0107
7/21
7:41A
703/INCOMNG
LDARLINGTON
VA
NY
0108
7/21
7:42A
INCOMING
1
0109
7/21
8:28A
SILVER SPR MD
1
0110
7/23
9:09P
NEW YORK
NY
1
0111 7/23 10:34P
800 SERV.
2
0112 7/23 10:36P
800 SERV.
51
0113 7/23 11:27P
800 SERV.
1
0114 7/24 9:23A
NEW YORK
NY
2
0115
7/24
9:34A
BROOKLYN
NY
5
0116 7/24 10:00A
GLEN BURNI MD
6
0117
7/24
11:40A
SILVER SPR MD
0118
7/24
11:45A
SILVER SPR MD
3
0119 7/24 12:21P
SILVER SPR MD
1
0120
7/24
1:14P
KENSINGTON MD
1
0121
7/24
2:25P
SILVER SPR MD
1
0122
7/24
2:29P
KENSINGTON MD
1
0123
7/24
2:37P
KENSINGTON MD
4
0124
7/24
2:45P
202/INCOMNG
LDALEXANDRIA DC NY
0125
7/24
2:46P
INCOMING
1
0126
7/24
3:05P
HYATTVILLE MD
1
0127
7/24
3:06P
HYATTVILLE MD
1
0128
7/24
3:30P
240/INCOMNG
LDDAMASCUS
MD
NY
0129
7/24
3:31P
INCOMING
3
0130
7/24
5:55P
SILVER SPR MD
4
0131
7/24
6:43P
SILVER SPR MD
2
0132
7/24
6:48P
SILVER SPR MD
2
0133
7/24
6:59P
SILVER SPR MD
1
0134
7/24
6:59P
202/INCOMNG
LDALEXANDRIA DC NY
0135
7/24
7:00P
INCOMING
1
0136
7/24
7:09P
SILVER SPR MD
1
0137
7/24
7:10P
SILVER SPR MD
1
0138
7/24
7:30P
SILVER SPR MD
1
0139
7/24
7:42P
KENSINGTON MD
1
0140 7/24 8:51P
IIII 7/24 11:21P
SILVER SPG MD
1
0141
7/24
9:51P
FALLS CHUR VA
5
0142
CROFTON
MD
1
0143
7/25
9:25A
KENSINGTON MD
3
0144 7/25 10:39A
SILVER SPR MD
2
0145 7/25 10:42A
BROOKLYN NY
1
0146 7/25 10:43A
BROOKLYN NY
10
0147 7/25 11:37A
SILVER SPR MD
1
0148
7/25
11:40A
SILVER SPR MD
1
0149
7/25
12:34P
KENSINGTON MD
1
0150
7/25
2:24P
FALLS CHUR VA
1
0151
7/25
2:27P
FALLS CHUR VA
5
0152
7/25
2:40P
HYATTVILLE MD
1
0153
7/25
2:47P
FALLS CHUR VA
1
0154
7/25
2:48P
SILVER SPR MD
4
0155 7/25 2:57P
SILVER SPR MD
1
0156
7/25
3:00P
HYATTVILLE MD
1
EFTA00014725

=== Page 9 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 11.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0157 7/25 3:01P
CLINTON
MD
1
0158
7/25
3:02P
CLINTON
MD
1
0159
7/25
3:04P
SILVER SPR
MD
1
0160
7/25
3:31P
202/INCOMNG
LDALEXANDRIA DC NY
0161
7/25
3:32P
INCOMING
1
0162
7/25
4:04P
CLINTON
MD
1
0163
7/25
4:20P
FALLS CHUR
VA
1
0164
7/25
4:20P
FALLS CHUR VA
1
0165
7/25
4:21P
CLINTON
MD
2
0166
7/25
4:22P
SILVER SPR
MD
2
0167
7/25
4:33P
FALLS CHUR VA
1
0168
7/25
4:35P
202/INCOMNG
LDALEXANDRIA DC NY
0169
7/25
4:36P
INCOMING
1
0170
7/25
4:50P
KENSINGTON MD
2
0171
7/25
4:51P
SILVER SPR MD
3
0172
7/25
4:55P
240/INCOMNG
LDDAMASCUS
MD NY
0173
7/25
4:57P
INCOMING
1
0174
7/25
4:57P
240/INCOMNG
LDDAMASCUS
MD NY
0175
7/25
4:58P
INCOMING
1
0176
7/25
5:46P
FALLS CHUR VA
4
0177 7/25 5:50P
SILVER SPR MD
3
0178
7/25
9:48P
240/INCOMNG
LDDAMASCUS
MD NY
0179
7/25
9:49P
INCOMING
19
0180
7/26
7:08A
800 SERV.
2
0181
7/26
7:10A
800 SERV.
64
0182
7/26
8:20A
FALLS CHUR VA
2
0183
7/26
9:18A
KENSINGTON MD
3
0184
7/26
9:24A
703/INCOMING
LDARLINGTON
VA
NY
0185
7/26
9:25A
INCOMING
1
0186
7/26
9:27A
703/INCOMNG
LDARLINGTON
VA
NY
0187
7/26
9:28A
INCOMING
1
0188
7/26
9:30A
KENSINGTON
MD
1
0189 7/26 9:55A
CLINTON
MD
2
0190
7/26
10:38A
703/INCOMNG
LDARLINGTON
VA
NY
0191 7/26 10:39A
INCOMING
1
0192
7/26
10:40A
SILVER SPR
MD
2
0193
7/26
10:45A
CLINTON
MD
1
0194 7/26 10:46A
FALLS CHUR
VA
1
0195 7/26 10:48A
CLINTON
MD
1
0196
7/26
10:53A
CLINTON
MD
1
0197
7/26
10:54A
FALLS CHUR VA
1
0198
7/26
11:50A
FALLS CHUR VA
4
0199
7/26
11:55A
CLINTON
MD
2
0200
7/26
11:59A
HYATTVILLE MD
10
0201
7/26
12:14P
HYATTVILLE
MD
3
0202
7/26
1:47P
CLINTON
MD
1
0203
7/26
5:15P
CLINTON
MD
1
0204
7/26
5:16P
CLINTON
MD
1
0205
7/27
9:26A
CLINTON
MD
1
0206
7/27
2:43P
CLINTON
MD
1
0207
7/27
4:24P
HYATTVILLE MD
3
0208
7/27
5:11P
FALLS CHUR
VA
1
0209
7/27
5:53P
610/INCOMNG
LDBALACYNWYD PA NY
0210
7/27
5:54P
INCOMING
7
0211
7/27
:21P
0212
5
BROOKLYN
NY
2
7/27
6:24P
WESTBURY
NY
1
0213
7/27
6:25P
BRANDYWINE
MD
1
0214
7/27
7:27P
215/INCOMNG
LDBRYN MAWR
PA NY
0215
7/27
7:27P
INCOMING
0216
7/27
7:30P
WASHINGTON MD
3
EFTA00014726

=== Page 10 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 12.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0217
7/27
7:32P
BRANDYWINE MD
1
0218
7/27
7:35P
CROFTON
MD
2
0219
7/27
7:39P
800 SERV.
64
0220
7/27
8:55P
MCLEAN
VA
2
0221
7/27
8:57P
A
MCLEAN
VA
2
0222
7/28
10:40A
NEW YORK
NY
3
0223
7/28
10:42A
NEW YORK
NY
3
0224
7/28
10:47A
NEW YORK
NY
2
0225
7/28
10:59A
INCOMING
5
0226
7/28
11:04A
NEW YORK
NY
1
0227
7/28
11:41A
INCOMING
1
0228
7/28
12:34P
MCLEAN
VA
13
0229
7/28
12:47P
BRANDYWINE
MD
2
0230
7/28
12:50P
BOWIGLNNDL
MD
9
0231
7/28
1:02P
MCLEAN
VA
5
0232
7/28
1:31P
INCOMING
1
0233
7/28
1:32P
NEW YORK
NY
1
0234
7/28
1:33P
NEW YORK
NY
1
0235
7/28
1:37P
NEW YORK
NY
2
0236
7/28
1:41P
NEW YORK
NY
2
0237
7/28
1:45P
QUEENS
NY
2
0238
7/28
3:55P
NEW YORK
NY
1
0239
7/28
4:13P
INCOMING
2
0240
7/28
5:17P
NEW YORK
NY
1
0241
7/28
5:43P
INCOMING
2
0242
7/29
9:04A
QUEENS
NY
1
0243
7/29
10:51A
INCOMING
3
0244
7/29
11:34A
QUEENS
NY
1
0245
7/29
12:38P
NEW YORK
NY
1
0246
7/29
12:39P
QUEENS
NY
2
0247
7/29
3:42P
NEW YORK
NY
1
0248
7/29
3:45P
QUEENS
NY
1
0249
7/29
3:48P
INCOMING
1
0250
7/29
3:49P
INCOMING
4
0251
7/29
4:54P
NEW YORK
NY
1
0252
7/29
6:49P
INCOMING
1
0253
7/30
8:41A
WASHINGTON
DC
1
0254
7/30
10:00A
WASHINGTON DC
1
0255
7/30
12:24P
BERWYN
MD
3
0256
7/30
12:26P
WASHINGTON DC
1
0257
7/30
1:14P
INCOMING
1
0258
7/30
1:15P
INCOMING
1
0259
7/30
1:16P
INCOMING
1
0260
7/30
3:04P
0261
3:06P
5
MCLEAN
VA
1
7/30
MCLEAN
VA
1
0262
7/30
3:06P
MCLEAN
VA
1
0263
7/30
3:08P
MCLEAN
VA
3
0264
7/30
3:10P
S
KENSINGTON
MD
1
0265
7/30
:49P
NEW YORK
NY
2
0266
7/30
3:51P
WASHINGTON
DC
1
0267
7/30
5:46P
BERWYN
MD
32
0268
7/30
7:25P
BERWYN
MD
2
0269
7/30
7:35P
BERWYN
MD
2
0270
7/31
8:45A
NEW YORK
NY
1
0271
7/31
9:30A
NEW YORK
NY
1
0272
7/31
12:29P
NEW YORK
NY
2
0273
7/31
12:32P
NEW YORK
NY
1
0274
7/31
12:53P
NEW YORK
NY
1
0275
7/31
WASHINGTON DC
1
0276
7/31
1:19P
WASHINGTON DC
1
EFTA00014727

=== Page 11 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 13.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0277
7/31
1:42P
NEW YORK
NY
6
0278
7/31
4:54P
NEW YORK
NY
1
0279
7/31
5:08P
NEW YORK
NY
1
0280
7/31
5:14P
NEW YORK
NY
1
0281
7/31
8:22P
BRANDYWINE MD
2
0282
7/31
8:42P
NEW YORK
NY
1
0283
7/31
8:51P
BERWYN
MD
4
0284
7/31
9:03P
BERWYN
MD
12
0285
8/01
9:58A
INCOMING
1
0286
8/01
4:20P
INCOMING
1
0287
8/01
5:01P
NEW YORK
NY
1
0288
8/01
5:08P
INCOMING
1
0289
8/01
5:16P
NEW YORK
NY
1
0290
8/01
5:25P
NEW YORK
NY
1
0291
8/01
5:32P
NEW YORK
NY
1
0292
8/01
5:59P
BERWYN
MD
4
0293
8/01
6:33P
INCOMING
2
0294
8/01
8:55P
INCOMING
2
0295
8/02
1:17P
MCLEAN
VA
1
0296
8/02
1:17P
CROFTON
MD
3
0297
8/02
2:47P
WASHINGTON MD
6
0298
8/02
3:02P
BRANDYWINE MD
1
0299
8/02
3:03P
NEW YORK
NY
8
0300
8/02
8:53P
MCLEAN
VA
1
0301
8/02
MCLEAN
VA
9
0302
8/03
12:23P
WASHINGTON
MD
4
0303
8/03
12:26P
CROFTON
MD
3
0304
8/03
12:53P
WASHINGTON
MD
16
0305
8/03
1:11P
NEW YORK
NY
2
0306
8/03
1:13P
WASHINGTON
MD
3
0307
8/03
1:15P
INCOMING
2
0308
8/03
1:54P
WASHINGTON
MD
14
0309
8/03
6:16P
WASHINGTON
MD
5
0310
8/03
6:24P
NEW YORK
NY
4
0311
8/03
9:22P
WASHINGTON
MD
6
0312
8/03
9:27P
CROFTON
MD
1
0313
8/03
9:28P
MCLEAN
VA
1
0314
8/03
9:29P
CROFTON
MD
1
0315
8/03
MCLEAN
VA
1
0316
8/03
9:29P
MCLEAN
VA
1
0317
8/03
9:32P
FAIRFAX
VA
4
0318
8/03
9:35P
FAIRFAX
VA
1
0319
8/03
9:36P
FAIRFAX
VA
1
0320
8/04
10:55A
BROOKLYN
NY
6
0321
8/04
12:32P
INCOMING
1
0322
8/04
12:49P
INCOMING
3
0323
8/05
1:22P
INCOMING
1
0324
8/06
10:45A
NEW YORK
NY
1
0325
8/06
10:47A
NEW YORK
NY
2
0326
8/06
10:50A
A
NEW YORK
NY
2
0327
8/06
10:53A
NEW YORK
NY
1
0328
8/06
11:24A
NEW YORK
NY
1
0329
8/06
11:26A
WESTBURY
NY
2
0330
8/06
3:58P
INCOMING
1
0331
8/06
11:01P
MCLEAN
VA
1
0332
8/07
11:08A
MCLEAN
VA
2
0333
8/07 11:10A
CROFTON
MD
1
0334
8/07
11:12A
INCOMING
1
0335
8/07 11:27A
INCOMING
1
0336
8/07
11:28A
INCOMING
1
EFTA00014728

=== Page 12 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 14.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0337
8/07 11:30A
NEW YORK
NY
1
0338
8/07
12:38P
WESTBURY
NY
2
0339
8/07
2:11P
INCOMING
1
0340
8/07
6:45P
INCOMING
2
0341
8/07
9:47P
CROFTON
MD
4
0342
8/07 10:12P
MCLEAN
VA
3
0343
8/07 10:16P A
MCLEAN
VA
3
0344
8/08
7:40P
BROOKLYN
NY
1
0345
8/08
9:23P
800 SERV.
2
0346
8/08
9:25P
800 SERV.
2
0347
8/08
9:26P
S
CROFTON
MD
1
0348
8/08
9:27P
MCLEAN
VA
4
0349
8/08
9:31P
800 SERV.
1
0350
8/09
2:56P
MCLEAN
VA
9
0351
8/09
3:07P
NEW YORK
NY
1
0352
8/10
9:23A
INCOMING
2
0353
8/10
11:14A
CROFTON
MD
1
0354
8/10
2:11P
MCLEAN
VA
4
0355
8/10
2:39P
INCOMING
3
0356
8/10
2:44P
NEW YORK
NY
1
0357
8/10
2:45P
NEW YORK
NY
2
0358
8/10
3:39P
NEW YORK
NY
3
0359
8/10
4:05P
NEW YORK
NY
1
0360
8/10
8:28P
NEW YORK
NY
1
0361
8/10
8:30P
MCLEAN
VA
1
0362
8/11
9:27A
INCOMING
1
0363
8/11
9:28A
INCOMING
5
0364
8/11
10:16A
NEW YORK
NY
1
0365
8/11
10:18A
NEW YORK
NY
1
0366
8/11
10:19A
NEW YORK
NY
1
0367
8/11
11:53A
BRANDYWINE
MD
1
0368
8/11
11:
BRANDYWINE
MD
2
0369
8/11
11:57A
FAIRFAX
VA
1
0370
8/11
12:32P
NEW YORK
NY
1
0371
8/11
12:33P
NEW YORK
NY
1
0372
8/11
12:34P
INCOMING
1
0373
8/11
12:35P
NEW YORK
NY
1
0374
8/11
12:36P
INCOMING
1
0375
8/11
4:44P
NEW YORK
NY
1
0376
8/11
4:45P
LEVITTOWN
NY
1
0377
8/11
4:48P
WASHINGTON
DC
29
0378
8/11
5:23P
NEW YORK
NY
1
0379
8/11
6:53P
CROFTON
MD
1
0380
8/11
9:55P
CROFTON
MD
1
0381
8/12
9:52A
INCOMING
1
0382
8/12
10:02A
WASHINGTON
DC
1
0383
8/12
10:04A
BRANDYWINE
MD
2
0384
8/12
11:57A
LEVITTOWN
NY
29
0385
8/12
12:25P
INCOMING
1
0386
8/12
12:51P
NEW YORK
NY
1
0387
8/12
2:08P
NEW YORK
NY
2
0388
8/12
2:39P
NEW YORK
NY
1
0389
8/12
2:40P
INCOMING
1
0390
8/12
2:42P
INCOMING
1
0391
8/12
3:09P
NEW YORK
NY
3
0392
3:12P
MCLEAN
VA
1
0393
3:12P
BERWYN
MD
1
0394
3:17P
CROFTON
MD
2
0395
12
3:21P
FAIRFAX
VA
1
EFTA00014729

=== Page 13 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE PAGE 15.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0396 8/12 4:23P
NEW YORK NY
1
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
1187
.00
.00
CALL CHARACTERISTICS:
S = Long Distance Service Billed Separately,
A = Automatic Dropped Call Credit
"CALLS FROM" KEY:
NY = NEW YORK
MESSAGING, CONTENT & APPLICATION CHARGES
Message
Message
Ref Date Time Message To Typ Chrg Ref Date Time Message To Typ Chrg
0001 7/30 11:43A
10
0002
7/30
11:43A
.10
0003
7/30
7:26P
-
.10
0004
7/30
8:15P
.10
0006
7/31
.10 0008
00
.10
0005 7/31 7:45A
7:46A
.10
0007 7/31 8:35A
7/31
10:38A
.10
0009 7/31 10:02P
.10 0010 8/06 10:27P
.10
0011 8/11 8:48A
.10
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
1.10
Message Types:
R= Received Messages
S= Sent Messages
I= International Messages
Times for Messaging, Content & Application charges are in your home time zone.
ROAMING CHARGES
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
Calls Made From: CHICAGO TI
0001 7/21 9:28P
NEW YORK
NY
1
.69
.40
0002
7/21
9:29PS
NEW YORK C NY
1
.69
0003 7/21 9:31P
BROOKLYN
NY
11
7.59
2.20
0004 7/22 5:20P
NEW YORK
NY
1
.69
.20
Subtotal for : CHICAGO, IL
14
9.66
2.80
.00
TOTAL ROAMING CHARGES
14
9.66
2.80
.00
CALL CHARACTERISTICS:
S = Long Distance Service Billed Separately
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
EFTA00014730

=== Page 14 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER BILL DATE PAGE 17.0
JEFFREY E EPSTEIN &
AUG 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
7/13/03 Through 8/12/03
MONTHLY SE - AT&T DIGITAL ONE RATE $14
149.99
CALL FORWARDING
.00
THREE WAY CALLING
.00
CALL WAITING
.00
CALLER ID
.00
LINE NUMBER BLOCKING
.00
WORLDCONNECT
7.99
DETAIL BILLING
.00
VOICEMAIL PLUS & TEXT MESSAGING
.00
TOTAL MONTHLY SERVICE CHARGES
157.98
HOME AIRTIME CHARGES
7/13/03 Through 8/12/03 - AT&T DIGITAL ONE RATE $149.99
Category
Minutes
Rate
Charge
INCLUDED IN PLAN
548
.000
.00
CALL FORWARDING MINS
159
.250
39.75
707
39.75
TOTAL HOME AIRTIME CHARGES
39.75
HOME LONG DISTANCE CHARGES
AT&T WIRELESS
15.40
TOTAL HOME LONG DISTANCE CHARGES
15.40
MESSAGING, CONTENT & APPLICATION CHARGES
7/13/03 Through 8/12/03
Category
Messages
Rate
Charge
SENT MESSAGES
5
.10
.50
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
.50
EFTA00014731

=== Page 15 ===
ACCOUNT NAME
ACCOUNT
NUMBER
BILL DATE PAGE 18.0
JEFFREY E EPSTEIN &
AUG 14, 2003
SUMMARY OF CHARGES (CONTINUED)
ROAMING CHARGES
ROAMING AIR
314.34
ROAMING LONG DISTANCE CHARGES
96.00
TOTAL ROAMING CHARGES
410.34
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
7.73
STATE TAX
10.24
LOCAL TAX
10.54
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
4.88
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
5.00
GROSS RECEIPTS SURCHARGE
8.40
TOTAL TAXES, SURCHARGES & REGULATORY FEES
48.29
TOTAL CURRENT MONTHLY CHARGES
672.26
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0001
7/13 4:07P 144/INCOMNG LDUN. KINGDO
NY
2.450
0002
7/16
8:43A
144/INCOMNG
LDUN.
KINGDO
NY
2.800
0003
7/16
8:51A
144/INCOMNG
LDUN.
KINGDO
NY
1.400
0004
7/20
7:02P
LDUN.
KINGDO
NY
7.350
0005
7/29
5:46P
NEW YORK
NY ME
1
0006
7/29
5:56P
NEW YORK
NY ME
1
0007
7/29
8:42P
MOBILE
NY
1
0008
7/30
9:09A
F212
079
NEW YORK
NY NY
1
.25
0009
7/30
9:10A
F212-879-9366
NEW YORK
NY NY
8
2.00
0010
7/30
11:17A
F212-879-9366
NEW
YORK
NY NY
2
.50
0011 7/30 12:05P F212-879-9366 NEW YORK NY NY
9
2.25
0012 7/30 12:09P F212-879-9366 NEW YORK NY NY
3
.75
0013
7/30
3:19P
F212-879-9366
NEW
YORK
NY NY
18
4.50
0014
7/30
4:52P
F212-879-9366
NEW YORK
NY NY
3
.75
0015 7/30 5:27P F212-879-9366 NEW YORK NY NY
3
.75
0016
7/30
5:50P
F212-879-9366
NEW YORK
NY NY
2
.50
0017
7/30
6:30P
F212-879-9366
NEW YORK
NY NY
3
.75
0018
7/30
6:48P
INCOMING
1
0019
7/30
6:49P
NEW YORK
NY
1
0020
7/30
6:50P
NEW YORK
NY
1
0021 7/30 7:30P RETRIEVAL
LOCAL
2
0022 7/30 7:32P RETRIEVAL
LOCAL
1
0023
7/30
7:33P
NEW YORK
NY
1
0024 7/30 7:34P
BETHESDA
DC
2
0025
7/30
7:36P
NEW YORK
NY
4
0026
7/30
8:02P
NEW YORK
NY
1
0027
7/30
8:03P
NEW YORK
NY
2
EFTA00014732

=== Page 16 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 19.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0028
7/30
8:05P
NEW YORK
NY
1
0029
7/30
8:15P
INCOMING
3
0030
7/30
8:21P
NEW YORK
NY
1
0031
7/30
8:40P
INCOMING
1
0032
7/30
10:07P
RETRIEVAL
LOCAL
1
0033
7/30
10:10P
NEW YORK
NY
1
0034
7/30
10:13P
BETHESDA
DC
1
0035
7/30
10:14P
BETHESDA
DC
1
0036
7/30
10:19P
NEW YORK
NY
1
0037
7/30
11:53P
LOCAL
1
0038
7/31
9:00A
NEW YORK
NY
1
0039
7/31
9:12A
NEW YORK
NY
6
0040
7/31
12:16P
REIRIEVAL
LOCAL
1
0041
7/31
12:33P
INCOMING
3
0042
7/31
12:35P
NEW YORK
NY
1
0043
7/31
12:57P
INCOMING
0044
7/31
2:54P
INCOMING
0045
7/31
3:16P
RETRIEVAL
LOCAL
1
0046
7/31
3:18P
RETRIEVAL
LOCAL
1
0047
7/31
3:19P
INCOMING
1
0048
7/31
3:20P
T OPERATOR
7
0049
7/31
3:28P
MORIARTY
NM
3
0050
7/31
3:30P
INCOMING
1
0051
7/31
3:32P
INCOMING
1
0052
7/31
3:32P
INCOMING
1
0053
7/31
3:34P
INCOMING
1
0054
7/31
3:41P
NEW YORK
NY
2
0055
7/31
3:47P
MOBILE
NY
1
0056
7/31
3:56P
NEW YORK
NY
2
0057
7/31
3:58P
NEW YORK
NY
1
0058
7/31
3:59P
MOBILE
NY
1
0059
7/31
4:17P
NEW YORK
NY
1
0060
7/31
4:18P
MOBILE
NY
2
0061
7/31
4:20P
NEW YORK
NY
6
0062
7/31
4:40P
INCOMING
1
0063
7/31
4:41P
INCOMING
2
0064
7/31
4:43P
NEW YORK
NY
2
0065
7/31
5:03P
INCOMING
0066
7/31
5:04P
NEW YORK
NY
5
0067
7/31
5:04P
INCOMING
1
0068
7/31
5:24P
NEW YORK
NY
1
0069
7/31
5:25P
MOBILE
NY
2
0070
7/31
5:28P
INCOMING
2
0071
7/31
5:35P
INCOMING
2
0072
7/31
5:54P
INCOMING
1
0073
7/31
6:18P
MOBILE
NY
1
0074
7/31
6:19P
INCOMING
1
0075
7/31
6:22P
INCOMING
0076
7/31
6:29P
INCOMING
1
0077
7/31
6:41P
NEW YORK
NY
1
0078
7/31
7:41P
NEW YORK
NY
2
0079
7/31
8:13P
INCOMING
0080
7/31
9:13P
INCOMING
0081
7/31
9:21P
W PALM BCH FL
2
0082
7/31
10:01P
NEW YORK
NY
1
0083
7/31
10:11P
NEW YORK
NY
2
0084
7/31
10:47P
INCOMING
0085
7/31
10:47P
W PALM BCH FL
11
0086
8/01
12:02P
INCOMING
2
0087
8/01
12:05P
INCOMING
7
EFTA00014733

=== Page 17 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 20.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF DATE
TIME
NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0088
8/01 12:07P
INCOMING
1
0089
8/01
12:25P
INCOMING
3
0090
8/01
1:41P
INCOMING
1
0091
8/01
2:50P
INCOMING
1
0092
8/01
2:59P
INCOMING
1
0093
8/01
3:00P
INCOMING
1
0094
8/01
4:03P
INCOMING
3
0095
8/01
4:11P
INCOMING
3
0096
8/01
4:30P
INCOMING
1
0097
8/01
4:44P
INCOMING
3
0098
8/01
5:28P
NEW YORK
NY
1
0099
8/01
5:33P
NEW YORK
NY
0100
8/01
5:34P
INCOMING
5
0101
8/01
5:44P
INCOMING
3
0102
8/01
5:46P
NEW YORK
NY
1
0103
8/01
5:52P
INCOMING
0104
8/01
6:14P
INCOMING
0105
8/01
6:31P
INCOMING
0106
8/01
8:25P
INCOMING
0107
8/01
9:05P
INCOMING
0108
8/01
9:05P
BETHESDA
DC
0109
8/01
9:06P
INCOMING
0110
8/01
9:07P
INCOMING
0111
8/01
9:14P
INCOMING
0112
8/01
10:50P
INCOMING
0113
8/01 10:53P
INCOMING
0114
8/01
10:54P
NEW YORK
NY
0115
8/01
10:55P
NEW YORK
NY
0116
8/02
1:00P
INCOMING
5
0117
8/02
1:18P
INCOMING
0118
8/02
1:24P
INCOMING
2
0119
8/02
1:43P
QUEENS
NY
3
0120
8/02
1:45P
NEW YORK
NY
1
0121
8/02
1:53P
BETHESDA
DC
1
0122
8/02
3:07P
NEW YORK
NY
2
0123
8/02
4:13P
INCOMING
1
0124
8/02
4:14P
RETRIEVAL
LOCAL
0125
8/02
4:16P
INCOMING
10
0126
8/02
4:42P
INCOMING
2
0127
8/02
4:44P
NEW YORK
NY
1
0128
8/02
4:56P
NEW YORK
NY
1
0129
8/02
5:08P
NEW YORK
NY
1
0130
8/02
5:14P
MOBILE
NY
2
0131
8/02
5:18P
INCOMING
1
0132
8/02
5:18P
DELRAY BCH FL
5
0133
8/02
5:25P
DELRAY BCH FL
1
0134
8/02
5:38P
INCOMING
2
0135
8/02
6:42P
INCOMING
2
0136
8/02
6:47P
INCOMING
2
0137
8/02
6:48P
INCOMING
5
0138
8/02
6:54P
INCOMING
0139
8/02
7:48P
INCOMING
0140
8/02
9:32P
RETRIEVAL
LOCAL
0141
8/02
9:35P
RETRIEVAL
LOCAL
2
0142
8/02
9:44P
INCOMING
0143
8/02
9:44P
INCOMING
0144
8/02 11:54P
INCOMING
0145
8/02 11:55P
RETRIEVAL
LOCAL
0146
8/03
12:38A
NEW YORK
NY
2
0147
8/03
12:39A
INCOMING
EFTA00014734

=== Page 18 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 21.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0148 8/03 12:54A
INCOMING
9
0149 8/03 10:10A
INCOMING
2
0150
8/03
10:58A
INCOMING
4
0151
8/03
12:45P
NEW YORK
NY
1
0152
8/03
1:11P
INCOMING
3
0153
8/03
1:40P
INCOMING
1
0154
8/03
1:57P
INCOMING
1
0155
8/03
2:24P
NEW YORK
NY
1
0156
8/03
2:24P A
NEW YORK
NY
1
0157
8/03
2:45P
INCOMING
1
0158
8/03
2:46P
RETRIEVAL
LOCAL
1
0159
8/03
5:34P
F
NEW YORK
NY NY
1
.25
0160
8/03
5:35P
F
NEW YORK
NY NY
1
.25
0161
8/03
6:07P F
NEW YORK
NY NY
4
1.00
0162
8/03
6:44P
DELRAY BCH
FL
2
0163
8/03
6:46P
INCOMING
2
0164
8/03
6:47P
NEW YORK
NY
1
0165
8/03
6:50P
NEW YORK
NY
3
0166
8/03
6:53P
NEW YORK
NY
1
0167
8/03
6:57P
NEW YORK
NY
1
0168
8/03
6:57P
NEW YORK
NY
1
0169
8/03
9:12P
RETRIEVAL
LOCAL
1
0170
8/03
9:30P
INCOMING
3
0171
8/03
10:46P
INCOMING
1
0172
8/03 10:52P
NEW YORK
NY
1
0173
8/03 10:52P
NEW YORK
NY
2
0174
8/04
6:18A
INCOMING
1
0175
8/04
9:49A
W PALM BCH
FL
FL
1
0176
8/04
9:50A
WEST PALM
FL
FL
4
0177
8/04
9:57A
INCOMING
FL
3
0178
8/04
10:28A
NEW YORK
NY
FL
2
0179
8/04
10:30A
NEW YORK
NY
FL
5
0180
8/04 10:34A S
UN. KINGDO
FL
1
0181
8/04 10:35A
UN. KINGDO
FL
2
.700
0182
8/04
10:38A
UN. KINGDO
FL
1
.350
0183
8/04
12:58P
RETRIEVAL
NEW YORK C NY US
1
0184
8/04
12:59P
RETRIEVAL
NEW YORK C NY US
1
0185
8/04
1:00P
NEW YORK
NY US
1
0186
8/04
1:00P
NEW YORK
NY
US
1
0187
8/04
4:39P
RETRIEVAL
0188
8/04
RETRIEVAL
NEW YORK CC NY US
1
5:07P
NEW YORK NY US
1
0189
8/04
5:16P
NEW YORK
NY
US
5
0190
8/04
5:57P
INCOMING
US
6
0191
8/04
7:21P
INCOMING
US
1
0192
8/04
10:20P
RETRIEVAL
NEW YORK C NY
US
1
0193
8/05
11:26A
INCOMING
US
1
0194
8/05 11:30A
INCOMING
US
1
0195
8/05
4:15P
W PALM BCH FL US
1
0196
8/05
4:55P
C ST CROIX VI US
1
0197
8/05
4:59P
NEW YORK C NY US
2
0198
8/05
5:02P
NEW YORK
NY
US
5
0199
8/05
5:07P
INCOMING
US
1
0200
8/05
5:21P
INCOMING
US
4
0201
8/05
5:22P
INCOMING
US
10
0202
8/05
5:32P
RETRIEVAL
NEW YORK C NY
US
1
0203
8/05
5:32P
NEW YORK NY US
1
0204
8/05
5:41P
INCOMING
US
2
0205
8/05
11:48P
RETRIEVAL
NEW YORK C NY
US
1
0206
8/06
9:49A
INCOMING
US
3
0207
8/06 10:46A
INCOMING
US
5
EFTA00014735

=== Page 19 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER
BILL DATE PAGE 22.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0208
8/06
10:59A
INCOMING
US
5
0209
8/06
11:57A
INCOMING
US
2
0210
8/06
12:01P
INCOMING
US
8
0211
8/06
1:29P
INCOMING
US
0212
8/06
1:56P
INCOMING
US
5
0213
8/06
4:13P
INCOMING
US
5
0214
8/06
4:18P
RETRIEVAL
NEW YORK C NY
US
2
0215
8/06
4:19P
NEW YORK
NY
US
13
0216
8/06
4:40P
GARDENA
CA
US
1
0217
8/07
11:13A
RETRIEVAL
NEW YORK C NY
US
0218
8/07 11:22A
INCOMING
US
13
0219
8/07
11:54A
CHARLT AML VI
US
0220
8/07
12:14P
QUEENS
NY
US
2
0221
8/07
12:48P
CHARLT AML
VI
US
5
0222
8/07
12:56P
RETRIEVAL
NEW YORK C NY
US
0223
8/07 12:58P
NEW YORK
NY
US
2
0224
8/07
1:10P
QUEENS
NY
US
1
0225
8/07
1:11P
NEW YORK
NY
US
1
0226
8/07
1:39P
NEW YORK
NY
US
0227
8/07
1:49P
INCOMING
US
5
0228
8/07
1:55P
INCOMING
US
5
0229
8/07
2:27P
INCOMING
US
2
0230
8/07
2:32P
NEW YORK
NY
US
2
0231
8/07
2:48P
INCOMING
US
0232
8/07
2:56P
INCOMING
US
0233
8/07
2:58P
ISLA VERDE PR
US
2
0234
8/07
4:47P
INCOMING
US
1
0235
8/07
6:57P
INCOMING
US
0236
8/07
9:01P
RETRIEVAL
NEW YORK C NY
US
2
0237
8/07
11:01P
INCOMING
US
15
0238
8/08
8:39A
INCOMING
US
5
0239
8/08
8:49A
RETRIEVAL
NEW YORK C NY
US
1
0240
8/08
8:53A
CHARLT AML VI
US
0241
8/08
10:16A
RETRIEVAL
NEW YORK C NY
US
2
0242
8/08
11:34A
INCOMING
US
1
0243
8/08
12:01P
INCOMING
US
1
0244
8/08
12:06P
W PALM BCH FL
US
2
0245
8/08
1:20P
INCOMING
US
2
0246
8/08
1:24P
INCOMING
US
3
0247
8/08
1:30P
INCOMING
US
1
0248
8/08
3:24P
INCOMING
US
3
0249
8/08
3:30P
MORIARTY
NM
US
2
0250
8/08
3:46P
INCOMING
US
0251
8/08
3:46P
INCOMING
US
6
0252
8/08
3:59P
UN. KINGDO
US
.350
0253
8/08
5:51P
NEW YORK
NY
US
0254
8/08
6:16P
RETRIEVAL
NEW YORK C NY
US
2
0255
8/08
6:49P
INCOMING
US
3
0256
8/09
12:24P
RETRIEVAL
NEW YORK C NY
US
0257
8/09
4:23P
INCOMING
US
2
0258
8/09
4:43P
W PALM BCH FL
US
0259
8/09
4:44P
W PALM BCH FL
US
0260
8/09
5:01P
INCOMING
US
0261
8/09
6:28P
QUEENS
NY
US
0262
8/09
6:29P
W PALM BCH
FL
US
0263
8/10
10:34A
INCOMING
US
4
0264
8/10
7:10P
NEW YORK
NY
1
0265
8/10
7:11P
RETRIEVAL
LOCAL
0266
8/10
8:30P
W PALM BCH FL
0267
8/10
8:49P
INCOMING
1
EFTA00014736

=== Page 20 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 23.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0268 8/10 8:52P
INCOMING
1
0269
8/10
8:55P
INCOMING
1
0270
8/10
9:16P
INCOMING
2
0271 8/11 10:09A
F
NEW YORK
NY NY
6
1.50
0272
8/11
10:14A
F
NEW YORK
NY NY
1
.25
0273
8/11
10:16A
F
NEW YORK
NY NY
4
1.00
0274 8/11 12:06P
F
NEW YORK
NY NY
1
.25
0275
8/11
12:38P
F
NEW YORK
NY NY
1
.25
0276
8/11
1:02P
F
NEW YORK
NY NY
5
1.25
0277
8/11
1:27P
F
NEW YORK
NY NY
1
.25
0278
8/11
2:00P
F
NEW YORK
NY NY
2
.50
0279
8/11
2:04P
F
NEW YORK
NY NY
1
.25
0280
8/11
2:05P
F
NEW YORK
NY NY
4
1.00
0281
8/11
5:59P
F
NEW YORK
NY NY
1
.25
0282
8/11
6:08P
F
NEW YORK
NY NY
1
.25
0283
8/11
6:23P
F
NEW YORK
NY NY
1
.25
0284
8/11
6:27P
F
NEW YORK
NY NY
1
.25
0285
8/11
6:30P
F
NEW YORK
NY NY
1
.25
0286
8/11
6:59P
F
NEW YORK
NY NY
1
.25
0287
8/11
7:05P
F
NEW YORK
NY NY
1
.25
0288
8/11
7:21P
F
NEW YORK
NY NY
3
.75
0289
8/11
7:47P
F
NEW YORK
NY NY
12
3.00
0290
8/11
8:41P
F
NEW YORK
NY NY
1
.25
0291
8/11
9:16P
NEW YORK
NY
1
0292
8/11
9:59P
NEW YORK
NY
2
0293
8/12
9:41A
F
NEW YORK
NY NY
3
.75
0294
8/12
10:15A
F
NEW YORK
NY NY
1
.25
0295
8/12
10:15A
F
NEW YORK
NY NY
8
2.00
0296
8/12
11:13A
F
NEW YORK
NY NY
2
.50
0297
8/12
12:09P
INCOMING
1
0298
8/12
12:26P
INCOMING
2
0299
8/12
12:58P
INCOMING
10
0300
8/12
2:59P
INCOMING
1
0301
8/12
5:14P
INCOMING
1
0302
8/12
7:10P
F
NEW YORK
NY NY
1
.25
0303 8/12 10:15P
F
NEW YORK
NY NY
32
8.00
0304 8/12 11:00P F
NEW YORK
NY NY
5
1.25
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
707
39.75
15.40
CALL CHARACTERISTICS:
F = Call Forwarding, T = 3 - Party Calling,
A = Automatic Dropped Call Credit
S = Long Distance Service Billed Separately
"CALLS FROM" KEY:
NY = NEW YORK, ME = MAINE, FL = FLORIDA
MESSAGING, CONTENT & APPLICATION CHARGES
Message
Message
Ref Date Time Message To Typ Chrg Ref Date Time Message To Typ Chrg
0001
8/12
8:14P
S
10 0002
8/12
8:28P
0003
9:16P
.10 0004 8/12 9:24P
S
.10
8/12
.10
EFTA00014737

=== Page 21 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 24.0
JEFFREY E EPSTEIN &
AUG 14, 2003
Message
Message
Ref Date Time Message To Typ Chrg Ref Date Time Message To Typ Chrg
0005 8/12 9:26P
S
.10
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
.50
Message Types:
R= Received Messages
S= Sent Messages
I= International Messages
Times for Messaging, Content & Application charges are in your home time zone.
ROAMING CHARGES
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
Calls Made From: ST. THOMAS, VI
0001
8/04
1:16P
QUEENS NYC NY
3
1.80
.45
0002
8/04
1:20P
QUEENS NYC NY
1
.60
.15
0003 8/04 1:22P
NEW YORK
NY
2
1.20
.30
0004
8/04
1:25P
QUEENS NYC NY
.60
.15
0005
8/04
1:26P
NEW YORK
NY
2
1.20
.30
0006
8/04
1:28P
QUEENS NYC NY
1
.60
.15
0007
8/04
4:31P
NEW YORK
NY
1
.60
.15
0008
8/04
4:31P
NEW YORK
NY
1
.60
.15
0009 8/04 5:52P
QUEENS NYC NY
1
.60
.15
0010
8/05
12:05P
MORIARTY
NM
3
1.80
.45
0011
8/05
12:07P
NEW YORK
NY
4
2.40
.60
0012
8/05
12:11P
QUEENS NYC NY
1
.60
.15
0013
8/05
12:12P
NEW YORK
NY
2
1.20
.30
0014 8/05 12:13P
INCOMING
1
.60
0015 8/05 12:13P
INCOMING
1
.60
0016 8/05 12:14P
QUEENS NYC NY
3
1.80
.45
0017 8/05 12:20P
NEW YORK
NY
1
.60
.15
0018
8/05
12:21P
NEW YORK
NY
2
1.20
.30
0019 8/05 4:00P
INCOMING
1
.60
0020 8/07 9:08P
CHICAGO
IL
2
1.20
.30
Subtotal for
: ST. THOMAS, VI
34
20.40
4.65
.00
Calls Made From: ITALY,
0021
7/25
7:32P
INTL NTWK
1
.99
.35
0022
7/25
7:33P
INTL NTWK
1
.99
0023 7/25 8:40P
INTL NTWK
1
.99
0024 7/25 9:12P
INTL NTWK
2
1.98
.70
0025
7/25
9:52P
INTL NTWK
1
.99
.35
0026
7/25
9:53P
INTL NTWK
3
2.97
1.05
0027
7/26
1:54A
INTL NTWK
1
.99
.35
0028
7/26
2:44A
INTL NTWK
-
.99
.35
0029
7/26
2:45A
INTL NTWK
1
.99
.35
0030
7/26
2:47A
INTL NTWK
1
.99
.35
0031
7/26
12:56P
INTL NTWK
1
.99
.35
0032
7/26
12:57P
INTL NTWK
1
.99
.35
0033
7/26
12:59P
INTL NTWK
1
I
.99
.35
0034
7/26
1:05P
INTL NTWK
4
3.96
1.40
0035
7/26
1:17P
INTL NTWK
1
.99
.35
0036
7/26
1:17P
INTL NTWK
1
.99
.35
EFTA00014738

=== Page 22 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 25.0
JEFFREY E EPSTEIN &
AUG 14, 2003
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0037 7/26 1:37P
INTL NTWK
1
.99
.35
0038
7/26
5:58P
INTL NTWK
2
1.98
.70
0039
7/26
8:27P
INTL NTWK
1
.99
.35
0040 7/26 9:02P
INTL NTWK
2
1.98
.70
0041 7/26 9:04P
INTL NTWK
21
20.79
7.35
0042 7/27 12:00A
CALL SVC
1
.99
0043 7/27 5:26P
INTL NTWK
1
.99
.35
0044 7/27 11:06P
INTL NTWK
7
6.93
2.45
Subtotal for : ITALY,
58
57.42
19.95
.00
Calls Made From: FRANCE,
0045
7/21
4:35P
INTL NTWK
2
1.98
.70
0046 7/21 9:57P
INTL NTWK
1
.99
.35
0047 7/21 10:01P
INTL NTWK
11
10.89
3.85
0048
7/22
6:19P
INTL NTWK
1
.99
.35
0049
7/22
7:04P
INTL NTWK
1
.99
.35
0050
7/22
7:11P
INTL NTWK
2
1.98
.70
0051
7/22
8:25P
INTL NTWK
2
1.98
.70
0052 7/22 8:27P
INTL NTWK
1
.99
.35
0053 7/22 8:36P
INTL NTWK
3
2.97
1.05
0054 7/22 11:37P
INTL NTWK
4
3.96
1.40
0055 7/22 11:40P
INTL NTWK
1
.99
.35
0056 7/22 11:42P
INTL NTWK
1
.99
.35
0057 7/23 10:59A
INTL NTWK
2
1.98
.70
Subtotal for
: FRANCE,
32
31.68
11.20
.00
Calls Made From: FRANCE,
0058 7/29 10:50A
INTL NTWK
1
.99
.35
Subtotal for : FRANCE,
1
.99
.35
.00
Calls Made From: ITALY,
0059
7/03
3:43P
INTL NTWK
7
6.93
2.45
0060 7/03 3:50P
INTL NTWK
6
5.94
2.10
0061 7/03 4:43P
INTL NTWK
1
.99
.35
0062 7/03 4:44P
INTL NTWK
13
12.87
4.55
0063 7/03 4:57P
INTL NTWK
4
3.96
1.40
0064
7/03
5:01P
INTL NTWK
10
9.90
3.50
0065
7/03
5:10P
INTL NTWK
11
10.89
3.85
0066
7/03
5:21P
INTL NTWK
2
1.98
.70
0067
7/03
5:31P
INTL NTWK
3
2.97
1.05
0068
7/03
5:34P
INTL NTWK
1
.99
.35
0069
7/03
5:45P
INTL NTWK
1
.99
.35
0070
7/03
5:46P
INTL NTWK
1
.99
.35
0071
7/03
5:59P
INTL NTWK
1
.99
.35
0072
7/03
5:59P
INTL NTWK
3
2.97
1.05
0073
7/03
6:01P
INTL NTWK
.99
.35
0074 7/03 6:03P
INTL NTWK
10
9.90
3.50
0075 7/03 6:13P
INTL NTWK
2
1.98
.70
0076
7/03
7:58P
INTL NTWK
1
.99
.35
0077 7/03 8:01P
INTL NTWK
2
1.98
.70
0078 7/04 12:48A
INTL NTWK
1
.99
.35
0079 7/04 12:51A
INTL NTWK
1
.99
.35
0080
7/04 12:20P
INTL NTWK
2
1.98
.70
0081 7/04 1:36P
INTL NTWK
2
1.98
.70
0082
7/04
3:29P
INTL NTWK
1
.99
.35
0083
7/04
8:20P
INTL NTWK
3
2.97
1.05
0084
7/04
9:42P
INTL NTWK
1
.99
.35
EFTA00014739

=== Page 23 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 26.0
JEFFREY E EPSTEIN &
AUG 14, 2003
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
Subtotal for : ITALY,
91
90.09
31.85
.00
Calls Made From: GREAT BRITAIN,
0085
7/03
6:57A
INTL NTWK
3
2.97
1.05
0086 7/13 12:00A
CALL SVC
1
.99
0087 7/13 11:38A
INTL NTWK
2
1.98
.70
0088
7/13
4:56P
INTL NTWK
1
.99
.35
0089 7/14 12:00A
CALL SVC
1
.99
0090 7/14 1:21P
INTL NTWK
3
2.97
1.05
0091 7/14 5:15P
INTL NTWK
1
.99
.35
0092
7/15
12:13A
INTL NTWK
1
.99
.35
0093
7/15
12:30A
INTL NTWK
5
4.95
1.75
0094
7/15
1:07P
INTL NTWK
1
.99
.35
0095
7/15
1:08P
INTL NTWK
29
28.71
10.15
0096
7/16
12:00A
CALL SVC
1
.99
0097
7/16
1:55P
INTL NTWK
1
.99
.35
0098
7/16
5:10P
INTL NTWK
3
2.97
1.05
0099
7/16
6:34P
INTL NTWK
2
1.98
.70
0100 7/16 11:07P
INTL NTWK
2
1.98
.70
0101 7/17 12:42A
INTL NTWK
1
.99
.35
0102 7/17 12:48P
INTL NTWK
.99
0103
7/17
3:57P
INTL NTWK
1
.99
0104 7/17 4:59P
INTL NTWK
1
.99
0105 7/17 8:44P
INTL NTWK
1
.99
0106
7/17 11:42P
INTL NTWK
1
.99
0107
7/18
9:33A
INTL NTWK
1
.99
0108
7/18
4:25P
INTL NTWK
2
1.98
.70
0109
7/18
9:14P
INTL NTWK
1
.99
.35
0110
7/18
9:17P
INTL NTWK
1
.99
.35
0111 7/18 10:45P
INTL NTWK
6
5.94
2.10
0112 7/19 11:53A
INTL NTWK
2
1.98
.70
0113 7/19 2:40P
INTL NTWK
1
.99
.35
Subtotal for
: GREAT BRITAIN,
77
76.23
25.90
.00
Calls Made From: ITALY,
0114 7/28 12:00A
CALL SVC
1
.99
0115 7/28 1:50P
INTL NTWK
1
.99
0116 7/28 1:51P
INTL NTWK
1
.99
0117 7/28 1:53P
INTL NTWK
1
.99
0118 7/28 2:02P
INTL NTWK
1
.99
.35
0119 7/28 3:57P
INTL NTWK
1
.99
.35
Subtotal for : ITALY,
6
5.94
1.75
.00
Calls Made From: SPAIN,
0120 7/23 12:00A
CALL SVC
1
.60
0121 7/23 4:44P
INTL NTWK
2
1.20
0122
7/23
4:52P
INTL NTWK
.60
0123
7/23
5:08P
INTL NTWK
3
1.80
0124
7/23
6:57P
INTL NTWK
2
1.20
0125
7/23
6:59P
INTL NTWK
1
.60
0126 7/23 8:30P
INTL NTWK
3
1.80
0127 7/23 8:33P
INTL NTWK
4
2.40
0128 7/24 12:00A
CALL SVC
1
.60
0129
7/24
1:33P
INTL NTWK
2
1.20
0130
7/24
3:45P
INTL NTWK
1
.60
0131
7/24
5:59P
INTL NTWK
.60
0132
7/24
6:29P
INTL NTWK
1
.60
EFTA00014740

=== Page 24 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 27.0
JEFFREY E EPSTEIN &
AUG 14, 2003
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0133 7/24 7:05P
INTL NTWK
1
.60
0134
7/24
9:01P
INTL NTWK
2
1.20
0135 7/24 9:03P
INTL NTWK
4
2.40
0136 7/24 9:07P
INTL NTWK
4
2.40
0137 7/24 9:53P
INTL NTWK
2
1.20
0138 7/25 12:22A
INTL NTWK
1
.60
0139 7/25 12:23A
INTL NTWK
1
.60
0140 7/25 12:24A
INTL NTWK
1
.60
0141
7/25
1:40P
INTL NTWK
1
.60
0142 7/25 1:50P
INTL NTWK
1
H
.60
0143 7/25 2:01P
INTL NTWK
1
.60
0144 7/25 2:02P
INTL NTWK
3
1.80
0145 7/25 2:33P
INTL NTWK
4
2.40
0146 7/25 2:47P
INTL NTWK
2
1.20
Subtotal for : SPAIN,
51
30.60
.00
.00
Calls Made From: FRANCE,
0147 7/11 2:24A
INTL NTWK
1
.99
.35
Subtotal for : FRANCE,
1
.99
.35
.00
TOTAL ROAMING CHARGES
351
314.34
96.00
.00
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
EFTA00014741

=== Page 25 ===
ACCOUNT NAME
ACCOUNT
NUMBER
NUMBER
BILL DATE PAGE 29.0
JEFFREY E EPSTEIN &
AUG 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
7/13/03 Through 8/12/03
MONTHLY SE - LOCAL PLAN $39.99
39.99
CALL FORWARDING
.00
THREE WAY CALLING
.00
CALL WAITING
.00
CALLER ID
.00
ENH DISCOUNT INTL DIAL
3.99
PCS VOICEMAIL W/NUMERIC MSG
.00
DETAIL BILLING
.00
AT&T 2-WAY TEXT MSG $0.00
.00
AT&T TOLL FREE NATIONWIDE
4.99
AT&T TOLL FREE CREDIT
4.99CR
REGULATORY PROGRAMS FEE
1.75
TOTAL MONTHLY SERVICE CHARGES
45.73
HOME AIRTIME CHARGES
7/07/03 Through 8/12/03 - LOCAL PLAN $39.99
Category
Minutes
Rate
Charge
UNLIMITED NIGHT & WKND
186
.000
.00
300 ADDITIONAL MINUTES
300
.000
.00
INCLUDED IN PLAN
79
.000
.00
565
.00
TOTAL HOME AIRTIME CHARGES
.00
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
1.51
STATE TAX
2.09
LOCAL TAX
2.15
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
.94
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
.96
GROSS RECEIPTS SURCHARGE
1.61
TOTAL TAXES, SURCHARGES & REGULATORY FEES
10.76
TOTAL CURRENT MONTHLY CHARGES
56.49
EFTA00014742

=== Page 26 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 30.0
JEFFREY E EPSTEIN &
AUG 14, 2003
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0001 7/07 11:00A
NEW YORK
NY
2
0002 7/13 11:16A
LOCAL
1
0003
7/13
4:16P
BROOKLYN
NY
2
0004 7/13 8:41P
BROOKLYN
NY
2
0005
7/13
8:43P
RETRIEVAL
LOCAL
1
0006
7/13
8:46P
INCOMING
1
0007
7/14
10:51A
NEW YORK
NY
1
0008 7/14 11:35A
INCOMING
1
0009 7/14 11:46A
BROOKLYN
NY
2
0010 7/14 12:09P
QUEENS
NY
1
0011 7/14 12:10P
NEW YORK
NY
1
0012
7/14
12:45P
LOCAL
1
0013
7/14
1:10P
NEW YORK
NY
2
0014
7/14
1:53P
LOCAL
2
0015
7/14
3:16P
NEW YORK
NY
1
0016
7/14
5:21P
BROOKLYN
NY
1
0017
7/14
5:22P
BROOKLYN
NY
2
0018
7/14
6:09P
INCOMING
3
0019
7/14
6:20P
NEW YORK
NY
0020
7/14
7:42P
INCOMING
0021
7/14
7:45P
INCOMING
1
0022 7/15 12:53P
INCOMING
1
0023 7/15 12:54P
INCOMING
1
0024 7/15 12:59P
NEW YORK
NY
1
0025
7/15
1:02P
NEW YORK
NY
0026
7/15
1:06P
INCOMING
2
0027
7/15
1:46P
INCOMING
1
0028
7/15
1:49P
NEW YORK
NY
0029 7/15 2:13P
INCOMING
0030
7/15
2:15P
NEW YORK
NY
0031
7/15
2:16P
INCOMING
1
0032
7/15
2:30P
INCOMING
1
0033
7/15
3:09P
NEW YORK
NY
1
0034
7/16
10:57A
NEW YORK
NY
1
0035
7/16
11:40A
INCOMING
1
0036
7/16
12:44P
INCOMING
1
0037
7/16
2:31P
NEW YORK
NY
4
0038
7/16
3:00P
INCOMING
1
0039
7/16
4:14P
NEW YORK
NY
2
0040 7/17 10:34A
INCOMING
1
0041 7/17 11:39A
NEW YORK
NY
3
0042 7/17 11:47A
INCOMING
2
0043
7/17
1:04P
BROOKLYN
NY
2
0044
7/17
3:33P
BROOKLYN
NY
4
0045
7/17
5:44P
BROOKLYN
NY
1
0046
7/17
5:48P
NEW YORK
NY
1
0047
7/17
5:49P
INCOMING
0048
7/17
5:50P
INCOMING
1
0049
7/17
5:55P
INCOMING
1
0050
7/18
9:55A
NEW YORK
NY
2
0051
7/18
10:06A
INCOMING
1
0052 7/18 10:07A
NEW YORK
NY
1
0053 7/18 10:29A
INCOMING
0054
7/18
12:17P
NEW YORK
NY
1
0055
7/18
12:38P
NEW YORK
NY
2
0056
7/18
1:14P
NEW YORK
NY
0057
7/18
1:16P
INCOMING
0058
7/18
1:17P
NEW YORK
NY
1
0059
7/18
1:19P
INCOMING
1
0060
7/18
1:28P
RETRIEVAL
LOCAL
1
EFTA00014743

=== Page 27 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 31.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0061
7/18
1:32P
NEW YORK
NY
1
0062
7/18
1:33P
QUEENS
NY
2
0063
7/18
1:34P W W
INCOMING
1
0064
7/18
1:34P
W
QUEENS
NY
1
0065
7/18
1:44P
INCOMING
1
0066
7/18
2:32P
NEW YORK
NY
1
0067
7/18
2:44P
INCOMING
2
0068
7/18
2:48P
INCOMING
1
0069
7/18
2:51P
NEW YORK
NY
1
0070
7/18
3:01P
NEW YORK
NY
3
0071
7/18
3:45P
INCOMING
1
0072
7/18
4:03P
NEW YORK
NY
2
0073
7/18
4:06P
NEW YORK
NY
1
0074
7/18
4:28P
NEW YORK
NY
2
0075
7/18
5:07P
NEW YORK
NY
1
0076
7/18
5:33P
NEW YORK
NY
1
0077
7/18
5:35P
NEW YORK
NY
1
0078
7/18
8:04P
BROOKLYN
NY
1
0079
7/18
8:05P
NEW YORK
NY
3
0080
7/28
10:31A
INCOMING
2
0081
7/28
10:59A
NEW YORK
NY
5
0082
7/28
11:51A
NEW YORK
NY
2
0083
7/28
12:26P
INCOMING
1
0084
7/29
9:40A
INCOMING
1
0085
7/29
10
34A
INCOMING
1
0086
7/29
10:53A
INCOMING
1
0087
7/29
11:05A
INCOMING
3
0088
7/29
11:36A
INCOMING
1
0089
7/29
12:33P
NEW YORK
NY
1
0090
7/29
12:38P
INCOMING
1
0091
7/29
2:04P
INCOMING
1
0092
7/29
3:47P
INCOMING
1
0093
7/29
3:48P
NEW YORK
NY
1
0094
7/29
4:08P
NEW YORK
NY
1
0095
7/29
4:55P
INCOMING
1
0096
7/29
5:56P
INCOMING
1
0097
7/29
6:47P
NEW YORK
NY
1
0098
7/29
6:48P
NEW YORK
NY
2
0099
7/29
7:10P
BROOKLYN
NY
6
0100
7/29
7:16P
NEW YORK
NY
2
0101
7/29
8:16P
PTWASHIGTN
NY
2
0102
7/29
8:20P
NEW YORK
NY
1
0103
7/29
8:40P
QUEENS
NY
1
0104
7/29
8:41P
QUEENS
NY
1
0105
7/29
9:02P
NEW YORK
NY
1
0106
7/29
9:16P
NEW YORK
NY
1
0107
7/29
9:31P
NEW YORK
NY
1
0108
7/30
9:38A
NEW YORK
NY
1
0109
7/30
9:43A
INCOMING
2
0110
7/30
10:37A
NEW YORK
NY
3
0111
7/30
10:40A
BROOKLYN
NY
6
0112
7/30
11:51A
INCOMING
1
0113
7/30
12:07P
PETRIEVAL
LOCAL
1
0114
7/30
12:08P
NEW YORK
NY
2
0115
7/30
1:14P
NEW YORK
NY
1
0116
7/30
1:16P
NEW YORK
NY
1
0117
7/30
2:09P
NEW YORK
NY
1
0118
7/30
2:14P
INCOMING
1
0119
7/30
2:22P
NEW YORK
NY
1
0120
7/30
2:56P
NEW YORK
NY
2
EFTA00014744

=== Page 28 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 32.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0121
7/30
3:04P
NEW YORK
NY
1
0122
7/30
3:05P
LOCAL
1
0123
7/30
3:05P
NEW YORK
NY
1
0124
7/30
3:07P
RETRIEVAL
LOCAL
0125
7/30
3:15P
INCOMING
1
0126
7/30
3:39P
NEW YORK
NY
3
0127
7/30
3:50P
INCOMING
1
0128
7/30
4:41P
NEW YORK
NY
2
0129
7/30
5:39P
NEW YORK
NY
1
0130
7/30
5:41P
INCOMING
1
0131
7/30
5:43P
INCOMING
0132
7/30
7:07P
NEW YORK
NY
0133
7/30
8:22P
NEW YORK
NY
3
0134
7/30
8:40P
LOCAL
1
0135
7/30
8:58P
BROOKLYN
NY
2
0136
7/30
9:08P
INCOMING
1
0137
7/30
9:11P
BROOKLYN
NY
7
0138
7/30
10:07P
BROOKLYN
NY
4
0139
7/30
10:11P
NEW YORK
NY
1
0140
7/31
9:00A
INCOMING
1
0141
7/31
9:30A
INCOMING
0142
7/31
9:58A
INCOMING
0143
7/31
10:51A
BROOKLYN
NY
2
0144
7/31
10:56A
NEW YORK
NY
2
0145
7/31
11:01A
NEW YORK
NY
2
0146
7/31
12:24P
INCOMING
0147
7/31
12:30P
INCOMING
2
0148
7/31
12:53P
INCOMING
1
0149
7/31
1:09P
INCOMING
1
0150
7/31
1:37P
NEW YORK
NY
0151
7/31
1:41P
NEW YORK
NY
0152
7/31
1:43P
INCOMING
6
0153
7/31
2:10P
NEW YORK
NY
1
0154
7/31
2:11P
NEW YORK
NY
1
0155
7/31
2:30P
NEW YORK
NY
1
0156
7/31
2:35P
INCOMING
2
0157
7/31
3:30P
INCOMING
1
0158
7/31
3:38P
NEW YORK
NY
1
0159
7/31
4:21P
NEW YORK
NY
1
0160
7/31
4:27P
NEW YORK
NY
1
0161
7/31
4:50P
NEW YORK
NY
0162
7/31
4:52P
INCOMING
0163
7/31
5:12P
RETRIEVAL
LOCAL
2
0164
7/31
5:15P
INCOMING
1
0165
7/31
5:24P
INCOMING
1
0166
7/31
5:44P
INCOMING
1
0167
7/31
5:48P
INCOMING
1
0168
7/31
5:49P
NEW YORK
NY
0169
7/31
5:54P
NEW YORK
NY
0170
7/31
6:04P
NEW YORK
NY
1
0171
7/31
6:17P
NEW YORK
NY
2
0172
7/31
6:40P
INCOMING
0173
7/31
6:40P
INCOMING
0174
7/31
7:22P
INCOMING
2
0175
7/31
7:58P
INCOMING
1
0176
7/31
7:58P
INCOMING
0177
7/31
8:16P
INCOMING
0178
7/31
8:23P
NEW YORK
NY
0179
7/31
8:32P
NEW YORK
NY
2
0180
7/31
9:28P
NEW YORK
NY
1
EFTA00014745

=== Page 29 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 33.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0181
7/31
9:28P
BROOKLYN
NY
1
0182
7/31
9:29P
INCOMING
11
0183
7/31
9:42P
NEW YORK
NY
1
0184
7/31
9:42P
INCOMING
2
0185
8/01
10:36A
BROOKLYN
NY
0186
8/01
10:41A
INCOMING
1
0187
8/01
10:43A
NEW YORK
NY
1
0188
8/01
11:18A
INCOMING
1
0189
8/01
11:20A
NEW YORK
NY
2
0190
8/01
11:30A
NEW YORK
NY
1
0191
8/01
11:31A
NEW YORK
NY
1
0192
8/01
11:37A
INCOMING
0193
8/01
11:47A
INCOMING
1
0194
8/01
1:08P
RETRIEVAL
LOCAL
1
0195
8/01
1:09P
NEW YORK
NY
0196
8/01
1:16P
NEW YORK
NY
0197
8/01
1:50P
INCOMING
2
0198
8/01
2:06P
NEW YORK
NY
1
0199
8/01
2:07P
NEW YORK
NY
0200
8/01
2:08P
NEW YORK
NY
0201
8/01
2:30P
NEW YORK
NY
2
0202
8/01
4:15P
NEW YORK
NY
0203
8/01
4:20P
INCOMING
0204
8/01
4:31P
INCOMING
2
0205
8/01
5:01P
INCOMING
1
0206
8/01
5:08P
NEW YORK
NY
0207
8/01
5:17P
INCOMING
0208
8/01
6:44P
NEW YORK
NY
1
0209
8/01
8:42P
NEW YORK
NY
1
0210
8/01
8:47P
INCOMING
0211
8/01
9:01P
INCOMING
1
0212
8/01
9:05P
NEW YORK
NY
0213
8/01
9:06P
NEW YORK
NY
1
0214
8/01
9:11P
INCOMING
1
0215
8/01
9:30P
NEW YORK
NY
5
0216
8/01
10:07P
NEW YORK
NY
15
0217
8/01
10:22P
NEW YORK
NY
8
0218
8/01
10:36P
INCOMING
5
0219
8/01
10:41P
NEW YORK
NY
0220
8/01
10:53P
NEW YORK
NY
0221
8/01
10:55P
INCOMING
6
0222
8/02
11:25A
-BROOKLYN
NY
2
0223
8/02
4:45P
NEW YORK
NY
2
0224
8/02
4:56P
INCOMING
0225
8/02
5:09P
INCOMING
0226
8/02
5:24P
NEW YORK
NY
5
0227
8/02
5:30P
NEW YORK
NY
1
0228
8/02
:35P
NEW YORK
NY
0229
8/02
:55P
INCOMING
0230
8/02
:18P
INCOMING
3
0231
8/02
6:31P
INCOMING
1
0232
8/02
6:35P
BROOKLYN
NY
0233
8/02
9:03P
NEW YORK
NY
0234
8/02
9:06P
INCOMING
0235
8/02
9:08P
NEW YORK
NY
0236
8/02
9:29P
NEW YORK
NY
0237
8/03
11:36A
RETRIEVAL
LOCAL
2
0238
8/03
12:05P
INCOMING
0239
8/03
12:08P
RETRIEVAL
LOCAL
2
0240
8/03
12:19P
INCOMING
1
EFTA00014746

=== Page 30 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 34.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0241 8/03 12:47P
BROOKLYN
NY
3
0242
8/03
1:15P
NEW YORK
NY
2
0243
8/03
1:17P
LOCAL
1
0244
8/03
:29P
NEW YORK
NY
2
0245
8/03
:32P
INCOMING
3
0246
8/03
2:39P
INCOMING
2
0247
8/03
:55P
NEW YORK
NY
1
0248
8/03
:59P
NEW YORK
NY
3
0249
8/03
:07P
NEW YORK
NY
1
0250
8/03
6:59P
INCOMING
5
0251
8/03
10:02P
LAS VEGAS
NV
1
0252
8/03
10:03P
A A
LAS VEGAS
NV
0253
8/03
10:04P
LAS VEGAS
NV
1
0254
8/03
10:05P
LAS VEGAS
NV
19
0255
8/03 11:25P
INCOMING
1
0256
8/04
:57A
INCOMING
1
0257
8/04
:18A
INCOMING
1
0258
8/04
:26A
NEW YORK
NY
4
0259
8/04
01A
NEW YORK
NY
1
0260
8/04
8:43A
INCOMING
1
0261
8/04
:44A
NEW YORK
NY
0262
8/04 1
:36A
INCOMING
0263
8/04
:31P
NEW YORK
NY
0264
8/04
2:57P
NEW YORK
NY
3
0265
8/04
10P
INCOMING
0266
8/05 12:09P
BROOKLYN
NY
0267
8/05 12:13P
BROOKLYN
NY
2
0268
8/06
10:13A
BROOKLYN
NY
0269
8/06
10:53A
INCOMING
3
0270
8/06
10:58A
NEW YORK
NY
5
0271
8/07
2A
NEW YORK
NY
0272
8/07
11:27A
NEW YORK
NY
0273
8/07
11:28A
NEW YORK
NY
0274
8/07
11:32A
INCOMING
0275
8/07
1:07P
BROOKLYN
NY
2
0276
8/07
1:57P
INCOMING
1
0277
8/08
3:02P
BROOKLYN
NY
2
0278
8/08
:11P
NEW YORK
NY
0279
8/08
:12P
NEW YORK
NY
2
0280
8/08
15P
NEW YORK
NY
0281
8/08
16P
INCOMING
2
0282
8/08
21P
NEW YORK
NY
2
0283
8/08
:54P
INCOMING
1
0284
8/09
:02P
NEW YORK
NY
1
0285
8/09
:17P
INCOMING
1
0286
8/09
2:17P
BROOKLYN
NY
2
0287
8/09
3:40P
INCOMING
1
0288
8/09
7:20P
BROOKLYN
NY
4
0289
8/10
4:55P
NEW YORK
NY
0290
8/10
4:58P
NEW YORK
NY
1
0291
8/10
5:39P
BROOKLYN
NY
1
0292
8/10
5:57P
NEW YORK
NY
0293
8/10
5:58P
INCOMING
0294
8/10
6:37P
RETRIEVAL
LOCAL
2
0295
8/10
8:32P
NEW YORK
NY
0296
8/10
8:32P
NEW YORK
NY
0297
8/10
8:51P
NEW YORK
NY
0298
8/10
8:52P
NEW YORK
NY
2
0299
8/11 11:14A
NEW YORK
NY
0300
8/11
11:26A
NEW YORK
NY
1
EFTA00014747

=== Page 31 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 35.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0301 8/11 12:34P
INCOMING
1
0302
8/11
12:34P
NEW YORK
NY
1
0303
8/11 12:56P
NEW YORK
NY
3
0304
8/11
1:51P
INCOMING
2
0305
8/11
2:29P
NEW YORK
NY
1
0306
8/11
2:47P
BROOKLYN
NY
2
0307
8/11
3:01P
NEW YORK
NY
1
0308
8/11
3:22P
INCOMING
4
0309
8/11
3:29P
INCOMING
1
0310 8/11 4:11P
INCOMING
1
0311 8/11 4:29P
NEW YORK
NY
1
0312
8/11
5:14P
RETRIEVAL
-LOCAL
0313
8/11
8:37P
NEW YORK
NY
1
0314
8/12
11:39A
INCOMING
1
0315
8/12
11:46A
RETRIEVAL
LOCAL
2
0316
8/12
11:50A
NEW YORK
NY
1
0317
8/12
12:08P
INCOMING
1
0318
8/12
12:33P
NEW YORK
NY
5
0319
8/12
12:38P
NEW YORK
NY
1
0320
8/12
12:52P
INCOMING
1
0321
8/12
1:21P
QUEENS
NY
0322
8/12
1:26P
NEW YORK
NY
2
0323 8/12 2:08P
INCOMING
1
0324
8/12
2:31P
NEW YORK
NY
2
0325
8/12
2:33P
NEW YORK
NY
1
0326
8/12
2:36P
NEW YORK
NY
1
0327
8/12
2:39P
INCOMING
1
0328
8/12
2:40P
NEW YORK
NY
1
0329
8/12
2:42P
NEW YORK
NY
1
0330
8/12
3:09P
INCOMING
2
0331
8/12
3:17P
NEW YORK
NY
1
0332
8/12
3:17P
NEW YORK
NY
1
0333 8/12 4:07P
INCOMING
2
0334
8/12
4:10P
INCOMING
1
0335
8/12
4:13P
INCOMING
1
0336 8/12 4:19P
NEW YORK
NY
1
0337 8/12 4:38P
INCOMING
1
0338
8/12
5:31P
NEW YORK
NY
2
0339
8/12
5:33P
BROOKLYN
NY
2
0340
8/12
6:04P
INCOMING
2
0341 8/12 6:32P
NEW YORK
NY
1
0342 8/12 7:21P
NEW YORK
NY
1
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
565
.00
.00
CALL CHARACTERISTICS:
W = Call Waiting,
= Automatic Dropped Call Credit
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
EFTA00014748

=== Page 32 ===
ACCOUNT NAME
ACCOUNT
NUMBER
NUMBER
BILL DATE PAGE 37.0
JEFFREY E EPSTEIN &
AUG 14, 2003
SUMMARY OF CHARGES
MONTHLY SERVICE CHARGES
7/13/03 Through 8/12/03
MONTHLY SE - NATIONAL PLAN $199.99
199.99
CALL FORWARDING
.00
CALL WAITING
.00
CALLER ID
.00
WORLDCONNECT
7.99
EQUIP INS PREMIUM/FEE
3.99
PCS VOICEMAIL W/NUMERIC MSG
.00
DETAIL BILLING
.00
AT&T 2-WAY TEXT MSG $0.00
.00
REGULATORY PROGRAMS FEE
1.75
TOTAL MONTHLY SERVICE CHARGES
213.72
HOME AIRTIME CHARGES
7/13/03 Through 8/12/03 - NATIONAL PLAN $199.99
Category
Minutes
Rate
Charge
UNLIMITED NIGHT & WKND
406
.000
.00
200 ADDITIONAL MINUTES
200
.000
.00
INCLUDED IN PLAN
280
.000
.00
---
886
.00
TOTAL HOME AIRTIME CHARGES
.00
HOME LONG DISTANCE CHARGES
AT&T WIRELESS
30.62
TOTAL HOME LONG DISTANCE CHARGES
30.62
MESSAGING, CONTENT & APPLICATION CHARGES
7/13/03 Through 8/12/03
Category
Messages
Rate
Charge
SENT MESSAGES
1
.10
.10
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
.10
EFTA00014749

=== Page 33 ===
ACCOUNT NAME
ACCOUNT
BILL DATE PAGE 38.0
JEFFREY E EPSTEIN &
AUG 14, 2003
SUMMARY OF CHARGES (CONTINUED)
ROAMING CHARGES
ROAMING AIR
919.17
ROAMING LONG DISTANCE CHARGES
282.70
TOTAL ROAMING CHARGES
1,201.87
OTHER CHARGES AND CREDITS
AT&T CONNECT CALLS
1 CALL
1.25
TOTAL OTHER CHARGES AND CREDITS
1.25
TAXES, SURCHARGES & REGULATORY FEES
FEDERAL TAX
13.93
STATE TAX
18.45
LOCAL TAX
18.99
911 SURCHARGE
1.20
NY CITY UTILITY G.R. SUR
8.77
LOCAL WIRELESS SURCHARGE
.30
UNIVERSAL CONNECTIVITY CHARGE
9.00
GROSS RECEIPTS SURCHARGE
15.28
TOTAL TAXES, SURCHARGES & REGULATORY FEES
85.92
TOTAL CURRENT MONTHLY CHARGES
1,533.48
HOME AIRTIME AND LONG DISTANCE CHARGES
CALL
LONG
REF DATE TIME NUMBER CALLED CALLS TO FROM
MIN
AIR
DISTANCE
0001 7/19 9:38A 336/INCOMNG LDRUFFIN
NC NY
0002 7/19 9:47A 336/INCOMNG LDRUFFIN
NC NY
0003 7/19 10:37A 336/INCOMNG LDRUFFIN
NC NY
0004 7/19 10:52A 336/INCOMNG LDRUFFIN
NC NY
0005 7/19 1:53P 336/INCOMNG LDGREENSBORO NC NY
0006 7/19 6:49P 336/INCOMNG LDGREENSBORO NC NY
0007 7/21 7:12A 336/INCOMNG LDGREENSBORO NC NY
0008 7/21 7:30A 336/INCOMNG LDGREENSBORO NC NY
0009 7/21 10:17A 336/INCOMNG LDGREENSBORO NC NY
0010 7/21 11:05A 336/INCOMNG LDGREENSBORO NC NY
0011 7/21 11:13A 336/INCOMNG LDGREENSBORO NC NY
0012 7/21 11:39A 336/INCOMNG LDGREENSBORO NC NY
0013 7/21 11:58A 336/INCOMNG LDGREENSBORO NC NY
0014 7/21 12:23P 336/INCOMNG LDGREENSBORO NC NY
0015 7/21 12:47P 336/INCOMNG LDGREENSBORO NC NY
0016 7/21 2:21P 336/INCOMNG LDGREENSBORO NC NY
0017 7/21 4:25P 336/INCOMNG LDGREENSBORO NC NY
0018 7/21 4:41P 336/INCOMNG LDGREENSBORO NC NY
0019 7/21 5:40P 336/INCOMNG LDGREENSBORO NC NY
EFTA00014750

=== Page 34 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE
NUMBER BILL DATE PAGE 39.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0020
7/22
9:14A 336/INCOMNG LDGREENSBORO NC NY
0021
7/22
9:19A
336/INCOMNG
LDGREENSBORO
NC
NY
0022
7/22
10:52A
336/INCOMNG
LDGREENSBORO
NC
NY
0023
7/22
10:53A
336/INCOMNG
LDGREENSBORO
NC
NY
0024
7/22
11:24A
336/INCOMNG
LDGREENSBORO
NC
NY
0025
7/22
11:49A
336/INCOMNG
LDGREENSBORO
NC
NY
0026
7/22
1:08P
336/INCOMNG
LDGREENSBORO
NC
NY
0027
7/22
1:36P
336/INCOMNG
LDGREENSBORO
NC
NY
0028
7/22
1:43P
336/INCOMNG
LDGREENSBORO
NC
NY
0029
7/22
1:53P
336/INCOMNG
LDGREENSBORO
NC
NY
0030
7/22
4:39P
336/INCOMNG
LDGREENSBORO
NC
NY
0031
7/22
5:08P
336/INCOMNG
LDGREENSBORO
NC
NY
0032
7/22
5:41P
336/INCOMNG
LDGREENSBORO
NC
NY
0033
7/22
5:59P
336/INCOMNG
LDGREENSBORO
NC
NY
0034
7/22
6:00P
336/INCOMNG
LDGREENSBORO
NC
NY
0035
7/22
6:15P
336/INCOMNG
LDGREENSBORO
NC
NY
0036
7/22
7:43P
336/INCOMNG
LDGREENSBORO
NC
NY
0037
7/22
8:44P
336/INCOMNG
LDGREENSBORO
NC
NY
0038
7/22
8:58P
336/INCOMNG
LDGREENSBORO
NC
NY
0039
7/23
9:15A
336/INCOMNG
LDGREENSBORO
NC
NY
0040
7/23
9:26A
336/INCOMNG
LDGREENSBORO
NC
NY
0041
7/23
9:26A
336/INCOMNG
LDGREENSBORO
NC
NY
0042
7/23
11:37A
336/INCOMNG
LDGREENSBORO
NC
NY
0043
7/23
11:52A
336/INCOMNG
LDGREENSBORO
NC
NY
0044
7/23
2:49P
336/INCOMNG
LDGREENSBORO
NC
NY
0045
7/23
3:57P
336/INCOMNG
LDGREENSBORO
NC
NY
0046
7/23
4:24P
336/INCOMNG
LDGREENSBORO
NC
NY
0047
7/23
4:51P
336/INCOMNG
LDGREENSBORO
NC
NY
0048
7/23
5:39P
336/INCOMNG
LDGREENSBORO
NC
NY
0049
7/24
10:30A
336/INCOMNG
LDGREENSBORO
NC
NY
0050
7/24
10:39A
336/INCOMNG
LDGREENSBORO
NC
NY
0051
7/24
11:00A
336/INCOMNG
LDGREENSBORO
NC
NY
0052
7/24
11:58A
336/INCOMNG
LDGREENSBORO
NC
NY
0053
7/24
12:03P
336/INCOMNG
LDGREENSBORO
NC
NY
0054
7/24
1:22P
336/INCOMNG
LDGREENSBORO
NC
NY
0055
7/24
5:19P
336/INCOMNG
LDGREENSBORO
NC
NY
0056
7/25
9:47A
336/INCOMNG
LDGREENSBORO
NC
NY
0057
7/25
9:56A
336/INCOMNG
LDGREENSBORO
NC
NY
0058
7/25
10:08A
336/INCOMNG
LDGREENSBORO
NC
NY
0059
7/25
11:50A
336/INCOMNG
LDGREENSBORO
NC
NY
0060
7/25
1:11P
336/INCOMNG
LDGREENSBORO
NC
NY
0061
7/25
1:51P
336/INCOMNG
LDGREENSBORO
NC
NY
0062
7/28
8:21P
336/INCOMNG
LDGREENSBORO
NC
NY
0063
7/29
7:05A
336/INCOMNG
LDGREENSBORO
NC
NY
0064
7/29
7:32A
336/INCOMNG
LDGREENSBORO
NC
NY
0065
7/29
8:36A
336/INCOMNG
LDGREENSBORO
NC
NY
0066
7/29
9:18A
336/INCOMNG
LDREIDSVILLE
NC
NY
0067
7/29
9:36A
336/INCOMNG
LDGREENSBORO
NC
NY
0068
7/29
10:03A
336/INCOMNG
LDGREENSBORO
NC
NY
0069
7/29
5:44P
NEW YORK
NY
0070
7/29
5:46P
INTERNATL
.070
0071
7/29
5:52P
207/INCOMNG
LDAUGUSTA
ME
NY
0072
7/29
5:52P
NEW YORK
NY
0073
7/29
5:52P
INCOMING
ME
0074
7/29
5:56P
NEW YORK
NY
0075
7/29
6:02P
MAIL
ME
0076
7/29
6:05P
W PALM BCH
FL
0077
7/29
7:33P
MOBILE
NY
2 2 1 1 1 3 1 1
0078
7/29
7:33P
MOBILE
NY
0079
7/29
7:35P
UN. KINGDO
.350
EFTA00014751

=== Page 35 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 40.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0080 7/29 9:02P
INCOMING
1
0081
7/29
9:43P
INCOMING
1
0082
7/29
10:44P
INCOMING
1
0083 7/29 11:12P
UN. KINGDO
1
.350
0084
7/29
11:33P
NEW YORK
NY
1
0085
7/30
8:57A
NEW YORK
NY
2
0086
7/30
9:05A
INCOMING
1
0087
7/30
9:07A
CHARLT AML VI
2
.400
0088
7/30
9:09A
NEW YORK
NY
4
0089
7/30
9:12A
INCOMING
2
0090
7/30
9:14A
RETRIEVAL
LOCAL
1
0091
7/30
9:15A
NEW YORK
NY
0092
7/30
9:17A
W PALM BCH FL
1
0093
7/30
18A
W PALM BCH FL
1
0094
7/30
:20A
W PALM BCH FL
1
0095
7/30
9:22A
W PALM BCH FL
0096
7/30
9:23A
W PALM BCH FL
0097
7/30
9:24A
NEW YORK
NY
0098
7/30
9:31A
INCOMING
2
0099
7/30
9:32A
NEW YORK
NY
0100
7/30
9:35A
INCOMING
0101
7/30
9:35A
RETRIEVAL
LOCAL
0102
7/30
9:36A
RETRIEVAL
LOCAL
1
0103
7/30
9:37A
NORTH DADE
FL
3
0104
7/30
9:43A
NEW YORK
NY
1
0105
7/30
9:48A
INCOMING
2
0106
7/30
9:51A
NEW YORK
NY
2
0107
7/30
9:52A
RETRIEVAL
LOCAL
1
0108
7/30
9:53A
CHARLT AML VI
1
.200
0109
7/30
9:54A
C ST CROIX VI
3
.600
0110
7/30
9:58A
LOCAL
1
0111
7/30
9:59A
NEW YORK
NY
6
0112
7/30
10:37A
INCOMING
1
0113
7/30
11:22A
BOYNTONBCH FL
3
0114
7/30
11:25A
W PALM BCH FL
1
0115
7/30
11:26A
LOSANGELES CA
2
0116
7/30
11:28A
NEW YORK
NY
6
0117
7/30
11:40A
INCOMING
1
0118
7/30
11:46A
INCOMING
1
0119
7/30
11:48A
W PALM BCH FL
1
0120
7/30
12:08P
W PALM BCH FL
1
0121
7/30
12:10P
MOBILE
NY
0122
7/30
12:10P
INCOMING
3
0123
7/30
12:13P
LONDON
ON
2
.400
0124
7/30
12:17P
NEW YORK
NY
1
0125
7/30
12:18P
NEW YORK
NY
2
0126
7/30
12:56P
LOCAL
2
0127
7/30
12:59P
MOROCCO
2
1.900
0128
7/30
1:06P
INCOMING
0129
7/30
1:08P
NEW YORK
NY
1
0130
7/30
1:09P
LOCAL
1
0131
7/30
1:10P
NEW YORK
NY
0132
7/30
1:53P
INCOMING
0133
7/30
2:01P
INCOMING
0134
7/30
2:07P
INCOMING
0135
7/30
2:22P
LAS VEGAS
NV
8
0136
7/30
2:52P
INCOMING
3
0137
7/30
3:10P
W PALM BCH FL
0138
7/30
:12P
NEW ALBANY OH
0139
7/30
3:20P
INCOMING
3
EFTA00014752

=== Page 36 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 41.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME
NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0140
7/30
3:34P
INCOMING
1
0141
7/30
3:36P
INCOMING
1
0142
7/30
3:56P
INCOMING
1
0143
7/30
4:25P
NEW YORK
NY
2
0144
7/30
4:33P
INCOMING
1
0145
7/30
5:01P
NEW ALBANY
OH
1
0146
7/30
5:13P
NEW YORK
NY
7
0147
7/30
5:34P
INCOMING
1
0148
7/30
5:38P
FTLAUDERDL FL
1
0149
7/30
5:40P
NEW YORK
NY
8
0150
7/30
6:01P
INCOMING
1
0151
7/30
6:24P
INCOMING
1
0152
7/30
7:22P
INCOMING
1
0153
7/30
7:27P
RETRIEVAL
LOCAL
2
0154
7/30
7:29P
NEW YORK
NY
8
0155
7/30
8:02P
INCOMING
5
0156
7/30
8:13P
RETRIEVAL
LOCAL
1
0157
7/30
8:14P
FTLAUDERDL FL
4
0158
7/30
8:26P
INCOMING
1
0159 7/30 8:30P
FRANCE
1
.350
0160
7/30
8:30P
MOBILE
NY
1
0161
7/30
8:55P
INCOMING
6
0162
7/30
9:38P
INCOMING
1
0163
7/30
9:40P
INCOMING
16
0164 7/30 10:10P
INCOMING
1
0165
7/30
10:14P
INCOMING
2
0166
7/30 11:17P
INCOMING
2
0167
7/30
11:27P
INCOMING
1
0168 7/30 11:28P
INCOMING
31
0169
7/31
7:53A
RETRIEVAL
LOCAL
1
0170
7/31
8:05A
FTLAUDERDL FL
2
0171 7/31 8:09A
FTLAUDERDL FL
35
0172 7/31 8:44A
LOCAL
1
0173 7/31 9:58A
NEW YORK
NY
1
0174
7/31
10:04A
NEW YORK
NY
2
0175
7/31
10:06A
NEW YORK
NY
3
0176
7/31
10:22A
INCOMING
1
0177
7/31
10:24A
INCOMING
1
0178
7/31
10:25A
NEW YORK
NY
2
0179
7/31
10:28A
NEW YORK
NY
2
0180
7/31
10:30A
BOCA RATON
FL
2
0181
7/31
10:33A
NEW YORK
NY
2
0182
7/31
10:35A
NEW YORK
NY
2
0183
7/31
11:56A
RETRIEVAL
LOCAL
1
0184
7/31
11:56A
RETRIEVAL
LOCAL
1
0185
7/31
12:39P
INCOMING
4
0186
7/31
12:44P
RETRIEVAL
LOCAL
1
0187
7/31
12:45P
RETRIEVAL
LOCAL
2
0188
7/31
12:48P
OAHU
HI
3
0189
7/31
12:51P
LAS VEGAS
NV
2
0190
7/31
12:54P
S
UN. KINGDO
2
0191
7/31
1:05P
NEW YORK
NY
7
0192
7/31
2:01P
LOCAL
1
0193
7/31
2:01P
NEW YORK
NY
3
0194
7/31
2:04P
144783674754
UN. KINGDO
6
2.100
0195 7/31 2:29P
LOCAL
2
0196
7/31
3:13P
FRANCE
1
.350
0197
7/31
3:14P
LOSANGELES CA
1
0198
7/31
3:24P
OAHU
HI
1
0199
7/31
3:42P
INCOMING
1
EFTA00014753

=== Page 37 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE
NUMBER BILL DATE PAGE 42.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0200
7/31
3:47P
800 SERV.
6
0201
7/31
3:54P
NEW YORK
NY
1
0202
7/31
3:55P
800 SERV.
12
0203
7/31
4:07P
RETRIEVAL
LOCAL
2
0204
7/31
4:08P
INCOMING
1
0205
7/31
4:09P
RETRIEVAL
LOCAL
1
0206
7/31
4:09P
RETRIEVAL
LOCAL
1
0207
7/31
4:10P
INCOMING
1
0208
7/31
4:11P
LOCAL
2
0209
7/31
4:13P
NEW YORK
NY
3
0210
7/31
4:16P
OAHU
HI
2
0211
7/31
4:17P
INCOMING
2
0212
7/31
4:21P
NEW YORK
NY
3
0213
7/31
4:29P
INCOMING
1
0214
7/31
4:33P
NEW YORK
NY
4
0215
7/31
4:50P
INCOMING
1
0216
7/31
4:51P
NEW YORK
NY
1
0217
7/31
4:52P
NEW YORK
NY
2
0218
7/31
5:17P
NEW YORK
NY
2
0219
7/31
5:24P
INCOMING
2
0220
7/31
5:26P
NEW YORK
NY
0221
7/31
5:27P
RETRIEVAL
LOCAL
1
0222
7/31
5:33P
RETRIEVAL
LOCAL
1
0223
7/31
5:40P
INCOMING
3
0224
7/31
5:43P
NEW YORK
NY
1
0225
7/31
5:45P
INCOMING
9
0226
7/31
5:58P
NEW YORK
NY
4
0227
7/31
6:10P
RETRIEVAL
LOCAL
2
0228
7/31
18P
INCOMING
1
0229
7/31
6:20P
INCOMING
0230
7/31
6:21P
INCOMING
1
0231
7/31
6:22P
MOBILE
NY
1
0232
7/31
6:23P
LOCAL
1
0233
7/31
6:24P
NEW YORK
NY
1
0234
7/31
6:25P
LOCAL
1
0235
7/31
6:26P
LOCAL
1
0236
7/31
6:27P
NEW YORK
NY
1
0237
7/31
6:27P
W PALM BCH FL
2
0238
7/31
6:34P
INCOMING
1
0239
7/31
6:39P
LOCAL
1
0240
7/31
7:26P
GARDENA
CA
2
0241
7/31
7:33P
NEW YORK
NY
1
0242
7/31
10:26P
NEW YORK
NY
WP
1
0243
7/31
10:26P
NEW YORK
NY WP
2
0244
7/31 10:27P
NEW YORK
NY WP
2
0245
7/31
10:31P
DURHAM
NC
WP
4
0246
8/01
9:24A
561/INCOMNG
LDW PALM BCH
FL
NY
0247
8/01
9:25A
INCOMING
WP
0248
8/01
9:27A
RETRIEVAL
NEW YORK
NY
WP
22
0249
8/01
10:20A
561/INCOMNG
LDW PALM BCH
FL
NY
0250
8/01
10:21A
INCOMING
WP
1
0251
8/01
10:51A
561/INCOMNG
LDW PALM BCH FL
NY
0252
8/01
10:52A
INCOMING
WP
1
0253
8/01
11:07A
561/INCOMNG
LDW PALM BCH FL NY
0254
8/01
11:08A
INCOMING
WP
1
0255
8/01
12:54P
RETRIEVAL
NEW YORK
NY
WP
1
0256
8/01
12:55P
RETRIEVAL
NEW YORK
NY
WP
1
0257
8/01
12:56P
RETRIEVAL
NEW YORK
NY
WP
0258
8/01
12:56P
RETRIEVAL
NEW YORK
NY
WP
0259
8/01
2:47P
RETRIEVAL
NEW YORK
NY
WP
INN
EFTA00014754

=== Page 38 ===
ACCOUNT NAME
ACCOUNT
MORILE
NUMBER
BILL DATE PAGE 43.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0260
8/01
2:50P
561/INCOMNG LDW PALM BCH FL NY
0261
8/01
2:51P
INCOMING
WP
1
0262
8/01
3:07P
NEW YORK
NY WP
2
0263
8/01
3:20P
C ST CROIX VI WP
4
.800
0264
8/01
3:30P
C ST CROIX VI WP
.200
0265
8/01
3:31P
C ST CROIX VI WP
.200
0266
8/01
3:32P
C ST CROIX VI WP
.200
0267
8/01
3:32P
C ST CROIX VI WP
.200
0268
8/01
3:47P
561/INCOMNG LDW PALM BCH FL NY
0269
8/01
3:49P
INCOMING
WP
0270
8/01
4:12P
MOBILE
WP
0271
8/01
4:12P
W PALM BCH FL WP
0272
8/01
4:13P
WEST PALM
FL
WP
0273
8/01
4:35P
C ST CROIX VI WP
.600
0274
8/01
4:42P
561/INCOMNG
LDW PALM BCH FL NY
0275
8/01
4:43P
INCOMING
WP
0276
8/01
4:54P
561/INCOMNG LDW PALM BCH FL NY
0277
8/01
4:55P
INCOMING
WP
0278
8/01
6:30P
RETRIEVAL
NEW YORK
NY WP
0279
8/01
6:31P
NEW YORK
NY WP
0280
8/01
6:33P
NEW YORK
NY WP
0281
8/01
6:36P
800 SERV.
WP
0282
8/01
7:43P
RETRIEVAL
NEW YORK
NY WP
0283
8/01
9:58P
RETRIEVAL
NEW YORK
NY WP
0284
8/01
10:00P
S
NEW YORK
NY WP
0285
8/01
10:01P
NEW YORK
NY WP
0286
8/01
10:35P
RETRIEVAL
NEW YORK
NY WP
0287
8/02
11:06A
RETRIEVAL
NEW YORK
NY WP
0288
8/02
11:07A
RETRIEVAL
NEW YORK
NY WP
0289
8/02
11:07A
RETRIEVAL
NEW YORK
NY WP
0290
8/02
11:55A
MOBILE
WP
0291
8/02
12:40P
561/INCOMNG
LDW PALM BCH
FL
NY
0292
8/02
12:41P
INCOMING
WP
0293
8/02
1:01P
NEW YORK
NY
WP
0294
8/02
1:38P
561/INCOMNG
LDW PALM BCH
FL
NY
0295
8/02
1:39P
INCOMING
WP
0296
8/02
1:41P
RETRIEVAL
NEW YORK
NY WP
0297
8/02
1:41P
NEW YORK
NY WP
0298
8/02
1:42P
WEST PALM
FL WP
0299
8/02
1:43P
WEST PALM
FL WP
0300
8/02
1:44P
NEW YORK
NY WP
0301
8/02
1:45P
561/INCOMNG
LDW PALM BCH
FL
NY
0302
8/02
1:46P
INCOMING
WP
0303
8/02
:20P
RETRIEVAL
NEW YORK
NY
WP
0304
8/02
3:20P
RETRIEVAL
NEW YORK
NY WP
0305
8/02
3:21P
RETRIEVAL
NEW YORK
NY WP
7 7 2 2 2 2 2 25 2 2 2 1 2 8 2 3 3 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 6 1 1 1 1 1 1 1
0306
8/02
3:22P
UN. KINGDO
WP
.700
0307
8/02
:23P
NEW YORK
NY
WP
0308
8/02
:27P
RETRIEVAL
NEW YORK
NY WP
0309
8/02
:49P
561/INCOMNG LDW PALM BCH FL NY
0310
8/02
:50P
INCOMING
WP
0311
8/02
:55P
561/INCOMNG LDW PALM BCH FL NY
0312
8/02
:57P W
INCOMING
WP
0313
8/02
:00P
NEW YORK
NY
WP
0314
8/02
6:14P
561/INCOMNG LDW PALM BCH FL
NY
0315
8/02
6:15P
INCOMING
WP
0316
8/02
6:59P
WEST PALM
FL
WP
0317
8/02
9:50P
561/INCOMNG LDW PALM BCH FL NY
0318
8/02
9:50P
INCOMING
WP
1
0319
8/02
9:50P
561/INCOMNG LDW PALM BCH FL NY
EFTA00014755

=== Page 39 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE
NUMBER BILL DATE PAGE 44.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0320 8/02 9:51P
INCOMING
WP
1
0321
8/03
11:10A
UN. KINGDO
WP
2
.700
0322
8/03
11:36A
800 SERV.
WP
22
0323
8/03
11:58A
RETRIEVAL
NEW YORK
NY
WP
1
0324
8/03
12:16P
LONDON
ON WP
2
.400
0325
8/03
12:18P
NEW YORK
NY WP
2
0326
8/03
12:20P
MOBILE
WP
1
0327
8/03
12:23P
ORLANDO
FL
WP
2
0328
8/03
12:25P
CHARLT AML
VI
WP
3
.600
0329
8/03
12:26P
561/INCOMNG LDW PALM BCH FL NY
0330
8/03
12:27P W
INCOMING
WP
3
0331
8/03
12:30P
CHARLT AML VI WP
3
.600
0332
8/03
12:36P
LONDON
ON WP
1
.200
0333
8/03
12:37P
LONDON
ON WP
1
.200
0334
8/03
12:38P
LONDON
ON WP
1
.200
0335
8/03
12:38P
WEST PALM
FL
WP
3
0336
8/03
12:44P
LONDON
ON WP
1
.200
0337
8/03
12:49P
QUEENS
NY WP
1
0338
8/03
12:49P
WEST PALM
FL
WP
4
0339
8/03
12:51P
561/INCOMNG
LDW PALM BCH
FL
NY
0340
8/03
12:52P W
INCOMING
WP
3
0341
8/03
12:53P
561/INCOMNG
LDW PALM BCH
FL
NY
0342
8/03
12:54P
W
INCOMING
WP
1
0343
8/03
12:55P
800 SERV.
WP
10
0344
8/03
1:07P
LONDON
ON WP
2
.400
0345
8/03
1:10P
NEW YORK
NY WP
1
0346
8/03
1:11P
NEW YORK
NY WP
4
0347
8/03
1:15P
CHARLT AML VI
WP
2
.400
0348
8/03
1:27P
561/INCOMNG
LDW PALM BCH FL NY
0349
8/03
1:28P
INCOMING
WP
1
0350
8/03
1:29P
561/INCOMNG
LDW PALM BCH FL NY
0351
8/03
1:30P
INCOMING
WP
8
0352
8/03
1:41P
561/INCOMNG LDW PALM BCH FL NY
0353
8/03
1:42P
INCOMING
WP
3
0354
8/03
2:45P
561/INCOMNG LDW PALM BCH FL NY
0355
8/03
2:47P
INCOMING
WP
1
0356
8/03
4:07P
561/INCOMNG LDW PALM BCH FL NY
0357
8/03
4:08P
INCOMING
WP
4
0358
8/03
4:23P
LONDON
ON WP
1
.200
0359
8/03
5:29P
LONDON
ON WP
2
.400
0360
8/03
5:35P
561/INCOMNG
LDW PALM BCH
FL
NY
0361
8/03
5:36P
INCOMING
WP
10
0362
8/03
5:47P
RETRIEVAL
NEW YORK
NY
WP
1
0363
8/03
6:22P
RETRIEVAL
NEW YORK
NY
WP
0364
8/03
HWWNNNHO
2
7:15P
MOBILE
WP
2
0365
8/03
7:17P
NEW YORK
NY
WP
2
0366
8/03
9:19P
RETRIEVAL
NEW YORK
NY WP
3
0367 8/03 9:23P
LONDON
ON WP
3
.600
0368
8/03
9:33P
WEST PALM
FL
WP
1
0369
8/03
9:34P
/TOC
INCOMING
LDW PALM BCH
FL
NY
0370
8/03
9:35P
INCOMING
WP
0371
8/04
7:43A
RETRIEVAL
NEW YORK
NY
WP
1/2
0372
8/04
9:53A
RETRIEVAL
NEW YORK
NY WP
1
0373
8/04
9:54A
ORLANDO
FL WP
2
0374
8/04
9:56A
WEST PALM
FL WP
2
0375
8/04
10:18A
NEW YORK
NY WP
1
0376
8/04 10:19A
WEST PALM
FL WP
1
0377 8/04 10:24A
NEW YORK
NY WP
0378 8/04 10:36A
NEW YORK
NY WP
0379
8/04
10:36A
561/INCOMNG LDW PALM BCH FL NY
EFTA00014756

=== Page 40 ===
ACCOUNT NAME
ACCOUNT NUMBER
MORILE NUMBER BILL DATE PAGE 45.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF DATE TIME NUMBER CALLED
CALLS TO FROM
MIN
AIR
DISTANCE
0380 8/04 10:37A W
INCOMING
WP
1
0381
8/04 10:38A
DELRAY BEA
FL
WP
2
0382
8/04
4:54P
787/INCOMNG
LDSANTURCE
PR NY
.800
0383
8/04
5:09P
787/INCOMNG
LDSANTURCE
PR NY
1.400
0384
8/05
5:36P
787/INCOMNG
LDSANTURCE
PR NY
.600
0385
8/05
9:05P
787/INCOMNG
LDSANTURCE
PR
NY
.200
0386
8/05
9:09P
787/INCOMNG
LDSANTURCE
PR
NY
.200
0387
8/05
9:10P
787/INCOMNG
LDSANTURCE
PR NY
.200
0388
8/05
10:39P
787/INCOMNG
LDSANTURCE
PR NY
.800
0389
8/06
2:12P
787/INCOMNG
LDSANTURCE
PR NY
.600
0390
8/06
2:15P
787/INCOMNG
LDSANTURCE
PR NY
.400
0391
8/06
3:00P
787/INCOMNG
LDSANTURCE
PR NY
.600
0392
8/07
2:46P
787/INCOMNG
LDSANTURCE
PR NY
.400
0393
8/07
3:08P
787/INCOMNG
LDSANTURCE
PR NY
.600
0394
8/07
3:16P
787/INCOMNG
LDSANTURCE
PR NY
.800
0395
8/07
7:06P
787/INCOMNG
LDSANTURCE
PR NY
.600
0396
8/07
7:10P
787/INCOMNG
LDSANTURCE
PR NY
.600
0397
8/08
9:44A
787/INCOMNG
LDSANTURCE
PR NY
.600
0398
8/08
9:54A
787/INCOMNG
LDSANTURCE
PR NY
.400
0399
8/08
10:37A
787/INCOMNG
LDSANTURCE
PR NY
.200
0400
8/08
10:59A
787/INCOMNG
LDSANTURCE
PR NY
.400
0401
8/08
11:17A
787/INCOMNG
LDSANTURCE
PR NY
.800
0402
8/08
12:04P
787/INCOMNG
LDSANTURCE
PR NY
.200
0403
8/08
12:12P
787/INCOMNG
LDSANTURCE
PR NY
1.200
0404
8/08
5:20P
RETRIEVAL
LOCAL
2
0405
8/08
5:22P
CHARLT AML VI
2
.400
0406
8/08
5:47P
NEW YORK
NY
1
0407
8/08
5:49P
INCOMING
3
0408
8/08
6:03P
NEW YORK
NY
3
0409
8/08
6:06P
NWYRCYZN01
NY
7
0410
8/08
6:18P
MOBILE
NY
2
0411
8/08
6:19P
MOBILE
NY
1
0412
8/08
6:21P
INCOMING
2
0413
8/08
6:25P
NWYRCYZN01 NY
1
0414
8/08
6:28P
RETRIEVAL
LOCAL
1
0415
8/08
6:29P
RETRIEVAL
LOCAL
1
0416
8/08
6:30P
NEW YORK
NY
7
0417
8/08
6:50P
NEW YORK
NY
4
0418
8/08
8:05P
INCOMING
4
0419
8/08
9:28P
INCOMING
2
0420
8/08
9:30P
NEW YORK
NY
1
0421
8/08
9:55P
NEW YORK
NY
3
0422
8/08
9:58P
UN. KINGDO
1
.350
0423
8/08
10:00P
FTLAUDERDL FL
2
0424
8/08
10:01P
OAHU
HI
2
0425
8/08
10:09P
INCOMING
1
0426
8/08
10:21P
NEW YORK
NY
1
0427
8/08
10:23P
INCOMING
4
0428
8/08
11:05P
NEW YORK
NY
0429
8/08
11:06P
NEW YORK
NY
1
0430
8/08
11:06P
NEW YORK
NY
1
0431
8/08
11:07P
NEW YORK
NY
1
0432
8/08
11:08P
NEW YORK
NY
1
0433
8/08
11:08P
NEW YORK
NY
1
0434
8/08
11:09P
NEW YORK
NY
1
0435
8/08
11:09P
NEW YORK
NY
1
0436
8/09
12:04A
NEW YORK
NY
2
0437
8/09
1:08A
NEW YORK
NY
0438
8/09
7:02A
CHARLT AML
VI
0439
8/09
7:08A
INCOMING
INS
.400
EFTA00014757

=== Page 41 ===
ACCOUNT NAME
ACCOUNT
NUMBER
MORILE
NUMBER
BILL DATE PAGE 46.0
JEFFREY E EPSTEIN &
AUG 14, 2003
CALL
LONG
REF
DATE
TIME NUMBER CALLED
CALLS
TO
FROM
MIN
AIR
DISTANCE
0440
8/09
7:16A
INCOMING
10
0441
8/09
8:02A
INCOMING
5
0442
8/09
8:30A D
NEW YORK
NY
3
0443
8/09
8:32A
NEW YORK
NY
1
0444
8/09
8:37A
NEW YORK
NY
1
0445
8/09
10:18A
INCOMING
2
0446 8/09 10:30A
INCOMING
3
0447
8/09 12:14P
INCOMING
38
0448
8/09
12:33P
INCOMING
1
0449
8/09
1:25P
INCOMING
2
0450
8/09
1:55P
FTLAUDERDL FL
6
0451
8/09
2:45P
INCOMING
4
0452
8/09
3:07P
CHARLT AML VI
2
.400
0453
8/09
3:40P
RETRIEVAL
LOCAL
2
0454
8/09
4:06P
RETRIEVAL
LOCAL
4
0455
8/09
4:08P
INCOMING
8
0456
8/09
4:16P
RETRIEVAL
LOCAL
2
0457
8/09
4:41P
FTLAUDERDL FL
1
0458
8/09
4:44P
FTLAUDERDL FL
3
0459
8/09
4:48P
A
FTLAUDERDL FL
1
0460 8/09 4:49P
INCOMING
0461
8/09
4:49P
INCOMING
1
0462
8/09
4:50P
INCOMING
1
0463
8/09
4:50P
INCOMING
1
0464
8/09
4:52P
CHARLT AML VI
7
1.400
0465
8/09
5:00P
NEW YORK
NY
1
0466
8/09
5:06P
LAS VEGAS
NV
1
0467
8/09
5:24P
RETRIEVAL
LOCAL
1
0468
8/09
5:25P
RETRIEVAL
LOCAL
1
0469
8/09
5:25P
RETRIEVAL
LOCAL
2
0470
8/09
5:28P
INCOMING
4
0471 8/09 5:32P
NEW YORK
NY
1
TOTAL HOME AIRTIME AND LONG DISTANCE CHARGES
886
.00
30.62
CALL CHARACTERISTICS:
S = Long Distance Service Billed Separately, W = Call Waiting,
D = AT&T Connect Calls, A = Automatic Dropped Call Credit
"CALLS FROM" KEY:
NY = NEW YORK
MESSAGING, CONTENT & APPLICATION CHARGES
Message
Message
Ref Date Time Message To Typ Chrg Ref Date Time Message To Typ Chrg
0001 8/01 10:06A
S
.10
TOTAL MESSAGING, CONTENT & APPLICATION CHARGES
.10
Message Types:
R= Received Messages
S= Sent Messages
I= International Messages
Times for Messaging, Content & Application charges are in your home time zone.
EFTA00014758

=== Page 42 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 47.0
JEFFREY E EPSTEIN &
AUG 14, 2003
ROAMING CHARGES
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
Calls Made From: BANGOR MR
0001
7/29
5:37P
MAIL
ME
2
1.38
.40
0002 7/29 6:01P
MAIL
ME
1
.69
.20
0003 7/29 6:04P
W PALM BCH FL
1
.69
.20
0004 7/29 6:06P
CHAR AMALE VI
2
1.38
.40
Subtotal for : BANGOR, ME
6
4.14
1.20
.00
Calls Made From: SAN JUAN, PR
0005 8/04 12:59P RETRIEVAL
NEW YORK C NY
8/04
22
1.38
0006
1:12P
PETRIEVAL
NEW YORK C NY
1.38
0007
8/07
1:02P
NEW YORK
NY
2
1.38
.40
0008
8/07
1:20P
NEW YORK
NY
10
6.90
2.00
0009
8/07
1:30P
QUEENS
NY
1
.69
.20
0010
8/07
1:39P
NEW YORK
NY
4
2.76
.80
0011
8/07
2:21P
NEW YORK
NY
2
1.38
.40
0012
8/07
2:47P
INCOMING
2
1.38
0013
8/07
2:58P
NEW YORK
NY
2
1.38
.40
0014
8/07
3:09P
INCOMING
3
2.07
0015 8/07 3:13P RETRIEVAL
NEW YORK C NY
1
.69
0016
8/07
3:17P
INCOMING
4
2.76
Subtotal for
: SAN JUAN, PR
35
24.15
4.20
.00
Calls Made From: USVI, VI
0017
8/04
3:15P RETRIEVAL
NEW YORK NY
NEW YORK CC C NY
2
1.38
0018
8/04
3:17P
RETRIEVAL
1
.69
0019
8/04
3:21P
800 SERV.
5
3.45
0020
8/04
3:26P
OXNARD
CA
2
1.38
.40
0021
8/04
3:33P
NEW YORK
NY
5
3.45
1.00
0022
8/04
3:49P
DEERFLDBCH FL
8
5.52
1.60
0023
8/04
4:55P
INCOMING
4
2.76
0024
8/04
4:58P
RETRIEVAL
NEW YORK C NY
2
1.38
0025
8/04
5:07P
NEW ALBANY
OH
2
1.38
.40
0026
8/04
5:10P
INCOMING
7
4.83
0027
8/04
9:56P
SANTA ROSA CA
1
.69
.20
0028
8/04
9:57P
800 SERV.
6
4.14
0029
8/04
10:03P
NEW YORK
NY
3
2.07
.60
0030
8/04
10:06P
NEW YORK
NY
5
3.45
1.00
0031
8/04
10:15P
800 SERV.
2
1.38
0032
8/05
9:02A
RETRIEVAL
NEW YORK C NY
2
1.38
0033
8/05
10:32A
RETRIEVAL
NEW YORK C NY
5
3.45
0034
8/05
10:57A
561-350-1700
DELRAY BCH FL
3
2.07
.60
0035
8/05
11:15A
RETRIEVAL
NEW YORK C NY
1
.69
0036
8/05
11:55A
UN. KINGDO
1
.69
.35
0037
8/05 11:56A
UN. KINGDO
1
.69
0038
8/05
1:32P
UN. KINGDO
1
.69
0039
8/05
3:29P
RETRIEVAL
NEW YORK C NY
2
1.38
0040
8/05
5:38P
INCOMING
3
2.07
0041
8/05
8:44P
RETRIEVAL
NEW YORK C NY
1
.69
0042
8/05
9:06P
INCOMING
1
.69
0043
8/05
9:10P
INCOMING
1
.69
0044
8/05
9:11P
INCOMING
1
.69
0045
8/05
10:40P
INCOMING
4
2.76
0046 8/06 9:51A RETRIEVAL
NEW YORK C NY
2
1.38
0047
8/06
11:48A
UN. KINGDO
1
.69
.35
0048
8/06
2:13P
INCOMING
3
2.07
0049
8/06
2:16P
INCOMING
2
1.38
EFTA00014759

=== Page 43 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 48.0
JEFFREY E EPSTEIN &
AUG 14, 2003
REF
DATE
TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0050
8/06
3:02P
INCOMING
3
2.07
0051
8/06
4:46P RETRIEVAL
NEW YORK C NY
2
1.38
0052
8/06
6:59P
RETRIEVAL
NEW YORK NY
1
.69
0053
8/06
7:00P
RETRIEVAL
NEW YORK NY
1
.69
0054 8/06 7:00P RETRIEVAL
NEW YORK NY
0055
8:27P RETRIEVAL
10000000 CC C CC C
1
.69
8/06
NEW YORK NY
2
1.38
0056
8/06
8:41P
RETRIEVAL
NEW YORK NY
1
.69
0057
8/07
8:57A
RETRIEVAL
NEW YORK NY
2
1.38
0058
8/07
9:35A
PETPIEVAL
NEW YORK NY
1
.69
0059
8/07
9:36A
NEW YORK NY
3
2.07
.60
0060
8/07
10:56A
RETRIEVAL
NEW YORK NY
2
1.38
0061
8/07
11:15A
PETRIEVAL
NEW YORK NY
1
.69
0062
8/07
11:43A
NEW YORK NY
2
1.38
.40
0063
8/07
4:59P
RETRIEVAL
NEW YORK NY
1
.69
0064
8/07
6:38P
RETRIEVAL
NEW YORK NY
2
1.38
0065
8/07
7:07P
INCOMING
3
2.07
0066
8/07
7:12P
INCOMING
3
2.07
0067
8/07
7:23P
800 SERV.
3
2.07
0068
8/07
7:27P
NEW YORK
NY
3
2.07
.60
0069
8/07
8:26P
800 SERV.
6
4.14
0070
8/07
8:35P
800 SERV.
17
11.73
0071
8/07
8:53P
800 SERV.
6
4.14
0072
8/07
9:09P
RETRIEVAL
NEW YORK C NY
0073
NEW YORK C CC NY
2
1.38
8/07
9:11P
PETRIEVAL
2
1.38
0074
8/07
9:15P
GARDENA
CA
1
.69
.20
0075
8/08
9:31A
QUEENS
NY
2
1.38
.40
0076
8/08
9:45A
INCOMING
3
2.07
0077
8/08
9:55A
INCOMING
2
1.38
0078
8/08
10:31A
NEW YORK
NY
3
2.07
.60
0079
8/08
10:38A
INCOMING
.69
0080
8/08
10:39A
BROOKLYN
NY
1
.69
.20
0081
8/08
10:42A
CHARLT AML VI
1
.69
.20
0082
8/08
10:45A
CHARLT AML VI
1
.69
.20
0083
8/08
11:00A
INCOMING
2
1.38
0084
8/08
11:09A
NEW YORK
NY
2
1.38
.40
0085
8/08
11:16A
NEW YORK
NY
2
1.38
.40
0086
8/08
11:18A
INCOMING
4
2.76
0087
8/08
11:58A
ITALY
2
1.38
.70
0088
8/08
12:04P
OAHU
HI
2
1.38
.40
0089
8/08
12:05P
INCOMING
1
.69
0090
8/08
12:06P
NEW YORK
NY
1
.69
.20
0091
8/08
12:09P
OAHU
HI
1
.69
0092
8/08
12:13P
INCOMING
6
4.14
0093 8/08 1:09P
NEW YORK
NY
1
.69
.20
0094 8/08 1:09P
NEW YORK
NY
4
2.76
.80
0095
8/08
1:22P
NEW YORK
NY
2
1.38
.40
Subtotal for
: USVI, VI
205
141.45
13.40
.00
Calls Made From: ITALY,
0096
7/26
2:42A
INTL NTWK
1
.99
.35
0097
7/26
2:43A
INTL NTWK
1
.99
0098
7/26
2:44A
INTL NTWK
1
.99
0099
7/26
2:47A
INTL NTWK
1
.99
0100
7/26
2:50A
INTL NTWK
1
.99
0101
7/26
2:50A
INTL NTWK
1
.99
0102
7/26
2:57A
INTL NTWK
1
.99
nu
0103
7/26
3:25A
INTL NTWK
.99
EFTA00014760

=== Page 44 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 49.0
JEFFREY E EPSTEIN &
AUG 14, 2003
REF
DATE
TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0104
7/26
4:26A
INTL NTWK
1
.99
.35
0105
7/26
11:59A
INTL NTWK
1
.99
0106
7/26
12:23P
INTL NTWK
2
1.98
0107
7/26
12:27P
INTL NTWK
1
99
0108
7/26
12:31P
INTL NTWK
1
99
3
0109
7/26
12:31P
INTL NTWK
1
.99
0110
7/26
12:55P
INTL NTWK
1
.99
0111
7/28
9:35A
INTL NTWK
1
.99
0112
7/28
9:38A
INTL NTWK
1
99
0113
7/28
1:09P
INTL NTWK
4
3.96
1.40
0114
7/28
1:31P
INTL NTWK
7
6.93
2.45
0115
7/28
1:48P
INTL NTWK
2
1.98
70
0116
7/28
2:04P
INTL NTWK
1
.99
0117
7/28
2:05P
INTL NTWK
2
1.98
.70
0118
7/28
2:07P
INTL NTWK
1
.99
0119
7/28
3:06P
INTL NTWK
1
.99
0120
7/28
3:06P
INTL NTWK
1
.99
0121 7/28 3:08P
INTL NTWK
1
.99
0122
7/28
3:09P
INTL NTWK
1
.99
0123
7/28
3:15P
INTL NTWK
2
1.98
0124
7/28
4:01P
INTL NTWK
7
6.93
0125
7/28
4:07P
INTL NTWK
6
5.94
2:4
Subtotal for : ITALY,
54
53.46
18.90
.00
Calls Made From: FRANCE.
0126
7/19
9:41P
INTL NTWK
10
9.90
3.50
0127
7/20 12:21A
INTL NTWK
99
0128
7/20
12:22A
INTL NTWK
5
4.95
1.75
0129
7/20
3:54P
INTL NTWK
2
1.98
0130
7/20
5:11P
INTL NTWK
1
99
0131
7/20
5:12P
INTL NTWK
1
.99
0132
7/20
5:12P
INTL NTWK
1
.99
0133
7/20
5:13P
INTL NTWK
1
.99
0134
7/20
5:14P
INTL NTWK
1
.99
0135
7/20
5:39P
INTL NTWK
1
.99
0136
7/21
3:48P
INTL NTWK
1
.99
0137
7/21
4:34P
INTL NTWK
1
.99
0138
7/21
5:16P
INTL NTWK
99
0139
7/21
5:42P
INTL NTWK
2
1.98
0140
7/21
5:44P
INTL NTWK
2
5:50P
HHH
1.98
70
0141
7/21
INTL NTWK
3
2.97
1.05
0142
7/21
6:02P
INTL NTWK
1
99
0143
7/21
6:03P
INTL NTWK
3
2.97
1.05
0144
7/21
6:07P
INTL NTWK
1
99
0145
7/21
6:36P
INTL NTWK
1
99
0146
7/21
6:51P
INTL NTWK
13
12.87
4.55
0147
7/21
7:04P
INTL NTWK
3
2.97
1.05
0148
7/21
8:56P
INTL NTWK
.99
0149
7/21
8:58P
INTL NTWK
18
17.82
6.30
0150
7/21
10:17P
INTL NTWK
1
.99
0151
7/22
1:34A
INTL NTWK
2
1.98
0152
7/22
3:07P
INTL NTWK
1
.99
0153
7/22
3:07P
INTL NTWK
1
.99
0154
7/22
3:08P
INTL NTWK
6
5.94
2.10
0155
7/22
3:25P
INTL NTWK
5
4.95
1.75
0156
7/22
3:40P
INTL NTWK
4
3.96
1.40
0157
7/22
4:03P
INTL NTWK
2
1.98
.70
EFTA00014761

=== Page 45 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 50.0
JEFFREY E EPSTEIN &
AUG 14, 2003
REF
DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0158
7/22
4:11P
INTL NTWK
1
99
35
0159
7/22
4:12P
INTL NTWK
3
1.05
0160
7/22
INTL NTWK
12
11.88
4.20
0161
7
5:09P
INTL NTWK
1
99
0162
7
5:09P
INTL NTWK
2
0163
7
:12P
INTL NTWK
3
1.05
0164
7/22
21P
INTL NTWK
3
1.05
0165
7/22
INTL NTWK
3
1.05
0166
7
INTL NTWK
99
0167
7
INTL NTWK
99
0168
7
INTL NTWK
2
0169
INTL NTWK
2
2.97 2.97 HONN 2.97 1:98 2.97 1.98 1.98 1.98
0170
7
13P
INTL NTWK
99
0171
7
9:22P
INTL NTWK
2
0172
11:29P
INTL NTWK
2
0173
INTL NTWK
99
0174
11:59P
INTL NTWK
99
0175
12:00A
INTL NTWK
99
0176
INTL NTWK
99
0177
INTL NTWK
99
0178
:59P
INTL NTWK
99
0179
2:08P
INTL NTWK
2
1.98
0180
INTL NTWK
1
99
0181
7
22P
INTL NTWK
2
1.98
0182
7
:25P
INTL NTWK
99
0183
7/23
INTL NTWK
99
0184
INTL NTWK
2
0185
INTL NTWK
3
1:98
1
0186
INTL NTWK
1
99
0187
INTL NTWK
99
0188
INTL NTWK
99
0189
7
:10P
INTL NTWK
11
10.89
3
0190
7
INTL NTWK
1
99
0191
7
INTL NTWK
99
0192
7
INTL NTWK
1
99
0193
7
INTL NTWK
1
99
0194
7
INTL NTWK
99
0195
INTL NTWK
99
0196
7:04P
INTL NTWK
99
0197
7:05P
INTL NTWK
99
0198
7:08P
INTL NTWK
99
0199
7/23
8:20P
INTL NTWK
2
1.98
0200
7
8
:23P
INTL NTWK
99
0201
7
INTL NTWK
99
0202
7
8
37P
INTL NTWK
99
0203
7
38P
INTL NTWK
99
0204
7
39P
INTL NTWK
99
0205
7
INTL NTWK
99
0206
7
46P
INTL NTWK
99
0207
041
INTL NTWK
99
0208
7
05B
INTL NTWK
2
0209
7
9:58P
INTL NTWK
0210
10:13P
INTL NTWK
0211
7
INTL NTWK
1.98 1.98 1.98
99
2
99
0212
INTL NTWK
2
0213
7
11:07P
INTL NTWK
99
0214
7/24
2:47P
INTL NTWK
.99
3
EFTA00014762

=== Page 46 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 51.0
JEFFREY E EPSTEIN &
AUG 14, 2003
REF
DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0215
7/24
3:51P
INTL NTWK
1
.99
.35
0216
7/24
6:21P
INTL NTWK
5
4.95
1.75
0217
7/24
6:37P
INTL NTWK
1
.99
0218
7/24
7:15P
INTL NTWK
1
.99
0219
7/24
7:16P
INTL NTWK
1
.99
0220
7/24
7:35P
INTL NTWK
1
.99
0221
7/25
3:13P
INTL NTWK
1
.99
0222
7/25
3:55P
INTL NTWK
1
.99
0000000000
0223
7/25
5:05P
INTL NTWK
1
.99
0224
7/25
7:04P
INTL NTWK
1
.99
Subtotal for
: FRANCE,
211
208.89
73.85
.00
Calls Made From: FRANCE,
0225
7/19
:56P
INTL NTWK
1
.99
.35
0226
7/19
2:58P
INTL NTWK
6
5.94
2.10
0227
7/19
3:08P
INTL NTWK
1
.99
.35
0228
7/19
3:38P
INTL NTWK
1
.99
.35
0229
7/19
INTL NTWK
3
2.97
1.05
0230
7/19
3:47P
INTL NTWK
1
.99
.35
0231
7/19
3:59P
INTL NTWK
15
14.85
5.25
0232
7/19
4:14P
INTL NTWK
2
1.98
.70
0233
7/19
4:17P
INTL NTWK
2
1.98
.70
0234
7/19
5:39P
INTL NTWK
2
1.98
.70
0235
7/19
5:41P
INTL NTWK
1
.99
.35
0236
7/19
8:16P
INTL NTWK
2
1.98
.70
0237
7/19
8:18P
INTL NTWK
4
3.96
1.40
0238
7/19
8:42P
INTL NTWK
2
1.98
70
0239
7/19
8:57P
INTL NTWK
1
.99
.35
0240
7/19
8:58P
INTL NTWK
2
1.98
70
0241
7/19
9:09P
INTL NTWK
3
2.97
1.05
0242
7/19
9:12P
INTL NTWK
2
1.98
.70
0243
7/25
8:58P
INTL NTWK
1
.99
.35
0244
7/28
7:13P
INTL NTWK
1
.99
0245
7/28
7:43P
INTL NTWK
2
1.98
.70
0246
7/28
9:12P
INTL NTWK
1
.99
0247
7/28
9:34P
INTL NTWK
1
.99
0248
7/29
12:00A
CALL SVC
1
.99
0249
7/29
1:05A
INTL NTWK
.99
0250
7/29
10:31A
INTL NTWK
1
.99
0251
7/29
10:32A
INTL NTWK
1
.99
0252
7/29
0253
1 1
INTL NTWK
2
1.98
7/29
INTL NTWK
1
.99
35
0254
7/29
INTL NTWK
1
.99
0255
7/29
:26P
INTL NTWK
2
1.98
70
0256
7/29
51P
INTL NTWK
1
.99
.35
0257
7/29
INTL NTWK
2
1.98
70
0258
7/29
:00P
INTL NTWK
1
.99
0259
7/29
:02P
INTL NTWK
1
.99
0260
7/29
:07P
INTL NTWK
11
10.89
3.85
0261
7/29
20P
INTL NTWK
1
.99
0262
7/29
:23P
INTL NTWK
3
2.97
1.05
0263
7/29
26P
INTL NTWK
2
1.98
0264
7/29
28P
INTL NTWK
2
1.98
0265
7/29
P
INTL NTWK
1
.99
0266
30P
INTL NTWK
1
.99
0267
INTL NTWK
1
.99
0268
7/29
32P
INTL NTWK
2
1.98
EFTA00014763

=== Page 47 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 52.0
JEFFREY E EPSTEIN &
AUG 14, 2003
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0269 7/29 3:34P
INTL NTWK
1
.99
.35
0270 7/29 3:45P
INTL NTWK
1
.99
.35
Subtotal for
: FRANCE,
98
97.02
33.95
.00
Calls Made From: ITALY.
0271 7/26 12:45A
INTL NTWK
1
99
0272 7/26 12:55A
INTL NTWK
13
12.87
4.55
0273 7/26 1:10A
INTL NTWK
1
99
0274
7/26
1:24A
INTL NTWK
1
1'
.99
0275
7/26
1:35A
INTL NTWK
1
.99
.35
0276
7/26
1:47A
INTL NTWK
99
0277
7/26
8:07P
INTL NTWK
3
2.97
1.05
0278
7/26
8:16P
INTL NTWK
2
1.98
.70
0279
7/26
8:19P
INTL NTWK
4
3.96
1.40
0280
7/26 11:55P
INTL NTWK
5
4.95
1.75
0281 7/27 12:05A
INTL NTWK
1
99
.35
0282 7/27 12:10A
INTL NTWK
1
99
.35
0283
7/27
12:11A
INTL NTWK
1
.99
0284
7/27
4:30A
INTL NTWK
0285
7/27
9:58A
INTL NTWK
23
0286 7/27 12:16P
22:77
8.05
11.55
INTL NTWK
3
1.05
0287 7/27 12:20P
INTL NTWK
1
99
.35
0288 7/27 12:21P
INTL NTWK
1
99
0289 7/27 12:23P
INTL NTWK
1
.99
0290 7/27 12:24P
INTL NTWK
1
.99
0291
7/27 12:27P
INTL NTWK
3
2.97
1.05
0292
7/27
12:30P
INTL NTWK
1
99
0293
7/27
1:04P
INTL NTWK
1
99
0294
7/27
1:50P
INTL NTWK
99
0295
7/27
3:48P
INTL NTWK
1
99
0296
7/27
3:51P
INTL NTWK
1
99
0297
7/27
4:17P
INTL NTWK
1
99
0298
7/27
4:18P
INTL NTWK
2
1.98
70
0299
7/27
5:03P
INTL NTWK
2
1.98
70
0300
7/27
5:12P
INTL NTWK
1
99
35
0301
7/27
5:23P
INTL NTWK
1
99
35
0302
7/27
5:56P
INTL NTWK
2
1.98
70
0303
7/27
6:15P
INTL NTWK
2
1.98
70
0304
7/27
7:19P
INTL NTWK
1
99
0305 7/27 8:42P
INTL NTWK
1
.99
.35
Subtotal for
: ITALY,
119
117.81
41.65
.00
Calls Made From: GREAT BRITAIN.
0306 7/13 12:09P
INTL NTWK
2
1.98
.70
0307 7/13 1:10P
INTL NTWK
2
1.98
.70
0308
7/13
1:27P
INTL NTWK
12
11.88
4.20
0309
7/13
1:52P
INTL NTWK
99
35
0310
7/13
1:52P
INTL NTWK
1
99
35
0311 7/13 1:55P
INTL NTWK
1
99
0312
7/13
1:57P
INTL NTWK
1
99
0313
7/13
1:57P
INTL NTWK
1
99
0314
7/13
1:58P
INTL NTWK
1
9
0315
7/14
12:13P
INTL NTWK
1
9
0316
7/14 12:19P
INTL NTWK
1
9
0317
7/14
1:18P
INTL NTWK
1
9
плллллллло
0318
7/14
1:19P
INTL NTWK
0319
7/14
2:15P
INTL NTWK
1
EFTA00014764

=== Page 48 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 53.0
JEFFREY E EPSTEIN &
AUG 14, 2003
REF
DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0320
7/14
2:15P
INTL NTWK
10
3.50
0321
7/14
INTL NTWK
7
0322
7/14
INTL NTWK
2
0323
8
0324
7/15
INTL NTWK
3
0325
7/15
2.97 6.93 9.90 1.98 1
2.45
.70
7/14
INTL NTWK
2
70
10:14A
1.05
1:30P
INTL NTWK
0326
7/15
1:37P
INTL NTWK
3
1.05
0327
7/15
3:00P
INTL NTWK
0328
7/15
4:40P
INTL NTWK
8
7.92
2
0329
7/15
6:10P
INTL NTWK
99
0330
7/15
INTL NTWK
99
0331
7/15
7:58P
INTL NTWK
99
0332
7/15
8:00P
INTL NTWK
99
0333
7/15
8:00P
INTL NTWK
99
0334
7/15
0335
11:02P
INTL NTWK
99
7/15
INTL NTWK
2
1.98
0336
7/16
9:35A
INTL NTWK
99
0337
7/16
9:37A
INTL NTWK
99
0338
7/16
10:38A
INTL NTWK
2
0339
7/16
INTL NTWK
9
1:98
3
0340
7/16
2:42P
INTL NTWK
99
0341
7/16
6:06P
INTL NTWK
99
0342
7/16
6:06P
INTL NTWK
.99
0343
7/16
6:53P
INTL NTWK
2
1.98
0344
7/16
7:01P
INTL NTWK
2
1.98
0345
7/16
7:04P
INTL NTWK
99
0346
7/16
7:07P
INTL NTWK
.99
0347
7/16
7:54P
INTL NTWK
.99
0348
7/16
7:56P
INTL NTWK
99
0349
7/16
INTL NTWK
2
1.98
0350
7/16
8:09P
INTL NTWK
99
0351
7/16
9:01P
INTL NTWK
99
0352
7/16
9:09P
INTL NTWK
99
0353
7/16
9:14P
INTL NTWK
6.93
2.45
0354
7/16
INTL NTWK
1
99
0355
7/17
INTL NTWK
99
0356
7/17
PPPP PPPP
INTL NTWK
3
0357
7/17
7A
INTL NTWK
8
2.97
0358
7/17
:39A
INTL NTWK
99
0359
7/17
10:28A
INTL NTWK
3
2.97
1.05
0360
7/17
INTL NTWK
99
0361
7/17
INTL NTWK
2
1.98
0362
7/17
INTL NTWK
99
0363
7/17
3:40P
INTL NTWK
99
0364
7/17
INTL NTWK
2
1.98
0365
7/17
INTL NTWK
11
10.89
3.85
0366
7/17
3:57P
INTL NTWK
1
.99
0367
7/17
4:22P
INTL NTWK
1
99
0368
7/17
4:24P
INTL NTWK
11
10.89
3.
0369
7/17
4:42P
INTL NTWK
1
99
0370
7/17
5:06P
INTL NTWK
1
.99
0371
7/17
5:11P
INTL NTWK
1
99
0372
7/17
INTL NTWK
3
2.97
1.
0373
7/17
:32P
INTL NTWK
.99
0374
7/17
0
INTL NTWK
3
2.97
1.
0375
7/17
P
INTL NTWK
1
99
0376
7/17
3
INTL NTWK
1
.99
.35
EFTA00014765

=== Page 49 ===
ACCOUNT NAME
ACCOUNT NUMBER
MOBILE NUMBER BILL DATE PAGE 54.0
JEFFREY E EPSTEIN &
AUG 14, 2003
REF DATE TIME NUMBER CALLED CALLS TO
MIN AIR DISTANCE TAXES
0377
7/17
6:27P
INTL NTWK
1
.99
.35
0378
7/17
6:28P
INTL NTWK
1
.99
.35
0379
7/17
6:30P
INTL NTWK
1
.99
.35
0380
7/17
6:33P
INTL NTWK
6
5.94
2.10
0381
7/17
7:15P
INTL NTWK
1
.99
.35
0382 7/17 7:16P
INTL NTWK
1
.99
.35
0383 7/18 7:04A
INTL NTWK
3
2.97
1.05
0384
7/18
1:04P
INTL NTWK
1
.99
.35
0385
7/18
2:12P
INTL NTWK
1
.99
.35
0386
7/18
3:07P
INTL NTWK
5
4.95
1.75
0387
7/18
3:47P
INTL NTWK
3
2.97
1.05
0388
7/18
4:46P
INTL NTWK
.99
.35
0389
7/18
9:54P
INTL NTWK
2
1.98
.70
0390 7/18 10:01P
INTL NTWK
1
.99
.35
0391 7/18 10:14P
INTL NTWK
12
11.88
4.20
0392
7/18
10:28P
INTL NTWK
1
.99
.35
0393
7/19
7:32A
INTL NTWK
2
1.98
.70
0394
7/19
7:53A
INTL NTWK
1
.99
.35
0395 7/19 9:57A
INTL NTWK
2
1.98
.70
0396 7/19 10:12A
INTL NTWK
2
1.98
.70
0397 7/19 10:15A
INTL NTWK
.99
.35
0398 7/19 10:28A
INTL NTWK
5
4.95
1.75
0399 7/19 11:51A
INTL NTWK
4
3.96
1.40
0400 7/19 12:08P
INTL NTWK
1
.99
.35
0401 7/19 12:13P
INTL NTWK
8
7.92
2.80
Subtotal for : GREAT BRITAIN,
235
232.65
82.25
.00
Calls Made From: ITALY.
0402 7/25 11:47P
INTL NTWK
1
.99
.35
0403 7/27 12:00A
CALL SVC
1
.99
0404 7/27 9:29P
INTL NTWK
2
1.98
.70
0405 7/27 9:38P
INTL NTWK
5
4.95
1.75
0406 7/27 10:46P
INTL NTWK
1
.99
.35
0407 7/27 10:47P
INTL NTWK
1
.99
.35
0408 7/27 10:48P
INTL NTWK
3
2.97
1.05
0409 7/28 12:00A
CALL SVC
1
.99
0410 7/28 12:26A
INTL NTWK
3
2.97
1.05
0411
7/28
6:54A
INTL NTWK
3
2.97
1.05
0412
7/28
7:54A
INTL NTWK
3
2.97
1.05
0413 7/28 12:32P
INTL NTWK
2
1.98
.70
0414
7/28 12:38P
INTL NTWK
1
.99
.35
0415 8/10 9:20A
INTL NTWK
5
4.95
1.75
0416
8/10 11:31A
INTL NTWK
1
.99
.35
0417 8/12 7:48P
INTL NTWK
5
1.98
.70
0418 8/12 7:50P
INTL NTWK
4.95
1.75
Subtotal for : ITALY,
40
39.60
13.30
.00
TOTAL ROAMING CHARGES
1003
919.17
282.70
.00
IF YOU HAVE ANY QUESTIONS CONCERNING YOUR INVOICE OR SERVICE,
LAST
PLEASE CALL OUR CUSTOMER CARE DEPARTMENT:
1-800-888-7600
PAGE
EFTA00014766


c1: EFTA00015158
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015158.pdf
c6: pdf
c7: images
c0:
=== 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
The following information is provided in response to your request for a III search from the State of Florida based on:
ADDITIONAL SENTENCING INFORMATION MAY BE AVAILABLE FROM ORIGINATING AGENCY
CRIMINAL HISTORY RECORD
Introduction
This rap sheet was produced in response to the following request:
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
EFTA00015158

=== Page 2 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
2/14
EFTA00015159

=== Page 3 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
3/14
EFTA00015160

=== Page 4 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
4/14
EFTA00015161

=== Page 5 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
5/14
EFTA00015162

=== Page 6 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
6/14
EFTA00015163

=== Page 7 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
/14
EFTA00015164

=== Page 8 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
8/14
EFTA00015165

=== Page 9 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
9/14
EFTA00015166

=== Page 10 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
10/14
EFTA00015167

=== Page 11 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
11/14
EFTA00015168

=== Page 12 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
EFTA00015169

=== Page 13 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
INDEX OF AGENCIES
Agency
Address
Agency
Address
Agency
Agency
Agency
13/14
EFTA00015170

=== Page 14 ===
10/6/21, 12:46 PM
III/FBI/State Delayed Response
Agency
Address
Agency
Agency
Agency
Agency
*** END OF RECORD ***
14/14
EFTA00015171


c1: EFTA00016974
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016974.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Bruce Barket
To:
Cc: Aida Leisenring
Subject: New mcc problems
Date: Thu, 16 Jan 2020 16:43:10 +0000
In case we don't have enough to do on the 22nd, I intend to raise several issues about the jail. In no particular
order;
1. They are refusing to allow us to view the cells and common areas where Nick has been held for nearly 3 years.
Initially, we were told we would be permitted and that photographs would be taken and reviewed by the staff. We
are going to file a motion to compel before the 22nd.
2. I have written multiple emails to
asking for an opportunity to view the physical evidence for the July
23rd suicide attempt. She has thus not responded at all
3. We wrote complaining about multiple reports of extreme heat on the tier. One or two inmates had to be
hospitalized. We have not been given an update.
4. We asked for a family visit after next week's court appearance and gave the same reasons we have been
giving. This time we were asked for more detail. I sense a change in the mcc approach. My inclination is to ask
the judge to help here.
I was hoping the new administration would improve the conditions while maintaining
responsiveness.
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country road
Garden City, NY 11530
Barket Epstein.com
EFTA00016974


c1: EFTA00015704
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015704.pdf
c6: pdf
c7: images
c0:
=== 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: Wed, 07 Aug 2019 17:29:30 +0000
Attachments:
wav
Time: Aug 7, 2019 1:29:30 PM
Click attachment to listen to Voice Message
EFTA00015704


c1: EFTA00016611
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016611.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Child Exploitation & Porn Update Report III
Date: Mon, 22 Feb 2021 17:06:38 +0000
Attachments: Child_Exploitation_&_Porn_Update_Report_II.pdf
Attached is the Child Exploitation & Porn Update Report III for Project Safe Childhood.
Chiefs and Project Safe Childhood Coordinator, please remind the assigned AUSA to make updates in their
cases. Thanks!
EFTA00016611


c1: EFTA00017109
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00017109.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
1
1
(In open court)
2
THE COURT: All right. So the first thing that I
3
think we should address, sounds like it might be a brief
4
conversation, is the Curcio issue I had alerted the government
5
that there is -- a Curcio issue has arisen. I had appointed
6
Ms. Sternheim to be Curcio counsel. She's here.
7
MS. STERNHEIM: Yes.
8
THE COURT: But my understanding -- Ms. Sternheim,
9
you'll let me know if I'm wrong about this -- that we're not
10
yet ready to address all the issues. I know you've been
11
working diligently on it, but we're not quite done; is that
12
right?
13
MS. STERNHEIM: That is correct, Judge. And I can
14
contact the parties and your Honor as to a schedule if that is
15
helpful, but I do not have that in place.
16
THE COURT: Okay. That's fine. That sounds like a
17
good suggestion, and we can go from there. So I'll thank you
18
again for taking on this assignment. I thank you for being
19
here today and for the update.
20
The next issue, I think it makes sense to address, is
21
this question of sealing the correspondence with regard to
22
prison conditions, prison designation and then I think we have
23
to resolve the issue of Mr. Tartaglione's housing. So I've
24
read all the letters.
25
I don't know, Ms.
if you want to add anything.
EFTA00017109

=== Page 2 ===
2
1
MS.
No, your Honor. I have nothing to add.
2
We'll rest on our papers.
3
THE COURT: Okay.
4
And I take it that counsel for Mr. Tartaglione remain
5
agnostic on this issue; is that right?
6
MR. BARKET: Yes.
7
THE COURT: Okay. All right. So what we're talking
8
about here is the government's request to seal letters that
9
have been docketed. There have been redacted versions filed,
10
but we're talking about Docket Numbers 150 and 153.
11
And the background of this is that back on
12
August 21st there was a conference where we discussed, among
13
other things, issues related to Mr. Tartaglione's housing in
14
the MCC, and what I had asked the government to do is inquire
15
about options for housing Mr. Tartaglione at either the MCC or
16
MDC because those are the only two Bureau of Prisons facilities
17
in the New York metropolitan area. Because it turns out that
18
the other facilities, whether they were in Nassau County or
19
here in Westchester County or in other counties, those are not
20
federal facilities and those facilities either didn't have
21
contracts with the Southern District Marshals, or otherwise had
22
advised that they were not going to house Mr. Tartaglione. So
23
the particular question was whether or not MDC would be willing
24
to take Mr. Tartaglione back, and we had had a pretty fulsome
25
discussion about the issues that had led to Mr. Tartaglione's
EFTA00017110

=== Page 3 ===
3
1
transfer from MDC to MCC.
2
The government followed up, as I had asked it to,
3
with a letter dated August 23rd, and that's the letter, the
4
first letter the government ask be placed under seal that
5
addressed the issue about housing Mr. Tartaglione at MDC and
6
MCC, and the government, as I said, asked that the letter be
7
sealed. The Court, on August 26th, temporarily filed it under
8
seal, but then asked the government to further explain its
9
reasons for permanently sealing that letter.
10
On August 28th, counsel for Mr. Tartaglione filed a
11
letter which addressed the merits of the government's housing
12
options as presented in the August 23rd letter and counsel had
13
asked that that letter be filed under seal because it was
14
responsive to the government's letter which had been filed
15
under seal.
16
On August 29th, the government filed a letter arguing
17
that its August 23rd letter or at least a portion of it should
18
be filed under seal because it addressed Bureau of Prisons'
19
reasoning for either why it was that certain things had been
20
considered and certain steps that the Bureau of Prisons thought
21
would be necessary to house Mr. Tartaglione, and also the
22
government filed a letter stating that the August 28th letter
23
should remain under seal, that is, counsel for Mr. Tartaglione.
24
On September 5th, the New York Post and the New York
25
Daily News filed a letter arguing for the unsealing of the
EFTA00017111

=== Page 4 ===
4
1
letters. They were joined by the New York Times on
2
September 10th.
3
The government, as the Court had previously asked,
4
had submitted a response to I guess the first letter from The
5
Post and the Daily News explaining why and really reiterating
6
its argument for sealing and that's when counsel for
7
Mr. Tartaglione announced their agnosticism on the issue.
8
So the question actually has a couple of layers to
9
it. So the first question is whether or not the government's
10
letters are considered judicial documents. And a judicial
11
document is an item that is, "relevant to the performance of
12
the judicial function and useful in the judicial process," and
13
that's from the Second Circuit's decision in Bernstein V
14
Bernstein Litowitz Berger & Grossmann LLP, 814 F.3d 132, 139,
15
quoting from an earlier Second Circuit's decision in a case
16
called Lugosch V Pyramid Company of Onondaga, 435 F.3d 110,
17
119. The mere filing, however, of anything, whether it's some
18
kind of a document or a letter with the court by itself doesn't
19
render such a document a judicial document. That's from the
20
Second Circuit's decision in US versus Amodeo, 44 F.3d 141,
21
145. But if an item is a judicial document, then the public
22
has a presumptive right of access to it under both the common
23
law and the First Amendment. Also from Amodeo. The purpose of
24
this right is to ensure that courts are held accountable and
25
that the public has "confidence in the administration of
EFTA00017112

=== Page 5 ===
5
1
justice. Also from Amodeo.
2
Under the common law analysis, the Court is to
3
determine the weight of the presumption of access. "Generally,
4
the information will fall somewhere on a continuum from matters
5
that directly affect an adjudication to matters that come
6
within the court's purview solely to ensure their irrelevance."
7
That's from the second Amodeo case, 731 F.3d at 1049.
8
"Finally, after determining the weight of the
9
presumption of access, the Court must 'balance competing
10
considerations against it. " Lugosch at page 120.
11
Competing considerations include both "the danger of
12
impairing law enforcement or judicial efficiency, or "the
13
privacy of interests of those resisting disclosure. "
14
The first Amendment analysis requires two different
15
approaches. The first considers "experience and logic," that
16
is, "whether the documents have historically been open to the
17
press and general public" and "whether public access plays a
18
significant and positive role in the function of the particular
19
process in question.' That's from Bernstein at page 141.
20
The second approach which applies when the judicial
21
proceedings themselves are covered by the First Amendment
22
considers whether the documents are "derived from or a
23
necessary corollary of the capacity to attend the relevant
24
proceedings. That's from Lugosch at 120.
25
Under either approach, the moving party has to
EFTA00017113

=== Page 6 ===
6
1
demonstrate that sealing is "essential to preserve higher
2
values and is narrowly tailored to serve that interest."
3
Bernstein at 134. Further, the Court has to make "specific,
4
on-the-record findings
demonstrating that closure is
5
essential to preserve higher values and is narrowly tailored to
6
serve that interest." Lugosch at 120.
7
So the Government's argument is that the August 23rd
8
letter, in the first instance, is that the August 23rd letter
9
doesn't qualify as a judicial document because it has no
10
bearing on the charges contained in the pending indictment" and
11
"the location where [Mr. Tartaglione] is to be detained pending
12
trial is ancillary to this criminal prosecution." So in the
13
Government's view, its August 23rd letter is status report
14
about the BOP's "internal deliberations."
15
The government argues in the alternative that even if
16
it is a judicial document, that redacting certain information,
17
including most specifically BOP's explanation of
18
Mr. Tartaglione's housing options, is appropriate. And that's
19
because, according to the government "the BOP maintains that
20
the public filing of those paragraphs would jeopardize its law
21
enforcement functions and inappropriately hamper its interim
22
deliberative processes." I guess the BOP is arguing that any
23
presumption of access is overcome because the letter also, to
24
the extent it's even a judicial document, it still addresses
25
what BOP considers an ancillary matter. And so a public filing
EFTA00017114

=== Page 7 ===
7
1
would "hinder the internal deliberative process of the MDC and
2
thereby jeopardies the BOP's ability to carry out its function
3
of securing pretrial defendants," because the letter provides
4
details that were "taken into account to make an appropriate
5
housing decision for a defendant charged with multiple
6
murders.' Also, the assertion is the public filing of the
7
document, the letter, would "risk circumvention of the law"
8
because "the public revelation of internal deliberations" would
9
"enable all inmates to alter their behavior and manipulate
10
their housing assignments to cause harm to others or engage in
11
illicit behavior. "
12
The aforementioned media organizations argue that the
13
letter, the letter of August 23rd, is a judicial document
14
because it was submitted to the Court for purposes seeking or
15
opposing an adjudication, and also that there's significant
16
public interest in the conditions in BOP facilities, and
17
finally the conditions of Mr. Tartaglione's confinement are
18
relative to his case and his rights.
19
So addressing the threshold question about whether
20
the August 23rd and August 28th letters are judicial documents,
21
the Court concludes that they are. While the letters
22
themselves may not directly address the actual charges filed
23
against Mr. Tartaglione, that is not the governing standard.
24
The correct standard I've already mentioned is broader than
25
that, and therefore, in my view, the letters are "relevant to
EFTA00017115

=== Page 8 ===
8
1
the performance of a judicial function and useful in a judicial
2
process." First of all, the letters were filed in response to
3
a court order. So calling them a nonjudicial document seems
4
anomalous as they were directed as part of the judiciary's
5
overseeing of this case.
6
Second, the letter is related to an issue, that is,
7
Mr. Tartaglione's conditions of confinement, that could
8
substantially impact his ability to mount a defense and thus
9
are directly related to his trial rights, his constitutional
10
rights, among other things, to defend himself.
11
Indeed, the housing issue has been repeatedly raised
12
by counsel for Mr. Tartaglione precisely on that ground, and I
13
think understandably so, and so the relevance of the letters
14
follows from the relevance of Mr. Tartaglione's conditions, and
15
of course it's not irrelevant that this is a capital case.
16
The proof of that is that the issues that are
17
addressed in the letters have been addressed here in open court
18
really from the very first time that these issues have been
19
raised.
20
So put it in the language of the Second Circuit, the
21
specific contents of the letters are "relevant to the nature of
22
the proceeding," that is, how Mr. Tartaglione is being housed
23
in connection with his ability to defend himself in this
24
capital case. And I think it certainly is the case that
25
access, public access to the letters "would materially assist
EFTA00017116

=== Page 9 ===
9
1
in the public's understanding of these housing issues before
2
the Court in evaluating the fairness and integrity of the
3
Court's proceedings." That's from Second Circuit's decision in
4
Newsday LLC County of Nassau, 730 F.3d 156, 166-67. And of
5
course all this, in the Court's view, is consistent with
6
holding those of us in the criminal justice system accountable
7
for what it is we do.
8
So given the letters are judicial documents, the
9
Court proceeds to consider the weight of the presumption of
10
access and whether any competing interest overcomes the weight
11
of access such that portions of the letters may be redacted.
12
There is, I think, at the outset a waiver issue,
13
because a lot of even the deliberative process of the MDC has
14
been discussed before. So, for example, some of the
15
disciplinary issues that Mr. Tartaglione had they have been
16
discussed. There's been a great deal of discussion involving
17
conversation with counsel for MCC all the various things MCC
18
has had 20 do to accommodate Mr. Tartaglione's concerns, and
19
there's been a great deal of discussion, for example, about
20
conversations for Mr. Tartaglione and MCC officials and counsel
21
for the government and MCC officials, but in any event, the
22
weight of the presumptive right of access here is heavy. This
23
is a capital case. Given the obvious stakes involved, the
24
public has a deep interest in ensuring judicial accountability
25
in all aspects of the case, including adjudicating any
EFTA00017117

=== Page 10 ===
10
1
grievances related to pretrial confinement that might affect
2
Mr. Tartaglione's ability to defend himself in the case. Of
3
course that goes to the very fairness of the proceedings. Also
4
the public has an interest in the conditions of confinement in
5
BOP facilities in general. Anything that would suggest to the
6
contrary would be Kafkaesque. And Mr. Tartaglione's conditions
7
in particular, and in ensuring that BOP's decision-making on
8
inmate housing is reasonable seems to me precisely the kind of
9
thing that should be accessible to the public. So I think
10
BOP's argument in that regard falters.
11
To the extent BOP is arguing that its deliberative
12
process in this case satisfies the sort of compelling interest
13
that could justify sealing the portions of the letters that it
14
wants sealed, it bears noting that the parties seeking sealing
15
that wants to overcome this presumption has to show that
16
sealing will further a compelling interest, such as a law
17
enforcement concern, a national security concern, a public
18
safety concern. Obviously privilege is certainly a valid
19
concern, as are privacy interests. And the burden, of course,
20
is on BOP to make that showing. But I don't think BOP has done
21
that here. The deliberative processes that BOP is talking
22
about are not protocols, for example, that it never publicizes
23
as to how it is that it might secure inmates at a facility.
24
That would be different. That could very well be a situation
25
where disclosure of how BOP addresses specific security
EFTA00017118

=== Page 11 ===
11
1
concerns could alert people to then circumvent those concerns
2
and put not only BOP officials at risk but also other inmates
3
at risk. That's not what we're talking about here. We're
4
talking about the deliberative process that BOP says it engaged
5
in in evaluating where to house Mr. Tartaglione and how in
6
particular it would do so at MDC and MCC.
7
So, for example, to the extent that Bureau of Prisons
8
has some concerns about housing Mr. Tartaglione in the general
9
housing and explains why, a lot of the things that letters that
10
the BOP had the government put in its letter are things that
11
people know. So the fact that Mr. Tartaglione is facing the
12
death penalty, the fact that he used to be in law enforcement,
13
the fact that there's been this whole public scrutiny over what
14
happened with Mr. Epstein and Mr. Tartaglione being involved in
15
that, these are things that are commonly known. So to the
16
extent that the BOP took factors that were commonly known into
17
its so-called deliberative process in evaluating how it is that
18
he could be housed at the two facilities, including, by the
19
way, the fact that there have been prior disciplinary issues,
20
that's also been publically discussed here in Court, and it's
21
been the subject of letters. So the cellphone thing, for
22
example, and other prior disciplinary issues, that's all been
23
publicly discussed, and to the extent BOP took all those things
24
into consideration, I think it's hard for BOP to argue that
25
taking into consideration factors that were publicly known
EFTA00017119

=== Page 12 ===
12
1
about how it is best to house Mr. Tartaglione is the type of
2
discussion of security protocols that otherwise aren't public.
3
So I think it distinguishes between what BOP has done here and
4
what it maybe does in coming up with very specific protocols,
5
either as to a particular individual or as to how it is it
6
houses people generally at its facilities.
7
So I just don't see how unsealing the letters and
8
revealing the deliberative process is something that's going to
9
uniquely publicize certain things that are going to jeopardize
10
BOP officials or other inmates. For example, to the extent BOP
11
argues a disclosure could lead to bad behavior, that inmates
12
could manipulate their housing assignments, I just don't see
13
that here.
14
There are certain things about Mr. Tartaglione that
15
he has no control over. He has no control over the fact
16
that -- in terms of things he can change. He was a law
17
enforcement officer. The fact that BOP took that
18
consideration, I don't see how somebody can manipulate that to
19
somehow pretend that, for example, they weren't a law
20
enforcement officer. You can't change your history. So I just
21
don't understand how that's going to somehow lead to
22
circumvention of security protocols.
23
So I just don't think BOP has made the case that the
24
public disclosure is going to risk harming anybody, and so give
25
given the BOP'S, in my view, failure to establish a compelling
EFTA00017120

=== Page 13 ===
13
1
interest to overcome the presumption of public access, I'm
2
going to order the letters be unsealed.
3
If BOP wants to have you go to the Second Circuit,
4
can you let me know. I mean, I'll wait a day, Ms.
if
5
they're that concerned, but you'll let me know by the end of
6
business tomorrow?
7
MS. COMEY: Yes, your Honor.
8
the ocurt: Okay, thank you.
9
All right, any updates from the government?
10
MS.
Your Honor, we remain in the same place
11
we were last time, the government is ready for trial. We would
12
ask the Court to set a trial date.
13
THE COURT: Okay.
14
Mr. Barket.
15
MR. BARKET: Well, I mean, before I get to the trial
16
date part, we actually have something to say about that today.
17
THE COURT: Yes.
18
MR. BARKET: I'm curious about the issue concerning
19
the telephone which has been stewing for some while.
20
MS.
The government will not be seeking a
21
warrant for that phone.
22
THE COURT: Okay.
23
MR. BARKET: I guess, less work.
24
On the issue of the trial date, we have had some
25
discussions among counsel as to laying out what we think is a
EFTA00017121

=== Page 14 ===
14
1
reasonable schedule among US. We've had a preliminary
2
conversation about it with Mr. Tartaglione. We are still in
3
the process of kind of finalizing that. So what I'm going to
4
suggest to the Court is that you allow that process to continue
5
internally, and that before the next Court date we'll have
6
completed it, met with the government, proposed it to them and
7
hopefully gotten their agreement on it and then we can come
8
back with a joint scheduling order all the way through to the
9
trial.
10
(End of excerpt)
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
EFTA00017122


c1: EFTA00014588
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014588.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Call w/ DOJ re. Epstein SDNY Investigation
Start Date: 2020-10-05 19:00:00 +0000
End Date: 2020-10-05 19:30:00 +0000
Organizer: Singer, Linda
Location:
4279915#
Class: X-PERSONAL
Date Created: 2020-10-02 16:36:56 +0000
Date Modified: 2020-10-02 16:36:56 +0000
Priority: 5
DTSTAMP: 2020-10-02 16:15:45 +0000
Attendee:
)
i
(USANYS)
>;
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.
EFTA00014588


c1: EFTA00016735
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016735.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
,
Cc:
,
Subject: Tartaglione Motion
Date: Tue, 14 Jan 2020 15:59:33 +0000
Attachments: 2020.01.13 - Def_Mot_for_Hearing.pdf
All - Attached is the motion that Barket filed last night seeking a hearing on the MCC video. We are working on a
response and will send around.
Co-Chief, Narcotics Unit
United States Attorney's Office
Southern District of New York
EFTA00016735


c1: EFTA00015994
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015994.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Bruce Barket
To:
(USANYS)"
Aida Leisenring
Tony Ricco
"BRUCE KOFFSKY"
>, John Diaz
"Kenneth J. Montgomery Esq"
Cc:
)"
Subject: RE: Statements by Mr. Tartaglione
Date: Fri, 22 Nov 2019 18:55:02 +0000
Received. Thanks
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination,
distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error,
please notify us immediately by telephone or email and immediately delete this message and all its attachments
From:
(USANYS) [mailto:
Sent: Friday, November 22, 2019 11:51 AM
To: Bruce Barket; Aida Leisenring; Tony Ricco; BRUCE KOFFSKY;
; John Diaz; Kenneth J.
Montgomery Esq
Cc:
)
Subject: RE: Statements by Mr. Tartaglione
All,
In response to your request for any statements made by Mr. Tartaglione during interviews at the MCC related to the
investigation into an event involving Jeffrey Epstein on or about July 23, 2019, we are producing to you a zip folder with
reports of those statements. The zip folder also contains reports of statements attributed to Mr. Tartaglione that were
conveyed to MCC staff by Mr. Epstein. These materials have been marked "sensitive" pursuant to the protective order in
this case and should be treated accordingly.
In response to your additional request for "all the reports and video regarding Mr. Epstein's attempted suicide on July 22-
23rd, we do not believe these materials are relevant to this case or covered under Rule 16, and therefore will not be
producing them. If you would like to discuss further, please give us a call.
S Attorney
From: Bruce Barket
Sent: Wednesday, November 20, 2019 8:50 AM
To:
(USANYS)
Cc:
is
>; ; Aida Leisenring
EFTA00015994

=== Page 2 ===
Subject: Re: Statements by Mr. Tartaglione
Thank you.
In addition to the statements attributed to Mr. Tartaglione we are asking did for all the reports and Video regarding
Epstein's attempted suicide on July 22-23rd.
I believe we sent a letter to the MCC shortly after the event asking that the video be preserved.
Bruce Barket
Barket, Epstein, Kearon, Aldea & LoTurco
666 Old Country road
Garden City, NY 11530
Barket Epstein.com
On Nov 19, 2019, at 12:23 AM,
(USANYS)
wrote:
Bruce - To the extent your request is to the MCC/BOP, the request is governed by the procedures set forth below in
email. To the extent the request is to our office pursuant to Rule 16, as a courtesy, we will look to see what
statements are in our possession and gather and produce them to you by the end of the week. The production will be
pursuant to the protective order in this case.
Assistant United States Attorney
From:
Sent: Monday, November 18, 2019 8:50 AM
To: Bruce Barket
is
(USANYS)
is
Cc: Aida Leisenring
Subject: Re: Statements by Mr. Tartaglione
Hi Bruce,
Pursuant to FOIA/Privacy Act and Touhy regulations, we need a release from the inmate, Touhy letter, and subpoena for
the request to be considered locally. Please also be advised that we would have to seek authority under Touhy through
the USAO.
Thank you,
>>> Bruce Barket
>
11/17/2019 5:03 PM>>>
It is my understanding that Mr. Tartaglione was interviewed by members of Bureau of Prisons in the late hours of July
22nd or the early hours of July 23, 2019 concerning Jeffrey Epstein's reported attempted suicide attempt. Pease provide
the record of any statements made by Mr. Tartaglione, any written statements made by Mr. Tartaglione and any
recording of any such statements.
Bruce A. Barket, Esq.
EFTA00015995

=== Page 3 ===
Barket Epstein Kearon Aldea & LoTurco, LLP
666 Old Country Road, Ste. 700
Garden City, NY 11530
www.barketepstein.com
This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear
that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review,
dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this
communication in error, please notify us immediately by telephone or email and immediately delete this message and all its
attachments
EFTA00015996


c1: EFTA00016422
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016422.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Akin Gump
STRAUSS HAUER & FELD LLP
PARVIN DAPHNE MOYNE
December 24, 2019
CONFIDENTIAL PURSUANT TO FED. R. CRIM. P. 6(e)
VIA ELECTRONIC DELIVERY
Assistant U.S. Attorney
U.S. Attorney's Office
Southern District of New York
1 Saint Andrew's Plaza
New York, NY 10007
Re: July 11, 2019 Subpoena to Deutsche Bank
Dear Mr.
On behalf of our client, Deutsche Bank AG, New York Branch and its affiliates ("Deutsche
Bank" or the "Bank"), we write in further response to the grand jury subpoena dated July 11, 2019
(the "Subpoena"). This letter and the enclosed document production represent the thirteenth
submission in our client's rolling response to the Subpoena.
Enclosed with this letter is an encrypted file labeled DB-SDNY-PROD013, responsive to
items 1, 2, 3, 4, 5, 6, 7, 8, 9, 17, 18, 19, 20, 21, 24, 26, and 27 of the Subpoena. The documents
are labeled DB-SDNY-0100861 to 0124801. We have prepared a production index, attached as
Appendix A, which identifies the following categories of documents responsive to the Subpoena:
Emails: Today's production contains emails from the custodial
files of
who served as Jeffrey Epstein's relationship manager from
2013 to 2016. The emails generally relate to Mr.
management of the
Bank's relationship with Jeffrey Epstein and his associates. Mr.
emails are responsive to multiple requests in the Subpoena, including account
openings, KYC reviews, wire transfers, and correspondence with account
holders. Mr.
emails are identified as
Emails" in the attached
production index.
Emails: Today's production contains emails from the custodial
files of
who served as the Co-Head of
from 2013 to 2016. Mr. Packard was involved in the decision to
EFTA00016422

=== Page 2 ===
December 24, 2019
Page 2
onboard Mr. Epstein as a client, as well as the decision to maintain the
relationship after concerns were raised in January 2015. Mr.
emails
are designated
Emails" in the attached production index.
The decryption password for the production will be provided by separate email. As we
have discussed, we continue to collect relevant information related to the Subpoena, and expect to
make additional productions in the near future.
*
Because we are producing these materials pursuant to a grand jury subpoena, it is our
understanding that this production will be treated as confidential consistent with Federal Rule of
Criminal Procedure 6(e). Notwithstanding the confidentiality of the enclosed materials and
information, should you receive any request for disclosure of such information, pursuant to the
Freedom of Information Act or otherwise, we ask to be notified in a timely fashion and given the
opportunity to object to such disclosure. Further, should you determine to disclose any materials
to any third party, we ask to be given reasonable advance notice in order to allow us to pursue any
available remedies. In such event, we request that you contact the undersigned by email or
telephone rather than rely on regular mail or facsimile transmission to provide such notice. Please
advise us if you object to or disagree with the foregoing requests.
For the avoidance of doubt, no response or document provided in response to the Subpoena
shall be construed as a waiver of any applicable privilege or doctrine available to Deutsche Bank
under state or federal law. If it were found that production of any of the enclosed materials
constitutes disclosure of otherwise privileged matters, such disclosure would be inadvertent. By
the production of such documents, Deutsche Bank does not intend to waive and has not waived
the attorney-client privilege or any other protections.
Please do not hesitate to contact us at
or
if you
have any questions. We look forward to continuing to work with you in a cooperative manner.
Sincerely,
Pa
Parvin D. Moyne
James J. Benjamin, Jr.
Thomas C. Moyer
EFTA00016423

=== Page 3 ===
December 24, 2019
Page 3
Enclosures
EFTA00016424


c1: EFTA00014377
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014377.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Automatic reply: 3500 Production
Date: Tue, 27 Aug 2019 02:19:03 +0000
I am currently on trial before the Honorable Ronnie Abrams. I will be checking email at the end of each trial day If need immediate
assistance in connection with United States V. Epstein, 19 Cr. 490 (RMB), please contact AUSA
at
For all other matters,
please contact
at
hank you.
EFTA00014377


c1: EFTA00015290
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015290.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "Matthew L. Schwartz"
To:
Cc:
)"
Subject: Re: Forfeiture question
Date: Mon, 14 Oct 2019 00:22:25 +0000
Thanks
If any of you have a moment for a forfeiture-related question in the next few days, please let me
know. FYI, this has nothing to do with my firm's representation of certain victims. Thanks.
-mls
Matthew L. Schwartz
On October 13, 2019 at 7:44:17 PM EDT,
wrote:
Hi
,
The Epstein case team are AUSAs
and
all cc'd on this email.
They're the right people to talk to about anything Epstein-related.
Sent from my iPhone
On Oct 13, 2019, at 2:59 PM, Matthew L. Schwartz
wrote:
Do either of you guys or the appropriate other person have 2 minutes to discuss a somewhat time-sensitive,
but by no means urgent, Epstein-related forfeiture question in the next few days?
Matthew L. Schwartz
The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain
information that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If
the reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby
notified that any dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received
this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your
computer. [v.1 08201831BSF
EFTA00015290


c1: EFTA00015156
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015156.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
10/6/21, 2:44 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
EFTA00015156


c1: EFTA00014649
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014649.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Letter due re GX 52
Start Date: 2021-11-21 17:00:00 +0000
End Date: 2021-11-21 17:30:00 +0000
Organizer:
Class: X-PERSONAL
Date Created: 2021-11-20 06:51:45 +0000
Date Modified: 2021-11-20 06:51:45 +0000
Priority: 5
DTSTAMP: 2021-11-20 00:15:15 +0000
Attendee:
Alarm: Display the following message 15m before start
Reminder
The Court is in receipt of the Government&#8217;s supplemental letter regarding Government
Exhibit 52, Dkt. No. 457, and the Defendant&#8217;s response, which has been temporarily filed
under seal to allow the parties the opportunity to request limited redactions. The Government is
hereby ORDERED to file a reply to Defendant&#8217;s response on or before 12:00 p.m. on
November 21, 2021. The letter reply should address the Defendant&#8217;s argument that
Employee-1 cannot authenticate Government Exhibit 52 because Mr.
a former
,
employee, purportedly removed the document from the property before Employee-1 began
working for Mr. Epstein. The parties are FURTHER ORDERED to file any proposed redactions to
the motion papers on the public docket on or before November 22, 2021, justifying any
requested redactions by reference to the three-part test articulated by the Second Circuit in
Lugosch V. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006).
EFTA00014649


c1: EFTA00014698
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014698.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
(USANYS)"
Cc:
)"
)"
)"
Subject: RE: [EXTERNAL] 20CR330 U.S. V GHISLAINE, MAXWELL
Date: Mon, 22 Nov 2021 18:31:34 +0000
Thank you!
From:
(USANYS)
Sent: Monday, November 22, 2021 1:31 PM
To:
Cc:
is
>;
Subject: Re: [EXTERNAL] 20CR330 U.S. V GHISLAINE, MAXWELL
Hi, thanks very much. We expect to be ordering the transcript for same day delivery. Thanks!
On Nov 22, 2021, at 10:57 AM,
wrote:
Hi, the FPTC for the above case is scheduled to take place tomorrow for 4 hours beginning at 9:30. Please let
me know if you're interested in ordering the transcript so we can assign reporters accordingly. Thank you!
EFTA00014698


c1: EFTA00016732
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016732.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
Subject: RE: Epstein flight records
Date: Wed, 08 Jan 2020 01:29:20 +0000
I believe they are
(they're initials, and at least
may have changed her name in the
interim). We haven't yet spoken to either.
From:
(
Sent: Tuesday, January 07, 2020 20:28
To:
Cc:
is
is
)
Subject: Re: Epstein flight records
Thanks very much. Who are the two potential Maxwell witnesses?
Sent from my iPhone
On Jan 7, 2020, at 7:56 PM,
wrote:
For your situational awareness, wanted to let you know that the flight records we received yesterday reflect that Donald
Trump traveled on Epstein's private jet many more times than previously has been reported (or that we were aware),
including during the period we would expect to charge in a Maxwell case. In particular, he is listed as a passenger on at
least eight flights between 1993 and 1996, including at least four flights on which Maxwell was also present. He is listed
as having traveled with, among others and at various times, Marla Maples, his daughter Tiffany, and his son Eric. On one
flight in 1993, he and Epstein are the only two listed passengers; on another, the only three passengers are Epstein,
Trump, and then-20-year-old
On two other flights, two of the passengers,
respectively, were women who would be possible witnesses in a Maxwell case. We've just finished reviewing the full
records (more than 100 pages of very small script) and didn't want any of this to be a surprise down the road.
Assistant U.S. Attorney
Southern District of New York
EFTA00016732


c1: EFTA00016425
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016425.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
)"
Cc:
)"
)"
Subject: FW: Epstein search warrant documents
Date: Mon, 18 May 2020 14:29:50 +0000
- would one of you be able to please send me a spreadsheet for the electronic devices seized from the New
York residence with locations/seizure information, like the one you sent me for the USVI search? Thanks!
From:
Sent: Friday, May 15, 2020 7:57 PM
To:
is
Cc:
is
is
is
Subject: RE: Epstein search warrant documents
,
I can get you better identifiers Monday. I'll be in then.
and
have access to better documentation to
the search, as in location of findings. I don't have that. Will get you the outstanding stuff as soon as I get the
drives to put it on.
cell
desk
On May 15, 2020 4:12 PM,
)"
wrote:
Thanks for this, it's a helpful start. In terms of being able to write our search warrant, one additional piece of information
we need is the serial number, or some other specific identifier, ideally for each device but at least for any device that there
is more than one of the same thing. So for example, we need to be able to somehow differentiate the following devices -
-
The two Dell power edge T310 hard drives (NYC024323 and NYC024324)
-
The two Sony Vaio laptop / Fujitsu hdd (NYC024336 and NYC024337)
-
the following loose storage devices:
Micro SD card (NYC024339)
Flash Drive (generic) (NYC024340)
Thumbdrive (Emtec) (NYC024341)
hard drive (loose) (NYC024342)
verbatim thumbdrive (NYC024343)
-
The four San Disk cruzer-thumbdrives (NYC024344-47)
-
The three Seagate IDE hard drives (NYC024348-50)
-
The camera SD card (NYC024351)
EFTA00016425

=== Page 2 ===
I think the rest of the devices are either specifically distinguishable and/or have an S/N listed. (By comparison, the USVI
spreadsheet we have lists an s/n for about 20 of the 25(ish) devices.
The other thing we're looking for is the location in the house (and ideally specific location) for each device, which the USVI
list also has - is that info available?
The list also has just five devices as still pending to be transferred to us, and I think it's right that the plan is to reproduce
all the materials so that we can get them in searchable format, but just wanted to confirm? Currently, we aren't able to
match any of the prior productions to specific devices - so if we're able to match them up by Bates number now, that
might work, but otherwise I think it makes sense for us to get everything. But let us know if any issue with that.
thanks very much,
From:
Sent: Thursday, May 14, 2020 15:54
To:
is
Cc:
is
is
is
Subject: Re: Epstein search warrant documents
Here is The listing of all the evidence gathered in NY that I have. I added some columns to guide you to the
unique numbers CART NY uses fro their evidence. The template wasn't a slam dunk over, so I did what I could to
convey the information. If you are confused by anything, please let me know. In the column for approximate
size, it is in GB, totaled at the bottom and converted to TB. In the materials contained column, I put what load
file group the data was transferred over in (Mac, Windows, Loose Media, IDE, or Blacklight) If there is no entry
in that column, that data has yet to be transferred. There are 2 Macs and a DVR you don't have as well as an
iPhone and an iPad. IF the descriptions are a bit light, let me know and I'll do what I can to beef them up. I will
get you the Island stuff tomorrow.
From:
Sent: Wednesday, May 13, 2020 12:25 PM
To:
is
Cc:
is
is
is
Subject: RE: Epstein search warrant documents
Respectfully, I think there are some miscommunications here - all we have asked is to receive the materials in a format
such that we can view them using a system we have access to. We're not able to get web-enabled access through any FBI
tool, so we asked for the materials to be transferred in a loadable format so we could put them on Relativity, which both
EFTA00016426

=== Page 3 ===
we and the agents can access. We're required to have the files in a format that we can produce them to defense counsel.
I've done that in many other cases and it hasn't previously been an issue. My understanding from
is that the best
way to do it now is just for us (the U.S. Attorney's Office) to get the original files, which our vendor will process-by which
I just mean converting into file formats that are loadable onto Relativity. It doesn't really have anything to do with the
taint review-we have to have access to the docs in our systems for discovery purposes.
And we were happy to get the materials as they were processed, but when we received the 1.1 million documents earlier
this year, they were in a format that wasn't usable for the reasons described in the email I sent on March 9. Again, I
understand from
that the best way forward is to just get copies of the materials in their original formats, which I
understand will be segregated and designated by device. That should work for us! I was just trying to understand the
approach, as well as the timeline.
thanks,
From:
Sent: Tuesday, May 12, 2020 13:03
To:
is
Cc:
is
is
is
Subject: Re: Epstein search warrant documents
Just to be clear. The US Attorney's Office (or it's contractors) are not "processing" anything. You are taking files
that I will be extracting from processed evidence and putting them into an E-Discovery tool (Relativity) to do a
taint review.
Relativity is NOT a forensic tool. It is incapable of dealing with many things that are found forensically on a
computer like free space, slack space, and system files to name a few. When we started this, and you insisted
you do the taint review in Relativity, I warned you that it was adding months worth of work on top of what was
already done, and that Relativity was incapable of viewing everything. You insisted we do it this way. So now
and I have come up with a way to fit this round peg into this square hole. We will get it done.
Sorry it has taken so long, but we are talking about terabytes worth of data over multiple forms of digital
evidence. Phones, tablets, loose media, cameras, DVRs, servers, laptops, and desktop computers. We have
gotten past encryption on multiple devices. When we review devices on such large cases, we usually do it piece
by piece as things are processed, I was unaware that you didn't want to review as things were processed, that
you wanted to do it "all at once", so that added to the delay. Sorry for that. Just a differentiation of
methodology I suppose.
and I feel confident that the method we have come up with will be more consistent and preserve the
attribution of files to devices and links of e-mails to attachments that the load file generation that I did a while
back was lacking.
EFTA00016427

=== Page 4 ===
From:
Sent: Tuesday, May 12, 2020 11:33 AM
To:
is
Cc:
is
Subject: RE: Epstein search warrant documents
Okay, so just to check, you both think that there is not a need to do a test run? You're both comfortable with just basically
sending us copies of everything? I don't totally understand why we couldn't have done that eight months ago, but
regardless of the passage of time, I want to make sure we understand so we can report to our supervisors. I assume that
means that we (at the U.S. Attorney's Office and through contractors) will therefore need to do all the processing
ourselves, correct? And thanks again to you both.
From:
Sent: Tuesday, May 12, 2020 11:30
To:
is
Cc:
is
)
Subject: RE: Epstein search warrant documents
Like
said in his earlier email. It will be the raw data and it will be marked so it is easier to attribute it to a
particular device. Problem now is how to get the data to
since he is teleworking.
cell
desk
On May 12, 2020 11:15 AM,
)"
wrote:
I have no doubt you do, but can you please tell us what that plan is? Thanks!
From:
Sent: Tuesday, May 12, 2020 11:11
To:
is
Cc:
is
Subject: RE: Epstein search warrant documents
I will use the spreadsheet, no problem.
and I ironed out all the details. We've got a good plan moving
forward that will meet your needs.
cell
desk
On May 12, 2020 10:34 AM,
)"
wrote:
it would be very helpful for us if you could please use the attached spreadsheet in transmitting that info so we
make sure we get all the info we need. I think you had previously sent us a list of certain information that unfortunately
wasn't helpful for us, so we want to make sure we're all on the same page.
EFTA00016428

=== Page 5 ===
In terms of data transfer,
are you just sending a literal copy of all the raw data, and we'll process and upload it on
our end? I ask to make sure we don't lose any searchability - when FBI sent versions before, it had already been
processed. I think what we talked about on the phone a month ago was getting, for example, data from one device to
make sure it transfers correctly, before sending over literally everything - is that still the plan?
thanks,
From:
Sent: Tuesday, May 12, 2020 10:27
To:
Cc:
Subject: RE: Epstein search warrant documents
Hello
Me and
just finished our phone call regarding the data.
will put together a list of the all of the data and
where the data was collected. I will work to send some hard drives to
so he can begin to copy the data and send
it to us. I will need to figure out a way to get the data off of the hard drives.
Please let us know if there are any questions.
Thank you.
From:
Sent: Friday, May 8, 2020 2:15 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
>;
is
is
is
Subject: RE: Epstein search warrant documents
Okay thanks - please do let us know if at any point that changes, otherwise we'll look forward to being able to review the
returns in early June. Thanks again.
From:
Sent: Friday, May 08, 2020 14:14
To:
(USANYS)
is
is
is
(USANYS)
Cc:
is
is
i
is
Subject: RE: Epstein search warrant documents
There has been talk of us returning to normal soon, so I don't think it will effect the timeline I initially gave you.
If it does, I'll let you know.
EFTA00016429

=== Page 6 ===
cell
desk
On May 8, 2020 1:58 PM,
)"
wrote:
Understood, thanks-it will be great to get that list on Thursday. As a refresh, the info we are looking for is in the
attached spreadsheet template.
On the returns themselves, do the changes you mentioned mean that the estimate of a month from now for complete
transmission of the search warrant returns is no longer likely? If so could you please let us know what the current
estimate would be, so we can factor that in? Thanks very much.
From:
Sent: Friday, May 08, 2020 13:50
To:
(USANYS)
i
-
is
V.
(USANYS)
Cc:
is
>;
>;
i
Subject: RE: Epstein search warrant documents
Sorry for the delay, they reduced us to 1 day a week, so things have been stretched out by a factor of 5. I will be
back in the office on Thursday and will be able to get you the list then as I have to access some of our systems to
do so.
Also,
, please reach out to me at one of the numbers below so we can brain storm. Thanks.
cell
desk
On May 8, 2020 12:10 PM,
)"
wrote:
Following up on the below, I think you had said you expected to be able to get us a list of the devices seized from the
search warrants at Epstein's residences in New York and the USVI, as well as from his person upon arrest, in about a
month (during our conference call a month ago) - so wanted to check if we can still expect that very soon? We're waiting
on that list to be able to do an updated search warrant on all of those devices. Please let us know the current timeline -
and also the current timeline on producing the results from those August and September searches? I think you and
were going to coordinate on that, and you had mentioned you expected we'd have it a couple months from our call, which
would be about a month from now. Wanted to make sure we're still on track.
thanks,
From:
Sent: Tuesday, April 07, 2020 15:27
To:
)
is
(USANYS)
EFTA00016430

=== Page 7 ===
>;
(USANYS)
Cc:
is
is
is
is
Subject: RE: Epstein search warrant documents
Ok let's plan on 11am tomorrow morning, I am trying to get an FBI line with a larger capacity but I won't know until
tomorrow am. I will push it out when confirmed.
Thanks
From:
[mailto:
Sent: Tuesday, April 07, 2020 3:15 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
i
i
is
is
)
Subject: RE: Epstein search warrant documents
Yes, I can do anytime tomorrow, and
can also join anytime tomorrow. So whenever is good on your end.
Also, we can host a conference call, but only up to six lines at a time - so if FBI has larger capacity than that let us know,
otherwise I'd propose we do:
From:
Sent: Tuesday, April 07, 2020 14:13
To:
(USANYS)
i
is
is
(USANYS)
Cc:
is
>;
is
is
Subject: RE: Epstein search warrant documents
,
Are you available tomorrow for a conference call to discuss this issue?
On Apr 7, 2020 1:55 PM,
)"
wrote:
EFTA00016431

=== Page 8 ===
Following up on this from a month ago - I know we're living in a different world than what existed four weeks ago, but are
you at all able to assist while working remotely? This has been pending for almost two months and we still don't have a
very basic list of each device or item that was seized and searched, or for which of those we've received materials. We're
happy to have a call if that would be useful, but as a first step the most basic thing we're looking for is the info in the
template spreadsheet we sent earlier (that's also attached).
thanks,
From:
Sent: Monday, March 09, 2020 12:00
To:
is
(USANYS)
is
(USANYS)
Cc:
is
is
is
Subject: RE: Epstein search warrant documents
Unfortunately I don't think this is very helpful to us. Did you take a look at the example spreadsheet I sent on 2/24? The
excel file you sent has descriptions that don't match up to the items listed in the search warrant returns (that we sent on
2/23), and we don't have the 1B or CART numbers to be able to cross-reference. We also can't tell what you mean by
"loose media" without a specific comparison to what was seized, we don't know which items you're referring to as
"Windows machines," and we can't tell whether the entirety of any particular item has been transferred, or just partial.
For example, it looks like we have gotten very, very few image files, which is surprising.
We have also encountered some very significant problems in trying to review the more than 1 million documents we
recently received:
-
The data we've received has no way to put any emails and attachments together. So if an email says, "see the
attached flight records," for example, we have no way of linking that up with the records themselves. Not only is
that a big problem for us in review, it's going to be a huge problem for producing the documents to defense
counsel.
The load file has no link to the native file, so when we load the data to the database, there's no way to have the
native files show up in the database. Because many of the files are too large to open in the viewer, it effectively
means that there are many files that are completely invisible to us.
Related, the control numbers in the load file don't match up to the native files. So we have two sets of numbers
and no way to match up anything-that is, even if we were to try to go hunt down every individual large file in the
native files, it would be impossible.
So the data that we most recently got, we need to get in a form that addresses those issues, and we likely will need to get
a similar reproduction of the data we received a couple months ago. Otherwise we're sifting through more than a million
documents without much rhyme or reason.
I've re-attached the spreadsheet we sent last week - I think that's a good place to start in terms of our necessary record-
keeping, and we need that info at the very least, as well as anything else you think would be useful. Also attaching the SW
returns for reference. And again, we're happy to meet up anytime and hash all this out in person if that's useful.
thanks,
EFTA00016432

=== Page 9 ===
From:
Sent: Wednesday, March 04, 2020 16:36
To:
is
(USANYS)
is
(USANYS)
Cc:
is
is
>;
is
Subject: RE: Epstein search warrant documents
Here is a listing of what I have already handed over in load files to the US Attorney's Office for taint review. Some points of
clarification: There were 9 IDE hard drives found in the Manhattan apartment, they turned out to be 3 copies of 3 drives
(9 drives in total) from a July 2007 search on one of his properties. I only processed 3 (as they were all copies). All the
loose media from the NY apartment is included. All the Windows machines from the NY apartment are included. Only 2
Macs from NY and 1 from the Island are included.
I will have to more closely coordinate with whoever is loading up Relativity with the remaining Macs as the tool
they have to be processed with does not easily re-name the load files.
Spreadsheet is attached.
(office)
(cell)
From:
)
[mailto:
Sent: Tuesday, March 03, 2020 12:25 PM
To:
is
(USANYS)
is
is
(USANYS)
Cc:
is
i
i
is
)
Subject: RE: Epstein search warrant documents
I could do Thursday morning, but I think it would be helpful for us to get the accounting in advance of the meeting so we
can figure out in advance what (if any) additional steps we need - is that possible?
From:
Sent: Tuesday, March 03, 2020 09:59
To:
(USANYS)
is
i
(USANYS)
Cc:
is
is
i
is
Subject: RE: Epstein search warrant documents
Can we do Thursday morning? My network should be back by then and I can give you a good accounting.
EFTA00016433

=== Page 10 ===
cell
desk
On Mar 2, 2020 11:15 AM,
)"
wrote:
Doing the weekly check in on this - is there a time this week when everyone can meet on this?
thanks,
From:
Sent: Monday, February 24, 2020 17:38
To:
>;
(USANYS)
i
is
(USANYS)
Cc:
is
>;
>;
i
Subject: RE: Epstein search warrant documents
Totally understand about the network issues-we can relate. I do still think it will be helpful to all sit down together to
have an in-person discussion, to make sure everybody is on the same page. Are folks available for that next week? And
what I think would be most helpful to facilitate that would be a spreadsheet of each separate device referenced in the two
search warrant returns, with columns for whether we've dumped the contents, whether they've been reviewed and/or
transferred, what portions were transferred, etc.
Something roughly like the attached, with any other categories you think would be useful - and the info on the attached is
mostly hypothetical, obviously, just as examples. That will help us fully understand what's been reviewed, transferred,
and received so far, and what remains.
(Also just on the pictures, we do want copies of those as well, please including from the discs and the devices - I think FBI
was going to do an initial screen to make sure no CP, and since I think the answer was no, we'll need to get those to be
able to review them as well.)
many thanks,
From:
Sent: Monday, February 24, 2020 09:24
To:
(USANYS)
i
>;
(USANYS)
Cc:
is
>;
is
i
Subject: RE: Epstein search warrant documents
,
Sorry for the delayed response. They are tearing out our old network and giving us a new one, they mandated we
delete old stuff (about 400 TB worth). Now that they are working on replacing the network, we can do only local
work. I should be able to give you an accounting of what is what. I can say, off the top of my head, that all
windows based items from the NY search have been handed over as well as all loose media. The CDs from NY
only contained pictures, no documents. There are still some Apple items from NY that need to be produced. As
far as the Island stuff goes, the 1st item on your spreadsheet, the "kitchen" mac has been produced. Still working
on the rest.
EFTA00016434

=== Page 11 ===
cell
desk
On Feb 23, 2020 12:21 AM,
)"
wrote:
Team,
Following up on the below from last weekend, I'm still not sure how we're addressing this so I thought it would make
sense for us to all schedule a (hopefully relatively brief) meeting to all get on the same page? We didn't hear back on
which files had previously been provided, but our tech folks did their best to differentiate, and we got access to the
materials yesterday and its well over a million documents, and we don't have any idea what we're looking at - i.e., which
devices the materials came from, whether it's full or partial results, how many more devices we have coming, etc.
Based on the attached search warrant returns, it looks like from the New York mansion (the PDF) there are approximately
40 devices that would have storage (computers, hard drives, thumb drives, etc.) and that's not even counting at least 60+
CDs. And then from the Virgin Islands (the Excel spreadsheet), at least more than 25 devices, including multiple servers /
server racks.
So we gotta know what we've already received, what remains, anticipated schedule, etc, and I know it's a lot of moving
pieces on all sides so wanted to loop in everybody at once. The case team will be in California this coming week from
Tuesday through Friday, but then I think generally around the first week of March, which will hopefully be plenty of time
to schedule a productive meeting.
thanks all,
From:
Sent: Saturday, February 15, 2020 16:30
To:
is
Cc:
is
>;
is
Subject: RE: Epstein search warrant documents
I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it - I have the
hard drive that
dropped off that has new Epstein search warrant materials, but it looks like there are also old
materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new.
Just generally, and
and I talked about this last week too, but it's basically impossible for us to keep track of what
we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of
which devices have been extracted and downloaded.
So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified
date of 11/14/19, which I think we may have already previously received - but I'm not sure, because we haven't gotten
any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a
modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has
more than 600,000 items.
EFTA00016435

=== Page 12 ===
I don't want to give
anything that we've already previously received and uploaded, and I can't tell from the folder or
file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to
what we already have.
are you able to give us some guidance on this? Ultimately what we really need is a
spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info -
which device, and what materials from it - are being given to us with each data transfer. Otherwise I think
organizationally and for review purposes it will be a total disaster for us.
We're happy to have a meeting on this if that's helpful - and thanks everybody for the assistance.
Assistant U.S. Attorney
Southern District of New York
EFTA00016436


c1: EFTA00015297
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015297.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To: "Berman, Geoffrey (USANYS)"
Subject: Re: Epstein
Date: Sat, 10 Aug 2019 12:35:45 +0000
I'm not far from the office if you need me.
Sent from my iPhone
> On Aug 10, 2019, at 8:24 AM, Berman, Geoffrey (USANYS)
wrote:
V
> I just got a call from
that Epstein committed suicide this morning. He died on the way to the
hospital.
EFTA00015297


c1: EFTA00015530
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015530.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
(USANYS)"
Cc:
)"
Subject: RE: Filing
Date: Fri, 12 Jul 2019 21:27:26 +0000
Importance: Normal
Attachments: 2019-07-12,_JE,_government_opposition_to_bail_motion_(with_exhibits).pdf
Just a few last-last-minute edits :) All filed, and attached for records.
From:
Sent: Friday, July 12, 2019 17:23
To:
(USANYS)
is
(USANYS)
Cc:
>;
Subject: Filing
I'm logged on remotely while waiting for my flight and am happy to file the bail reply letter if the final version is ready and
is still tied up.
Assistant United States Attorney
Southern District of New York
EFTA00015530


c1: EFTA00015942
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015942.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: FW: CRUCIAL EVIDENCE FEGARDING TO JEFFREY EPSTEIN'S DEATH/TRAFFICKING
RINGS/MAIN CONNECTIONS
Date: Mon, 13 Jul 2020 22:05:31 +0000
Sending this per our usual practice - thanks.
From:
Sent: Monday, July 13, 2020 18:04
To:
Subject: Fwd: CRUCIAL EVIDENCE FEGARDING TO JEFFREY EPSTEIN'S DEATH/TRAFFICKING RINGS/MAIN CONNECTIONS
Sent from my iPhone
Begin forwarded message:
From: Jose Leon <jos.israelleon@gmail.com>
Date: July 13, 2020 at 5:17:58 PM EDT
To:
Subject: CRUCIAL EVIDENCE FEGARDING TO JEFFREY EPSTEIN'S DEATH/TRAFFICKING
RINGS/MAIN CONNECTIONS
Please read carefully. The following information is not to be taken lightly. The following information will
provide key Witnesses as well as many others involved within Child/sex Trafficking/Pornography Rings
leading up to the Main Owners seeking and using Government Technology within the State of Wisconsin. July
13th 4:11pm.
https://photos.app.goo.gl/Gc8xGDJ3JcDT6LoF9
https://photos.app.goo.gl/3H2uZcV5pSAkqhQD6
https://photos.app.goo.gl/3H2uZcV5pSAkqhQD6
https://photos.app.goo.gl/s5eUvfo5vpC3yTuz5
https://photos.app.goo.gl/XCQSt6x4TvYKzGPMA
https://photos.app.goo.gl/8mBpvec45A82Frox7
https://goo.gl/94E4Om
EFTA00015942

=== Page 2 ===
https://photos.app.goo.gl/ncWRvTiiue68u2iC7
https://photos.app.goo.gl/4g6JzNiYHDgW3KcU7
https://photos.app.goo.gl/N4qjJfneZXPEceYr7
https://photos.app.goo.gl/xqa7DkCnviUK4r5Y6
https://photos.app.goo.gl/aKjrR2xTBgym5qvK8
https://photos.app.goo.gl/ede7q9XKYhhLo48HA
https://photos.app.goo.gl/PcJwCekLpVNB3usC6
https://photos.app.goo.gl/WDZLrfUdvWCUDoXW8
https://photos.app.goo.gl/gCEqt7HCWm25eBgd6
https://photos.app.goo.gl/zHJzuE5JS8zCvxR39
https://photos.app.goo.gl/gCEqt7HCWn25eBgd6
https://photos.app.goo.gl/PXu9QMGyx2DW4ZGo6
https://photos.app.goo.gl/nCueoEtRs44y4Kbu9
https://photos.app.goo.gl/SuTtiEoLonXvGEmc9
https://photos.app.goo.gl/6jbSWFAfyXpmQnNx8
https://photos.app.goo.gl/zSvu9RGYYZ3gup3cA
https://photos.app.goo.gl/Lz9WJYCPDmdYGoec6
https://photos.app.goo.gl/aCQ5dWzfKYReriHi8
https://photos.app.goo.gl/3H2uZcV5pSAkqhQD6
June 1st 2020. 12:41pm.
https://photos.app.goo.gl/GdKda8Y11DCTQwJy8https.//photos.app.goo.gl/GdKda8Y11DCTQwIy8https:/pho
tos.app.goo.gl/GdKda8Y11DCTQwJy8
https://photos.app.goo.gl/ywC6q2EXHkHArPff8
https://photos.app.goo.gl/6i1WM5Pi6dbhikSu9
June 7th 2020. 12:55am.
"Every Crucial Piece of Evidence Coming From The State of Wisconsin." "Extremists within Obvious
Evidencial Procedures." "We'll blow the entire world up!" "Blueprint plans of mass destruction are into US
borders." "Rockafellers did PIGS!" JUNE 7TH 2020. 7:12PM.
https://photos.app.goo.gl/vbbd3hhKaW5f1NWu6
June 7th 7:12th 2020
EFTA00015943

=== Page 3 ===
anthony.mayne@socom.mil
https://photos.app.goo.gl/Gc8xGDJ3JcDT6LoF9
https://photos.app.goo.gl/3H2uZcV5pSAkqhQD6
https://photos.app.goo.gl/3H2uZcV5pSAkqhQD6
https://photos.app.goo.gl/s5eUvfo5vpC3yTuz5
https://photos.app.goo.gl/XCQSt6x4TvYKzGPMA
https://photos.app.goo.gl/8mBpvec45A82Frox7
https://goo.gl/94E4Om
https://photos.app.goo.gl/ncWRvTiiue68u2iC7
https://photos.app.goo.gl/4g6JzNiYHDgW3KcU7
https://photos.app.goo.gl/N4qjJfneZXPEceYr7
https://photos.app.goo.gl/xqa7DkCnviUK4r5Y6
https://photos.app.goo.gl/aKjrR2xTBgym5qvK8
https://photos.app.goo.gl/ede7q9XKYhhLo48HA
https://photos.app.goo.gl/PcJwCekLpVNB3usC6
https://photos.app.goo.gl/WDZLrfUdvWCUDoXW8
https://photos.app.goo.gl/gCEqt7HCWm25eBgd6
EFTA00015944

=== Page 4 ===
https://photos.app.goo.gl/zHJzuE5JS8zCvxR39
https://photos.app.goo.gl/gCEqt7HCWm25eBgd6
https://photos.app.goo.gl/PXu9QMGyx2DW4ZGo6
https://photos.app.goo.gl/nCueoEtRs44y4Kbu9
https://photos.app.goo.gl/SuTtiEoLonXvGEmc9
https://photos.app.goo.gl/6jbSWFAfyXpmQnNx8
https://photos.app.goo.gl/zSvu9RGYYZ3gup3cA
https://photos.app.goo.gl/Lz9WJYCPDmdYGoec6
https://photos.app.goo.gl/aCQ5dWzfKYReriHi8
https://photos.app.goo.gl/3H2uZcV5pSAkqhQD6
June 4th 2020. 1:30pm.
https://www.bbc.com/news/uk-52907101
https://photos.app.goo.gl/3S1SWQQRfhy1wv4T6
https://photos.app.goo.gl/Af2gvXVCjWex5NWq7
https://photos.app.goo.gl/Gc8xGDJ3JcDT6LoF9
https://photos.app.goo.gl/3H2uZcV5pSAkqhQD6
https://photos.app.goo.gl/3H2uZcV5pSAkqhQD6
https://photos.app.goo.gl/s5eUvfo5vpC3yTuz5
EFTA00015945

=== Page 5 ===
https://photos.app.goo.gl/XCQSt6x4TvYKzGPMA
https://photos.app.goo.gl/8mBpvec45A82Frox7
https://goo.gl/94E4Om
https://photos.app.goo.gl/ncWRvTiue68u2iC7
https://photos.app.goo.gl/4g6JzNiYHDgW3KcU7
https://photos.app.goo.gl/N4qjJfneZXPEceYr7
https://photos.app.goo.gl/xqa7DkCnviUK4r5Y6
https://photos.app.goo.gl/aKjrR2xTBgym5qvK8
https://photos.app.goo.gl/ede7q9XKYhhLo48HA
https://photos.app.goo.gl/PcJwCekLpVNB3usC6
https://photos.app.goo.gl/WDZLrfUdvWCUDoXW8
https://photos.app.goo.gl/gCEqt7HCWm25eBgd6
https://photos.app.goo.gl/zHJzuE5JS8zCvxR39
https://photos.app.goo.gl/gCEqt7HCWm25eBgd6
https://photos.app.goo.gl/PXu9QMGyx2DW4ZGo6
https://photos.app.goo.gl/nCueoEtRs44y4Kbu9
https://photos.app.goo.gl/SuTtiEoLonXvGEmc9
https://photos.app.goo.gl/6jbSWFAfyXpmQnNx8
EFTA00015946

=== Page 6 ===
https://photos.app.goo.gl/zSvu9RGYYZ3gup3cA
https://photos.app.goo.gl/Lz9WJYCPDmdYGoec6
https://photos.app.goo.gl/aCQ5dWzfKYReriHi8
https://photos.app.goo.gl/3H2uZcV5pSAkqhQD6
June 4th 2020. 1:30pm.
https://www.bbc.com/news/uk-52907101
https://photos.app.goo.gl/3S1SWQQRfhy1wv4T6
https://photos.app.goo.gl/Af2gvXVCjWex5NWq7
https://photos.app.goo.gl/aVf6qq5YHVNMFkweA
https://photos.app.goo.gl/gd986RtmCaF4SqX16a
https://photos.app.goo.gl/aVf6qq5YHVNMFkweA
https://photos.app.goo.gl/gd986RtmCaF4SqX16
Info@osc.gov
EFTA00015947


c1: EFTA00015151
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00015151.pdf
c6: pdf
c7: images
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:
ADDITIONAL SENTENCING INFORMATION MAY BE AVAILABLE FROM ORIGINATING AGENCY
CRIMINAL HISTORY RECORD
Introduction
This record contains Florida 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 Florida Statute. (; 2021-10-06)
This is a multi-source offender record. (; 2021-10-06)
IDENTIFICATION
Subject Name(s)
1/4
EFTA00015151

=== 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
2/4
EFTA00015152

=== Page 3 ===
10/6/21, 12:58 PM
III/FBI/State Delayed Response
3/4
EFTA00015153

=== Page 4 ===
Agency
Margate Police Department; FL0062100;
Address
5790 Margate Boulevard
Margate, FL 33063
Agency
Palm Beach County Clerk of Court; FL050015J;
Agency
Palm Beach County Sheriffs Office; FL0500000;
Agency
Palm Beach County State Attorney's Office;
FL050015A;
Address
401 N. Dixie Hwy
West Palm Beach, FL 33401
Agency
Riviera Beach Police Department; FL0500700;
Address
600 West Blue Heron Boulevard
Riviera Beach, FL 33404
*** END OF RECORD ***
4/4
EFTA00015154


c1: EFTA00016973
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00016973.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: Bruce Barket <bbarket@barketepstein.com>
To:
Cc: Aida Leisenring <aleisenring@barketepstein.com>
Subject: viewing evidince
Date: Fri, 10 Jan 2020 14:19:15 +0000
I am told by
that you will arrange for us to view physical evidence from the July 23rd attempted suicide by
Jeffery Epstein while he was incarcerated in the same cell as Mr. Tartaglione. Please let us know some dates and times for
the viewing. Thanks
Bruce A. Barket, Esq.
Barket Epstein Kearon Aldea & LoTurco, LLP
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
EFTA00016973


c1: EFTA00014981
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014981.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: Nathan NYSD Chambers
Cc:
)"
)"
,
>, Christian Everdell
,
Jeff Pagliuca
, "Laura
Menninger"
Subject: US V. Maxwell, 20 Cr. 330 (AJN) - Def. Expert Notice
Date: Mon, 08 Nov 2021 15:12:48 +0000
Attachments: Def_Expert_Notice_[proposed_redactions].pdf
Chambers,
Pursuant to the Court's order at Dkt. No. 409, attached are the Government's proposed redactions to Dkt. No. 406 Ex. A.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
New York, New York 10007
EFTA00014981


c1: EFTA00014635
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014635.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Subject: US V. Maxwell - Joint Letter re Pretrial Schedule
Date: Fri, 14 May 2021 15:49:38 +0000
Attachments: 2021-05-14_Joint_Letter_re_Pretrial_Schedule.pdf
s,
As discussed yesterday, attached is a proposed joint letter seeking an extension of the deadline to file a letter regarding
the pretrial schedule. Please let us know if you have any comments.
Thanks,
Assistant United States Attorney
Southern District of New York
EFTA00014635


c1: EFTA00014192
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0002/EFTA00014192.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 1 of 51
1
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
2
WEST PALM BEACH DIVISION
3
CASE NO. 08-80119-CIV-MARRA
4
WEST PALM BEACH, FLORIDA
JANE DOE, et al.,
5
Plaintiffs,
JUNE 12, 2009
6
VS.
7
JEFFREY EPSTEIN,
8
Defendant.
9
X
10
TRANSCRIPT OF MOTION HEARING
11
BEFORE THE HONORABLE KENNETH A. MARRA,
UNITED STATES DISTRICT JUDGE
12
APPEARANCES:
13
FOR THE PLAINTIFFS:
ADAM D. HOROWITZ, ESQ.
14
Mermelstein & Horowitz
18205 Biscayne Boulevard
15
Miami, FL 33160
305.931.2200
For Jane Doe
16
BRADLEY J. EDWARDS, ESQ.
17
Rothstein Rosenfeldt Adler
401 East Las Olas Boulevard
18
Fort Lauderdale, FL 33301
Jane Doe 3, 4, 5, 6, 7
19
954.522.3456
20
ISIDRO M. GARCIA, ESQ.
Garcia Elkins Boehringer
21
224 Datura Avenue
West Palm Beach, FL 33401
22
Jane DOE II
561.832.8033
23
RICHARD H. WILLITS, ESQ.
2290 10th Avenue North
24
Lake Worth, FL 33461
For C.M.A.
561.582.7600
25
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014192

=== Page 2 ===
Case 9:08-cv-80119-KAM
Document 180
Entered on FLSD Docket 06/24/2009
Page 2 of 51
2
1
ROBERT C. JOSEFSBERG, ESQ.
2
Podhurst Orseck Josefsberg
25 West Flagler Street
3
Miami, FL 33130
For Jane Doe 101 305.358.2800
4
(Via telephone)
5
KATHERINE W. EZELL, ESQ.
Podhurst Orseck Josefsberg
6
25 West Flagler Street
Miami, FL 33130
7
For Jane Doe 101 305.358.2800
8
FOR THE DEFENDANT:
ROBERT D. CRITTON, JR., ESQ.
MICHAEL BURMAN, ESQ.
9
Burman Critton, etc.
515 North Flagler Street
10
West Palm Beach, FL 33401
561.842.2820
11
JACK A. GOLDBERGER, ESQ.
12
Atterbury Goldberger Weiss
250 Australian Avenue South
13
West Palm Beach, FL 33401
561.659.8300
14
, ESQ.
15
Assistant U.S. Attorney
500 East Broward Boulevard
16
Fort Lauderdale, FL 33394
For U.S.A.
17
MARTIN G. WEINBERG, ESQ.
18
20 Park Plaza
Boston MA 02116
19
(Via telephone)
617.227.3700
20
JAY LEFKOWITZ, ESQ.
(Via telephone)
21
REPORTED BY:
LARRY HERR, RPR-RMR-FCRR-AE
22
Official United States Court Reporter
Federally Certified Realtime Reporter
23
400 North Miami Avenue, Room 8N09
Miami, FL 33128
305.523.5290
24
25
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014193

=== Page 3 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 3 of 51
3
1
THE COURT: We are here in the various Doe VS. Epstein
2
cases.
3
May I have counsel state their appearances?
4
MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs
5
Jane 2 through Jane Doe 7.
6
THE COURT: Good morning.
7
MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane
8
Doe.
9
THE COURT: Good morning.
10
MR. GARCIA: Good morning, Your Honor. Sid Garcia for
11
Jane Doe II.
12
THE COURT: Good morning.
13
MR. WILLITS: Good morning, Your Honor. Richard
14
Willits, here on behalf of the plaintiff C.M.A..
15
THE COURT: Good morning.
16
MS. EZELL: Good morning, Your Honor. I'm Katherine
17
Ezell from Podhurst Orseck, here with Amy Adderly and Susan
18
Bennett, and I believe my partner, Bob Josefsberg, is going to
19
appear by telephone.
20
THE COURT: Mr. Josefsberg, are you there?
21
MR. JOSEFSBERG: I am, Your Honor.
22
THE COURT: Good morning.
23
MR. JOSEFSBERG: Good morning.
24
THE COURT: All right. Do we have all the plaintiffs
25
stated their appearances? Okay.
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014194

=== Page 4 ===
Case 9:08-cv-80119-KAM
Document 180
Entered on FLSD Docket 06/24/2009
Page 4 of 51
4
1
Defense?
2
MR. CRITTON: Your Honor, Robert Critton on behalf of
3
Mr. Epstein, and my partner, Michael Burman.
4
THE COURT: Good morning.
5
MR. GOLDBERGER: Good morning, Your Honor. Jack
6
Goldberger on behalf of Mr. Epstein.
7
THE COURT: I see we have some representatives from
8
the United States Attorney's Office here.
9
MS.
:
Good morning, Your Honor.
10
for the U.S. Attorney's office.
11
THE COURT: Good morning.
12
Who else do we have on the phone?
13
MR. CRITTON: Your Honor, we have two members of the
14
defense team are on the phone, also.
15
THE COURT: Who do we have on the phone?
16
MR. WEINBERG: Martin Weinberg. Good morning, Your
17
Honor.
18
MR. LEFKOWITZ: Jay Lefkowitz. Good morning, Your
19
Honor.
20
THE COURT: Good morning.
21
I scheduled this hearing for very limited issues
22
which, as you all know, there's been a motion by Mr. Epstein to
23
stay the civil proceedings against him. The one issue I have
24
concern about is Mr. Epstein's contention or assertion that by
25
defending against the allegations in the civil proceedings, he
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014195

=== Page 5 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 5 of 51
5
1
may expose himself to an allegation by the United States in the
2
non-prosecution agreement that he's violated that agreement and
3
therefore would subject himself to potential federal charges.
4
I had asked for some briefing on this. I asked the
5
United States to present its position to me. And I received
6
the Government's written response, which I frankly didn't find
7
very helpful. And I still am not sure I understand what the
8
Government's position is on it.
9
So first let me hear from Mr. Epstein's attorneys as
10
to what do you believe the concern is. I don't believe the
11
non-prosecution agreement has ever been filed in this Court; am
12
I correct?
13
MR. CRITTON: To my knowledge, Your Honor, it has not.
14
THE COURT: So I don't believe I've ever seen the
15
entire agreement. I've seen portions of it.
16
MR. EDWARDS: Your Honor, I believe that it was filed
17
under Jane Doe 1 and 2 VS. United States of America, case under
18
seal in your court.
19
THE COURT: Okay.
20
MR. EDWARDS: In a separate case.
21
THE COURT: In that case, okay. Was it actually filed
22
in that case?
23
MR. EDWARDS: I filed it under seal.
24
THE COURT: In any event, what's Mr. Epstein's concern
25
about if you defend the civil actions, you're going to expose
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014196

=== Page 6 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 6 of 51
6
1
yourself to a claim for a breach by the United States of the
2
non-prosecution agreement?
3
MR. CRITTON: Robert Critton.
4
Your Honor, our position on this case is, I'd say is
5
somewhat different. When this issue originally came before the
6
Court, as you are aware prior to my firm's involvement in the
7
case, there was a motion filed on behalf of Mr. Epstein seeking
8
a stay. And I think it was in Jane Doe 102 and then
9
subsequently Jane Doe 2 through 5 because all of those cases
10
were filed on or about the same time.
11
And at that time the Court looked at the issue and it
12
was based upon a statutory provision at that time. And the
13
Court said I don't find that it's applicable, or for whatever
14
reason I think the Court said I don't consider that to be a
15
pending proceeding or a proceeding at that particular time.
16
In that same order, which was in Jane Doe 2, I
17
believe it's -- not I believe, I know it's docket entry 33, the
18
Court also went on to talk about at that particular point in
19
time dealt with the issue of the discretionary stay.
20
And the Court said at that time, I'm paraphrasing, but
21
the Court also does not believe a discretionary stay is
22
warranted. And what the Court went on to say is that if
23
defendant does not breach the agreement, then he should have no
24
concerns regarding his Fifth Amendment right against
25
self-incrimination.
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014197

=== Page 7 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 7 of 51
7
1
The fact that the U.S. Attorney or other law
2
enforcement officials may object to some discovery in these
3
civil cases is not in and of itself a reason to stay the civil
4
litigation, so that any such issue shall be resolved as they
5
arise in the course of the litigation.
6
And I would respectfully submit to the Court that the
7
position that the Government has taken in its most recent
8
filings changes the playing field dramatically. Because what
9
the Government in essence has said as distinct from the U.S.
10
saying is, well, we object to some discovery, or we may object
11
to some discovery in the civil cases.
12
What they have, in essence, said is if you take some
13
action, Mr. Epstein, that we believe unilaterally, and this is
14
on pages 13 and 14 of their pleading or of their response memo
15
to the Court's inquiry, they say if Mr. Epstein breaches the
16
agreement. They said it's basically like a contract, and if
17
one side breaches, the other side can sue.
18
In this instance what the Government will do is if we
19
believe that Mr. Epstein has breached the agreement, we'll
20
indict him. We will indict him. And his remedy under that
21
circumstance, which is an incredible and catastrophic catch 22
22
is, we'll indict him and then he can move to dismiss. That's a
23
great option.
24
In this particular instance my mandate in defending --
25
and that's a dramatic change in the Government's position,
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014198

=== Page 8 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 8 of 51
8
1
because the Government is not saying, and the Court was pretty
2
specific in what you asked the Government for in its response
3
is, in essence, and it's the same question in a more limited
4
fashion you're posing today is whether Mr. Epstein's defense of
5
the civil action violates the NPA agreement, the
6
non-prosecution agreement, between the U.S. and Mr. Epstein.
7
And the Government refuses to answer that question.
8
They won't come out and say, yes, it will, or no, it won't.
9
What they're doing is they want to sit on the sideline, and as
10
their papers suggest is, they want us to lay in wait and that
11
if, in fact, they believe he violates a provision of the NPA as
12
it relates to the defense of this case or these multitude of
13
cases, then they can come in and indict him -- no notice, no
14
opportunity to cure.
15
We don't think that's what the NPA says, but that's
16
certainly what their papers say. We'll indict him, no notice,
17
no opportunity to cure. We will indict him, and his remedy
18
under that circumstance is that he can move to dismiss the
19
indictment.
20
Well, that's great except Mr. Epstein, his mandate to
21
me and I know his mandate to his criminal lawyers, is: Make
22
certain I don't do anything, in particular in these civil cases
23
that would in any way suggest that I am in willful violation of
24
the NPA.
25
Now, in the Court's prior ruling in the docket entry
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014199

=== Page 9 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 9 of 51
9
1
33, certainly some aspects of the NPA are within Mr. Epstein's
2
control. There's no question about that. But aspects that
3
relate to the defense of these cases, either in terms of the
4
civil lawyers who are defending these, I think there's 12 or 13
5
pending cases in front of you, there's another four cases in
6
the state court, is the risk is substantial, it's real, and it
7
presents a chilling effect for the civil lawyers in moving
8
forward to determine whether or not we're taking some action
9
that in some way may be a violation of the NPA.
10
And the Government's, again, refusal or non-position
11
with regard to past acts that have been taken in the civil case
12
with regard to the defense or future acts that we may take with
13
regard to these contested litigation casts an extraordinary
14
cloud of doubt and uncertainty and fear that the defense of
15
these cases could jeopardize Mr. Epstein and put him in the
16
irreparable position of violating the NPA and then subsequently
17
being indicted.
18
In this particular instance, again, Mr. Epstein has no
19
intention of willfully violating the NPA, but it's of great
20
concern to him. And I'd say with the position that the
21
Government has taken, no notice, no cure period, no opportunity
22
to discuss. Again, we think that's not what the NPA provides,
23
it's not what the deal was between the two contracting parties,
24
the United States and Mr. Epstein. But that's clearly what
25
their papers say under the circumstances, and it would create
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014200

=== Page 10 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 10 of 51
10
1
this irreparable harm to Mr. Epstein under the circumstances.
2
In essence, we're left with a catch 22 in defending
3
the civil cases. We have a mandate to take no action, to take
4
any action which may be deemed to be a violation of the NPA,
5
either in the past or in the future, which would in any way
6
risk Mr. Epstein being indicted by the United States.
7
He has the clear risk of an indictment based upon the
8
papers that the Government filed. It's real, it's not remote,
9
and it's not speculative. It chills the action of the defense
10
in this instance of both Mr. Epstein and his attorneys in
11
trying to defend these cases and decide under the circumstances
12
can we do this, can we take this position with regard to
13
depositions, can we take this legal position with regard to
14
motions to dismiss, with regard to responses, with regard to
15
replies?
16
And we send out paper discovery. Is this in some way
17
if we contact someone who may be an associate of these
18
individuals as part of our investigation, is that potentially
19
in any way a violation of the NPA? Again, we don't think SO.
20
And, obviously, again, my direction has been from my
21
client: Don't take any action that would result in me being
22
indicted under the NPA. Well, that's great. But, generally,
23
civil lawyers or civil lawyers in defending a personal injury
24
case or a tort case, which is exactly what these are, and from
25
a practical standpoint, we use various tools to do discovery.
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014201

=== Page 11 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 11 of 51
11
1
They're standard. They're specific. They're very temporary.
2
Very typical.
3
But in this instance, as the Court knows, things are
4
not typical with regard to this case in any way, shape or form.
5
We can't even serve subpoenaes, there's objections and there's
6
-- we can't even serve objections to third parties so we can
7
obtain documents unless we have to filter it through the
8
plaintiffs' attorneys. They won't allow us to use their
9
clients' names, even in a subpoena that would never be filed in
10
the court.
11
How do we do a deposition of a third party? We wanted
12
to take the deposition of Jane Doe 4. Well, who is she? Well,
13
we can't tell you that. Well, who's the defendant? Well, we
14
can't tell you that because nobody wants anybody to know
15
anything about the case. They want to present it strictly
16
through rose-colored glasses.
17
And in this particular instance, we simply can't
18
defend this case or take certain action with the spector
19
hanging over us that, in fact, the Government may deem it to be
20
a violation of the NPA, because very clearly in their response
21
papers, they don't say. They say we don't take the position,
22
and then they take a substantial position is we think there's
23
not all that substantial factors that would entitle him to a
24
stay.
25
Except for the one major issue which the Court posed
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014202

=== Page 12 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 12 of 51
12
1
in the question is, is can he defend these cases? That's what
2
I really want to know. Can he defend these cases and, in
3
essence, what he has done in the past or what his defense team
4
has done in the past and what they're going to do in the
5
future, can you give him, Epstein, assurances that the
6
Government under this situation, whatever he does, based on
7
advice of counsel, that that cannot be a willful violation of
8
the NPA, which they can -- they, the U.S. -- can then turn
9
around and say that's a violation of the agreement and,
10
therefore, we're going to go proceed to indict you under the
11
circumstances.
12
Our position is, Your Honor, is that the U.S. has now
13
cavalierly suggested that, as they did in picking up on the
14
court's docket entry or prior order, is, look, compliance with
15
the NPA is solely up to Mr. Epstein. In this type of balance
16
of equities, it doesn't speak in favor of a stay.
17
Well, that's great. And maybe that was the position
18
back in '08, on August 5th of '08, when the issue came up in
19
front of the Court with regard to the initial stay.
20
But the Government's papers under these circumstances
21
suggested a very different set of circumstances. Their own
22
unilateral, which is the issue that we argued in the motion for
23
stay, is that the Government's position is that we can
24
unilaterally indict this man if we think he's breached the NPA.
25
We don't think that's right, but we have no buffer
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014203

=== Page 13 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 13 of 51
13
1
between us and the Government. They'll say, and as the Court
2
knows, the Government has substantial power. The Government
3
does what it wants. Most of the time hopefully they're right.
4
Sometimes they make mistakes.
5
But in this particular instance, my client has rights.
6
We think that there's notice provisions, we think there's cure
7
provisions under the NPA. That's not what their paper says
8
under the circumstances.
9
And what we'd like to know from the Government, and
10
maybe the answer is basically what the Court asks is, let the
11
Government come forward today and say, based on the knowledge
12
that we have, or as of today's date, June 12th, 2009, we, the
13
Government, agree that there is no set of circumstances, not
14
that we're not aware of, but as of today's date, there is
15
nothing that exists that would be a violation of the NPA.
16
THE COURT: Well, that's way beyond what I'm
17
interested in. I don't know what Mr. Epstein may have done
18
outside the context of defending this case that may constitute
19
a violation. And if he has done something outside the context
20
of defending this case that's a violation, I don't care.
21
That's between the United States and Mr. Epstein.
22
I'm only concerned about whether anything he does in
23
defending these civil actions is going to be a violation of the
24
non-prosecution agreement. If he has done something else, it's
25
none of my business, and I don't care, and I'm not going to
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014204

=== Page 14 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 14 of 51 14
1
even ask the Government to give you an assurance that he hasn't
2
done anything that might have violated the agreement up till
3
today. I'm only interested in defending these civil actions.
4
MR. CRITTON: Then I would respectfully submit to the
5
Court that the Government be asked in that limited context, are
6
they as of today, whether there were or not, but as of today is
7
there anything that has been done or will you take the
8
position, the United States, that any position that Mr. Epstein
9
has taken with regard to defending these civil cases is in any
10
way a violation of the NPA?
11
THE COURT: Well, I'm not sure what they're going to
12
say, but that might -- that cures the problem up to this point.
13
But then we have to deal with what's going to happen from here
14
on in. And that's another issue that we have to deal with.
15
So I understand your position.
16
But has anyone suggested to you on behalf of the
17
United States that there is something that you've done in
18
defending this case that they believe may or could be construed
19
as a violation of the non-prosecution agreement? Has anyone
20
pointed to anything that you've done? For example, the fact
21
that you've wanted to take their -- I don't know if you've
22
noticed depositions or not in this case, but if you've sent
23
notice of taking deposition, if you sent requests for
24
production of documents, if you sent interrogatories, if you
25
issued third party subpoenas? Is anything you've done thus far
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014205

=== Page 15 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 15 of 51
15
1
in the context of this case been brought to your attention as a
2
potential violation?
3
MR. CRITTON: I have received no notification nor am I
4
aware that we've received any notification of any action that
5
we have taken today. As I suggested to the Court, I don't know
6
when they've done or not. And in their papers they suggested,
7
well, we don't know everything that's gone on in the civil
8
litigation.
9
But from a practical standpoint, it was a number of
10
comments that were made in their papers is, we can indict, we
11
can see if there's a breach.
12
Judge, I may have some --
13
THE COURT: Before you go on.
14
MR. CRITTON: I'm sorry.
15
THE COURT: You've focused a great deal on the
16
Government's response to my inquiry as supporting your position
17
that you're in jeopardy. But you've made the suggestion, even
18
before this brief was filed, that defending the case was going
19
to potentially result in an assertion or allegation that you
20
breached the non-prosecution agreement.
21
So what was it that caused you to make that initial
22
assertion? Because that's what caught my attention, was not --
23
this brief that the Government has filed was in response to
24
something that you filed initially in your most recent motion
25
for a stay which raised the issue.
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014206

=== Page 16 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 16 of 51
16
1
So what was it that gave you some concern to even
2
raise the issue that defending this case is going to constitute
3
a breach?
4
MR. CRITTON: Because there are other instances where
5
counsel other than myself, not in the civil aspects, where
6
allegations have been made and letters have been sent by the
7
United States suggesting that there's been a violation of the
8
NPA. And under those circumstances, some notification was
9
provided.
10
THE COURT: Did it have anything to do with defending
11
the civil actions?
12
MR. CRITTON: It did not.
13
THE COURT: So then why was that issue raised by you
14
in the first instance?
15
MR. CRITTON: Because of the prospect that the
16
defendant could take, that the U.S. would take the position
17
under the circumstances that a position that we took with
18
regard to the contested litigation may well impact, that the
19
Government may have a very different view of what the
20
interpretation of the agreement is.
21
And as an example is a number of the parties, and I
22
know the Court doesn't want to get into a discussion, the issue
23
is, is under 2255 is that from the defendant's perspective the
24
deal that was cut on that, it was a very specific deal. It
25
dealt with both consensual and contested litigation. It dealt
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014207

=== Page 17 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 17 of 51
17
1
with a secret list of individuals who we had no idea who was on
2
the list, and a commitment that he would under certain
3
circumstances be required to pay a minimum amount of damages,
4
which our position is under 2255 based upon the statute that
5
was in effect at the time, a $50,000 as to anyone who wanted --
6
who came forward who was on the list and met certain criteria.
7
The position that now has been asserted by a number of
8
the plaintiffs under the circumstances, and it's been pled, and
9
actually a number of the complainants is, is Epstein agreed,
10
and they cite to a letter that was sent by Ms.
from
11
the Government, that says he has to plead guilty or he can't
12
contest liability. That may be true under very, very limited
13
or specific circumstances.
14
But what the plaintiffs have done in a number of the
15
cases, and these are pending motions, is they've said is, well,
16
we think C.M.A. cases is a good example, they've pled 30
17
separate counts of 2255 alleged violations. And they're saying
18
under the circumstances is, therefore, we have 2255 violations,
19
there's 30 of them, so 30 times 150, or should be, or whether
20
it's 150, that's the amount of money that we want, so maybe $15
21
million, or whatever the number is.
22
Some of the other plaintiffs' lawyers have been even
23
more creative. They've said is, well, we'll agree that it's
24
only one cause of action but that each number of violations;
25
that is, if 20 alleged incidents occurred, that we would
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014208

=== Page 18 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 18 of 51 18
1
consider to be, or that we will argue are violations, then we
2
can take 20 times the 50, or the 150, depending on which
3
statute is applicable.
4
So the Government under that set of circumstance could
5
say, and, again, this is one of the reasons that we raised it,
6
they could say, look, our deal with you was that you couldn't
7
contest liability, that you were waiving liability, or your
8
ability to contest an enumerated offense under 2255.
9
Again, part of the deal was as to an enumerated
10
offense. Okay. Well, what's that mean? What did he plead to?
11
Well, he really didn't plead to anything, which is another
12
issue associated with the 2255. But if the Government comes in
13
and says, no, wait a minute, our position was, is that you're
14
stuck with 2255 and the language within the NPA. And,
15
therefore, whether it's an offense or whether it's multiple
16
offenses or violations or each one represents an individual
17
cause of action, if the Government takes the position that's
18
adverse to what we think the clear reading of the agreement was
19
under those circumstances, they could claim a violation.
20
And as a result -- and that's one of the reasons we
21
put -- that was the most glaring one to us, so we raised that
22
issue. And then when the Government's response came with
23
regard to, is we can just proceed to indict if we think that
24
there's been a breach of the agreement.
25
That puts us at substantial risk and chills our
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014209

=== Page 19 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 19 of 51 19
1
ability to move forward. Thank you, Your Honor.
2
THE COURT: Thank you. Who wants to be heard from the
3
plaintiffs first?
4
Is there any plaintiff's attorney who is contending
5
that the defense of these civil actions by Mr. Epstein is going
6
to constitute a breach of the non-prosecution agreement?
7
MR. JOSEFSBERG: Your Honor, this is Bob Josefsberg.
8
May I speak?
9
THE COURT: Yes, sir.
10
MR. JOSEFSBERG: We're not quite confident that any
11
breaches of any agreement, which were third-party
12
beneficiaries, should be resolved by you. We're not saying it
13
shouldn't. But we have not raised any breach of agreement. We
14
think that is between the United States and Mr. Epstein.
15
What I find incredulous and disingenuous is that
16
Mr. Epstein is saying that he wants a stay because he may be
17
forced into taking actions in the defense of this case that
18
would violate the agreement.
19
And let me make our position clear on that. If he
20
wants to move to take depositions, interrogatories, production,
21
and they are according to your rulings appropriate, not
22
invasive of the privacy of someone, and they are relevant, then
23
I don't know how those could in any way be violations of the
24
agreement.
25
What I find hypocritical is that there are two parts
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014210

=== Page 20 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 20 of 51 20
1
to the agreement that I am a beneficiary of. One of them is
2
that he has agreed that on any action brought in the 2255, he
3
will admit to liability.
4
And I received on May 26 a motion to dismiss, which
5
we're prepared to respond to and disagree with, but totally
6
contesting liability, saying that the statute doesn't apply
7
because the girls are no longer minors and saying, and this is
8
the great one, saying that the predicate of the conviction
9
under 2255 has not been satisfied.
10
Now, the understanding that I have is the agreement
11
between the Government and Mr. Epstein was that the Government
12
desired to see these victims made whole, and wanted them to be
13
in the same position as if Mr. Epstein had been prosecuted and
14
pled or convicted. And they would be able to have the
15
predicate of that criminal conviction, which just as a matter
16
of liability would just be introduced as proof that he's done
17
this.
18
They, under the agreement, are supposed to admit to
19
liability on limited something that's under 2255. He has
20
filed, but since there is no conviction, there can be no civil
21
suit under 2255, with which we disagree. But it is totally in
22
opposite of the NPA.
23
The second part is there are many young ladies, and
24
this perhaps he can use this to his great advantage, who are
25
humiliated about this entire situation. Some of them won't
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014211

=== Page 21 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 21 of 51 21
1
come forward.
2
We were appointed by Judge Davis as a Special Master
3
to represent these young ladies. And some of them don't even
4
want to file suit. They don't even want to be known as Jane
5
Doe 103. They don't want any of the risks for these motions
6
that are pending.
7
And part of the agreement was that if we represented
8
them and they settle, Mr. Epstein would pay our fees. And he
9
has written us as of yesterday that he is under no obligation
10
to pay our fees on settling cases.
11
Now, those two matters, I believe, may be breaches.
12
But I am not asking this Court at this time to do anything
13
about them. Nor am I telling the Government, I'm not running
14
to the Government and saying indict him because I want you to
15
pressure him to do what he agreed to.
16
I'm a third-party beneficiary for that agreement, and
17
I may move to enforce certain parts of it. But as far as the
18
issue of staying the litigation, that is the exact opposite of
19
the intent and the letter of the NPA. The purpose of the NPA
20
was so that these 34 young ladies, these victims who have been
21
severely traumatized, may move on with their lives.
22
And to stay this action would be the exact opposite of
23
the purpose of that agreement and would be horrible
24
psychologically for all of my clients.
25
THE COURT: Mr. Josefsberg, I understand your
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014212

=== Page 22 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 22 of 51 22
1
position. And I don't want to argue the merits of whether a
2
stay should or should not be granted.
3
I'm just trying to understand what the ground rules
4
are going to be if I grant a stay or if I deny a stay. And
5
I've already denied a stay once. I have to decide this current
6
motion, and I just want to know what is going to happen if I
7
deny the stay in terms of Mr. Epstein's exposure under the
8
non-prosecution agreement. That's my concern.
9
So if you're telling me that you're not going to urge
10
the United States, on behalf of any of your clients, to take
11
the position that he's breached the agreement because he's
12
taking depositions, because he's pursuing discovery, because
13
he's conducting investigations that anyone in any other type of
14
civil litigation might conduct with respect to plaintiffs that
15
are pursuing claims against a defendant, that those typical
16
types of actions, in your judgment, are not breaches of the
17
agreement and that he can go forward and defend the case as any
18
other defendant could defend, and you're not going to run to
19
the United States and say, hey, he's breaching the agreement by
20
taking depositions and he's breaching the agreement by issuing
21
subpoenas to third parties in order to gather information
22
necessary to defend, then I don't have a problem. But if he's
23
going to be accused of breaching the agreement because he sends
24
out a notice of deposition of one of your clients, how is he
25
supposed to defend the case?
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014213

=== Page 23 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 23 of 51 23
1
MR. JOSEFSBERG: Your Honor, you're totally correct.
2
He can depose my client. That's not a problem. But the
3
problem is that these are not typical clients and this is not a
4
typical case. He has written in his pleadings that he wants to
5
publish the names of these girls in the newspapers so that
6
other people may come forward to discuss their sexual
7
activities with these different plaintiffs. That's not your
8
typical case. But are rulings that you'll make in this case,
9
and they're not part of the NPA.
10
As far as my going to the Government is concerned, I
11
find it very uncomfortable for me to use the Government to try
12
to pursue my financial interest in litigation. And I know that
13
Mr. Epstein and his counsel will make much ado about it. So I
14
am not going to be running there.
15
However, if they start taking depositions regarding
16
liability, I will consider that to be a breach because they're
17
supposed to have admitted liability.
18
THE COURT: But, again, I don't have the agreement and
19
I don't remember reading the agreement. But what I'm being
20
told is the part of the agreement that admits liability is only
21
as to a 2255 claim, and there are numerous other personal
22
injury tort claims other than 2255 claims.
23
And there's a limit of damages on the 2255 claim, as I
24
understand it, but I presume that all the plaintiffs are going
25
to seek more than the limited or capped amount of damages in
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014214

=== Page 24 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 24 of 51 24
1
the non-prosecution agreement as to the other claims.
2
And so why aren't they entitled to defend and limit
3
the amount of damages that your client is seeking on the
4
non-2255 tort claims?
5
MR. JOSEFSBERG: Your Honor, you are correct. On
6
non-2255 tort claims, they are permitted to do the defense,
7
whatever is appropriate.
8
My cases are pure 2255 on which liability under the
9
agreement is supposed to be admitted. Now, as to the amount of
10
damages, there are legal issues that will be before you and
11
under the C.M.A. cases that are getting before you, as to
12
whether it is 50 or 150. That has nothing to do with the NPA.
13
There are legal issues that are before you as to
14
whether it is per statute, per count or per incident or per
15
plaintiff. Those have nothing to do with the NPA. There is no
16
amount in NPA. Those will be resolved.
17
Anyone who has brought a case that is outside of 2255,
18
the defense is permitted to contest liability under the NPA.
19
That's no violation.
20
Under the NPA if someone brought a case under just
21
2255, Mr. Epstein, if he is to keep his word, cannot contest
22
liability. And there would no need to stay this. Because it
23
is a self-fulfilling agreement. He can contest liability. And
24
as far as the amount of damages, anyone that wants to go over
25
the statutory minimums, of course, he can contest that in any
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014215

=== Page 25 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 25 of 51 25
1
way that is proper under the Rules of Evidence and your
2
rulings. The NPA has no limitation on his contesting damages
3
above the minimum statutory amount.
4
The only thing that he has done is in his actions of
5
refusing to pay for settling defendants, and in his saying that
6
he has no liability under 2255, those appear to be contrary to
7
what's in the NPA.
8
But I'm not in any position right now to claim a
9
breach, and I don't know whether I'd be claiming a breach or
10
enforcing it in front of you, suing him for fees, asking you to
11
have him admit liability, or complaining to the Government.
12
And that's why I'm not that helpful in this situation because I
13
think it's the Government's role.
14
But I do not waive the right to be a third-party
15
beneficiary because pursuant to my appointment, which was
16
agreed to by Mr. Epstein, I and my clients have certain rights,
17
and we want to enforce them.
18
But his defending this lawsuit will not in any way be
19
a violation. His getting this lawsuit stayed would be a
20
violation of the spirit of taking care of these girls, and
21
there would be other issues. Like if there is a stay, Your
22
Honor, would he be posting a bond?
23
THE COURT: We don't need to talk about those issues.
24
That's not my concern.
25
MR. JOSEFSBERG: I agree, Your Honor, we don't.
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014216

=== Page 26 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 26 of 51 26
1
THE COURT: That's not my concern. So, again, I just
2
want to make sure that if the cases go forward and if
3
Mr. Epstein defends the case as someone ordinarily would defend
4
a case that's being prosecuted against him or her, that that in
5
and of itself is not going to cause him to be subject to
6
criminal prosecution.
7
MR. JOSEFSBERG: I agree, Your Honor.
8
THE COURT: Any other plaintiff's counsel want to
9
chime in?
10
MR. WILLITS: Richard Willits on behalf of C.M.A.. I
11
would join, to weigh in on what Mr. Josefsberg said.
12
MR. JOSEFSBERG: Your Honor, I could not hear.
13
THE COURT: We'll get him to a microphone.
14
Mr. Willits is speaking.
15
MR. WILLITS: On behalf of my client, C.M.A., we join
16
in what Mr. Josefsberg said, and we also want to point out
17
something to the Court.
18
First, we want to make a representation to the Court,
19
we have no intention of complaining to the U.S. Attorney's
20
Office, never had that intention, don't have that intention in
21
the future, but, of course, subject to what occurs in the
22
future.
23
I want to point out to the Court that Mr. Epstein went
24
into this situation with his eyes wide open, represented by
25
counsel, knowing that civil suits had to be coming. If he
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014217

=== Page 27 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 27 of 51 27
1
didn't know it, his lawyers knew it.
2
He appears to be having second thoughts now about he
3
could have negotiated this way or he could have negotiated that
4
way with the U.S. Attorney's Office. And they want to impose
5
their second thoughts on the innocent plaintiffs. We don't
6
think that's fair. We think it's in the nature of invited
7
error, if there was any error whatsoever.
8
Thank you.
9
THE COURT: You agree he should be able to take the
10
ordinary steps that a defendant in a civil action can take and
11
not be concerned about having to be prosecuted?
12
MR. WILLITS: Of course. And we say the same thing
13
Mr. Josefsberg said. It's all subject to your rulings and the
14
direction of this Court as to what is proper and what is not
15
proper. And we're prepared to abide by the rulings of this
16
Court, and we have no intention of running to the State's
17
Attorney.
18
THE COURT: The U.S. Attorney?
19
MR. WILLITS: I'm sorry. The U.S. Attorney.
20
THE COURT: Mr. Garcia.
21
MR. GARCIA: Thank you, Your Honor.
22
If I may briefly, I think perhaps defense counsel
23
forgot about this, but on pages 17 and 19 of my memorandum of
24
law in opposition to the motion to dismiss, I did make
25
reference to the non-prosecution agreement, and I did say that
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014218

=== Page 28 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 28 of 51 28
1
the contesting of the jurisdiction of this Court was a
2
potential breach of the non-prosecution agreement.
3
So my client happens to have, and they have filed with
4
the Court a copy of her state court complaint, given the fact
5
that the non-prosecution agreement limits the non-contesting of
6
jurisdiction to claims exclusively brought under the federal
7
statute.
8
I'm going to go ahead and withdraw those contentions
9
on pages 17 and 19 of my memo of law because it doesn't apply
10
to my case. So to the extent that I raised this issue with
11
defense counsel and the Court, I'm going to withdraw that
12
aspect of it.
13
THE COURT: Can you file something in writing on that
14
point with the Court?
15
MR. GARCIA: Yes.
16
THE COURT: What do you say about this issue that
17
we're here on today?
18
MR. GARCIA: I think that the problem that I have with
19
it is that this non-prosecution agreement is being used by
20
defense counsel for the exact opposite purpose that it was
21
intended. My perception of this thing, and I wasn't around, is
22
that Mr. Epstein essentially bought his way out of a criminal
23
prosecution, which is wonderful for the victims in a way, and
24
wonderful for him, too.
25
Now he's trying to use the non-prosecution agreement
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014219

=== Page 29 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 29 of 51 29
1
as a shield against the plaintiffs that he was supposed to make
2
restitution for.
3
And, certainly, he can take my client's depo. He's
4
done extensive discovery in the state court case -- very
5
intrusive, I might add. And we don't care, because we can win
6
this case with the prosecution agreement or without the
7
prosecution agreement. We are ready to go forward.
8
THE COURT: You're not going to assert to the United
9
States Government that what he's doing in defending the case is
10
a violation for which he should be further prosecuted?
11
MR. GARCIA: Absolutely not.
12
THE COURT: Anyone else for the plaintiffs?
13
MR. HOROWITZ: Judge, Adam Horowitz, counsel for
14
plaintiffs Jane Doe 2 through 7.
15
I just wanted to address a point that I think you've
16
articulated it. I just want to make sure it's crystal clear,
17
which is that we can't paint a broad brush for all of the
18
cases.
19
The provision relating to Mr. Epstein being unable to
20
contest liability pertains only to those plaintiffs who have
21
chosen as their sole remedy the federal statute. My clients,
22
Jane Doe 2 through 7, have elected to bring additional causes
23
of action, and it's for that reason we were silent when you
24
said does anyone here find Mr. Epstein to be in breach of the
25
non-prosecution agreement. That provision, as we understand
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014220

=== Page 30 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 30 of 51 30
1
it, it doesn't relate to our clients.
2
THE COURT: Okay. But, again, you're in agreement
3
with everyone else so far that's spoken on behalf of a
4
plaintiff that defending the case in the normal course of
5
conducting discovery and filing motions would not be a breach?
6
MR. HOROWITZ: Subject to your rulings, of course,
7
yes.
8
THE COURT: Thank you.
9
Anyone else have anything to say from the plaintiffs?
10
Ms.
,
if you would be so kind as to maybe
11
help us out. I appreciate the fact that you're here, and I
12
know you'r not a party to these cases and under no obligation
13
to respond to my inquiries. But as I indicated, it would be
14
helpful for me to understand the Government's position.
15
MS.
: Thank you, Your Honor. And we, of
16
course, are always happy to try to help the Court as much as
17
possible. But we are not a party to any of these lawsuits, and
18
in some ways we are at a disadvantage because we don't have
19
access. My access is limited to what's on Pacer. So I don't
20
really know what positions Mr. Epstein may have taken either in
21
correspondence or in discovery responses that aren't filed in
22
the case file.
23
But your first order was really just what do you think
24
about a stay, and then the second order related to this hearing
25
and asked a much more specific question, which is whether we
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014221

=== Page 31 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 31 of 51 31
1
believe that Mr. Epstein's defense was a breach of the
2
agreement.
3
And I've tried to review as many of the pleadings as
4
possible. As you know, they're extremely voluminous. And I
5
haven't been through all of them. But we do believe that there
6
has been a breach in the filing that Mr. Josefsberg referred
7
to, and contrary to Mr. Critton, we do understand that we have
8
an obligation to provide notice, and we are providing notice to
9
Mr. Epstein today.
10
The pleading that we found to be in breach -- the
11
non-prosecution agreement, sought to do one thing, which was to
12
place the victims in the same position they would have been if
13
Mr. Epstein had been convicted of the federal offenses for
14
which he was investigated.
15
And that if he had been federally prosecuted and
16
convicted, the victims would have been entitled to restitution,
17
regardless of how long ago the crimes were committed,
18
regardless of how old they were at the time, and how old they
19
are today, or at the time of the conviction.
20
And it also would have made them eligible for damages
21
under 2255.
22
And so our idea was, our hope was that we could set up
23
a system that would allow these victims to get that restitution
24
without having to go through what civil litigation will expose
25
them to.
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014222

=== Page 32 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 32 of 51 32
1
You have a number of girls who were very hesitant
2
about even speaking to authorities about this because of the
3
trauma that they have suffered and about the embarrassment that
4
they were afraid would be brought upon themselves and upon
5
their families.
6
So we did through the non-prosecution agreement tried
7
to protect their rights while also protecting their privacy.
8
So, pursuant to the non-prosecution agreement -- on the other
9
hand, we weren't trying to hand them a jackpot or a key to a
10
bank. It was solely to sort of put them in that same position.
11
So we developed this language that said if -- that
12
provided for an attorney to represent them. Most of the
13
victims, as you know from the pleadings, come from not wealthy
14
circumstances, may not have known any attorneys who would be in
15
a position to help them.
16
So we went through the Special Master procedure that
17
resulted in the appointment of Mr. Josefsberg, and the goal was
18
that they would be able to try to negotiate with Mr. Epstein
19
for a fair amount of restitution/damages. And if Mr. Epstein
20
took the position, which apparently he has, which is that the
21
$50,000 or $150,000 floor under 2255 also would be a cap. That
22
if they were to proceed to file suit in Federal Court to get
23
fair damages under 2255, Mr. Epstein would admit liability, but
24
he, of course, could fight the damages portion, which means
25
that, of course, he would be entitled to depositions; of
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014223

=== Page 33 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 33 of 51 33
1
course, he would be entitled to take discovery, and we don't
2
believe that any of that violates the non-prosecution
3
agreement.
4
The issue with the pleading that he filed, the motion
5
to dismiss the case, I believe it's Jane Doe 101, represented
6
by Mr. Josefsberg, is that that is a case that was filed
7
exclusively under 18 U.S.C., Section 2255. She met that
8
requirement. Mr. Epstein is moving to dismiss it, not on the
9
basis of damages, he is saying that he cannot be held liable
10
under 2255 because he was not convicted of an offense.
11
The reason why he was not convicted of an offense is
12
because he entered into the non-prosecution agreement. So that
13
we do believe is a breach.
14
The issue really that was raised in the motion to stay
15
and that I addressed in our response to the motion to stay is
16
that Mr. Epstein's -- Mr. Epstein wants to stay the litigation
17
in order to leave, in order to sort of attack the cases of the
18
victims whether they are fully within the non-prosecution or
19
not, non-prosecution agreement or not, and leave the Government
20
without a remedy if he does, in fact, breach those terms. And
21
that is why we opposed the stay.
22
THE COURT: I'm not sure what you mean by that last
23
statement.
24
MS.
:
Well, because this issue related to
25
the motion to dismiss on Mr. Josefsberg's client came up after
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014224

=== Page 34 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 34 of 51 34
1
we had filed that response. And what we said in the response
2
to the motion to stay is that the reason why he wants to stay
3
the litigation is so that the non-prosecution agreement
4
terminates based on a period of time, as he puts it. And then
5
afterwards he would be able to come in here and make all of
6
these arguments that clearly violate the non-prosecution
7
agreement but we would be without remedy.
8
THE COURT: But you're not taking the position that
9
other than possibly doing something in litigation which is a
10
violation of an express provision of the non-prosecution
11
agreement, any other discovery, motion practice, investigations
12
that someone would ordinarily do in the course of defending a
13
civil case would constitute a violation of the agreement?
14
MS.
:
No, Your Honor. I mean, civil
15
litigation is civil litigation, and being able to take
16
discovery is part of what civil litigation is about. And while
17
there may be, for example, if someone were to try to subpoena
18
the Government, we would obviously resist under statutory
19
reasons, all that sort of stuff. But, no, Mr. Epstein is
20
entitled to take the deposition of a plaintiff and to subpoena
21
records, etc.
22
THE COURT: And even if he seeks discovery from a
23
Government agency, you have the right to resist it under the
24
rules of procedure but that would not constitute a violation,
25
again unless there's a provision in the prosecution agreement
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014225

=== Page 35 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 35 of 51 35
1
that says I can't do this?
2
MS.
:
Correct.
3
THE COURT: That's your position?
4
MS.
: Yes.
5
THE COURT: Thank you.
6
MS.
:
Thank you, Your Honor.
7
THE COURT: Mr. Critton, did you want to add anything?
8
MR. CRITTON: Yes, sir. Just a few responses to some
9
of the issues that have been raised.
10
The most glaring, at least from our perspective, is
11
both Mr. Josefsberg's comments that he believes that there's a
12
violation of the NPA as well as Ms.
with regard to
13
Jane Doe 101.
14
Mr. Josefsberg, while he was the attorney rep who was
15
selected by Judge Davis to represent a number of individuals,
16
alleged victims that may have been on the list, he represents
17
many of them. And the type of response that was filed in 101
18
would probably be very similar to what we will file if he
19
files -- and he filed 102 as well. But if he files 103, 104
20
and 105, or whatever number he files, we may well take that
21
same legal position in our motions and in our response or in
22
reply.
23
And what we've been, in essence, told today is we
24
consider that to be a violation of the NPA under the
25
circumstances.
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014226

=== Page 36 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 36 of 51 36
1
102 is a perfect example that he filed is, we have
2
e-mails going back and forth between the Government and my
3
clients' attorneys at the time that suggested that 102 probably
4
doesn't even fit within the statute of limitations.
5
So under Mr. Josefsberg's argument is as well, we've
6
only brought a 2255 claim. We don't care whether she's within
7
or is outside the statute of limitations. Because she was on
8
the list and under the circumstances, he has to admit
9
liability, which we contest is under that set of circumstances
10
you're stuck with it. You can fight damages if you can, but
11
she's a real person and you can't raise statute of limitations.
12
The other point that kind of strikes out is there's
13
probably a difference. And I'm happy to provide a copy of the
14
NPA or a redacted portion of the NPA which deals with the civil
15
issues, which are paragraphs 7, 8, 9 and 10, and the entire
16
addenda in camera for the Court to look at, if plaintiff's
17
counsel and the Government, I guess, really, because they're
18
not a party, is if they have no objection because they all have
19
access based on a prior court order to the non-prosecution
20
agreement.
21
So I'm happy to provide that to the Court today and
22
show it to counsel so that the Court can review that.
23
But our position with regard to the 2255 claims is
24
that -- there were two types of claims that could be filed, one
25
was consensual litigation, the second was contested litigation.
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014227

=== Page 37 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 37 of 51 37
1
And under the consensual, in essence, which Mr. Epstein did, is
2
he's offered $50,000 of the statutory minimum for that time
3
period to all of those individuals.
4
THE COURT: Can I interrupt you a second?
5
MR. CRITTON: Yes, sir.
6
THE COURT: I'm not here, and I don't believe it's my
7
role to decide whether or not there is or is not a breach of
8
the agreement. I'm just trying to understand what the
9
Government's position is regarding your defending these cases.
10
Now, I'm just saying this as an example. If, for
11
example, in the non-prosecution agreement there was a provision
12
that said explicitly: Jeffrey Epstein shall not move to
13
dismiss any claim brought under 2255 by any victim no matter
14
how long ago the allegations or the acts took place, period.
15
If that was in the agreement and you filed a motion to
16
dismiss by someone who brought a claim, it might sound like it
17
might be a violation.
18
MR. CRITTON: I agree.
19
THE COURT: So you would know that when you filed your
20
motion because it was right there for you to read.
21
And so to stay the case because I want to do something
22
that the contract expressly prohibits me from doing, so stay
23
the case until the agreement expires so then I can do something
24
that the agreement said I couldn't do so you won't be in fear
25
of prosecuting, I'm not sure that that is what I'm concerned
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014228

=== Page 38 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 38 of 51 38
1
about.
2
I'm concerned about discovery, investigation, motion
3
practice, that's not prohibited by a provision of the
4
agreement. If there's something that's prohibited by the
5
agreement that you, knowing what the agreement says, go ahead
6
and do, anyway, I guess that's a risk you're going to have to
7
take. If there's a legitimate dispute about it, I guess some
8
arbiter is going to decide whether it's a breach or not.
9
But, again, that's something you and Mr. Burman,
10
Mr. Goldberger, and you are all very good lawyers, and he's got
11
a whole list of lawyers representing him, and you've got the
12
agreement and you're going to make legal decisions on how to
13
proceed, and you're going to have to go and make your own
14
decisions.
15
I'm concerned about things that aren't in the
16
agreement, that aren't covered, that you're going to be accused
17
of violating because, again, you take depositions, you send out
18
subpoenas, you file motions that are not prohibited by the
19
agreement. And that's what I'm concerned about.
20
MR. CRITTON: And I understand that, Your Honor.
21
But at the same time, it's as if the lawyers and the
22
clients, based upon our interpretation of the agreement, and,
23
believe me, we would not have filed 101, the motion to dismiss,
24
but for believing that there was a good faith basis to do that
25
under the circumstances.
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014229

=== Page 39 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 39 of 51 39
1
And now, in essence, we're being accused not only by
2
-- not accused, but it's been suggested that there's a breach
3
of the NPA, not only by Mr. Josefsberg on behalf of 101, but as
4
well Ms.
on behalf of the United States.
5
That's the perfect example. They're basically saying
6
we think you violated. We may send you notice under the
7
circumstances. So does that mean that on 101 we have to back
8
off of it because we think in good faith that it's a motion and
9
is that something that this Court ultimately will rule?
10
THE COURT: I don't know that I'm the one who is going
11
to make that decision. Again, that's not the kind of thing
12
that I was concerned about. I was more concerned about the
13
normal, ordinary course of conducting and defending a case that
14
would not otherwise expressly be covered under the agreement,
15
that you're going to then have someone say, ah, he's sent a
16
notice of deposition, he's harassing the plaintiffs. I don't
17
know if there's a no contact provision in the agreement or no
18
harassment type of provision in the agreement. Ah, this is a
19
breach because you sent discovery, or he's issuing subpoenas to
20
third parties trying to find out about these victims'
21
backgrounds, he's breaching the agreement.
22
Those are the kind of things that I was worried about.
23
MR. CRITTON: The concern that we have is as part of
24
doing this general civil litigation, it's not just the
25
discovery process. And I understand the issues that the Court
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014230

=== Page 40 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 40 of 51 40
1
has raised.
2
But part of it is that often cases are disposed of
3
either on a summary basis or certainly legal issues that come
4
before the Court during the course of the case, just like in a
5
criminal case. That's clearly part of the, I'd say the defense
6
of the case under the circumstances; and if, in fact, an
7
individual can't legally bring a cause of action for certain
8
reasons, such as has been suggested in 101, and may be
9
suggested in 102 when that pleading is filed, that certainly is
10
a position that puts my client at risk.
11
As another example that I use with C.M.A., that they
12
filed this 30-count complaint. Now, they have the state court
13
claims as well. But they, in essence, have said they filed
14
another pleading with the Court that says depending on what the
15
Court rules, in essence, on whether we can file multiple claims
16
or one cause of action with multiple violations, we may dump
17
the state court claims and, therefore, we'll just ride along on
18
that. That's a very different --
19
Mr. Epstein would never have entered into, nor would
20
his attorneys have allowed him to enter into that agreement
21
under those circumstances where he had this unlimited
22
liability. That clearly was never envisioned by any of the
23
defendants -- by the defendant or any of his lawyers under the
24
circumstances.
25
And if that's claimed to be a violation, either by the
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014231

=== Page 41 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 41 of 51 41
1
attorneys; i.e., he's not recapitulating on liability under the
2
2255, and that's all we have now. That's our exclusive remedy.
3
And the Government says, yeah, that's right, that's a
4
violation of the NPA. It again chills us from moving forward,
5
filing the necessary motion papers and taking legal positions
6
that may put my client at risk for violating the NPA and then
7
creating the irreparable harm of, after having been in jail,
8
after having pled guilty to the state court counts, after
9
registering on release as a sex offender, he's complied and
10
done everything, taken extraordinary efforts to comply with the
11
NPA, puts him at substantial risk. And that's what our worry
12
is moving forward.
13
MR. JOSEFSBERG: Your Honor, may I be heard. May I
14
make three comments? It will take less than a minute.
15
THE COURT: Yes, sir.
16
MR. JOSEFSBERG: Mr. Critton refers to the alleged
17
victims. I want you to know that our position is that pursuant
18
to the NPA they're not alleged victims. They are actual, real
19
victims, admitted victims.
20
Secondly, he argues about the statute of limitations
21
on 102. I know that you don't want to hear about that, and I'm
22
not going to comment about it. But please don't take our lack
23
of argument about this as being we agree with anything.
24
Last and most important, we totally agree with
25
Mr. Critton in his suggestion that he hand you a copy of the
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014232

=== Page 42 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 42 of 51 42
1
NPA. I think that many of the questions you asked will be
2
answered when you read the NPA, and I think it's very unfair of
3
everyone who is sitting in front of you who have the NPA to be
4
discussing with you whether it's being breached, whether there
5
should be a stay when you're not that familiar with it.
6
If we would give you a copy of it, I think it would be
7
much more helpful in making your ruling.
8
THE COURT: Maybe Judge Colvat will resolve this issue
9
for me.
10
MR. JOSEFSBERG: Even if he doesn't, Your Honor, I
11
believe we are allowed to show it to you.
12
THE COURT: I'll tell you what: I'll wait for Judge
13
Colvat to rule, and then if he rules that it should remain
14
sealed, then I'll consider whether or not I want to have it
15
submitted to me in camera.
16
Anything else, Mr. Josefsberg?
17
MR. JOSEFSBERG: No. I thank you on behalf of myself
18
and the other counsel on the phone for permitting us to appear
19
by phone.
20
THE COURT: All right. Anyone else have anything they
21
want to add?
22
MR. EDWARDS: Brad Edwards on behalf of Jane Doe.
23
I only had one issue here, and when I read your motion
24
that you wanted to hear on the narrow issue of just defense in
25
the civil actions filed against him violates the
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014233

=== Page 43 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 43 of 51 43
1
non-prosecution agreement, I was expecting that we were going
2
to hear something from the Government similar to the affidavit
3
that was filed by Mr. Epstein's attorneys wherein he indicates
4
as of the day of this affidavit attached to the motion to stay,
5
the U.S. Attorney's Office has taken the position that Epstein
6
has breached the non-prosecution agreement and it names
7
specifically investigation by Epstein of this plaintiff and
8
other plaintiffs, Epstein's contesting damages in this action.
9
Epstein, or his legal representatives, making statements to the
10
press. And we didn't hear any of those things.
11
So that's what I was expecting that the U.S.
12
Attorney's Office was going to expound on and say, yes, we've
13
made some communications to Epstein. He's violating.
14
What we're hearing right now, today, just so that I'm
15
clear, and I think the Court is clear now, is that the
16
non-prosecution agreement is what it is. There have been no
17
violations, but for maybe what Mr. Josefsberg brought up.
18
But there are very few restrictions on Mr. Epstein.
19
He went into this eyes wide open. And whether or not I agree
20
with the agreement, how it came to be in the first place, is
21
neither here nor there.
22
But there have been no violations or breaches up to
23
this point. And his affidavit that was filed, I'm just
24
troubled by where it even came from. I mean, it's making
25
specific allegations that the U.S. Attorney's Office is
TOTAL ACCESS COURTROOM NETWORK REALTIME TRANSCRIPTION
EFTA00014234

=== Page 44 ===
Case 9:08-cv-80119-KAM Document 180 Entered on FLSD Docket 06/24/2009 Page 44 of 51 44
1
threatening a breach, and this is part of the motion to stay,
2
which we're all battling here.
3
So I just wanted to indicate to the Court or remind
4
the Court that there have been specific allegations made, the
5
United States Attorney's Office is making these allegations of
6
breach, which we haven't heard any of the evidence of.
7
Thank you.
8
THE COURT: All right.
9
Ms.
, did you want to respond to that
10
suggestion that there were other allegations of breach besides
11
the one that you've just mentioned today?
12
MS.
: No, Your Honor.
13
THE COURT: Thank you. I appreciate your giving me
14
the information, which I think has been very helpful today, and
15
I'll try and get an order out as soon as possible.
16
[Court adjourned at 11:10 a.m.].
17
CERTIFICATE
18
I hereby certify that the foregoing is an accurate
19
transcription of proceedings in the above-entitled matter.
20
s/Larry Herr
21
DATE
LARRY HERR, RPR-CM-RMR-FCRSC
22
Official United States Court Reporter
400 N. Miami Avenue
23
Miami, FL 33128 - 305/523-5290
(Fax) 305/523-5639
24
email: Lindsay165@aol.com
25
Quality Assurance by Proximity Linguibase Technologies
EFTA00014235

=== Page 45 ===
Case 9:08-cv-80119-KAM
Document 180
Entered on FLSD Docket 06/24/2009
Page 45 ofage 45
A
against 4:23,25 6:24
16:10 18:11 21:12
B
43:6
abide 27:15
22:15 26:4 29:1
30:9 35:7 41:23
back 12:18 36:2 39:7
breaches 7:15,17
ability 18:8 19:1
42:25
42:16,20
backgrounds 39:21
19:11 21:11 22:16
able 20:14 27:9
agency 34:23
anyway 38:6
balance 12:15
43:22
32:18 34:5,15
ago 31:17 37:14
apparently 32:20
bank 32:10
breaching 22:19,20
about 4:24 5:25 6:10
agree 13:13 17:23
appear 3:19 25:6
based 6:12 10:7 12:6
22:23 39:21
6:18 9:2 11:15
25:25 26:7 27:9
42:18
13:11 17:4 34:4
brief 15:18,23
13:22 20:25 21:13
37:18 41:23,24
appearances 1:12
36:19 38:22
briefing 5:4
23:13 25:23 27:2
43:19
3:3,25
basically 7:16 13:10
briefly 27:22
27:11,23 28:16
agreed 17:9 20:2
appears 27:2
39:5
bring 29:22 40:7
30:24 32:2,2,3
21:15 25:16
applicable 6:13 18:3
basis 33:9 38:24
broad 29:17
34:16 38:1,2,7,15
agreement 5:2,2,11
apply 20:6 28:9
40:3
brought 15:1 20:2
38:19 39:12,12,20
5:15 6:2,23 7:16
appointed 21:2
battling 44:2
24:17,20 28:6 32:4
39:22 41:20,21,22
7:19 8:5,6 12:9
appointment 25:15
Beach 1:2,4,21 2:10
36:6 37:13,16
41:23
13:24 14:2,19
32:17
2:13
43:17
above 25:3
15:20 16:20 18:18
appreciate 30:11
before 1:11 6:5
Broward 2:15
above-entitled 44:19
18:24 19:6,11,13
44:13
15:13,18 24:10,11
brush 29:17
Absolutely 29:11
19:18,24 20:1,10
appropriate 19:21
24:13 40:4
buffer 12:25
access 30:19,19
20:18 21:7,16,23
24:7
behalf 3:14 4:2,6 6:7
Burman 2:8,9 4:3
36:19
22:8,11,17,19,20
arbiter 38:8
14:16 22:10 26:10
38:9
according 19:21
22:23 23:18,19,20
argue 18:1 22:1
26:15 30:3 39:3,4
business 13:25
accurate 44:18
24:1,9,23 27:25
argued 12:22
42:17,22
accused 22:23 38:16
28:2,5,19,25 29:6
argues 41:20
C
being 9:17 10:6,21
39:1,2
29:7,25 30:2 31:2
argument 36:5
23:19 26:4 28:19
C 2:1 44:17,17
action 7:13 8:5 9:8
31:11 32:6,8 33:3
41:23
29:19 34:15 39:1
came 6:5 12:18 17:6
10:3,4,9,21 11:18
33:12,19 34:3,7,11
arguments 34:6
41:23 42:4
18:22 33:25 43:20
15:4 17:24 18:17
34:13,25 36:20
arise 7:5
believe 3:18 5:10,10
43:24
20:2 21:22 27:10
37:8,11,15,23,24
around 12:9 28:21
5:14,16 6:17,17,21
camera 36:16 42:15
29:23 40:7,16 43:8
38:4,5,5,12,16,19
articulated 29:16
7:13,19 8:11 14:18
cap 32:21
actions 5:25 13:23
38:22 39:14,17,18
asked 5:4,4 8:2 14:5
21:11 31:1,5 33:2
capped 23:25
14:3 16:11 19:5,17
39:21 40:20 43:1,6
30:25 42:1
33:5,13 37:6 38:23
care 13:20,25 25:20
22:16 25:4 42:25
43:16,20
asking 21:12 25:10
42:11
29:5 36:6
activities 23:7
ah 39:15,18
asks 13:10
believes 35:11
case 1:3 5:17,20,21
acts 9:11,12 37:14
ahead 28:8 38:5
aspect 28:12
believing 38:24
5:22 6:4,7 8:12
actual 41:18
al 1:4
aspects 9:1,2 16:5
beneficiaries 19:12
9:11 10:24,24 11:4
actually 5:21 17:9
allegation 5:1 15:19
assert 29:8
beneficiary 20:1
11:15,18 13:18,20
Adam 1:13 3:4
allegations 4:25 16:6
asserted 17:7
21:16 25:15
14:18,22 15:1,18
29:13
37:14 43:25 44:4,5
assertion 4:24 15:19
Bennett 3:18
16:2 19:17 22:17
add 29:5 35:7 42:21
44:10
15:22
besides 44:10
22:25 23:4,8,8
addenda 36:16
alleged 17:17,25
Assistant 2:15
between 8:6 9:23
24:17,20 26:3,4
Adderly 3:17
35:16 41:16,18
associate 10:17
13:1,21 19:14
28:10 29:4,6,9
additional 29:22
allow 11:8 31:23
associated 18:12
20:11 36:2
30:4,22 33:5,6
address 29:15
allowed 40:20 42:11
assurance 14:1
beyond 13:16
34:13 37:21,23
addressed 33:15
along 40:17
assurances 12:5
Biscayne 1:14
39:13 40:4,5,6
adjourned 44:16
already 22:5
attached 43:4
Bob 3:18 19:7
cases 3:2 6:9 7:3,11
Adler 1:17
always 30:16
attack 33:17
Boehringer 1:20
8:13,22 9:3,5,5,15
admit 20:3,18 25:11
Amendment 6:24
attention 15:1,22
bond 25:22
10:3,11 12:1,2
32:23 36:8
America 5:17
Atterbury 2:12
Boston 2:18
14:9 17:15,16
admits 23:20
amount 17:3,20
attorney 2:15 7:1
both 10:10 16:25
21:10 24:8,11 26:2
admitted 23:17 24:9
23:25 24:3,9,16,24
19:4 27:17,18,19
35:11
29:18 30:12 33:17
41:19
25:3 32:19
32:12 35:14
bought 28:22
37:9 40:2
ado 23:13
Amy 3:17
attorneys 5:9 10:10
Boulevard 1:14,17
casts 9:13
advantage 20:24
Ann 2:14 4:9
11:8 32:14 36:3
2:15
catastrophic 7:21
adverse 18:18
another 9:5 14:14
40:20 41:1 43:3
Brad 3:7 42:22
catch 7:21 10:2
advice 12:7
18:11 40:11,14
Attorney's 4:8,10
BRADLEY 1:16
caught 15:22
affidavit 43:2,4,23
answer 8:7 13:10
26:19 27:4 43:5,12
breach 6:1,23 15:11
cause 17:24 18:17
afraid 32:4
answered 42:2
43:25 44:5
16:3 18:24 19:6,13
26:5 40:7,16
after 33:25 41:7,8,8
anybody 11:14
August 12:18
23:16 25:9,9 28:2
caused 15:21
afterwards 34:5
anyone 14:16,19
Australian 2:12
29:24 30:5 31:1,6
causes 29:22
again 9:10,18,22
17:5 22:13 24:17
authorities 32:2
31:10 33:13,20
cavalierly 12:13
10:19,20 18:5,9
24:24 29:12,24
Avenue 1:21,23 2:12
37:7 38:8 39:2,19
certain 8:22 11:18
23:18 26:1 30:2
30:9 42:20
2:23 44:22
44:1,6,10
17:2,6 21:17 25:16
34:25 38:9,17
anything 8:22 11:15
aware 6:6 13:14 15:4
breached 7:19 12:24
40:7
39:11 41:4
13:22 14:2,7,20,25
a.m 44:16
15:20 22:11 42:4
certainly 8:16 9:1
EFTA00014236

=== Page 46 ===
Case 9:08-cv-80119-KAM
Document 180
Entered on FLSD Docket 06/24/2009
Page 46 ofage 46
29:3 40:3,9
committed 31:17
course 7:5 24:25
Davis 21:2 35:15
39:19,25
Certified 2:22
communications
26:21 27:12 30:4,6
day 43:4
discretionary 6:19
certify 44:18
43:13
30:16 32:24,25
deal 9:23 14:13,14
6:21
change 7:25
complainants 17:9
33:1 34:12 39:13
15:15 16:24,24
discuss 9:22 23:6
changes 7:8
complaining 25:11
40:4
18:6,9
discussing 42:4
charges 5:3
26:19
court 1:1 2:22 3:1,6
deals 36:14
discussion 16:22
chilling 9:7
complaint 28:4
3:9,12,15,20,22,24
dealt 6:19 16:25,25
disingenuous 19:15
chills 10:9 18:25
40:12
4:4,7,11,15,20
decide 10:11 22:5
dismiss 7:22 8:18
41:4
compliance 12:14
5:11,14,18,19,21
37:7 38:8
10:14 20:4 27:24
chime 26:9
complied 41:9
5:24 6:6,11,13,14
decision 39:11
33:5,8,25 37:13,16
chosen 29:21
comply 41:10
6:18,20,21,22 7:6
decisions 38:12,14
38:23
circumstance 7:21
concern 4:24 5:10,24
8:1 9:6 11:3,10,25
deem 11:19
disposed 40:2
8:18 18:4
9:20 16:1 22:8
12:19 13:1,10,16
deemed 10:4
dispute 38:7
circumstances 9:25
25:24 26:1 39:23
14:5,11 15:5,13,15
defend 5:25 10:11
distinct 7:9
10:1,11 12:11,20
concerned 13:22
16:10,13,22 19:2,9
11:18 12:1,2 22:17
DISTRICT 1:1,1,11
12:21 13:8,13 16:8
23:10 27:11 37:25
21:12,25 23:18
22:18,22,25 24:2
DIVISION 1:2
16:17 17:3,8,13,18
38:2,15,19 39:12
25:23 26:1,8,13,17
26:3
docket 6:17 8:25
18:19 32:14 35:25
39:12
26:18,23 27:9,14
defendant 1:8 2:8
12:14
36:8,9 38:25 39:7
concerns 6:24
27:16,18,20 28:1,4
6:23 11:13 16:16
documents 11:7
40:6,21,24
conduct 22:14
28:4,11,13,14,16
22:15,18 27:10
14:24
cite 17:10
conducting 22:13
29:4,8,12 30:2,8
40:23
Doe 1:4,15,18,22 2:3
civil 4:23,25 5:25 7:3
30:5 39:13
30:16 32:22 33:22
defendants 25:5
2:7 3:1,5,8,11 5:17
7:3,11 8:5,22 9:4,7
confident 19:10
34:8,22 35:3,5,7
40:23
6:8,9,16 11:12
9:11 10:3,23,23
consensual 16:25
36:16,19,21,22
defendant's 16:23
21:5 29:14,22 33:5
13:23 14:3,9 15:7
36:25 37:1
37:4,6,19 39:9,10
defending 4:25 7:24
35:13 42:22
16:5,11 19:5 20:20
consider 6:14 18:1
39:25 40:4,12,14
9:4 10:2,23 13:18
doing 8:9 29:9 34:9
22:14 26:25 27:10
23:16 35:24 42:14
40:15,17 41:8,15
13:20,23 14:3,9,18
37:22 39:24
31:24 34:13,14,15
constitute 13:18
42:8,12,20 43:15
15:18 16:2,10
done 12:3,4 13:17,19
34:16 36:14 39:24
16:2 19:6 34:13,24
44:3,4,8,13,16,22
25:18 29:9 30:4
13:24 14:2,7,17,20
42:25
construed 14:18
court's 7:15 8:25
34:12 37:9 39:13
14:25 15:6 17:14
claim 6:1 18:19
contact 10:17 39:17
12:14
defends 26:3
20:16 25:4 29:4
23:21,23 25:8 36:6
contending 19:4
covered 38:16 39:14
defense 4:1,14 8:4,12
41:10
37:13,16
contention 4:24
create 9:25
9:3,12,14 10:9
doubt 9:14
claimed 40:25
contentions 28:8
creating 41:7
12:3 19:5,17 24:6
dramatic 7:25
claiming 25:9
contest 17:12 18:7,8
creative 17:23
24:18 27:22 28:11
dramatically 7:8
claims 22:15 23:22
24:18,21,23,25
crimes 31:17
28:20 31:1 40:5
dump 40:16
23:22 24:1,4,6
29:20 36:9
criminal 8:21 20:15
42:24
during 40:4
28:6 36:23,24
contested 9:13 16:18
26:6 28:22 40:5
denied 22:5
40:13,15,17
16:25 36:25
criteria 17:6
deny 22:4,7
E
clear 10:7 18:18
contesting 20:6 25:2
Critton 2:8,9 4:2,2
depending 18:2
E 44:17,17
19:19 29:16 43:15
28:1 43:8
4:13 5:13 6:3,3
40:14
each 17:24 18:16
43:15
context 13:18,19
14:4 15:3,14 16:4
depo 29:3
East 1:17 2:15
clearly 9:24 11:20
14:5 15:1
16:12,15 31:7 35:7
depose 23:2
Edwards 1:16 3:7,7
34:6 40:5,22
contract 7:16 37:22
35:8 37:5,18 38:20
deposition 11:11,12
5:16,20,23 42:22
client 10:21 13:5
contracting 9:23
39:23 41:16,25
14:23 22:24 34:20
42:22
23:2 24:3 26:15
contrary 25:6 31:7
crystal 29:16
39:16
effect 9:7 17:5
28:3 33:25 40:10
control 9:2
cure 8:14,17 9:21
depositions 10:13
efforts 41:10
41:6
convicted 20:14
13:6
14:22 19:20 22:12
either 9:3 10:5 30:20
clients 11:9 21:24
31:13,16 33:10,11
cures 14:12
22:20 23:15 32:25
40:3,25
22:10,24 23:3
conviction 20:8,15
current 22:5
38:17
elected 29:22
25:16 29:21 30:1
20:20 31:19
cut 16:24
desired 20:12
eligible 31:20
36:3 38:22
copy 28:4 36:13
C.M.A 1:24 3:14
determine 9:8
Elkins 1:20
client's 29:3
41:25 42:6
17:16 24:11 26:10
developed 32:11
email 44:24
cloud 9:14
correct 5:12 23:1
26:15 40:11
difference 36:13
embarrassment 32:3
Colvat 42:8,13
24:5 35:2
different 6:5 12:21
enforce 21:17 25:17
come 8:8,13 13:11
correspondence
D
16:19 23:7 40:18
enforcement 7:2
21:1 23:6 32:13
30:21
D 1:13 2:8
direction 10:20
enforcing 25:10
34:5 40:3
counsel 3:3,4,7 12:7
damages 17:3 23:23
27:14
enter 40:20
comes 18:12
16:5 23:13 26:8,25
23:25 24:3,10,24
disadvantage 30:18
entered 33:12 40:19
coming 26:25
27:22 28:11,20
25:2 31:20 32:23
disagree 20:5,21
entire 5:15 20:25
comment 41:22
29:13 36:17,22
32:24 33:9 36:10
discovery 7:2,10,11
36:15
comments 15:10
42:18
43:8
10:16,25 22:12
entitle 11:23
35:11 41:14
count 24:14
date 13:12,14 44:21
29:4 30:5,21 33:1
entitled 24:2 31:16
commitment 17:2
counts 17:17 41:8
Datura 1:21
34:11,16,22 38:2
32:25 33:1 34:20
EFTA00014237

=== Page 47 ===
Case 9:08-cv-80119-KAM
Document 180
Entered on FLSD Docket 06/24/2009
Page 47 ofage 47
entry 6:17 8:25
extraordinary 9:13
form 11:4
7:18 8:1,2,7 9:21
35:6 38:20 41:13
12:14
41:10
Fort 1:18 2:16
10:8 11:19 12:6
42:10 44:12
enumerated 18:8,9
extremely 31:4
forth 36:2
13:1,2,2,9,11,13
HONORABLE 1:11
envisioned 40:22
eyes 26:24 43:19
forward 9:8 13:11
14:1,5 15:23 16:19
hope 31:22
Epstein 1:7 3:1 4:3,6
Ezell 2:5 3:16,17
17:6 19:1 21:1
17:11 18:4,12,17
hopefully 13:3
4:22 6:7 7:13,15
e-mails 36:2
22:17 23:6 26:2
20:11,11 21:13,14
Horowitz 1:13,14
7:19 8:6,20 9:15
29:7 41:4,12
23:10,11 25:11
3:4,4 29:13,13
9:18,24 10:1,6,10
F
found 31:10
29:9 33:19 34:18
30:6
12:5,15 13:17,21
F 44:17
four 9:5
34:23 36:2,17 41:3
horrible 21:23
14:8 17:9 19:5,14
fact 7:1 8:11 11:19
frankly 5:6
43:2
humiliated 20:25
19:16 20:11,13
14:20 28:4 30:11
from 3:17 4:7 5:9 7:9
Government's 5:6,8
hypocritical 19:25
21:8 23:13 24:21
33:20 40:6
10:20,24 13:9
7:25 9:10 12:20,23
25:16 26:3,23
factors 11:23
14:13 15:9 16:23
15:16 18:22 25:13
I
28:22 29:19,24
fair 27:6 32:19,23
17:10 19:2 30:9
30:14 37:9
idea 17:1 31:22
30:20 31:9,13
faith 38:24 39:8
32:13,13 34:22
grant 22:4
II 1:22 3:11
32:18,19,23 33:8
familiar 42:5
35:10 37:22 41:4
granted 22:2
impact 16:18
33:16 34:19 37:1
families 32:5
43:2,24
great 7:23 8:20 9:19
important 41:24
37:12 40:19 43:5,7
far 14:25 21:17
front 9:5 12:19
10:22 12:17 15:15
impose 27:4
43:9,13,18
23:10 24:24 30:3
25:10 42:3
20:8,24
incident 24:14
Epstein's 4:24 5:9,24
fashion 8:4
fully 33:18
ground 22:3
incidents 17:25
8:4 9:1 22:7 31:1
favor 12:16
further 29:10
guess 36:17 38:6,7
incredible 7:21
33:16 43:3,8
Fax 44:23
future 9:12 10:5
guilty 17:11 41:8
incredulous 19:15
equities 12:16
fear 9:14 37:24
12:5 26:21,22
indicate 44:3
error 27:7,7
federal 5:3 28:6
H
indicated 30:13
ESQ 1:13,16,20,23
29:21 31:13 32:22
G
H 1:23
indicates 43:3
2:1,5,8,8,11,14,17
federally 2:22 31:15
G 2:17
hand 32:9,9 41:25
indict 7:20,20,22
2:20
fees 21:8,10 25:10
Garcia 1:20,20 3:10
hanging 11:19
8:13,16,17 12:10
essence 7:9,12 8:3
few 35:8 43:18
3:10 27:20,21
happen 14:13 22:6
12:24 15:10 18:23
10:2 12:3 35:23
field 7:8
28:15,18 29:11
happens 28:3
21:14
37:1 39:1 40:13,15
Fifth 6:24
gather 22:21
happy 30:16 36:13
indicted 9:17 10:6
essentially 28:22
fight 32:24 36:10
gave 16:1
36:21
10:22
et 1:4
file 21:4 28:13 30:22
general 39:24
harassing 39:16
indictment 8:19 10:7
etc 2:9 34:21
32:22 35:18 38:18
generally 10:22
harassment 39:18
individual 18:16
even 11:5,6,9 14:1
40:15
getting 24:11 25:19
harm 10:1 41:7
40:7
15:17 16:1 17:22
filed 5:11,16,21,23
girls 20:7 23:5 25:20
having 27:2,11
individuals 10:18
21:3,4 32:2 34:22
6:7,10 10:8 11:9
32:1
31:24 41:7,8
17:1 35:15 37:3
36:4 42:10 43:24
15:18,23,24 20:20
give 12:5 14:1 42:6
hear 5:9 26:12 41:21
information 22:21
event 5:24
28:3 30:21 33:4,6
given 28:4
42:24 43:2,10
44:14
ever 5:11,14
34:1 35:17,19 36:1
giving 44:13
heard 19:2 41:13
initial 12:19 15:21
everyone 30:3 42:3
36:24 37:15,19
glaring 18:21 35:10
44:6
initially 15:24
everything 15:7
38:23 40:9,12,13
glasses 11:16
hearing 1:10 4:21
injury 10:23 23:22
41:10
42:25 43:3,23
go 12:10 15:13 22:17
30:24 43:14
innocent 27:5
evidence 25:1 44:6
files 35:19,19,20
24:24 26:2 28:8
held 33:9
inquiries 30:13
exact 21:18,22 28:20
filing 30:5 31:6 41:5
29:7 31:24 38:5,13
help 30:11,16 32:15
inquiry 7:15 15:16
exactly 10:24
filings 7:8
goal 32:17
helpful 5:7 25:12
instance 7:18,24
example 14:20 16:21
filter 11:7
going 3:18 5:25 12:4
30:14 42:7 44:14
9:18 10:10 11:3,17
17:16 34:17 36:1
financial 23:12
12:10 13:23,25
her 26:4 28:4
13:5 16:14
37:10,11 39:5
find 5:6 6:13 19:15
14:11,13 15:18
Herr 2:21 44:20,21
instances 16:4
40:11
19:25 23:11 29:24
16:2 19:5 22:4,6,9
hesitant 32:1
intended 28:21
except 8:20 11:25
39:20
22:18,23 23:10,14
hey 22:19
intent 21:19
exclusive 41:2
firm's 6:6
23:24 26:5 28:8,11
him 4:23 7:20,20,22
intention 9:19 26:19
exclusively 28:6 33:7
first 5:9 16:14 19:3
29:8 36:2 38:6,8
8:13,16,17 9:15,20
26:20,20 27:16
exists 13:15
26:18 30:23 43:20
38:12,13,16 39:10
11:23 12:5 21:14
interest 23:12
expecting 43:1,11
fit 36:4
39:15 41:22 43:1
21:15 25:10,11
interested 13:17
expires 37:23
FL 1:15,18,21,24 2:3
43:12
26:4,5,13 28:24
14:3
explicitly 37:12
2:6,10,13,16,23
Goldberger 2:11,12
38:11 40:20 41:11
interpretation 16:20
expose 5:1,25 31:24
44:23
4:5,6 38:10
42:25
38:22
exposure 22:7
Flagler 2:2,6,9
gone 15:7
himself 5:1,3
interrogatories
expound 43:12
floor 32:21
good 3:6,9,10,12,13
Honor 3:10,13,16,21
14:24 19:20
express 34:10
FLORIDA 1:1,4
3:15,16,22,23 4:4
4:2,5,9,13,17,19
interrupt 37:4
expressly 37:22
focused 15:15
4:5,9,11,16,18,20
5:13,16 6:4 12:12
introduced 20:16
39:14
forced 19:17
17:16 38:10,24
19:1,7 23:1 24:5
intrusive 29:5
extensive 29:4
foregoing 44:18
39:8
25:22,25 26:7,12
invasive 19:22
extent 28:10
forgot 27:23
Government 7:7,9
27:21 30:15 34:14
investigated 31:14
EFTA00014238

=== Page 48 ===
Case 9:08-cv-80119-KAM
Document 180
Entered on FLSD Docket 06/24/2009
Page 48 Page 48
investigation 10:18
K
limitation 25:2
43:17
need 24:22 25:23
38:2 43:7
Katherine 2:5 3:16
limitations 36:4,7,11
mean 18:10 33:22
negotiate 32:18
investigations 22:13
keep 24:21
41:20
34:14 39:7 43:24
negotiated 27:3,3
34:11
KENNETH 1:11
limited 4:21 8:3 14:5
means 32:24
neither 43:21
invited 27:6
key 32:9
17:12 20:19 23:25
members 4:13
never 11:9 26:20
involvement 6:6
kind 30:10 36:12
30:19
memo 7:14 28:9
40:19,22
irreparable 9:16
39:11,22
limits 28:5
memorandum 27:23
newspapers 23:5
10:1 41:7
knew 27:1
Lindsay165@aol.c...
mentioned 44:11
nobody 11:14
ISIDRO 1:20
know 4:22 6:17 8:21
44:24
merits 22:1
none 13:25
issue 4:23 6:5,11,19
11:14 12:2 13:9,17
list 17:1,2,6 35:16
Mermelstein 1:14
non-contesting 28:5
7:4 11:25 12:18,22
14:21 15:5,7 16:22
36:8 38:11
met 17:6 33:7
non-position 9:10
14:14 15:25 16:2
19:23 22:6 23:12
litigation 7:4,5 9:13
Miami 1:15 2:3,6,23
non-prosecution 5:2
16:13,22 18:12,22
25:9 27:1 30:12,20
15:8 16:18,25
2:23 44:22,23
5:11 6:2 8:6 13:24
21:18 28:10,16
31:4 32:13 37:19
21:18 22:14 23:12
Michael 2:8 4:3
14:19 15:20 19:6
33:4,14,24 42:8,23
39:10,17 41:17,21
31:24 33:16 34:3,9
microphone 26:13
22:8 24:1 27:25
42:24
knowing 26:25 38:5
34:15,15,16 36:25
might 14:2,12 22:14
28:2,5,19,25 29:25
issued 14:25
knowledge 5:13
36:25 39:24
29:5 37:16,17
31:11 32:6,8 33:2
issues 4:21 24:10,13
13:11
lives 21:21
million 17:21
33:12,18,19 34:3,6
25:21,23 35:9
known 21:4 32:14
long 31:17 37:14
minimum 17:3 25:3
34:10 36:19 37:11
36:15 39:25 40:3
knows 11:3 13:2
longer 20:7
37:2
43:1,6,16
issuing 22:20 39:19
look 12:14 18:6
minimums 24:25
non-2255 24:4,6
i.e 41:1
L
36:16
minors 20:7
normal 30:4 39:13
lack 41:22
looked 6:11
minute 18:13 41:14
North 1:23 2:9,23
J
ladies 20:23 21:3,20
mistakes 13:4
nothing 13:15 24:12
J 1:16
M
Lake 1:24
money 17:20
24:15
Jack 2:11 4:5
language 18:14
M 1:20
more 8:3 17:23
notice 8:13,16 9:21
jackpot 32:9
32:11
MA 2:18
23:25 30:25 39:12
13:6 14:23 22:24
jail 41:7
LARRY 2:21 44:21
made 15:10,17 16:6
42:7
31:8,8 39:6,16
Jane 1:4,15,18,22
Las 1:17
20:12 31:20 43:13
morning 3:6,9,10,12
noticed 14:22
2:3,7 3:5,5,7,11
last 33:22 41:24
44:4
3:13,15,16,22,23
notification 15:3,4
5:17 6:8,9,16
Lauderdale 1:18
major 11:25
4:4,5,9,11,16,18
16:8
11:12 21:4 29:14
2:16
make 8:21 13:4
4:20
NPA 8:5,11,15,24
29:22 33:5 35:13
law 7:1 27:24 28:9
15:21 19:19 23:8
most 7:7 13:3 15:24
9:1,9,16,19,22
42:22
lawsuit 25:18,19
23:13 26:2,18
18:21 32:12 35:10
10:4,19,22 11:20
Jay 2:20 4:18
lawsuits 30:17
27:24 29:1,16 34:5
41:24
12:8,15,24 13:7,15
Jeffrey 1:7 37:12
lawyers 8:21 9:4,7
38:12,13 39:11
motion 1:10 4:22
14:10 16:8 18:14
jeopardize 9:15
10:23,23 17:22
41:14
12:22 15:24 20:4
20:22 21:19,19
jeopardy 15:17
27:1 38:10,11,21
making 42:7 43:9,24
22:6 27:24 33:4,14
23:9 24:12,15,16
join 26:11,15
40:23
44:5
33:15,25 34:2,11
24:18,20
Josefsberg 2:1,2,5
lay 8:10
man 12:24
37:15,20 38:2,23
35:12,24 36:14,14
3:18,20,21,23 19:7
least 35:10
mandate 7:24 8:20
39:8 41:5 42:23
39:3 41:4,6,11,18
19:7,10 21:25 23:1
leave 33:17,19
8:21 10:3
43:4 44:1
42:1,2,3
24:5 25:25 26:7,11
Lefkowitz 2:20 4:18
many 20:23 31:3
motions 10:14 17:15
number 15:9 16:21
26:12,16 27:13
4:18
35:17 42:1
21:5 30:5 35:21
17:7,9,14,21,24
31:6 32:17 33:6
left 10:2
Marie 2:14 4:9
38:18
32:1 35:15,20
35:14 39:3 41:13
legal 10:13 24:10,13
MARRA 1:11
move 7:22 8:18 19:1
numerous 23:21
41:16 42:10,16,17
35:21 38:12 40:3
Martin 2:17 4:16
19:20 21:17,21
43:17
41:5 43:9
Master 21:2 32:16
37:12
0
Josefsberg's 33:25
legally 40:7
matter 20:15 37:13
moving 9:7 33:8
object 7:2,10,10
35:11 36:5
legitimate 38:7
44:19
41:4,12
objection 36:18
JR 2:8
less 41:14
matters 21:11
much 23:13 30:16
objections 11:5,6
Judge 1:11 15:12
let 5:9 13:10 19:19
may 3:3 5:1 7:2,10
30:25 42:7
obligation 21:9
21:2 29:13 35:15
letter 17:10 21:19
9:9,12 10:4,17
multiple 18:15 40:15
30:12 31:8
42:8,12
letters 16:6
11:19 13:17,18
40:16
obtain 11:7
judgment 22:16
liability 17:12 18:7,7
14:18 15:12 16:18
multitude 8:12
obviously 10:20
June 1:5 13:12
20:3,6,16,19 23:16
16:19 17:12 19:8
myself 16:5 42:17
34:18
jurisdiction 28:1,6
23:17,20 24:8,18
19:16 20:4 21:11
occurred 17:25
just 18:23 20:15,16
21:17,21 23:6
N
24:22,23 25:6,11
occurs 26:21
22:3,6 24:20 26:1
29:20 32:23 36:9
27:22 30:20 32:14
N 44:22
off 39:8
29:15,16 30:23
40:22 41:1
34:17 35:16,20
names 11:9 23:5
offender 41:9
35:8 37:8,10 39:24
liable 33:9
39:6 40:8,16 41:6
43:6
offense 18:8,10,15
40:4,17 42:24
like 7:16 13:9 25:21
41:13,13
narrow 42:24
33:10,11
43:14,23 44:3,11
37:16 40:4
maybe 12:17 13:10
nature 27:6
offenses 18:16 31:13
limit 23:23 24:2
17:20 30:10 42:8
necessary 22:22 41:5
offered 37:2
EFTA00014239

=== Page 49 ===
Case 9:08-cv-80119-KAM
Document 180
Entered on FLSD Docket 06/24/2009
Page 49 ofpage 49
office 4:8,10 26:20
15:6,10 41:5
point 6:18 14:12
31:15
reference 27:25
27:4 43:5,12,25
paragraphs 36:15
26:16,23 28:14
prosecuting 37:25
referred 31:6
44:5
paraphrasing 6:20
29:15 36:12 43:23
prosecution 26:6
refers 41:16
Official 2:22 44:22
Park 2:18
pointed 14:20
28:23 29:6,7 34:25
refusal 9:10
officials 7:2
part 10:18 18:9
portion 32:24 36:14
prospect 16:15
refuses 8:7
often 40:2
20:23 21:7 23:9,20
portions 5:15
protect 32:7
refusing 25:5
okay 3:25 5:19,21
34:16 39:23 40:2,5
posed 11:25
protecting 32:7
regard 9:11,12,13
18:10 30:2
44:1
posing 8:4
provide 31:8 36:13
10:12,13,14,14
Olas 1:17
particular 6:15,18
position 5:5,8 6:4
36:21
11:4 12:19 14:9
old 31:18,18
7:24 8:22 9:18
7:25 9:16,20 10:12
provided 16:9 32:12
16:18 18:23 35:12
once 22:5
11:17 13:5
10:13 11:21,22
provides 9:22
36:23
one 4:23 7:17 11:25
parties 9:23 11:6
12:12,17,23 14:8,8
providing 31:8
regarding 6:24
17:24 18:5,16,20
16:21 22:21 39:20
14:15 15:16 16:16
provision 6:12 8:11
23:15 37:9
18:21 20:1,8 22:24
partner 3:18 4:3
16:17 17:4,7 18:13
29:19,25 34:10,25
regardless 31:17,18
31:11 36:24 39:10
parts 19:25 21:17
18:17 19:19 20:13
37:11 38:3 39:17
registering 41:9
40:16 42:23 44:11
party 11:11 14:25
22:1,11 25:8 30:14
39:18
relate 9:3 30:1
only 13:22 14:3
30:12,17 36:18
31:12 32:10,15,20
provisions 13:6,7
related 30:24 33:24
17:24 23:20 25:4
past 9:11 10:5 12:3,4
34:8 35:3,21 36:23
psychologically
relates 8:12
29:20 36:6 39:1,3
pay 17:3 21:8,10
37:9 40:10 41:17
21:24
relating 29:19
42:23
25:5
43:5
publish 23:5
release 41:9
open 26:24 43:19
pending 6:15 9:5
positions 30:20 41:5
pure 24:8
relevant 19:22
opportunity 8:14,17
17:15 21:6
possible 30:17 31:4
purpose 21:19,23
remain 42:13
9:21
people 23:6
44:15
28:20
remedy 7:20 8:17
opposed 33:21
per 24:14,14,14,14
possibly 34:9
pursuant 25:15 32:8
29:21 33:20 34:7
opposite 20:22 21:18
perception 28:21
posting 25:22
41:17
41:2
21:22 28:20
perfect 36:1 39:5
potential 5:3 15:2
pursue 23:12
remember 23:19
opposition 27:24
perhaps 20:24 27:22
28:2
pursuing 22:12,15
remind 44:3
option 7:23
period 9:21 34:4
potentially 10:18
put 9:15 18:21 32:10
remote 10:8
order 6:16 12:14
37:3,14
15:19
41:6
rep 35:14
22:21 30:23,24
permitted 24:6,18
power 13:2
puts 18:25 34:4
replies 10:15
33:17,17 36:19
permitting 42:18
practical 10:25 15:9
40:10 41:11
reply 35:22
44:15
person 36:11
practice 34:11 38:3
REPORTED 2:21
ordinarily 26:3
personal 10:23
predicate 20:8,15
Q
Reporter 2:22,22
34:12
23:21
prepared 20:5 27:15
question 8:3,7 9:2
44:22
ordinary 27:10
perspective 16:23
present 5:5 11:15
12:1 30:25
represent 21:3 32:12
39:13
35:10
presents 9:7
questions 42:1
35:15
originally 6:5
pertains 29:20
press 43:10
quite 19:10
representation
Orseck 2:2,5 3:17
phone 4:12,14,15
pressure 21:15
26:18
other 7:1,17 16:4,5
42:18,19
presume 23:24
R
representatives 4:7
17:22 22:13,18
picking 12:13
pretty 8:1
R 44:17
43:9
23:6,21,22 24:1
place 31:12 37:14
prior 6:6 8:25 12:14
raise 16:2 36:11
represented 21:7
25:21 26:8 32:8
43:20
36:19
raised 15:25 16:13
26:24 33:5
34:9,11 36:12
plaintiff 3:7,14
privacy 19:22 32:7
18:5,21 19:13
representing 38:11
42:18 43:8 44:10
24:15 30:4 34:20
probably 35:18 36:3
28:10 33:14 35:9
represents 18:16
otherwise 39:14
43:7
36:13
40:1
35:16
out 8:8 10:16 22:24
plaintiffs 1:5,13
problem 14:12 22:22
read 37:20 42:2,23
requests 14:23
26:16,23 28:22
3:24 11:8 17:8,14
23:2,3 28:18
reading 18:18 23:19
required 17:3
30:11 36:12 38:17
17:22 19:3 22:14
procedure 32:16
ready 29:7
requirement 33:8
39:20 44:15
23:7,24 27:5 29:1
34:24
real 9:6 10:8 36:11
resist 34:18,23
outside 13:18,19
29:12,14,20 30:9
proceed 12:10 18:23
41:18
resolve 42:8
24:17 36:7
39:16 43:8
32:22 38:13
really 12:2 18:11
resolved 7:4 19:12
over 11:19 24:24
plaintiff's 19:4 26:8
proceeding 6:15,15
30:20,23 33:14
24:16
own 12:21 38:13
36:16
proceedings 4:23,25
36:17
respect 22:14
playing 7:8
44:19
Realtime 2:22
respectfully 7:6 14:4
P
Plaza 2:18
process 39:25
reason 6:14 7:3
respond 20:5 30:13
Pacer 30:19
plead 17:11 18:10,11
production 14:24
29:23 33:11 34:2
44:9
pages 7:14 27:23
pleading 7:14 31:10
19:20
reasons 18:5,20
response 5:6 7:14
28:9
33:4 40:9,14
prohibited 38:3,4,18
34:19 40:8
8:2 11:20 15:16,23
paint 29:17
pleadings 23:4 31:3
prohibits 37:22
recapitulating 41:1
18:22 33:15 34:1,1
Palm 1:2,4,21 2:10
32:13
proof 20:16
received 5:5 15:3,4
35:17,21
2:13
please 41:22
proper 25:1 27:14
20:4
responses 10:14
paper 10:16 13:7
pled 17:8,16 20:14
27:15
recent 7:7 15:24
30:21 35:8
papers 8:10,16 9:25
41:8
prosecuted 20:13
records 34:21
restitution 29:2
10:8 11:21 12:20
Podhurst 2:2,5 3:17
26:4 27:11 29:10
redacted 36:14
31:16,23
EFTA00014240

=== Page 50 ===
Case 9:08-cv-80119-KAM
Document 180
Entered on FLSD Docket 06/24/2009
Page 50 ofasge 50
restitution/damages
seen 5:14,15
Special 21:2 32:16
suggest 8:10,23
12:24,25 13:6,6
32:19
selected 35:15
specific 8:2 11:1
suggested 12:13,21
17:16 18:18,23
restrictions 43:18
self-fulfilling 24:23
16:24 17:13 30:25
14:16 15:5,6 36:3
19:14 25:13 27:6,6
result 10:21 15:19
self-incrimination
43:25 44:4
39:2 40:8,9
27:22 28:18 29:15
18:20
6:25
specifically 43:7
suggesting 16:7
30:23 39:6,8 42:1
resulted 32:17
send 10:16 38:17
spector 11:18
suggestion 15:17
42:2,6 43:15 44:14
review 31:3 36:22
39:6
speculative 10:9
41:25 44:10
third 11:6,11 14:25
Richard 1:23 3:13
sends 22:23
spirit 25:20
suing 25:10
22:21 39:20
26:10
sent 14:22,23,24
spoken 30:3
suit 20:21 21:4 32:22
third-party 19:11
ride 40:17
16:6 17:10 39:15
standard 11:1
suits 26:25
21:16 25:14
right 3:24 6:24
39:19
standpoint 10:25
summary 40:3
thoughts 27:2,5
12:25 13:3 25:8,14
separate 5:20 17:17
15:9
supporting 15:16
threatening 44:1
34:23 37:20 41:3
serve 11:5,6
start 23:15
supposed 20:18
three 41:14
42:20 43:14 44:8
set 12:21 13:13 18:4
state 3:3 9:6 28:4
22:25 23:17 24:9
through 3:5 6:9 11:7
rights 13:5 25:16
31:22 36:9
29:4 40:12,17 41:8
29:1
11:16 29:14,22
32:7
settle 21:8
stated 3:25
sure 5:7 14:11 26:2
31:5,24 32:6,16
risk 9:6 10:6,7 18:25
settling 21:10 25:5
statement 33:23
29:16 33:22 37:25
till 14:2
38:6 40:10 41:6,11
severely 21:21
statements 43:9
Susan 3:17
time 6:10,11,12,15
risks 21:5
sex 41:9
States 1:1,11 2:22
system 31:23
6:19,20 13:3 17:5
Robert 2:1,8 4:2 6:3
sexual 23:6
4:8 5:1,5,17 6:1
s/Larry 44:20
21:12 31:18,19
role 25:13 37:7
shape 11:4
9:24 10:6 13:21
34:4 36:3 37:2
Room 2:23
shield 29:1
14:8,17 16:7 19:14
T
38:21
Rosenfeldt 1:17
show 36:22 42:11
22:10,19 29:9 39:4
T 144:17,17
times 17:19 18:2
rose-colored 11:16
Sid 3:10
44:5,22
take 7:12 9:12 10:3,3
today 8:4 13:11 14:3
Rothstein 1:17
side 7:17,17
State's 27:16
10:12,13,21 11:12
14:6,6 15:5 28:17
RPR-CM-RMR-F.
sideline 8:9
statute 17:4 18:3
11:18,21,22 14:7
31:9,19 35:23
44:21
silent 29:23
20:6 24:14 28:7
14:21 16:16,16
36:21 43:14 44:11
RPR-RMR-FCRR..
similar 35:18 43:2
29:21 36:4,7,11
18:2 19:20 22:10
44:14
2:21
simply 11:17
41:20
27:9,10 29:3 33:1
today's 13:12,14
rule 39:9 42:13
since 20:20
statutory 6:12 24:25
34:15,20 35:20
told 23:20 35:23
rules 22:3 25:1 34:24
sir 19:9 35:8 37:5
25:3 34:18 37:2
38:7,17 41:14,22
tools 10:25
40:15 42:13
41:15
stay 4:23 6:8,19,21
taken 7:7 9:11,21
tort 10:24 23:22
ruling 8:25 42:7
sit 8:9
7:3 11:24 12:16,19
14:9 15:5 30:20
24:4,6
rulings 19:21 23:8
sitting 42:3
12:23 15:25 19:16
41:10 43:5
totally 20:5,21 23:1
25:2 27:13,15 30:6
situation 12:6 20:25
21:22 22:2,4,4,5,7
takes 18:17
41:24
run 22:18
25:12 26:24
24:22 25:21 30:24
taking 9:8 14:23
TRANSCRIPT 1:10
running 21:13 23:14
sole 29:21
33:14,15,16,21
19:17 22:12,20
transcription 44:19
27:16
solely 12:15 32:10
34:2,2 37:21,22
23:15 25:20 34:8
trauma 32:3
some 4:7 5:4 7:2,10
42:5 43:4
41:5
traumatized 21:21
S
7:11,12 9:1,8,9
stayed 25:19
talk 6:18 25:23
tried 31:3 32:6
same 6:10,16 8:3
10:16 15:12 16:1,8
staying 21:18
team 4:14 12:3
troubled 43:24
20:13 27:12 31:12
17:22 20:25 21:3
steps 27:10
telephone 2:4,19,20
true 17:12
32:10 35:21 38:21
30:18 35:8 38:7
still 5:7
3:19
try 23:11 30:16
satisfied 20:9
43:13
Street 2:2,6,9
tell 11:13,14 42:12
32:18 34:17 44:15
saying 7:10 8:1
someone 10:17 19:22
strictly 11:15
telling 21:13 22:9
trying 10:11 22:3
17:17 19:12,16
24:20 26:3 34:12
strikes 36:12
temporary 11:1
28:25 32:9 37:8
20:6,7,8 21:14
34:17 37:16 39:15
stuck 18:14 36:10
terminates 34:4
39:20
25:5 33:9 37:10
something 13:19,24
stuff 34:19
terms 9:3 22:7 33:20
turn 12:8
39:5
14:17 15:24 20:19
subject 5:3 26:5,21
thank 19:1,2 27:8,21
two 4:13 9:23 19:25
says 8:15 13:7 17:11
26:17 28:13 34:9
27:13 30:6
30:8,15 35:5,6
21:11 36:24
18:13 35:1 38:5
37:21,23 38:4,9
submit 7:6 14:4
42:17 44:7,13
type 12:15 22:13
40:14 41:3
39:9 43:2
submitted 42:15
their 3:3,25 7:14,14
35:17 39:18
scheduled 4:21
Sometimes 13:4
subpoena 11:9 34:17
8:10,16 9:25 11:8
types 22:16 36:24
seal 5:18,23
somewhat 6:5
34:20
11:20 12:21 13:7
typical 11:2,4 22:15
sealed 42:14
soon 44:15
subpoenaes 11:5
14:21 15:6,10
23:3,4,8
second 20:23 27:2,5
sorry 15:14 27:19
subpoenas 14:25
21:21 23:6 27:5
30:24 36:25 37:4
sort 32:10 33:17
22:21 38:18 39:19
29:21 32:5,7,7
U
Secondly 41:20
34:19
subsequently 6:9
themselves 32:4
ultimately 39:9
secret 17:1
sought 31:11
9:16
thing 25:4 27:12
unable 29:19
Section 33:7
sound 37:16
substantial 9:6
28:21 31:11 39:11
uncertainty 9:14
see 4:7 15:11 20:12
South 2:12
11:22,23 13:2
things 11:3 38:15
uncomfortable
seek 23:25
SOUTHERN 1:1
18:25 41:11
39:22 43:10
23:11
seeking 6:7 24:3
speak 12:16 19:8
sue 7:17
think 6:8,14 8:15 9:4
under 5:17,17,23
seeks 34:22
speaking 26:14 32:2
suffered 32:3
9:22 10:19 11:22
7:20 8:18 9:25
EFTA00014241

=== Page 51 ===
Case 9:08-cv-80119-KAM
Document 180
Entered on FLSD Docket 06/24/2009
Page 51 ofasge
51
10:1,11,22 12:6,10
44:9,12
went 6:18,22 26:23
40:8
50 18:2 24:12
12:20 13:7,8 16:8
violate 19:18 34:6
32:16 43:19
102 6:8 35:19 36:1,3
500 2:15
16:17,23 17:2,4,8
violated 5:2 14:2
were 6:10 14:6 15:10
40:9 41:21
515 2:9
17:12,18 18:4,8,19
39:6
18:7 19:11 21:2
103 21:5 35:19
561.582.7600 1:24
20:9,18,19,21 21:9
violates 8:5,11 33:2
29:23 31:17,18
35:19
561.659.8300 2:13
22:7 24:8,11,18,20
42:25
32:1,4,22 34:17
105 35:20
561.832.8033 1:22
24:20 25:1,6 28:6
violating 9:16,19
36:24 43:1 44:10
11:10 44:16
561.842.2820 2:10
30:12 31:21 32:21
38:17 41:6 43:13
weren't 32:9
12 1:5 9:4
32:23 33:7,10
violation 8:23 9:9
West 1:2,4,21 2:2,6
12th 13:12
6
34:18,23 35:24
10:4,19 11:20 12:7
2:10,13
13 7:14 9:4
6 1:18
36:5,8,9 37:1,13
12:9 13:15,19,20
we'll 7:19,22 8:16
14 7:14
617.227.3700 2:19
38:25 39:6,14 40:6
13:23 14:10,19
17:23 26:13 40:17
150 17:19,20 18:2
40:21,23 41:1
15:2 16:7 18:19
we're 9:8 10:2 12:10
24:12
7
understand 5:7
24:19 25:19,20
13:14 19:10,12
27:23 28:9
7 1:18 3:5 29:14,22
14:15 21:25 22:3
29:10 34:10,13,24
20:5 27:15 28:17
18 33:7
36:15
23:24 29:25 30:14
35:12,24 37:17
39:1 43:14 44:2
18205 1:14
31:7 37:8 38:20
40:25 41:4
we've 15:4 35:23
19 27:23 28:9
8
39:25
violations 17:17,18
36:5 43:12
8 36:15
understanding
17:24 18:1,16
whatsoever 27:7
2
8N09 2:23
20:10
19:23 40:16 43:17
while 32:7 34:16
23:5 5:17 6:9,16
unfair 42:2
43:22
35:14
29:14,22
9
unilateral 12:22
voluminous 31:4
whole 20:12 38:11
2:18 17:25 18:2
9 36:15
unilaterally 7:13
vs 1:6 3:1 5:17
wide 26:24 43:19
2009 1:5 13:12
2:16
12:24
willful 8:23 12:7
22 7:21 10:2
954.522.3456 1:19
United 1:1,11 2:22
W
willfully 9:19
224 1:21
4:8 5:1,5,17 6:1
W 2:5
Willits 1:23 3:13,14
2255 16:23 17:4,17
9:24 10:6 13:21
wait 8:10 18:13
26:10,10,14,15
17:18 18:8,12,14
14:8,17 16:7 19:14
42:12
27:12,19
20:2,9,19,21 23:21
22:10,19 29:8 39:4
waive 25:14
win 29:5
23:22,23 24:8,17
44:5,22
waiving 18:7
withdraw 28:8,11
24:21 25:6 31:21
unless 11:7 34:25
want 8:9,10 11:15
wonderful 28:23,24
32:21,23 33:7,10
unlimited 40:21
12:2 16:22 17:20
word 24:21
36:6,23 37:13 41:2
until 37:23
21:4,4,5,14 22:1,6
worried 39:22
2290 1:23
urge 22:9
25:17 26:2,8,16,18
worry 41:11
2:2,6
use 10:25 11:8 20:24
26:23 27:4 29:16
Worth 1:24
250 2:12
23:11 28:25 40:11
35:7 37:21 41:17
writing 28:13
20:4
used 28:19
41:21 42:14,21
written 5:6 21:9 23:4
U.S 2:15 4:10 7:1,9
44:9
3
8:6 12:8,12 16:16
wanted 11:11 14:21
X
31:18
26:19 27:4,18,19
17:5 20:12 29:15
X 1:9
3017:16,19,19
43:5,11,25
42:24 44:3
30-count 40:12
U.S.A 2:16
wants 11:14 13:3
Y
305.358.2800 2:3,7
U.S.C 33:7
19:2,16,20 23:4
yeah 41:3
305.523.5290 2:23
24:24 33:16 34:2
yesterday 21:9
305.931.2200 1:15
V
warranted 6:22
young 20:23 21:3,20
305/523-5290 44:23
various 3:1 10:25
wasn't 28:21
305/523-5639 44:23
very 4:21 5:7 11:1,2
way 8:23 9:9 10:5,16
$
33 6:17 9:1
11:20 12:21 16:19
10:19 11:4 13:16
$15 17:20
33128 2:23 44:23
16:24 17:12,12
14:10 19:23 25:1
$150,000 32:21
33130 2:3,6
23:11 29:4 32:1
25:18 27:3,4 28:22
$50,000 17:5 32:21
33160 1:15
35:18 38:10 40:18
28:23
37:2
33301 1:18
42:2 43:18 44:14
ways 30:18
33394 2:16
Via 2:4,19,20
wealthy 32:13
0
33401 1:21 2:10,13
victim 37:13
weigh 26:11
02116 2:18
33461 1:24
victims 20:12 21:20
Weinberg 2:17 4:16
08 12:18,18
421:20
28:23 31:12,16,23
4:16
08-80119-CIV-M...
32:13 33:18 35:16
Weiss 2:12
1:3
4
39:20 41:17,18,19
well 7:10 8:20 10:22
4 1:18 11:12
41:19
11:12,12,13,13
1
400 2:23 44:22
view 16:19
12:17 13:16 14:11
15:17
401 1:17
2:14 4:9
15:7 16:18 17:15
36:15
4:10 17:10 30:10
17:23 18:10,11
10th 1:23
5
30:15 33:24 34:14
33:24 35:12,19,20
101 2:3,7 33:5 35:13
5 1:18 6:9
35:2,4,6,12 39:4
36:5 39:4 40:13
35:17 38:23 39:3,7
5th 12:18
EFTA00014242


