# docs_fts_content

c1: EFTA00021407
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021407.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Correction on
and here is your other bomb
Date: Tue, 16 Jul 2019 18:35:41 +0000
Importance: Normal
Embedded: Voice_Message_Attached_from
-HOLDSCLAW_SUSAN.msg
Yep - voicemail with cell phone number attached (and email address below). Thanks.
From:
Sent: Tuesday, July 16, 2019 14:34
To:
>;
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
From:
Sent: Tuesday, July 16, 2019 1:21 PM
To:
Subject: Fwd: Correction on
and here is your other bomb
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.
EFTA00021407

=== Page 2 ===
thanks,
From: Susan Harriman
Sent: Tuesday, July 16, 2019 12:06
To:
is
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_990PF.pdf
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 MM Iain Ferguson Bruce M MM Ian Charles
Stone MM
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
EFTA00021408

=== Page 3 ===
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.
EFTA00021409


c1: EFTA00021875
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021875.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Subject: bumping!
Date: Tue, 11 Aug 2020 17:24:59 +0000
Attachments: letter_to_USA_re_protective_order_(002)_002)final.pdf
Inline-Images: image001.jpg
Thanks very much.
Also, I know we disagree on this (a non-passive-aggressive instance of "reasonable minds can disagree"!), so just in the
interest of transparency I think there's case law that strongly suggests we need to disclose the victim names. I'll send that
around, but obviously if you have anything else on the subject, don't hesitate to send, and all without prejudice to further
discussion. Thanks as always.
From:
Sent: Monday, August 10, 2020 11:37
To:
Cc:
Subject: FW: Letter regarding discovery attached.
I think
is particularly swamped this week - can you please take the lead on whatever we're going to do with this
(i.e., presumably whatever the chiefs decide)? My personal vote would be to tell them that the protective order explicitly
precludes the use of criminal grand jury materials in Maxwell's civil cases, and the materials are sealed because they
relate to an ongoing grand jury investigation and they should feel free to raise the issue with Nathan and we'll respond.
(And I would think our response could basically be a copy-paste of the letter I wrote to Netburn.) We could also note in
our response to Jeff and Laura, if we wanted to, that given their awareness of the materials, we assume they will retract
the obviously false claims about government malfeasance.
All that said, I also wouldn't object if they just want to allow them to file these materials under seal; I don't think it
matters hugely. If we could have resolved
(et al) by now, none of this would be an issue.
thanks,
From: Jeff Pagliuca <jpagliuca@hmflaw.com>
Sent: Sunday, August 09, 2020 18:56
To:
is
)
V.
)
Cc: Laura Menninger <Imenninger@hmflaw.com>; Christian Everdell <CEverdell@CohenGresser.com>; Mark S. Cohen
<mcohen@CohenGresser.com>; Nicole Simmons <nsimmons@hmflaw.com>
Subject: Letter regarding discovery attached.
Dear Counsel,
Please see attached conferral letter.
Jeff
EFTA00021875

=== Page 2 ===
Jeffrey S. Pagliuca
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
jpagliuca@hmflaw.com
www.hmflaw.com
mation that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to
the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing,
distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have
received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its
attachments without reading or saving it in any manner. Thank you
EFTA00021876


c1: EFTA00021371
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021371.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Final Voucher 10416822-1(1) prepared by a travel arranger is pending your review
Date: Wed, 24 Jul 2019 20:23:22 +0000
Importance: Normal
Dear
Final voucher 10416822-1(1) has been prepared by your travel arranger and is ready for your review. Please log
into E2 Solutions to review the document.
Trip ID: 10416822-1
Voucher ID: 1
Voucher type: Final
Traveler name:
Purpose: R19NYS13654 - U.S. V. Epstein (2018R01618) - Victim Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-07-11 - 2019-07-12
Current status: Pending Voucher Approval
Voucher total expenses: 779.97
Estimated trip cost: 1050.66
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0012
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00021371


c1: EFTA00020943
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020943.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Accepted: Conference: Jeffrey Epstein
Date: Wed, 17 Jul 2019 18:02:00 +0000
Importance: Normal
Attachments: unnamed
EFTA00020943


c1: EFTA00023424
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023424.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Page 1 of 4
OGC Electronic Freedom of Information - NYT FOIA request - -- BOP #2, filed 8/13/19
From:
"Ivory, Danielle"
To:
Date:
8/13/2019 5:00 PM
Subject: NYT FOIA request -- BOP #2, filed 8/13/19
Hi, I am enclosing a FOIA request, below. Please let me know if I can be of any help in explaining this
or narrowing it.
Many thanks,
Danielle
Danielle Ivory
Reporter
The New York Times
620 Eighth Avenue
New York, NY 10018
Office phone:
Mobile phone:
Email:
Aug. 13, 2019
Bureau of Prisons
FREEDOM OF INFORMATION ACT REQUEST
Dear FOIA Officer:
Requested records
"Records" means information of any kind, including writings (handwritten, typed, electronic or otherwise
produced, reproduced or stored), letters, memoranda, correspondence, notes, applications, completed
forms, studies, reports, reviews, telephone conversations, faxes, emails, documents, photographs,
EFTA00023424

=== Page 2 ===
Page 2 of 4
minutes of meetings, records of meetings in any form, and any other compilation of data from which
information can be obtained. All of the foregoing are included in this request if they are in the
possession of or otherwise under the New York Times requests for Records of the following type in the
possession, custody, or control of OSHA.
Pursuant to the Freedom of Information Act, 5 U.S.C. Section 552 et seq ("FOIA"), I request copies of
(or access to) documents about Jeffrey Epstein who died at the Metropolitan Correctional Center
(MCC) on Aug. 10, 2019, specifically (hereafter described as "the records"):
(1) All video camera footage at MCC pertinent to the Jeffrey Epstein suicide and the first suicide
attempt.
(2) All BOP documents pertaining to Jeffrey Epstein's suicide and first suicide attempt.
(3) All BOP documents, including email correspondence and meeting minutes, pertaining to the
decision to remove Jeffrey Epstein from suicide watch.
(4) All BOP special investigation reports mentioning Jeffrey Epstein.
(5) All BOP correspondence with the U.S. Attorney's Office regarding Jeffrey Epstein.
The Bureau of Prisons web-based inmate locator shows that only one Jeffrey Epstein is listed in the
BOP system, so identifying the correct Jeffrey Epstein should not be a problem for the bureau. For this
request, records generated by BOP employees based in New York, Texas, and in Washington, DC,
should be searched.
I am a reporter for The New York Times, an accredited and recognized newsgathering organization. I
request the Records to inform the public about matters of public concern.
ONGOING LAW ENFORCEMENT PROCEEDINGS/INVESTIGATIONS
As to any records located in the investigative files of pending investigations, you may not assert
Exemption 7(A) without conducting a document-by-document review to determine whether release of
the records would interfere with ongoing law enforcement proceedings.
The United States District Court of the District of Columbia recently "remind[ed] the FBI of its obligation
to conduct record-level reviews at the administrative level before refusing to produce records contained
in its investigative files." Tipograph V. Dep't of Justice, 83 F. Supp. 2d 234 (D.D.C. Mar. 18, 2015)
In addition, the FOIA Improvement Act of 2016 added a provision instructing federal agencies to
withhold records only when their release would work some foreseeable or is prohibited by law, not just
because they may technically be exempt.
Even if the records might otherwise be exempt, an agency may withhold them only if their disclosure
EFTA00023425

=== Page 3 ===
Page 3 of 4
would actually harm the interest protected by the exemption, or if it is prohibited by some other law. 5
U.S.C 552(a)(8). The agency does need to identify what reasonably foreseeable harm would flow from
release of the information being withheld, consider partial disclosure of the information, take reasonable
steps to segregate and release nonexempt information.
RESPONSE TIME
FOIA requires that your agency respond to this request within 20 business days. This request is
segregable, and your agency may not withhold entire records because of one section that you believe
is exempt from disclosure. Under federal law, if you choose to withhold any such parts of the records
from disclosure, you must specify in a written response the factual and legal basis for withholding any
part of the Records.
ESTIMATED DATE OF COMPLETION
I respectfully request that you provide me with a reasonably estimated date of completion. See 5 U.S.C.
$ 552(a)(7)(B)(ii). If the estimated date of completion is being significantly delayed because of a portion
of the request needs to be processed by another agency, please inform me which agency that is and
whether it has provided you with an estimated date of completion.
FORMAT OF REQUESTED RECORDS
I am further requesting that the Records be provided to me on computer files in the same format as
they are currently maintained at the agency, pursuant to Burka V. Dept. of Health & Human Svcs., 87
F.3d 508 (D.C. Cir. 1996). As you know, providing documents electronically is cheaper than mailing
hard copies.
FEE WAIVER
I respectfully request that you waive all fees in connection with this request as provided by 5 U.S.C. $
552(a)(4)(A)(iii). FOIA was designed to provide citizens a broad right to access government records.
FOIA's basic purpose is to "open agency action to the light of public scrutiny," with a focus on the
public's "right to be informed about what their government is up to." U.S. Dep't of Justice V. Reporters
Comm. For Freedom of Press, 489 U.S. 749, 773-74 (1989) (internal quotation and citations omitted).
In order to provide public access to this information, FOIA's fee waiver provision requires "[d]ocuments
shall be furnished without any charge or at a [reduced] charge
disclosure of the information is in the
public interest because it is likely to contribute significantly to public understanding of the operations or
activities of the government and is not primarily in the commercial interest of the requester." 5 U.S.C. $
EFTA00023426

=== Page 4 ===
Page 4 of 4
552(a)(4)(A)(iii).
EXPEDITED PROCESSING
There is extreme public interest in records concerning the prison stay and death of Jeffrey Epstein, who
was accused of sexually abusing scores of women and underage girls. Not only has a person died in
federal custody, but the death has generated multiple conspiracy theories implicating government
works at the highest levels and taxpayer money. Disclosure of the records request is in the public
interest because disclosure is likely to contribute significantly to the understanding of the operations or
activities of the government. In addition, as one of the largest circulation newspapers in the United
States, The New York Times plays an important role in sharing information with the public and helping
the public understand how the federal government works. Disclosure of the records is not primarily in
the commercial interest of myself or The New York Times but is intended to facilitate reporting on the
operations of government.
Please contact me if I may assist in your office's response to this request.
Yours,
Danielle Ivory
Danielle Ivory
The New York Times
Office:
Cell:
Fax:
Signal encrypted chat:
EFTA00023427


c1: EFTA00021710
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021710.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Bcc:
Subject: RE: Request re Ghisliane Maxwell
Date: Fri, 08 Jan 2021 17:01:50 +0000
Embedded: RE:_Request_re_Ghisliane_Maxwell.msg
Sender:
Subject: RE: Request re Ghisliane Maxwell
Message-Id: <5FF88FF5020000920008C47B@SMTP1.BOP.GOV>
Recipient:
EFTA00021710


c1: EFTA00023045
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023045.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
STATE
STATE
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
July 21, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These discovery materials
are stamped with control numbers SDNY_GM_02753552 through SDNY_GM_02759392.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential
Designation
SDNY_GM_02753552
SDNY_GM_02759392
FedEx Records
Confidential
EFTA00023045

=== Page 2 ===
Page 2
The Government recognizes that its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials.
Very truly yours,
United States Attorney
by:
Assistant United States Attorneys
EFTA00023046


c1: EFTA00021648
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021648.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: protective order
Date: Wed, 24 Jul 2019 20:36:34 +0000
Attachments: 2019-07-24,_JE,_protective_order_for_discovery_(RMB).docx
Sorry, one additional change, updated version attached.
From:
Sent: Wednesday, July 24, 2019 4:18 PM
To:
Subject: protective order
The new language is highlighted-let me know if you're good with this to go out.
Thanks!
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00021648


c1: EFTA00021699
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021699.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Haddon, Morgan and Foreman, P.C
Laura A. Menninger
HADDON
150 East 10th Avenue
Denver, Colorado 80203
MORGAN
PH 303.831.7364 FX 303.832.2628
FOREMAN
www.hmflaw.com
LMenninger@hmflaw.com
March 8, 2021
VIA EMAIL
United States Attorney's Office
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Request to view physical evidence, "highly confidential" materials and scenes
Dear Counsel:
I write to formally request an opportunity to (a) view, inspect, and document the physical
evidence seized and held in connection with this case, (b) view and inspect all materials
designated by your office as "Highly Confidential" under the terms of the Protective Order,
and (c) visit, document and inspect any physical scene where you allege illegal conduct
occurred, to include the Epstein properties for which you included photographs in the
Superseding Indictment.
Counsel for Ms. Maxwell and our investigator(s) are available for purposes of reviewing the
physical evidence and Highly Confidential materials on March 17-18, 2021. Given the
volume of materials seized, we anticipate that the evidence view may take more than one eight
(8) hour session to complete and we ask that you plan accordingly. We request that Ms.
Maxwell be present and able to participate in that evidence view.
If you have a log of all evidence seized in connection with this case, we ask that you provide
it to us in advance of the evidence-view so that we may bring the appropriate equipment to
document the items as necessary.
With regard to the scene visits, we are open to discussing dates and times for those to occur
over the next month. Please contact me with your proposal. We will need to make
appropriate travel arrangements.
EFTA00021699

=== Page 2 ===
Ms. Comey, Moe and Pomerantz
March 6, 2021
Page 2
If you have any questions, please do not hesitate to contact me.
Respectfully submitted,
Jan Laura A. Menninger a.
CC: Counsel of Record via Email
EFTA00021700


c1: EFTA00023458
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023458.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
BOBBI C STERNHEIM
Cc: Christian Everdell
Subject: Re: [EXTERNAL] URGENT: Ghislaine Maxwell 02879-509
Date: Fri, 29 Oct 2021 16:38:40 +0000
There was mail picked up today.
>>> BOBBI C STERNHEIM
10/29/2021 11:50 AM
Further my earlier email today, as of 10:30 a.m., USPO tracking lists
the following 4 items of legal mail
"Available for Pickup" and does not indicate that MDC has retrieved or
received them.
Ms. Maxwell has not received legal mail in more than a week.
Please confirm IMMEDIATELY the status of these items on your end.
Failure to response today will result in the filing of an order to show
cause requiring your presence in Court.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10007
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.
V
>
V
V
V
> Isabel Maxwell, Paralegal, Leah Saffian, Inc.
> LAW OFFICES OF LEAH SAFFIAN; LEAH SAFFIAN BA JD LLM
LOS ANGELES, CA 90025, USA
V
EFTA00023458

=== Page 2 ===
> NOTICE: The information transmitted by this email is intended only
for the person or entity to which it is addressed. This email may
contain proprietary, business-confidential and/or legally privileged
material. If you are not the intended recipient of this message, be
aware that any use, review, retransmission, distribution, reproduction
or any action taken in reliance upon this message is strictly
prohibited. If you received this in error, please contact the sender
Isabel Maxwell at Tel
and delete the material from all
computers.
EFTA00023459


c1: EFTA00023039
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023039.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: Undisclosed recipients:;
Bec:
Subject: ORGANIZED CRIMES - METALS MANIPULATION, FRAUDULENT AUDITS: DEUTSCHE
ET AL - MAFIA - PAEDOPHILIA - JEFFREY EPSTEIN
Date: Sat, 27 Jul 2019 15:54:21 +0000
This audio is well worth listening to. It discloses many intricate details about global organized
crime; regulatory, judicial, and political corruption; child trafficking, and other crimes. Also, Jeffrey
Epstein's alleged connection to the British government.
https://www.youtube.com/watch?v=qMpfx_aMpFg&feature=youtu.be
EFTA00023039


c1: EFTA00021980
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021980.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Nathan NYSD Chambers
Cc:
(USANYS)"
)"
=
)"
"
Subject: United States V. Maxwell, 20 Cr. 330, juror questionnaires
Date: Mon, 08 Nov 2021 02:45:19 +0000
Attachments: 2021-11-07_joint_letter_regarding_juror_questionnaires.final.pdf.
Chambers,
Attached please find a joint letter regarding prospective juror questionnaires.
Respectfully submitted,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00021980


c1: EFTA00023500
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023500.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
)"
Cc:
(USANYS)"
Subject: RE: Question re SDFL Epstein file
Date: Thu, 18 Feb 2021 00:55:10 +0000
We are on a 25% work schedule in the office. I have sent an email to
to see if she can drive in and find the
document in question. I expect she will check her email in the morning, so l'll let you know then. You should hear
something before 12:00 p.m.
Good luck.
From:
Sent: Wednesday, February 17, 2021 7:53 PM
To:
;
Cc:
(USANYS)
Subject: RE: Question re SDFL Epstein file
Hi
Yes, this would be included in the files you provided, but unfortunately, we have been having a lot of trouble reviewing
the scans that were provided to us by the vendor. Our tech folks are still working out the bugs, so we are not able to
quickly look for this document. We'd be very grateful if
would be able to pull just this document and send it to us,
please.
Thanks very much,
From:
Sent: Wednesday, February 17, 2021 7:50 PM
To:
Cc:
is
(USANYS)
Subject: RE: Question re SDFL Epstein file
Hi
:
I reached out to
about this, who has been keeping track of these files. Isn't this something that you all
would have a copy of from when you scanned our files? Just trying to track it down.
From:
Sent: Wednesday, February 17, 2021 7:45 PM
To:
Cc:
is
(USANYS)
Subject: Question re SDFL Epstein file
Hi
Hope you're doing well. We have a small follow-up question about the Jeffrey Epstein file. I'm attaching a privilege log
filed by your office in connection with the CVRA lawsuit. We were hoping you might be able to send us the item on page 5
of the log, which has the following description:
The log gives the following identifiers for the document: "Box #1 P-003679 Thru P-
003680."
Thanks very much - we're currently briefing an issue relating to this, so we really appreciate your help.
Best,
Assistant United States Attorney
Southern District of New York
EFTA00023500

=== Page 2 ===
EFTA00023501


c1: EFTA00022086
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022086.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: "Berman, Geoffrey (USANYS)"
Subject: RE:
Date: Wed, 15 Apr 2020 14:38:43 +0000
I'll check the complaint/other sources beyond NYT.
Original Message
From: Berman, Geoffrey (USANYS)
Sent: Wednesday, April 15, 2020 10:38 AM
To:
Subject: Re:
So massaging her chest is as explicit as it gets? What about her complaint?
> On Apr 15, 2020, at 10:24 AM,
wrote:
>
>
In the article version accompanying the daily it is written like this:
(
)
>
>
also recalled Ms. Maxwell repeatedly asking whether she wanted a massage. Eventually relenting,
followed directions by taking off her clothes and bra and getting under a sheet on a massage table.
Ms. Maxwell performed the massage, at one point having
lie on her back as Ms. Maxwell pulled
down the sheet to massage her chest.
V
> "I don't think there was any reason for her to be touching me that way,"
said.
V
>
Original Message
> From:
> Sent: Wednesday, April 15, 2020 10:23 AM
> To: Berman, Geoffrey (USANYS)
> Subject: RE:
>
> From the daily:
)
>
> Mike Baker
V
then remembers Ghislaine repeatedly asked whether -
V
V
>
Have you ever gotten a massage?
V
> Mike Baker
V
wanted a massage.
V
>
V
I'm very skilled in massage, right, and so I want to make sure you get a massage.
V
> Mike Baker
V
She said that she was very -
V
EFTA00022086

=== Page 2 ===
>
>
She was skilled in massage. Yeah.
V
> Mike Baker
V
And she eventually relents.
>
>
> But I had never had a professional massage before. So I didn't know what really was involved in that. And so
she said that I would take off my clothes and lay under the sheet.
>
> Mike Baker
>
Ghislaine performs the massage.
>
>
>
She had me, you know, flip over to my back. And then she pulled the sheet down so that my breasts were
exposed.
V
> Mike Baker
> And she remembers how Ghislaine then went on to massage her chest.
V
>
>
Like it just - this feels weird. This feels uncomfortable. I don't think this is probably right, but I don't know.
V
> Mike Baker
> And all this time, she's struggling to figure out what's going on. Jeffery Epstein, she says, wasn't participating
in the massage. But she has this sense that he's in the area, that the doors are open, it's kind of an open area where
she's getting the massage.
> Sent: Wednesday, April 15, 2020 10:08 AM
> > > > > > > > >
I could feel his presence, like, oh, I'm sure he can see me from where he is.
Original Message
From: Berman, Geoffrey (USANYS)
> To:
> Subject:
> Can you resend me the
quote from NYT about Maxwell massaging her breasts.
EFTA00022087


c1: EFTA00023161
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023161.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Epstein-related Touhy request
Start Date: 2020-05-18 18:00:00 +0000
End Date: 2020-05-18 18:30:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-05-15 23:04:19 +0000
Date Modified: 2020-05-15 23:04:19 +0000
Priority: 5
DTSTAMP: 2020-05-15 22:47:27 +0000
Attendee:
(USANYS)
EFTA00023161


c1: EFTA00022057
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022057.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Subject: FW: Epstein Image/Video File Review Protocol
Date: Tue, 20 Oct 2020 16:57:12 +0000
Attachments:2020-06-26,_search_warrant_application,_20_mag_6719.pdf,2020-06-
26,_search_warrant,_20_mag_6719.pdf;
2020.10.19_Epstein_devices_responsivenes_review_protocol_-_image_&_video_files.pdf;
Maxwell_Superseding_Indictment_-_S1_20_Cr_330_(AJN)_(docketed).pdf
Hi
Has the FBI team been able to start this review yet? Is there a time when I can hop onto a phone call with you and them
just to make sure we're all on the same page, please?
Thanks so much,
From:
)
Sent: Monday, October 19, 2020 4:08 PM
To:
is
is
is
)
is
Cc:
is
(
Subject: Epstein Image/Video File Review Protocol
All,
Attached please find the review protocol for the image and video files from Epstein's devices. The protocol asks that all
reviewers read the warrant and supporting affidavit, which are both attached here as well. I am also attaching a copy of
the Maxwell indictment, which contains a photograph of Epstein and Maxwell.
Once the USAO and FBI review teams are assembled, please let me know when would be a good time for me to have a
call with them to talk through the review and answer any questions.
In the first instance, we would ask that the FBI team review the following devices:
NYC024363
NYC024394
NYC024326
NYC024368
NYC024390
NYC024334
NYC027910
NYC024323
NYC024355
NYC027908
Depending on how quickly the FBI and USAO teams move through the review, we may reassign some devices between the
teams.
EFTA00022057

=== Page 2 ===
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00022058


c1: EFTA00020702
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020702.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Jeffrey Epstein
Date: Tue, 09 Jul 2019 17:01:39 +0000
Importance: Normal
You are a mess
From:
Sen
To:
Subject: RE: Jeffrey Epstein
lol - maybe he can play him in the inevitable lifetime movie
From:
Sent
11:26
To:
Subject: RE: Jeffrey Epstein
Well he can pass for his twin because he looks just like him
From:
Sent: Tuesday, July 09, 2019 11:35 AM
To:
Subject: RE: Jeffrey Epstein
I don't think so! He's a rich finance guy
From:
Sent: Tuesday, July 09, 2019 11:34
To:
Subject: Jeffrey Epstein
Is this the guy from NCIS?
EFTA00020702


c1: EFTA00022391
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022391.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UBS Financial Services Inc.
Private Wealth Management
UBS
299 Park Avenue
25th Floor
Resource Management Account
New York NY 10171-0002
November 2016
CNP7005535545 1116X135 Y1 0
GHISLAINE MAXWELL
P.O. BOX 308
TEANECK NJ 07666-0308
Account name: GHISLAINE MAXWELL
Friendly account name: .Q52167006
Account number:
Your Financial Advisor:
SCOTT STACKMAN/LYLE CASRIEL
Phone: 212-821-7000/800-308-3140
Questions about your statement?
Call your Financial Advisor or the
Value of your account
RMA ResourceLine at 800-RMA-1000,
on October 31 ($)
on November 30 ($)
account 029023574
Your assets
1,135,630.52
772.39
Visit our website:
Your liabilities
0.00
0.00
www.ubs.com/financialservices
Value of your account
$1,135,630.52
$772.39
Accrued interest in value above
$3,566.38
$0.00
Sources of your account growth
Tracking the value of your account
during 2016
Value of your account
$ Thousands
at year end 2015
$1,311,717.81
1,584.3
Net deposits and
withdrawals
1,311.7
-$1,366,602.20
1,135.6
Your investment return:
Dividend and
interest income
$59,045.75
Change in value of
accrued interest
-$5,178.88
0.8
Change in
Dec 2014
Dec 2015
market value
Oct 2016
$1,789.91
Nov 2016
Value of your account
on Nov 30, 2016
$772.39
Member SIPC
CNP70008005535545 NP7000185219 00004 1116 030575004 Y123574550 101010
Page 1 of 8
EFTA00022391

=== Page 2 ===
UBS
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
November 2016
Friendly account name Indiv. 052167006
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Your account balance sheet
Summary of your assets
Value on
Percentage of
November 30 ($)
your account
A
Cash and money balances
772.39
100.00%
Your current asset allocation
B
Cash alternatives
0.00
0.00%
C
Equities
0.00
0.00%
D
Fixed income
0.00
0.00%
E
Non-traditional
0.00
0.00%
F
Commodities
0.00
0.00%
G
Other
0.00
0.00%
Total assets
$772.39
100.00%
A
Value of your account
$772.39
Eye on the markets
Percentage change
Index
November 2016
Year to date
S&P 500
3.70%
9.79%
Russell 3000
4.48%
10.58%
MSCI- - Europe, Australia & Far East
-1.98%
-1.86%
Barclays Capital U.S. Aggregate Bond Index
-2.37%
2.50%
Interest rates on November 30, 2016
3-month Treasury bills: 0.48%
One-month LIBOR: 0.62%
CNP70008005535546 NP7000185219 00004 1116 030575004 Y123574550 101010
Page 2 of 8
EFTA00022392

=== Page 3 ===
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
UBS
Friendly account name; Indiv O52167006
November 2016
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Change in the value of your account
Dividend and interest income earned
November 2016 ($)
Year to date ($)
For purposes of this statement, taxability of interest and dividend income has been determined from a US
Opening account value
$1,135,630.52
$1,311,717.81
tax reporting perspective. Based upon the residence of the account holder, account type, or product type,
some interest and/or dividend payments may not be subject to United States (US) and/or Puerto Rico (PR)
Deposits, including investments
income taxes. The client monthly statement is not intended to be used and cannot be relied upon for tax
transferred in
purposes. Clients should refer to the applicable tax reporting forms they receive from UBS annually, such as
0.00
8,340.00
the Forms 1099 and the Forms 480, for tax reporting information It is the practice of UBS to file the
applicable tax reporting forms with the US Internal Revenue Service and PR Treasury Department, and in
Withdrawals and fees,
such forms accurately classify dividends and/or interest as tax exempt or taxable income. Please consult your
including investments transferred
individual tax preparer.
out
-1,149,960.69
-1,374,942.20
November 2016 ($)
Year to date ($)
Dividend and interest income
4,993.84
59,045.75
Taxable dividends
0.00
7,202.28
Change in value of accrued
interest
-3,566.38
-5,178.88
Long-term capital gains
160.27
160.27
Change in market value
13,675.10
1,789.91
Taxable interest
4,537.51
42,495.89
Closing account value
$772.39
$772.39
Tax-exempt interest
0.00
7,500.00
Miscellaneous
296.06
1,687.31
Total current year
$4,993.84
$59,045.75
Total dividend & interest
$4,993.84
$59,045.75
Summary of gains and losses
Values reported below exclude products for which gains and losses are not classified
Realized gains and losses
Unrealized
November 2016 ($)
Year to date ($)
gains and losses ($)
Short term
0.00
586.02
0.00
Long term
0.00
6,027.80
0.00
Total
$0.00
$6,613.82
$0.00
CNP70008005535547 NP7000185219 00004 1116 030575004 Y123574550 101010
Page 3 of 8
EFTA00022393

=== Page 4 ===
UBS
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
Friendly account name: Indiv. O52167006
November 2016
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Cash activity summary
UBS Bank USA Deposit Account APY
See Account activity this month for details. Balances in your Sweep Options are included in the opening and
closing balances value. FDIC insurance applies only to deposits at UBS Bank USA, not to deposits at UBS AG,
Interest period Oct 7 - Nov 6
Stamford Branch or bank deposits placed through the UBS International Deposit Account program. SIPC
protection applies to money market sweep fund holdings but not bank deposits. See important information
Opening UBS Bank USA Deposit balance Oct 7
$0.00
about your statement on the last two pages of this document for details.
Closing UBS Bank USA Deposit balance Nov 6
$1,837.51
November 2016 ($)
Year to date ($)
Number of days in interest period
31
Opening balances
$10,680.70
$541.48
Average daily balance
$989.83
Additions
Interest earned
Deposits and other funds credited
0.00
$0.01
8,340.00
Dividend and interest income
4,993.84
Annual percentage yield earned
0.01%
59,045.75
Proceeds from investment transactions
150,000.00
325,303.76
Total additions
$154,993.84
$392,689.51
Your investment objectives:
Subtractions
You have identified the following investment objectives for this account. If you have questions
about these objectives, disagree with them, or wish to change them, please contact your
Professional management fees and
Financial Advisor or Branch Manager. You can find a full description of the alternative
related services
772.39
-7,528.38
investment objectives in Important information about your statement at the end of this
Other funds debited
document.
-165,674.54
-382,355.28
Funds withdrawn for investments
Your return objective:
bought
0.00
-2,574.94
Current income & capital appreciation
Your risk profile:
Total subtractions
-$164,902.15
-$392,458.60
Primary - Moderate
Investment eligibility consideration - None selected
Net cash flow
-$9,908.31
$230.91
Closing balances
$772.39
$772.39
Your account instructions
Your account cost basis default closing method is FIFO, First In, First Out.
CNP70008005535548 NP7000185219 00004 1116 030575004 Y123574550 101010
Page 4 of 8
EFTA00022394

=== Page 5 ===
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
UBS
Friendly account name: Indiv. Q52167006
November 2016
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Your assets
Some prices, income and current values shown may be approximate. As a result, gains and losses may not
be accurately reflected. See Important information about your statement at the end of this document for
more information.
Cash
Cash and money balances
Opening balance
Closing balance
Price per share
Average
Dividend/Interest
Holding
Days in
on Nov 1 ($)
on Nov 30 ($)
on Nov 30 ($)
rate
period
period
Cap amount ($)
Cash
4,726.37
772.39
UBS BANK USA DEP ACCT
5,954.33
0.00
250,000.00
Total
$10,680.70
$772.39
Your total assets
Percentage of
Cost
Estimated
Unrealized
Value on Nov 30 ($)
your account
basis ($)
annual income ($)
gain or loss ($)
Cash
Cash and money balances
772.39
100.00%
772.39
Total
$772.39
100.00%
$772.39
Account activity this month
Date
Activity
Description
Amount ($)
Dividend and interest income
Long-term capital gains
Nov 14 Lt Cap Gain
BLACKSTONE GROUP LP/THE UNIT REPSTG LTD PARTNERSHIP INT
160.27
Total long-term capital gains
160.27
Taxable interest
Nov 1
Interest
COUNTRYWIDE CAP V 7.000% DUE 11/01/36 CALLABLE PAID ON
4200
1,837.50
CUSIP: 222388209
Nov 7 Interest
UBS BANK USA DEPOSIT ACCOUNT AS OF 11/04/16
0.01
Nov 15 Interest
BANK OF AMER INTERNOTES 03.600% 111516 DTD110410FC051511 NTS
2,700.00
B/E
CUSIP: 06050WDW2
Total taxable interest
$4,537.51
CNP70008005535549 NP7000185219 00004 1116 030575004 Y123574550 101010
Page 5 of 8
EFTA00022395

=== Page 6 ===
UBS
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
Friendly account name: Indiv. O52167006
November 2016
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Account activity this month (continued)
Date
Activity
Description
Amount ($)
Dividend and interest income (continued)
Miscellaneous
Nov 14 Dividend
BLACKSTONE GROUP LP/THE UNIT REPSTG LTD PARTNERSHIP INT PAID ON
7.79
1113
Nov 14 Return
BLACKSTONE GROUP LP/THE UNIT REPSTG LTD PARTNERSHIP INT PAID ON
14.47
Of Capital
1113
Nov 14 Dividend
BLACKSTONE GROUP LP/THE UNIT REPSTG LTD PARTNERSHIP INT
273.80
Total miscellaneous
$296.06
Total dividend and interest income
$4,993.84
Date
Activity
Description
Amount ($)
Fees
Nov 30 Refund
PRORATED ADVISORY FEE
772.39
Total professional management fees
$772.39
Date
Activity
Description
Amount ($)
Other funds debited
Nov 1
Transfer
JOURNAL TO Y1 23575 GHISLAINE MAXWELL
-10,680.70
Nov 28 Transfer
TO Y1 36509 2200
-154,993.84
Total other funds debited
-$165,674.54
Investment transactions
For more information about the price/value shown for restricted securities, see Important information about
your statement at the end of this document.
Proceeds from
Funds
investment
withdrawn for
Date
Activity
Accrued
Description
Quantity
Value ($)
Price ($)
transactions ($)
investments bought ($)
interest ($)
Nov 15
Call
BANK OF AMER INTERNOTES 03.600% 111516
-150,000.000
150,000.00
Redemption
DTD110410 FC051511 NTS B/E
CUSIP: 06050WDW2
Nov 28
Transfer
BIRDVILLE TX INDPT SCH D PREF
BE/R/ 5
-90,000.000
-90,777.60
DUE 021529 DTD 011507 CALLABLE
PRE-REFUNDED TO Y1 36509 2200
CUSIP: 090874LJ5
Nov 28
Transfer
BIRDVILLE TX INDPT SCH D
BE/R/ 5
-10,000.000
-10,082.50
DUE 021529 DTD 011507 CALLABLE TO Y1
36509 2200
CUSIP: 090874LM8
continued next page
CNP70008005535550 NP7000185219 00004 1116 030575004 Y123574550 101010
Page 6 of 8
EFTA00022396

=== Page 7 ===
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
UBS
Friendly account name: Indiv. 052167006
November 2016
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Account activity this month (continued)
Investment transactions (continued)
Proceeds from
Funds
investment
withdrawn for
Date
Accrued
Activity
Description
Quantity
Value ($)
Price ($)
transactions ($)
investments bought ($)
interest ($)
Nov 28
Transfer
MICHIGAN MUN BD AUTH RV
BE/R/ 5
-5,000.000
-5,016.80
DUE 100126 DTD 110206 CALLABLE TO Y1
36509 2200
CUSIP: 59455T485
Nov 28
Transfer
COUNTRYWIDE CAP V 7.000% DUE 11/01/36
-4,200.000
-106,940.40
CALLABLE TO Y1 36509 2200
CUSIP: 222388209
Nov 28
Transfer
CITIGROUP CAPITAL XIII FXD/FLT TRUST PFD
-10,000.000
-259,000.00
7.121% DUE 10/30/2040 TO Y1 36509 2200
CUSIP: 173080201
Nov 28
Transfer
BANK OF AMER CORP TO Y1 36509 2200
-944.000
-19,163.20
Nov 28
Transfer
BLACKSTONE GROUP LP/THE UNIT REPSTG LTD
-1,113.000
-28,726.53
PARTNERSHIP INT TO Y1 36509 2200
Nov 28
Transfer
GENERAL MOTORS CO TO Y1 36509 2200
-1,023.000
-34,833.15
Nov 28
Transfer
SPDR S&P 500 ETF TR TO Y1 36509 2200
-1,257.000
-277,143.36
Nov 28
Transfer
JP MORGAN CHASE & CO 07.900% 042949
-150,000.000
-153,375.00
DTD042308 FC103008 NTS B/E TO Y1 36509
2200
CUSIP: 46625HHA1
Total
$150,000.00
Securities transferred out
-$985,058.54
Date
Activity
Description
Amount ($)
Money balance activities
Oct 31
Balance forward
$5,954.33
Nov 1
Deposit
UBS BANK USA DEPOSIT ACCOUNT
4,726.37
Nov 2
Withdrawal
UBS BANK USA DEPOSIT ACCOUNT AS OF 11/01/16
-8,843.20
Nov 7
Deposit
UBS BANK USA DEPOSIT ACCOUNT AS OF 11/04/16
0.01
Nov 15
Deposit
UBS BANK USA DEPOSIT ACCOUNT
456.33
Nov 16
Deposit
UBS BANK USA DEPOSIT ACCOUNT
152,700.00
Nov 29
Withdrawal
UBS BANK USA DEPOSIT ACCOUNT AS OF 11/28/16
-154,993.84
Nov 30
Closing UBS Bank USA Deposit Account
$0.00
The UBS Bank USA Deposit Account is your primary sweep option.
CNP70008005535551 NP7000185219 00004 1116 030575004 Y123574550 101010
Page 7 of 8
EFTA00022397

=== Page 8 ===
UBS
Resource Management Account
Account name:
GHISLAINE MAXWELL
Your Financial Advisor:
Friendly account name: Indiv. Q52167006
November 2016
SCOTT STACKMAN/LYLE CASRIEL
Account number:
212-821-7000/800-308-3140
Realized gains and losses
The estimated realized gains and losses shown below are not for tax purposes. Please note that gain or loss
information We may not adjust gains and losses for all capital changes. We automatically adjust cost basis for
recognized on the sale or redemption of certain Structured Products, like Contingent Debt Securities, may be
tax-exempt and AMT coupon municipal securities for estimated amortization of bond premiums and for accreted OID
ordinary, and not capital, gain or loss. Please check with your tax advisor. To calculate gains and losses, we
for securities issued at a discount. If you requested that UBS adjust cost basis for the bond premium amortization on
liquidate the oldest security lot first. This is known as the first-in, first-out or FIFO accounting method We use
taxable debt securities then cost basis reflected for these securities has been adjusted. Estimates in the Unclassified
this method unless you specified which tax lot to close when you placed your order. This is known as a versus
section can not be classified as short term or long term because information is missing, or the product is one in which
purchases or VSP order. See important information about your statement at the end of this document for more
the gain/loss calculation is not provided.
Long-term capital gains and losses
Wash sale
Quantity or Purchase
Sale
Sale
Cost
cost basis
Security description
Method
face value date
date
amount ($)
basis ($)
adjustment($)
Loss ($)
Gain ($)
BANK OF AMER INTERNOTES
03.600% 111516 DTD110410
FC051511 NTS B/E
FIFO
150,000.000 Nov 01, 10
Nov 15, 16
150,000.00
150,000.00
CNP70008005535552 NP7000185219 00004 1116 030575004 Y123574550 101010
Page 8 of 8
End of statement for account number Y1 23574 S5
EFTA00022398


c1: EFTA00021523
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021523.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Final Voucher 10416822-1(1) has received final approval
Date: Tue, 30 Jul 2019 11:02:41 +0000
Importance: Normal
Dear
Final voucher 10416822-1(1) has received final approval.
Trip ID: 10416822-1
Voucher ID: 1
Voucher type: Final
Traveler name:
Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104)
Purpose: R19NYS13654 - U.S. V. Epstein (2018R01618) - Victim Interviews
Destination: West Palm Beach, FL, United States
Dates: 2019-07-11 - 2019-07-12
Current status: Voucher Awaiting Payment
Voucher total expenses: 779.97
Estimated trip cost: 1050.66
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# V0008
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00021523


c1: EFTA00023329
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023329.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:20-cr-00330-AJN Document 64 Filed 10/14/20 Page 1 of 6
CG
800 Third Avenue
COHEN & GRESSER LLP
New York, NY 10022
+1 212 7600 phone
www.cohengresser.com
Christian R. Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
October 14, 2020
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write on behalf of our client, Ghislaine Maxwell, in opposition to the government's
October 6, 2020 letter requesting the Court's permission to delay the disclosure of photographs
and documents relating to certain alleged victims of sexual abuse by Jeffrey Epstein (the
"Materials"), pursuant to Rule 16(d)(1) of the Federal Rules of Criminal Procedure. (Dkt. 60).
The government's request should be denied for two reasons.
First, it is clear from the government's letter that the Materials pertain to individuals who
claim to have been "sexually abused by [Jeffrey] Epstein" (id. at 2), but who have not accused Ms.
Maxwell of participating in or facilitating that conduct in any way. Accordingly, the Materials
identifying these witnesses and their prior statements are exculpatory evidence, which must be
disclosed pursuant to the government's obligations under Brady V. Maryland, 373 U.S. 83 (1963)
and its progeny. 1
Second, the Court should order the government to disclose the Materials under Rule 16
because the Materials are "material to preparing the defense" and the government has not shown
good cause to delay production of the Materials under Rule 16(d)(1).
I
We note that yesterday we sent the government a letter making specific Brady requests, including "[a]ny statements
or written communications made by any witness who has alleged that she was sexually abused or assaulted by Mr.
Epstein, but has not alleged that Ms. Maxwell participated in, was involved in, or facilitated the alleged sexual abuse."
EFTA00023329

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 64 Filed 10/14/20 Page 2 of 6
The Honorable Alison J. Nathan
October 14, 2020
Page 2
A. Applicable Law
1. Brady
"Under Brady and its progeny, 'the Government has a constitutional duty to disclose
favorable evidence to the accused where such evidence is 'material' either to guilt or to
punishment." United States V. Certified Envtl. Servs., Inc., 753 F.3d 72, 91 (2d Cir. 2014)
(quoting United States V. Coppa, 267 F.3d 132, 139 (2d Cir. 2001)). "Favorable evidence" that
must be disclosed for purposes of Brady "includes not only evidence that tends to exculpate the
accused, but also evidence that is useful to impeach the credibility of a government witness," id.,
also known as "Giglio material," as well as any statements of witnesses "which are contradictory
or inconsistent with the government's theory of the case." United States V. Harris, No. 00 Cr. 105
(RPP), 2000 WL 1273720, at *2 (S.D.N.Y. Sept. 7, 2000) (citing Kyles V. Whitley, 514 U.S. 419
(1995).
2. Rule 16
Rule 16 provides, in pertinent part:
Upon a defendant's request, the government must permit the
defendant to inspect and to copy or photograph books, papers,
documents, data, photographs, tangible objects, buildings or
places, or copies or portions of any of these items, if the item is
within the government's possession, custody, or control and
the
item is material to preparing the defense[.]
Fed. R. Crim. P. 16(a)(1)(E). Evidence is material under Rule 16 if it "could be used to counter
the government's case or to bolster a defense." United States V. Stevens, 985 F.2d 1175, 1180 (2d
Cir. 1993). "The materiality standard [of Rule 16] normally is not a heavy burden; rather,
evidence is material as long as there is a strong indication that it will play an important role in
uncovering admissible evidence, aiding witness preparation, corroborating testimony, or assisting
impeachment or rebuttal." United States V. Stein, 488 F. Supp. 2d 350, 356-57 (S.D.N.Y. 2007)
(quoting United States V. Lloyd, 992 F.2d 348, 351 (D.C. Cir. 1993) (internal quotation marks
omitted)).
Rule 16(d)(1) provides that a party may seek a protective order from the court to "deny,
restrict, or defer discovery" upon a showing of "good cause." Fed. R. Crim. P. 16(d)(1). To
establish good cause, the party must show "that disclosure will result in a clearly defined, specific
and serious injury." United States V. Smith, 985 F. Supp. 2d 506, 523 (S.D.N.Y. 2013) (citations
omitted). A finding of harm "must be based on a particular factual demonstration of potential
harm, not on conclusory statements." Id. (citations omitted).
EFTA00023330

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 64 Filed 10/14/20 Page 3 of 6
The Honorable Alison J. Nathan
October 14, 2020
Page 3
B. Discussion
1. The Materials Are Subject to Disclosure Under Brady Because They Refute the
Government's Theory of the Charged Crimes
The government states that, as part of its "broader investigation into Epstein's sexual abuse
of minors," it interviewed "dozens" of alleged victims of Epstein's sexual abuse and obtained
sensitive documents and photographs from certain alleged victims who claim they were assaulted
after 1997 - i.e., after the end of the time period charged in Counts One through Four of the
superseding indictment (the "Indictment"). (Dkt. 60 at 2). Stated differently, the government has
interviewed and collected evidence from numerous witnesses who have never asserted that Ms.
Maxwell participated in Epstein's alleged sexual abuse, or "groomed" them for Epstein, or had
anything whatsoever to do with any episode of sexual abuse they may have experienced.
Although the government represents that these women were sexually abused by Epstein after the
time period charged in Counts One through Four of the Indictment, this evidence is still
fundamentally inconsistent with the government's theory that Ms. Maxwell was Epstein's
"madam" and the principal facilitator of his sexual abuse scheme.
Furthermore, this evidence directly contradicts the government's theory of the perjury
counts. The government insists that the Materials are irrelevant to the charges in the Indictment
because they relate to instances of sexual abuse that took place after 1997, and therefore "post-date
the time period charged in the Indictment." (Dkt. 60 at 2). That is incorrect. The government
forgets that it chose to put at issue Epstein's sexual abuse that occurred after 1997 when it
included the perjury counts in the Indictment.
The perjury counts stem from a defamation suit brought against Ms. Maxwell in 2015 by
one of Epstein's alleged victims ("Accuser-1"). In December 2014, Accuser-1 filed a motion to
join a lawsuit challenging the validity of Epstein's Non-Prosecution Agreement executed in 2007.
Accuser-1's motion "described Maxwell's role as one of the main women who Epstein used to
procure under-aged girls for sexual activities and a primary co-conspirator and participant in his
sexual abuse and sex trafficking scheme." ([Accuser-1] V. Maxwell, 15-CV-07433 (RWS)
(S.D.N.Y.), Dkt. 1 at 27). Ms. Maxwell publicly denied Accuser-1's allegations, claiming that
they were untrue. Accuser-1, in turn, claimed that these statements were defamatory and sued Ms.
Maxwell.
Counts Five and Six allege that Ms. Maxwell lied at two different depositions in this case.
The scope of these depositions was not limited to the 1994-1997 timeframe. On the contrary, Ms.
Maxwell was asked questions about, among other things, her knowledge of Epstein's sexual
activities in general. Whether Ms. Maxwell knew about Epstein's sexual abuse after 1997 is
therefore directly relevant to whether she lied at these depositions.
EFTA00023331

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 64 Filed 10/14/20 Page 4 of 6
The Honorable Alison J. Nathan
October 14, 2020
Page 4
For example, Count Five alleges that Ms. Maxwell lied in the following exchange:
Q: Did Jeffrey Epstein have a scheme to recruit underage girls for sexual
massages? If you know.
A: I don't know what you're talking about.
Similarly, Count Six alleges that Ms. Maxwell lied in the following exchange:
Q: Other than yourself
with whom did Mr. Epstein have sexual activities?
A: I wasn't aware that he was having sexual activities with anyone when I was
with him other than myself.
Q: I want to make sure that I'm clear. Is it your testimony that in the 1990s and
2000s, you were not aware that Ms. Epstein was having sexual activities with
anyone other than yourself
?
A: That is my testimony, that is correct.
The government has spoken to numerous individuals who claim to have been assaulted by Epstein
after 1997, but do not implicate Ms. Maxwell in the assault or claim that she knew about it in any
way. That bolsters Ms. Maxwell's defense that she was not aware of either Epstein's scheme to
recruit and sexually abuse underage girls, or that Epstein was engaging in sexual activities with
others, and therefore did not perjure herself in response to those questions.
Accordingly, the Materials and the prior statements of the witnesses to whom they pertain
are exculpatory evidence inconsistent with the government's theory of the charges in the
Indictment and must be disclosed pursuant to the government's Brady obligations.
2. The Government Has Not Shown Good Cause that Disclosure of the Materials Will
Interfere with an Ongoing Investigation
Even if the Court does not find this evidence to be exculpatory, the Materials are "material
to preparing the defense" and therefore should be disclosed under Rule 16(a)(1)(E). The
government agrees that the Materials should be produced, but asserts that there is good cause to
delay the production of the Materials until eight weeks before trial, pursuant to Rule 16(d). (Dkt.
60 at 2-3). The government's justification for the delay, however, is entirely inadequate to
establish good cause.
The government asserts that disclosing the Materials will prematurely reveal to the defense
the identities of certain victims of Epstein who are not referenced in the Indictment, as well as
EFTA00023332

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 64 Filed 10/14/20 Page 5 of 6
The Honorable Alison J. Nathan
October 14, 2020
Page 5
sensitive information about them. (Id.). The government further asserts that such disclosure will
"jeopardize the government's ongoing investigation" because it will reveal to the defendant the
scope of the government's investigation and may deter other alleged victims from coming forward
to provide evidence. (Id. at 1, 3). Essentially, the government is arguing that disclosure of the
Materials should be delayed because it would rather not let Ms. Maxwell know, at this stage of the
proceedings, who the government spoke to, and because it is concerned that other people might
not come forward to provide additional evidence against Ms. Maxwell.
These are not the sorts of concerns that courts have found may jeopardize an ongoing
investigation and establish good cause for delaying disclosure. Courts typically allow delayed
disclosure on these grounds when immediate disclosure may alert other potential targets of the
investigation that they are being investigated or may identify individuals who are proactively
cooperating with the government to gather evidence against other potential targets. The cases
cited in the government's own letter make this clear. See Smith, 985 F. Supp. 2d at 531-32
(disclosure of certain discovery materials might "alert the targets of the investigation and could
lead to efforts by them to frustrate the ongoing investigations"); United States V. Mennino, 480 F.
Supp. 1182, 1188 (S.D.N.Y. 1979) (government's ongoing investigation into other potential
defendants could be disrupted by disclosure of certain discovery materials). Similarly, courts
often grant protective orders in this context when the government has made a sufficient showing
that disclosure may lead to witness intimidation or threats to their safety. See United States V.
Urena, 989 F. Supp. 2d 253, 262-63 (S.D.N.Y. 2013) (collecting cases).
The government has done neither here. The government has not made any showing that
disclosure would thwart an ongoing investigation into other potential targets, or would jeopardize
the safety of any potential witnesses. Instead, the government asserts a speculative and self-
serving concern that disclosure of the Materials it might make it more difficult to recruit additional
witnesses for its existing case against Ms. Maxwell. That is not the type of "clearly defined,
specific and serious injury" that establishes good cause to delay disclosure under Rule 16(d)(1).
For the foregoing reasons, the Court should deny the government's requested relief under
Rule 16(d)(1) and instead order the government to immediately produce the Materials and the
prior statements of these witnesses to the defense.
Sincerely,
/s/ Christian Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
EFTA00023333

=== Page 6 ===
Case 1:20-cr-00330-AJN Document 64 Filed 10/14/20 Page 6 of 6
The Honorable Alison J. Nathan
October 14, 2020
Page 6
cc:
Mark S. Cohen, Esq.
Jeff Pagliuca, Esq.
Laura Menninger, Esq.
Bobbi C. Sternheim, Esq.
EFTA00023334


c1: EFTA00021252
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021252.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
:
UNITED STATES OF AMERICA
:
INDICTMENT
:
- V. -
:
19 Cr.
:
JEFFREY EPSTEIN,
:
:
Defendant.
:
:
X
The Grand Jury charges:
OVERVIEW
1. As set forth herein, over the course of many years,
JEFFREY EPSTEIN, the defendant, sexually exploited and abused
dozens of minor girls at his homes in Manhattan, New York, and
Palm Beach, Florida, among other locations.
2.
In particular, from at least in or about 2002, up to
and including at least in or about 2005, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
recruited, minor girls to visit his mansion in Manhattan, New
York (the "New York Residence") and his estate in Palm Beach,
Florida (the "Palm Beach Residence") to engage in sex acts with
him, after which he would give the victims hundreds of dollars
in cash. Moreover, and in order to maintain and increase his
supply of victims, EPSTEIN also paid certain of his victims to
recruit additional minor girls to be similarly abused by
EPSTEIN. In this way, EPSTEIN created a vast network of
EFTA00021252

=== Page 2 ===
underage victims for him to sexually exploit, often on a daily
basis, in locations including New York and Palm Beach.
3.
The victims described herein were as young as 14 years
old at the time they were abused by JEFFREY EPSTEIN, the
defendant, and were, for various reasons, often particularly
vulnerable to exploitation. Moreover, EPSTEIN, who
intentionally sought out minors, knew that many of victims were
in fact under the age of 18, including because, in some
instances, victims expressly told him that they were underage.
4. In creating and maintaining this network of minor
victims in multiple states to sexually abuse and exploit,
JEFFREY EPSTEIN, the defendant, worked with others, including
employees and associates who facilitated his conduct by, among
other things, contacting victims and scheduling their sexual
encounters with EPSTEIN at the New York Residence and at the
Palm Beach Residence.
FACTUAL BACKGROUND
5.
During all time periods charged in this Indictment,
JEFFREY EPSTEIN, the defendant, was a financier with multiple
residences in the continental United States, including the New
York Residence and the Palm Beach Residence.
6.
Beginning in at least 2002, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
recruited, dozens of minor girls to engage in sex acts with him,
2
EFTA00021253

=== Page 3 ===
after which EPSTEIN paid the victims hundreds of dollars in
cash, at the New York Residence and the Palm Beach Residence.
7.
In both New York and Florida, JEFFREY EPSTEIN, the
defendant, perpetuated this abuse in similar ways. Victims were
initially recruited to provide "massages" to EPSTEIN, which
would be performed nude or partially nude, became increasingly
sexual in nature, and would typically include one or more sex
acts. EPSTEIN paid his victims hundreds of dollars in cash for
each encounter. Moreover, EPSTEIN actively encouraged certain
of his victims to recruit additional minor girls to be similarly
sexually abused. EPSTEIN incentivized his victims to become
recruiters by paying these victim-recruiters hundreds of dollars
for each minor girl that they brought to EPSTEIN to be sexually
abused. In so doing, EPSTEIN maintained a steady supply of new
victims to exploit.
The New York Residence
8. At all times relevant to this Indictment, JEFFREY
EPSTEIN, the defendant, possessed and controlled a multi-story
private residence on the Upper East Side of Manhattan, New York,
i.e., the New York Residence. Between at least in or about 2002
and in or about 2005, EPSTEIN abused numerous minor victims at
the New York Residence by causing these victims to be recruited
to engage in sex acts with him, after which EPSTEIN would
provide the victims with hundreds of dollars in cash.
3
EFTA00021254

=== Page 4 ===
9.
When a victim arrived at the New York Residence, she
would be escorted to a room with a massage table, where she
would perform a massage on JEFFREY EPSTEIN, the defendant. The
victims, who were as young as 14 years of age, were told by
EPSTEIN or other individuals to partially or fully undress
before beginning the "massage." During the encounter, EPSTEIN
would escalate the nature and scope of physical contact with his
victim to include, among other things, sex acts such as groping
and direct and indirect contact with the victims' genitals.
EPSTEIN typically would also masturbate during these sexualized
encounters, ask victims to touch him while he masturbated, and
touch victims' genitals with his hands or with sex toys.
10. In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash. Victims typically were paid hundreds
of dollars for each encounter.
11. JEFFREY EPSTEIN, the defendant, knew that certain of
his victims were underage, including because certain victims
told him their age. Further, once these minor victims were
recruited, many were abused by EPSTEIN on multiple subsequent
occasions at the New York Residence. EPSTEIN sometimes
personally contacted victims to schedule appointments for
"massages" at the New York Residence. In other instances,
EPSTEIN directed employees and associates, including a New York-
4
EFTA00021255

=== Page 5 ===
based employee ("Employee-1"), to communicate with victims via
phone to arrange for these victims to return to the New York
Residence for additional sexual encounters with EPSTEIN.
12. Additionally, and to further facilitate his ability to
abuse minor girls in New York, JEFFREY EPSTEIN, the defendant,
asked and enticed certain of his victims to recruit additional
minor girls to perform "massages" and similarly engage in sex
acts with EPSTEIN. When a victim would recruit another minor
girl for EPSTEIN, he paid both the victim-recruiter and the new
victim hundreds of dollars in cash. Through these victim-
recruiters, EPSTEIN gained access to and was able to abuse
dozens of additional minor girls.
13. In particular, certain recruiters brought dozens of
additional minor girls to the New York Residence to give
"massages" to and engage in sex acts with JEFFREY EPSTEIN, the
defendant. EPSTEIN encouraged victims to recruit additional
minor girls by offering to pay these victim-recruiters for every
additional minor girl they brought to EPSTEIN to be sexually
abused. When a victim-recruiter accompanied a new minor victim
to the New York Residence to be exploited by EPSTEIN, both the
victim-recruiter and the new minor victim were paid hundreds of
dollars by EPSTEIN for each encounter. In addition, certain
victim-recruiters routinely scheduled these encounters through
5
EFTA00021256

=== Page 6 ===
Employee-1, who sometimes asked the recruiters to bring a
specific minor girl for EPSTEIN.
The Palm Beach Residence
14. In addition to recruiting and abusing minor girls in
New York, JEFFREY EPSTEIN, the defendant, created a similar
network of minor girls to victimize in Palm Beach, Florida,
where EPSTEIN owned, possessed and controlled another large
residence, i.e., the Palm Beach Residence. EPSTEIN frequently
traveled from New York to Palm Beach by private jet, including
on occasions in which an employee or associate would ensure that
minor victims were available for encounters upon his return to
Florida.
15. At the Palm Beach Residence, JEFFREY EPSTEIN, the
defendant, engaged in a similar course of abusive conduct.
When a victim initially arrived at the Palm Beach Residence, she
would be escorted to a room, sometimes by an employee of
EPSTEIN's, including, at times, two assistants who, as described
herein, were also responsible for scheduling the sexual
encounters with minor victims ("Employee-2" and "Employee-3").
Once inside, the victim would provide a nude or semi-nude
massage for EPSTEIN, who would himself typically be naked.
During these encounters, EPSTEIN would escalate the nature and
scope of the physical contact to include sex acts such as
groping and direct and indirect contact with the victims'
6
EFTA00021257

=== Page 7 ===
genitals. EPSTEIN would also typically masturbate during these
encounters, ask victims to touch him while he masturbated, and
touch victims' genitals with his hands or with sex toys.
16. In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash. Victims typically were paid hundreds
of dollars for each encounter.
17. JEFFREY EPSTEIN, the defendant, knew that certain of
his victims were underage, including because certain victims
told him their age. In addition, as with New York-based
victims, many Florida victims, once recruited, were abused by
JEFFREY EPSTEIN, the defendant, on multiple additional
occasions.
18. JEFFREY EPSTEIN, the defendant, who during the
relevant time period was frequently in New York, would arrange
for Employee-2 or other employees to contact victims by phone in
advance of EPSTEIN's return to Florida to ensure appointments
were scheduled for when he arrived. In particular, in certain
instances, Employee-2 placed phone calls to minor victims in
Florida to schedule encounters at the Palm Beach Residence. At
the time of certain of those phone calls, EPSTEIN and Employee-2
were in New York, New York. Additionally, certain of the
individuals victimized at the Palm Beach Residence were
contacted by phone by Employee-3 to schedule these encounters.
7
EFTA00021258

=== Page 8 ===
19. Moreover, as in New York, to ensure a steady stream of
minor victims, JEFFREY EPSTEIN, the defendant, asked and enticed
certain victims in Florida to recruit other minor girls to
engage in sex acts. EPSTEIN paid hundreds of dollars to victim-
recruiters for each additional minor girl they brought to the
Palm Beach Residence to be sexually abused by EPSTEIN.
STATUTORY ALLEGATIONS
COUNT ONE
(Sex Trafficking Conspiracy)
20. From at least in or about 2002, up to and including in
or about 2005, in the Southern District of New York and
elsewhere, JEFFREY EPSTEIN, the defendant, and others known and
unknown, willfully and knowingly did combine, conspire,
confederate, and agree together and with each other to commit an
offense against the United States, to wit, sex trafficking of
minors, in violation of Title 18, United States Code, Section
1591 (a) and (b).
21. It was a part and object of the conspiracy that
JEFFREY EPSTEIN, the defendant, and others known and unknown,
would and did, in and affecting interstate and foreign commerce,
recruit, entice, harbor, transport, provide, and obtain, by any
means a person, and to benefit, financially and by receiving
anything of value, from participation in a venture which has
engaged in any such act, knowing that the person had not
8
EFTA00021259

=== Page 9 ===
attained the age of 18 years and would be caused to engage in a
commercial sex act, in violation of Title 18, United States
Code, Sections 1591 (a) and (b) (2).
Overt Acts
22. In furtherance of the conspiracy and to effect the
illegal object thereof, the following overt acts, among others,
were committed in the Southern District of New York and
elsewhere:
a.
In or about 2004, JEFFREY EPSTEIN, the defendant,
enticed and recruited multiple minor victims, including minor
victims identified herein as Minor Victim-1, Minor Victim-2, and
Minor Victim-3, to engage in sex acts with EPSTEIN at his
residences in Manhattan, New York, and Palm Beach, Florida,
after which he provided them with hundreds of dollars in cash,
respectively, for each encounter.
b. In or about 2002, Minor Victim-1 was recruited to
engage in sex acts with EPSTEIN and was repeatedly sexually
abused by EPSTEIN at the New York Residence over a period of
years, and was paid hundreds of dollars for each encounter.
EPSTEIN also encouraged and enticed Minor Victim-1 to recruit
other girls to engage in sex acts, which she did, and was paid
hundreds of dollars for each additional girl she brought to
EPSTEIN. EPSTEIN asked Minor Victim-1 how old she was, and
Minor Victim-1 answered truthfully.
9
EFTA00021260

=== Page 10 ===
C.
In or about 2004, Employee-1, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-1 in order to schedule an
appointment for Minor Victim-1 to engage in paid sex acts with
EPSTEIN.
d.
In or about 2004, Minor Victim-2 was recruited to
engage in sex acts with EPSTEIN and was repeatedly sexually
abused by EPSTEIN at the Palm Beach Residence over a period of
years, and was paid hundreds of dollars after each encounter.
EPSTEIN also encouraged and enticed Minor Victim-2 to recruit
other girls to engage in sex acts, which she did, and was paid
hundreds of dollars for each additional girl she brought to
EPSTEIN.
e.
In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-2 in order to schedule an
appointment for Minor Victim-2 to engage in paid sex acts with
EPSTEIN at the Palm Beach Residence.
f. In or about 2005, Minor Victim-3 was recruited to
engage in sex acts with EPSTEIN and was repeatedly sexually
abused by EPSTEIN at the Palm Beach Residence over a period of
years, and was paid hundreds of dollars for each encounter.
EPSTEIN also encouraged and enticed Minor Victim-2 to recruit
other girls to engage in sex acts, which she did, and was paid
10
EFTA00021261

=== Page 11 ===
hundreds of dollars for each additional girl she brought to
EPSTEIN. EPSTEIN asked Minor Victim-3 how old she was, and
Minor Victim-3 answered truthfully.
g. In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-3 in order to schedule an
appointment for Minor Victim-3 to engage in paid sex acts with
EPSTEIN at the Palm Beach Residence.
h.
In or about 2004, Employee-3 placed a phone call
to Minor Victim-3 in order to schedule an appointment for Minor
Victim-3 to engage in paid sex acts with EPSTEIN at the Palm
Beach Residence.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Sex Trafficking)
23. From at least in or about 2002, up to and including in
or about 2005, in the Southern District of New York and
elsewhere, JEFFREY EPSTEIN, the defendant, willfully and
knowingly, in and affecting interstate and foreign commerce, did
recruit, entice, harbor, transport, provide, and obtain by any
means a person, knowing that the person had not attained the age
of 18 years and would be caused to engage in a commercial sex
act, and did aid and abet the same, to wit, EPSTEIN recruited,
enticed, harbored, transported, provided, and obtained numerous
11
EFTA00021262

=== Page 12 ===
individuals who were less than 18 years old, including but not
limited to Minor Victim-1, as described above, and who were then
caused to engage in at least one commercial sex act in
Manhattan, New York.
(Title 18, United States Code, Sections 1591 (a),
(b) (2), and 2.)
FORFEITURE ALLEGATIONS
24. As a result of committing the offense alleged in Count
Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall
forfeit to the United States, pursuant to Title 18, United
States Code, Section 1594 (d), any property, real and personal,
that was used, or intended to be used to commit or to facilitate
the commission of the offense alleged in Count One, and any
property, real and personal, constituting or derived from, any
proceeds obtained, directly or indirectly, as a result of the
offense alleged in Count One, or any property traceable to such
property, and the following specific property:
a. The lot or parcel of land, together with its
buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 9 East 71st Street, New York, New
York, with block number 1386 and lot number 10, owned by
Maple, Inc.
12
EFTA00021263

=== Page 13 ===
Substitute Asset Provision
25. If any of the above-described forfeitable property, as
a result of any act or omission of the defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a
third person;
(c) has been placed beyond the jurisdiction of the Court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot
be subdivided without difficulty;
it is the intent of the United States, pursuant to 18 U.S.C.
$ 2253 (b), 21 U.S.C. $ 853 (p) and 28 U.S.C. $ 2461 (c), to seek
forfeiture of any other property of the defendant up to the
value of the above forfeitable property.
(Title 18, United States Code, Sections 981 and 1594; and
Title 28, United States Code, Section 2461.)
FOREPERSON
GEOFFREY S. BERMAN
United States Attorney
13
EFTA00021264

=== Page 14 ===
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
V.
JEFFREY EPSTEIN
Defendant.
INDICTMENT
(18 U.S.C. $$ 371, 1591 (a), (b) (2),
and 2)
GEOFFREY S. BERMAN
United States Attorney
Foreperson
14
EFTA00021265


c1: EFTA00021987
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021987.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Bcc: USAHUB-USAJournal111
Subject: Re:
Date: Wed, 14 Oct 2020 21:39:25 +0000
Embedded: Re:
Sender:
Subject: Re:
Message-Id: <E3151915-38C8-497B-B7DB-C015B535AA8A@usa.doj.gov>
To:
Cc:
Cc:
Cc:
Cc:
EFTA00021987


c1: EFTA00022347
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022347.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Marshals Intake Form
Date: Fri, 26 Jul 2019 23:56:12 +0000
Please process the following:
Requestor's Phone Number:
(212) 637-2324
Name / Alias(es): Jeffrey Epstein
Court Number: 19 Cr. 490 (RMB)
USAO Number: 2018R01618
USMS Number: 76318-054
Arrest Date: 7/6/2019
Date of Birth: 1/20/1953
Documents: Email
Photo:
Email
Remarks:
EFTA00022347


c1: EFTA00021194
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021194.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
)"
(USANYS)"
Cc:
)"
Subject: RE: GM - Draft Voir Dire
Date: Tue, 28 Sep 2021 18:28:04 +0000
Importance: Normal
Attachments: Proposed_Voir_Dire_v1.5.agm.aar.docx
Just a few more on top of those.
I
Thanks, Lara!
From:
Sent: Tuesday, September 28, 2021 2:00 PM
To:
(USANYS)
>;
Cc:
Subject: RE: GM - Draft Voir Dire
Thanks! A few things in the attached doc.
From:
(USANYS)
Sent: Tuesday, September 28, 2021 1:00 PM
To:
>;
Cc:
Subject: GM - Draft Voir Dire
Hi team - A draft VD attached for your review, a couple questions for your consideration. I'm going to send the jury
questionnaire and VD together to the chiefs later today.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00021194


c1: EFTA00022050
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022050.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
)"
Cc:
)"
)"
Subject: Epstein Image/Video File Review Protocol
Date: Mon, 19 Oct 2020 20:08:24 +0000
Attachments: 2020-06-26,_search_warrant_application,_20_mag_6719.pdf; 2020-06-
26,_search_warrant,_20_mag_6719.pdf;
2020.10.19_Epstein_devices_responsiveness_review_protocol_-_image_t_video_filespdf
Maxwell_Superseding_Indictment_-_S1_20_Cr_330_(AJN)_(docketed).pdf
All,
Attached please find the review protocol for the image and video files from Epstein's devices. The protocol asks that all
reviewers read the warrant and supporting affidavit, which are both attached here as well. I am also attaching a copy of
the Maxwell indictment, which contains a photograph of Epstein and Maxwell.
Once the USAO and FBI review teams are assembled, please let me know when would be a good time for me to have a
call with them to talk through the review and answer any questions.
In the first instance, we would ask that the FBI team review the following devices:
NYC024363
NYC024394
NYC024326
NYC024368
NYC024390
NYC024334
NYC027910
NYC024323
NYC024355
NYC027908
Depending on how quickly the FBI and USAO teams move through the review, we may reassign some devices between the
teams.
Thanks very much,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
EFTA00022050


c1: EFTA00022431
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022431.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(CRM)"
To:
)"
Subject: Fwd: New Jeffrey Epstein accuser emerges; defamation suit filed I Bradenton Herald
Date: Wed, 17 Apr 2019 12:13:58 +0000
Importance: Normal
Thanks for your email yesterday. I don't need more details at this point, but glad to hear the investing continues
to advance.
Attached is one more communication from Sarnoff.
I
Criminal Division
I
Sent from my mobile device. Please excuse any brevity and mispellings.
Begin forwarded message:
From: conchita sarnoff
Date: April 16, 2019 at 11:47:05 PM EDT
To:
Subject: New Jeffrey Epstein accuser emerges; defamation suit filed I Bradenton Herald
https://www.miamiherald.com/news/nation-world/article229277874.html
Dear Sirs,
Again please note remarks concerning modeling allegations.
The victims were lured according to court files and my interviews, they could potentially model at Victoria's
Secret
Mr. Epstein's close friend
or MC2 (modeling agency owned by Epstein
associate/friend, Frenchman,
EFTA00022431


c1: EFTA00021283
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021283.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Fwd: Mark Epstein
Date: Wed, 30 Oct 2019 12:08:39 +0000
Begin forwarded message:
From:
Date: October 30, 2019 at 8:05:33 AM EDT
To:
Subject: Re: Mark Epstein
I got a call from
this morning that he was at Fox and Friends to give his views.
Please note this was not authorized by me. I wanted to discuss all of these issues with you and
the investigators as I felt that the appropriate way to go -through you alone.
Law Offices of
Bronx, New York 10461
(Main)
(Facsimile)
***Confidentiality Notice***
This email and any accompanying documents contains information that is intended only for the use of the
individual or entity to whom it is addressed and may contain information that is legally privileged, confidential
or otherwise exempt from disclosure under applicable laws. If the reader of this message is not the recipient,
any disclosure, dissemination, distribution, copying, or other use or retention of this communication or its
substance is prohibited. If you have received this email in error, please delete it and notify the sender by return
email. Thank you.
From:
Sent: Monday, October 28, 2019 7:43 PM
To:
Cc:
Subject: RE: Mark Epstein
Confirmed for 11/7 at 10 am at our office.
From:
Sent: Monday, October 28, 2019 7:01 PM
EFTA00021283

=== Page 2 ===
To:
Cc:
Subject: Re: Mark Epstein
I will work with any date you have the week of 11/4. I truly apologize. After our conversation I called my client for
10/31. He is quite anxious. I did not intend to waste anyone's time or resources.
Sent from my iPhone
On Oct 28, 2019, at 6:26 PM,
wrote:
Hi
Per my email, we made ourselves available for today and confirmed 3 p.m. today. I did not confirm 10/31. We're not
available this week and I'll have to go back to the case team to see when they're available. You can send us some
dates for the weeks of 11/4 and 11/11 that work for you.
From:
Sent: Monday, October 28, 2019 6:19 PM
To:
Cc:
Subject: Re: Mark Epstein
What will? My client is flying in from Florida based on our original conversation. From our discussion you said 10/31
and I called him immediately.
Sent from my iPhone
On Oct 28, 2019, at 6:02 PM,
wrote:
No, that won't work for us unfortunately.
From:
Sent: Monday, October 28, 2019 6:00 PM
To:
Cc:
Subject: Re: Mark Epstein
I am sorry I would not have confirmed for today. I had a 4 pm doctors appointment scheduled for months. I had told
mark 10/31 as well. My apologies. Can we still do 10/31?
Sent from my iPhone
On Oct 28, 2019, at 5:51 PM,
wrote:
EFTA00021284

=== Page 3 ===
Hi
Per my email on October 24 below, we were confirmed for Monday (which was today, October 28).
From:
Sent: Monday, October 28, 2019 5:27 PM
To:
Cc:
Subject: Re: Mark Epstein
Greetings. We are set for 10/31 at three per your direction. Did I miss an update?
Sent from my iPhone
On Oct 28, 2019, at 3:12 PM,
wrote:
Hi
Are you en route? Thanks.
On Oct 24, 2019, at 10:55 AM,
>
wrote:
We are confirmed for a meeting at 3:00 p.m. on Monday at
See you then. Thanks.
Assistant United States Attorney
Southern District of New York
Tel:
EFTA00021285


c1: EFTA00021524
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021524.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
Subject: RE: Wednesday
Date: Tue, 30 Jul 2019 21:00:48 +0000
Inline-Images: image001.jpg; image002.png; image003.jpg; image004.png; image005.jpg
I would recommend coordinating with your client to meet her and travel together, if that works. Thanks.
From:
Sent: Tuesday, July 30, 2019 4:56 PM
To:
Cc:
;
Subject: RE: Wednesday
Thank you very much. Also, since the courthouse is near the Bowery hotel is there any chance that
car could pick
me up at the courthouse after the car picks up
Then I would be able to ride with her to my hotel, the Lotte New
York Palace .In the alternative, I guess I could try to get to her hotel to go with her in the car to my hotel, but picking me
up at the courthouse would be easier for me.
From:
Sent: Tuesday, July 30, 2019 1:48 PM
To: Gloria Allred
Cc:
Subject: RE: Wednesday
Let's plan to meet tomorrow at 2 p.m. at your hotel, in that case. l'll send a separate email, copying
to
make sure that car arrangements are made for your client. Hope you have a good flight.
From:
Sent: Tuesday, July 30, 2019 4:41 PM
To:
EFTA00021524

=== Page 2 ===
Cc:
Subject: RE: Wednesday
My flight is leaving for New York now and I will not be able to respond to more emails until tonight. I am sorry that I am
unable to arrange for a room at her hotel. If you are able to arrange for a room at her hotel and if the government will pay
for it ,that will be fine as far as I am concerned.
From:
Sent: Tuesday, July 30, 2019 1:36 PM
To:
Cc
Subject: RE: Wednesday
That is understandable, and thanks for letting us know. Are you referring to meeting at her hotel or at yours? If possible, I
think it would be easier for everyone to meet at her hotel, if you're able to arrange for a conference room there. We are
available to meet at 2 in either case. Thanks.
From:
Sent: Tuesday, July 30, 2019 4:32 PM
To:
Cc:
Subject: RE: Wednesday
She emailed me that she would feel more comfortable meeting at the hotel. Would you be available to meet at 2 or 3
P.M. instead of at 1P.M. so that there is time for lunch after the court status conference? Also, I have good news. When we
meet tomorrow, I will discuss a third victim whom I represent who would like to meet with you in August in New York.
EFTA00021525

=== Page 3 ===
From:
Sent: Tuesday, July 30, 2019 1:25 PM
To:
Cc:
Subject: RE: Wednesday
Hi
Do you have a sense yet of what time works for you and your client to come to our office tomorrow afternoon?
Thanks,
From
Sent: Monday, July 29, 2019 6:17 PM
To
Subject: RE: Wednesday
I understand. I will let you know as soon as I hear from
- Also, I am open to having the meeting later than 1P.M.
,because I scheduled that time prior to knowing about the status conference in the morning. Let me see what
wants
to do and then we can discuss the where and when and will work for you.
From:
)
Sent: Monday, July 29, 2019 3:09 PM
To:
Cc:
Subject: RE: Wednesday
Hi
Thanks for letting us know about the possible meeting location change- please let us know once you've been able to
confirm with your client, and we can let
know so that she can cancel the car service.
EFTA00021526

=== Page 4 ===
Regarding the court conference, we are unfortunately not able to reserve seats for anyone-the court manages court
security and the crowd, so we don't have control over that. The other victim attorneys have been attending the
conferences on their own, and although I don't know, I would guess that means that they have been arriving early.
Thanks,
From:
Sent: Monday, July 29, 2019 6:00 PM
To:
Subject: RE: Wednesday
Thank you very much for this information. I plan to attend this court this status conference on Wednesday. I am
concerned that the courtroom may be full and no seat will be available for me Would you be kind enough to have
someone on your staff save a seat for me? Also, since the courthouse is very close to your office I have emailed
to
ask if she would be willing to meet at your office instead of at my hotel at 1P.M.Since her hotel is near to your office and
near the courthouse and since I will be in the area now as well, if she feels comfortable meeting at your office instead of
my hotel I am willing to meet at your office to save you and her the time to travel to my hotel. I will let you know when
she responds.
From:
Sent: Monday, July 29, 2019 1:50 PM
To:
Subject: RE: Wednesday
H
Yes-in this district, criminal defendants are present at all court conferences absent unusual circumstances.
From:
Sent: Monday, July 29, 2019 4:46 PM
To:
Subject: Wednesday
I see that a status conference is scheduled for Mr. Epstein's criminal case in court in New York at 11A.M.on Wednesday
,July 31. Do you know if Mr. Epstein will be present for the status conference in court on Wednesday?
EFTA00021527

=== Page 5 ===
EFTA00021528


c1: EFTA00020621
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020621.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: Subpoena -
Date: Thu, 30 Sep 2021 20:55:59 +0000
Importance: Normal
Attachments: 2021.09.30_Court_Subpoena_ -
.pdf
gave me your contact information - he and I spoke on the phone today about a subpoena to
He
told me to serve the subpoena by email to you, so a copy of the subpoena is attached.
told me that you would likely send us records on an encrypted flash drive. If so, you can send it to me at the below
address.
Please feel free to give me a call if you have any questions, and thanks a lot for your assistance with this matter.
Andrew
Assistant United States Attorney
Southern District of New York
1 Saint Andrews Plaza
New York, New York 10007
EFTA00020621


c1: EFTA00021061
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021061.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Bcc:
Subject: Re: Epstein -- travel approval form
Date: Tue, 04 Feb 2020 17:44:49 +0000
I may run late. Don't come till I call!
Sent from my iPhone
On Feb 3, 2020, at 5:45 PM,
wrote:
That works, thanks - just let me know if your schedule changes, otherwise l'll come by at 1:00 tomorrow. Thanks again
and looking forward to it.
From:
Sent: Monday, February 03, 2020 16:07
To:
Subject: RE: Epstein -- travel approval form
Right now 1 p.m. looks open.
From:
Sent: Monday, February 3, 2020 1:33 PM
To:
Subject: RE: Epstein -- travel approval form
No problem at all, and I'm very flexible tomorrow afternoon - whatever time is good for you I can make work, so just let
me know and l'll put it in the calendar.
From:
Sent: Monday, February 03, 2020 13:31
To:
Subject: RE: Epstein -- travel approval form
So sorry for the delay. Maybe tomorrow? I have time in the afternoon.
From:
Sent: Friday, January 31, 2020 1:09 PM
To:
Subject: RE: Epstein -- travel approval form
Totally understand, and next week would be fine - let me know if it's helpful to set a time, and otherwise l'll touch base
midweek if we haven't connected by then.
EFTA00021061

=== Page 2 ===
And thanks very much re: the memo.
From:
Sent: Friday, January 31, 2020 12:53
To:
Cc:
Subject: RE: Epstein -- travel approval form
Already signed and sent upstairs
I will do my best to ensure signature immediately.
Re: this afternoon: it may be best to kick it to next week. If some time develops before 3, I'll let you know, but right
now it is iffy.
From:
Sent: Friday, January 31, 2020 12:21 PM
To:
Cc:
Subject: Epstein -- travel approval form
We dropped off the Sweden travel memo for you - we were unexpectedly significantly delayed in getting OIA approval,
but it finally came this morning, so with apologies for the short turnaround, hoping to get Office and final DOJ approval
this afternoon. Thank you!
And separately, if you still wanted to meet up today, I'll be around until about 3:00, but I'm also flexible next week if
that's easier.
thanks again,
Assistant U.S. Attorney
Southern District of New York
EFTA00021062


c1: EFTA00023355
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023355.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
)"
Subject: CC letter
Date: Sat, 13 Nov 2021 02:49:09 +0000
Attachments: 2021-11-12_GM_letter_re_CC_statements_v3.docx.
Final version attached. Anyone want to review again before I file?
Assistant United States Attorney
Southern District of New York
New York, NY 10007
EFTA00023355


c1: EFTA00021872
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021872.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: delivery of hard drive to MDC for discovery production to inmate
Date: Wed, 05 Aug 2020 23:05:06 +0000
Hard drives should be mailed to the facility to the attention of the legal department. We need to etch the drive with a
number and provide an authorization memo so she can retain it. Then it will be provided to her. It can be password protected
so long as you include a cover letter that contains the password for her.
Hope this helps,
8/5/2020 4:34 PM>>>
We have a hard drive with loaded discovery that we need to deliver to Ghislaine Maxwell,
at MDC. Could you
please let us know what the current protocol is for that? Also, it's our understanding that hard drives with discovery
materials for inmates needs to be non-encrypted (and not have a password for access), is that also correct?
We're hoping to get these materials to her tomorrow if at all possible, so we greatly appreciate your help. And I'm
reachable any time at
if it would be helpful to discuss.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00021872


c1: EFTA00021400
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021400.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: "Weingarten, Reid"
Cc:
Subject: RE: bail topics
Date: Mon, 15 Jul 2019 23:18:43 +0000
Importance: Normal
Reid,
No problem, and we can chat later this week at the hearing and then meet when that makes sense. In the interim we'll
start work on some general discovery and also on a draft protective order.
thanks,
From: Weingarten, Reid
Sent: Monday, July 15, 2019 16:47
To:
Cc:
Subject: Re: bail topics
So in a word I am eager to sit down with you guys to figure out if there is any way forward at all to find common
ground in this nightmare a combination of demanding judges in other cases and an unexpected potential
conflict has tied me in knots today. sorry. and I am on the west coast the rest of the week. obviously this is
not going anywhere soon so hopefully we can find time when I get back again sorry for the false starts. reid
Sent from my BlackBerry 10 smartphone.
From:
)
Sent: Monday, July 15, 2019 2:38 PM
To: Martin G. Weinberg; Weingarten, Reid
Cc:
);
)
Subject: RE: bail topics
Marty, Reid,
Briefly following up on this morning, if you could please let us know what if any information you're able to provide about
the passport we discussed, with the copies we provided to you, we can address any new info as appropriate for a possible
submission tomorrow.
Related, something I'm not sure we've specifically asked, and I'm not sure whether pretrial asked-can you please advise
whether Mr. Epstein currently is, or has been in the past, a citizen or legal permanent resident of a country other than the
United States?
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00021400

=== Page 2 ===
EFTA00021401


c1: EFTA00020995
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020995.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(USANYS)"
Subject: Automatic reply: Web Update -
does this work?
Date: Tue, 27 Aug 2019 19:34:42 +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.
EFTA00020995


c1: EFTA00020944
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020944.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Conference: Jeffrey Epstein
Start Date: 2019-07-18 15:30:00 +0000
End Date: 2019-07-18 17:30:00 +0000
Location: Courtroom 17B, 500 Pearl
Class: X-PERSONAL
Comment:
Date Created: 2019-07-17 19:21:21 +0000
Date Modified: 2019-07-17 19:21:21 +0000
Priority: 5
DTSTAMP: 2019-07-17 18:01:58 +0000
Attendee:
EFTA00020944


c1: EFTA00021376
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021376.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Bcc: "USAHUB-USAJournal111"
Subject: FW: Motions to Suppress
Date: Mon, 22 Feb 2021 18:59:16 +0000
Embedded: FW:_Motions_to_Suppress.msg
Sender:
Subject: FW: Motions to Suppress
Message-Id:
<DM2P110MB0121E05C86696B086510427C89819@DM2P110MB0121.NAMP110.PROD.OUTLOOK.COM
>
To:
EFTA00021376


c1: EFTA00021717
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021717.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: Maxwell drive delivery Monday 1/11
Date: Mon, 11 Jan 2021 16:23:23 +0000
Ok see you in a few.
> On Jan 11, 2021, at 11:13,
wrote:
> Hi
> > >
,
Yes, I will meet you outside 1SA at 11:30 today. If anything comes up, please feel free to give me a call at
Thank you!
V
>
Original Message
> From:
> Sent: Monday, January 11, 2021 10:47 AM
> To:
> Cc:
> Subject: Re: Maxwell drive delivery Monday 1/11
V
V
,
V
>
I will be picking up the drives today. Are you available to run out to me around 11:30?
V
V
V
or
ideally I'd be bringing the drives directly to you after pick up. Are you available around 12-
1230?
V
> Feel free to call me at
>
V
>
V
V
>> On Jan 11, 2021, at 09:48,
wrote:
>> It will be myself or
.
>> Best,
)"
1/8/2021 2:20
>> PM »
EFTA00021717

=== Page 2 ===
Good afternoon,
>> The FBI has very kindly agreed to deliver two new drives from my
>> office to the MDC for Ghislaine Maxwell on Monday, January 11th. I've
>>
cc'd Special Agent
, who will be coordinating the delivery.
>>
Would you please let us know what time the FBI should plan to make the
delivery and who will be available to receive the drives on Monday?
>> Thank you all very much for your help.
Best,
Assistant United States Attorney
Southern District of New York
>>
1 St. Andrew's Plaza
>>
New York, NY 10007
<mailto:
EFTA00021718


c1: EFTA00023042
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023042.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
)"
)"
Subject: RE: Voice Message Attached from
- Intake Line
Date: Thu, 18 Jul 2019 16:50:44 +0000
No problem. Thanks.
Original Message
From:
)
Sent: Thursday, July 18, 2019 12:46 PM
To: Morey,
(USANYS) <RMorey@usa.doj.gov>
Cc:
i
)
Subject: FW: Voice Message Attached from
- Intake Line
Hi
,
The caller in this voicemail references the Epstein case, but his complaint appears to be about a separate matter.
Would you please process this as a civilian complaint?
Thanks,
Original Message
From: postmaster@voip.usa.doj.gov <postmaster@voip.usa.doj.gov>
Sent: Thursday, July 18, 2019 12:40 PM
To:
<2126372324@voip.usa.doj.gov>
Cc:
Subject: Voice Message Attached from
- Intake Line
Time: Jul 18, 2019 12:39:35 PM
Click attachment to listen to Voice Message
EFTA00023042


c1: EFTA00020779
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020779.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
To:
Subject: Fwd: Anonymous figures argue against disclosure of Jeffrey Epstein case
Date: Wed, 20 Mar 2019 23:12:25 +0000
Importance: Normal
Nick Lewin.
Sent from my iPhone
Begin forwarded message:
From:
Date: March 20, 2019 at 7:08:31 PM EDT
To:
Subject: Anonymous figures argue against disclosure of Jeffrey Epstein case
Anonymous figures argue against disclosure of Jeffrey Epstein case
https://www.nydailynews.com/news/national/ny-epstein-sealed-document-20190320-
ipkejwbsuraqfn5za7n5mwl32u-story.html
EFTA00020779


c1: EFTA00021013
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021013.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Bcc: "USAHUB-USAJournal111"
Subject: RE: redactions
Date: Thu, 28 Jan 2021 21:05:54 +0000
Embedded: RE:_redactions.msg
Sender:
Subject: RE: redactions
Message-Id:
<BN3P110MB02570EB0758186972007BD208ABA9@BN3P110MB0257.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
To:
EFTA00021013


c1: EFTA00023480
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023480.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Testifying Witness Questions
Date: Tue, 05 Oct 2021 18:27:03 +0000
Attachments:
31E-MM-108062-GJ-1A4.pdf
Just FYI, the notes and documents for
were in 31E-MM-108062 - GJ 1A4. They are attached here as well.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
From:
Sent: Monday, October 4, 2021 7:58 PM
To:
Cc:
Subject: [EXTERNAL EMAIL] - Testifying Witness Questions
I'm attaching the 302 for
from an interview on August 22, 2006. The last paragraph refers to her providing a
copy of the hours she worked at Epstein's residence as well as some notes she made at her time of employment. Can you
please send the notes and the documents she provided? I don't believe we have them.
Also can you please send the notes of the 8/15/06 interview of
? The 302 is attached.
Thanks!
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00023480


c1: EFTA00020936
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020936.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Page 1 of 1
From:
Mike O'Neil
Sent:
Friday, September 30, 2005 10:27 AM
To:
Subject: Trilateral Meeting
Dear Mr. Epstein:
I hope you have seen the program and other materials for the 2005 North American regional m eeting
coming up on November 4-6 in Montreal. We: have not heard from you about attending and want to be sure you
are aware of the meeting and have had a chance to consider attending. To that end, I attach the progr am and a
reservation form.
Please let us know if you can attend or not. Just reply to this email or send In a completed rese rvation
form.
Thanks,
Michael O'Neil
-
9/30/2005
02/11/2015
Page 2626
Public Records Request No.: 15-268
EFTA00020936


c1: EFTA00021765
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021765.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "
To:
Cc:
Subject: Letter re MCC
Date: Wed, 08 Jan 2020 22:48:14 +0000
Attachments: 2020.01.08_letter_to_KMK_re_MCC_tape_v2.docx
- Attached is the letter. Please let us know if there is anything you want to discuss. We plan to file in the morning.
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:
EFTA00021765


c1: EFTA00023030
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023030.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From
USANYS) [Contractor]"
To:
)"
(USANYS)
[Contractor]"
Cc:
)"
i
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: RE:
shared the folde
Documents" with you.
Date: Wed, 20 Jan 2021 15:20:59 +0000
Embedded: RE:
Documents"_with_you..msg
Sender:
Subject: RE:
shared the folder
Documents" with you.
Message-Id:
<CY1P110MB01651F198E2466F1F47ED0D9F5A20@CY1P110MB0165.NAMP110.PROD.OUTLOOK.COM
>
To:
To:
Cc:
Cc:
EFTA00023030


c1: EFTA00022349
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022349.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: US V. Gatto - Oath Inc. Motion to Intervene
Date: Fri, 02 Aug 2019 15:36:11 +0000
Attachments: Brown_v_Maxwell.doc
Sounds fine to me
From:
Sent: Friday, August 2, 2019 11:22 AM
To:
; Peng, Victoria
>; ; Steve
Haney
Schachter, Michael
;
Moore, Mark
C.
Cc:
is
Subject: RE: US V. Gatto - Oath Inc. Motion to Intervene
Dear Counsel: Would you please let me know if you have any objection to my filing with the Court a copy of the attached
decision of the Second Circuit in Brown V. Maxwell (July 3, 2019)? Thank you, and have a good weekend. Jon
Jonathan M. Albano
Morgan, Lewis & Bockius LLP
One Federal Street Boston, MA 02110-1726
Direct:
Main:
Fax:
www.morganlewis.com
Assistant: Kathleen A. Slowe
I
From:
Sent: Monday, July 22, 2019 5:17 PM
To: Albano, Jonathan M.
>; Peng, Victoria
; Steve
Haney
Schachter, Michael
Moore, Mark
C.
Cc:
is
in
(USANYS)
Subject: US V. Gatto - Oath Inc. Motion to Intervene
[EXTERNAL EMAIL]
Counsel,
Please find attached the Government's opposition to Oath Inc.'s motion to intervene for the limited purpose of obtaining
materials. An unredacted version of this filing is being provided to the Court on an ex parte basis.
Best,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
EFTA00022349

=== Page 2 ===
New York, NY 10007
DISCLAIMER
This e-mail message is intended only for the personal use
of the recipient(s) named above. This message may be an
attorney-client communication and as such privileged and
confidential and/or it may include attorney work product.
If you are not an intended recipient, you may not review,
copy or distribute this message. If you have received this
communication in error, please notify us immediately by
e-mail and delete the original message.
EFTA00022350


c1: EFTA00021378
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021378.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: NPA
Date: Tue, 23 Feb 2021 15:38:51 +0000
Attachments: Ex._A.pdf
Thanks, all. I'm attaching the NPA, in case that's useful.
From:
Sent: Tuesday, February 23, 2021 10:36 AM
To:
is
Cc:
Subject: RE: NPA
Great, thanks to you both.
- let's touch base after
sends edits around so we can figure out who will
jump in next.
From:
Sent: Tuesday, February 23, 2021 10:35 AM
To:
Cc:
is
Subject: Re: NPA
My laptop isn't letting me connect to the network this morning, but my plan is to review as soon as that's fixed (which
should be in about 30 minutes).
On Feb 23, 2021, at 10:32 AM,
wrote:
I will look now.
From:
Sent: Tuesday, February 23, 2021 10:13 AM
To:
is
is
Subject: RE: NPA
Thanks,
Has anyone started to review this yet? I'm tied up for a bit if someone else has a chance to look
From:
Sent: Tuesday, February 23, 2021 2:02 AM
To:
>;
;
Subject: NPA
All,
EFTA00021378

=== Page 2 ===
Attached is the most recent draft of the NPA brief. Apologies for the delay, I really struggled with this one. I think our
arguments in the first half are strong, but I'm really not wild about the second half. Would very much appreciate your
comments/edits. I've also flagged a few issues for consideration/discussion. If you're able to review tomorrow morning,
that would be great.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint
Plaza
New York, NY 10007
EFTA00021379


c1: EFTA00021719
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021719.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
Cc:
Bcc: "USAHUB-USAJournal111" <usahub-usajournal11@usa.doj.gov>
Subject: RE: Brunel
Date: Tue, 12 Jan 2021 15:05:23 +0000
Embedded: RE:_Brunel.msg
Sender:
Subject: RE: Brunel
Message-Id:
<BN3P110MB0417D07D210DC41503636A708AAA0@BN3P110MB0417.NAMP110.PROD.OUTLOOK.CO
M>
To
To:
To:
Cc:
EFTA00021719


c1: EFTA00020812
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020812.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Spreadsheets from Denver exports without thumbnails
Date: Thu, 14 Oct 2021 03:34:25 +0000
Attachments: 2021.10.13_Maxwell_Letter.pdf
Sure - updated letter attached.
From:
Sent: Wednesday, October 13, 2021 11:32 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
sorry one small thing, can you just list the documents in the index in the letter as "Spreadsheets" not FBI
Spreadsheets? Thanks!
From:
Sent: Wednesday, October 13, 2021 11:31 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
Thanks!
From:
(USANYS)
Sent: Wednesday, October 13, 2021 11:30 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
Great, thanks! I will copy you on the email to defense counsel.
From:
Sent: Wednesday, October 13, 2021 11:22 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
Updated PDF attached, thanks! I can upload to USAfx after you share the correspondence with them. If you have no
objections, l'll share the production with the same people we did last time
Should take only a few minutes to upload. Thanks!
From:
(USANYS)
Sent: Wednesday, October 13, 2021 11:15 PM
EFTA00020812

=== Page 2 ===
Subject: RE: Spreadsheets from Denver exports without thumbnails
Thanks so much,
Can you please update the bates range in the first paragraph and then send me a PDF of the
letter? Can you please remove the word "discovery" from the title of the PDF? Are you able to share with the defense via
USAfx?
From:
Sent: Wednesday, October 13, 2021 10:55 PM
Subject: RE: Spreadsheets from Denver exports without thumbhails
The production is stamped and saved here for your review:
Twenty-Fourth Production (2021-10-13)
I updated the cover letter (attached and saved here) to reflect the updated Bates range of SDNY_GM_02765031-2765061.
Any edits, please let me know. Thanks!
From:
(USANYS)
Sent: Wednesday, October 13, 2021 9:37 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
Here is a cover letter for the production. Just the bates numbers need to be added in. thanks!
From:
)
Sent: Wednesday, October 13, 2021 9:25 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
Hi
Are you able to send this out first thing tomorrow morning, if you're not able to send tonight (and no worries if you can't)
Thanks!
From:
(USANYS)
Sent: Wednesday, October 13, 2021 7:41 PM
Subject: RE: Spreadsheets from Denver exports without thumbnails
Sorry for the night email, but we need to send out the spreadsheets
sent us to the defense tonight. Are you able to
get them in a production and stamp them? l'll circulate a discovery letter.
Thanks!
EFTA00020813

=== Page 3 ===
From:
Sent: Wednesday, October 13, 2021 7:10 PM
Subject: [EXTERNAL] Spreadsheets from Denver exports without thumbnails
See attached.
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
EFTA00020814


c1: EFTA00022022
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022022.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: MCC guards
Date: Wed, 30 Jun 2021 16:36:24 +0000
Thanks
On number #2, yes that is certainly my memory of the interview, and we included that information in the
pros memo.
From:
Sent: Wednesday, June 30, 2021 11:32 AM
To:
Cc:
Subject: MCC guards
Hi,
Two things:
1. The guards that Noel named as not doing rounds/counts and pre-filling were COs
2. According to the notes of his interview with us,
said he knew but did not tell anyone that
was
released or Epstein was without a cellmate. He also stated that he was waiting for the captain or warden to put
someone new in the cell. In a recent interview with OIG, he says that he didn't know tha
was gone and
denies his prior statement. Do you have a recollection of this interview? If so, Lyeson wants to know if we think the
notes/MOI are correct.
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
EFTA00022022


c1: EFTA00020777
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020777.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
"
Cc:
)"
)"
Subject: RE:
interview notes
Date: Tue, 28 Jul 2020 13:37:18 +0000
Thanks very much.
From:
Sent: Tuesday, July 28, 2020 9:37 AM
To:
Cc:
is
)
Subject: RE
interview notes
The notes have been saved and added to the tracker.
From:
Sent: Monday, July 27, 2020 7:46 PM
To:
Cc:
>;
Subject: FW:
interview notes
Hi
Would you please save these on the Epstein share drive and note them in the tracker?
Thanks,
From:
Sent: Monday, July 27, 2020 6:38 PM
To:
>;
)
V.
Cc:
Subject:
interview notes
Attached are the interview notes from
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
U
EFTA00020777


c1: EFTA00021068
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021068.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Bcc: "USAHUB-USAJournal111"
Subject: RE: SK
Date: Thu, 01 Oct 2020 19:21:48 +0000
Embedded: RE:_SK.msg
Sender:
Subject: RE: SK
Message-Id:
To:
To:
EFTA00021068


c1: EFTA00020815
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020815.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 13, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States V. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
You requested a copy of the spreadsheets on the hard drives you have reviewed at the FBI
office in Denver. Those spreadsheets are embedded with hyperlinks to the images on the hard
drives. The Government is not able to provide you with copies of the versions of the spreadsheets
on the hard drives because those spreadsheets are embedded with photographs depicting, among
other things, child exploitation materials. However, the FBI has prepared a version of the
spreadsheets you requested without the embedded photographs, which we are producing to you
today, as listed in the below index. These materials are stamped with control numbers
SDNY_GM_02765031 through SDNY_GM_02765061.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. The Department of Justice directed this office to cease the dissemination of materials
marked with the word "confidential" in order to avoid potential confusion with markings reserved
for classified documents. Accordingly, in order to note the appropriate designation of this
production under the operative Protective Order in this case, the materials being produced today
are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,
EFTA00020815

=== Page 2 ===
Page 2
8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective
Order that govern today's production.
An index of the materials contained in this production is below:
Bates Start
Bates End
Summary Description
Confidential Designation
SDNY GM 02765031
SDNY GM 02765061
Spreadsheets
Confidential
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by:
s/
Assistant United States Attorneys
EFTA00020816


c1: EFTA00023113
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023113.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
(USANYS)"
Subject: RE: FW: Ghislaine Maxwell 02879-509
Date: Wed, 30 Dec 2020 18:35:26 +0000
Yes, I'll call you in a minute.
Original Message
From:
Sent: Wednesday, December 30, 2020 1:35 PM
To:
)
Cc:
)
(USANYS)
Subject: Re: FW: Ghislaine Maxwell 02879-509
Available right now for a quick call?
"
)"
12/30/2020 1:20
PM
and
,
Additional email to discuss when you are available.
Thanks,
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
<mailto:
From: BOBBI C STERNHEIM <bcsternheim@mac.com>
Sent: Wednesday, December 30, 2020 8:43 AM
To:
Cc:
(USANYS)
i
Christian Everdell
>; ; Mark S. Cohen
Subject: Ghislaine Maxwell 02879-509
Good morning,
I am responding to select portions of yesterday's email:
Ms. Maxwell reports that she is searched, patted, and wanded multiple times per day
1- Isolation Cell to Day Room
EFTA00023113

=== Page 2 ===
2- Day Room to VTC Room -
3- - VTC Room to Day Room
4- Day Room to Isolation Cell
2 additional searches if she goes to and from recreation.
In addition, mulitple times per day, she is required -to remove her shoes for inspection of her feet and shoes -to
remove her mask for inspection of her mouth (now with a
flashlight)
accompanied by inspection inside and behind her ears.
Her cell is search multiple times per day:
In her presence- when she is taken out of her Isolation Cell in the morning Outside her presence-evidenced by
items removed from her locker and papers left in disarray.
Also, her personal papers are searched in the Day Room.
At least 2 guards have eyes on her while she showers (her feet and head
exposed) -"for her safety."
Re: ambient temperature, which registered 68.6 on 12/21 (and decreases during the night)- Monday night (12/28)
the ambient temperature was taken just inside the door frame of her Isolation Cell, not near the external non-
insulated concrete wall on which condensation accumulates due to differentials between external and internal
temperature.
Ms. Maxwell was given the third blanket in response to her being cold after condensation had accumulated.
Unlike other inmates - whose body temperatures elevate heat in common areas - Ms. Maxwell is an isolated
inmate; no heat is generated from others to provide additional heat.
Given that she is surveilled 24 hours a day by handheld and stationery cameras, is escorted from locked area to
locked area in the custody and control of 3 to 6 guards, and has no contact with any other inmates, it is
unreasonable to compare her circumstances to any other inmate.
The searching is disproportionate to the amount of security and cameras focused directly on her and her
circumstances as an isolated inmate under constant surveillance.
Thank you for your continued assistance.
Best wishes to you and your family for a happy and healthy new year.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
New York, NY 10011
Main:
Cell:
Fax:
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
EFTA00023114

=== Page 3 ===
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.
EFTA00023115


c1: EFTA00021697
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021697.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Cc:
(NYPD)"
Subject: FW: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes
Date: Tue, 09 Mar 2021 19:13:54 +0000
Attachments: 2021.03.08_LAM_Letter_to_USAO_re_evidence_view_(F).pdf
Inline-Images: image001.jpg
Hey
Can we discuss this today, please?
Thanks,
From: Laura Menninger <lmenninger@hmflaw.com>
Sent: Monday, March 8, 2021 2:03 PM
To:
is
is
(USANYS)
Cc: Jeff Pagliuca <jpagliuca@hmflaw.com>; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
<ceverdell@cohengresser.com>; 'BOBBI C STERNHEIM' <bcsternheim@mac.com>
Subject: US V. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
Counsel -
Please see attached correspondence.
-Laura
Laura A. Menninger
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
Imenninger@hmflaw.com
www.hmflaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to it may contain information that is confidential or legally privileged. If you are not the intended
recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you
must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the
information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this
transmission in error, please notify the sender by telephone or return e-mail and delete the original
transmission and its attachments without reading or saving it in any manner. Thank you.
EFTA00021697

=== Page 2 ===
EFTA00021698


c1: EFTA00021014
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021014.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: RE: ATT records
Date: Tue, 02 Feb 2021 02:00:29 +0000
Embedded: RE:_ATT_records.msg
Sender
Subject: RE: ATT records
Message-Id:
<BN3P110MB0419663607083F3DA8A7B2BAF5B59@BN3P110MB0419.NAMP110.PROD.OUTLOOK.CO
M>
To:
Cc:
Cc:
Cc:
EFTA00021014


c1: EFTA00023487
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023487.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject:
Date: Thu, 11 Feb 2021 22:35:37 +0000
Attachments:
See attached. Judge Koetl has not yet ruled on this issue in
case.
Assistant United States Attorney
Southern District of New York
EFTA00023487


c1: EFTA00020592
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020592.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
June 01,2007-
AIR GHISLAINE INC
June 29, 2007
JPMorgan
Primary Account Number:
Private Bank
Total enclosures: 4
Page 1 of 4
JPMorgan Chase Bank, N.A.
262 000 PB
AIR GHISLAINE INC
Your JPMorgan Private Bank Team:
C/O NEW YORK STRATEGY GROUP LLC
FRANCISCO VILLACIS
MELISSA DALTON
NEW YORK NY 10022
Private Bank ServiceLine
For assistance after business hours,
7 days a week.
(800) 243-6727
Relationship Banking Summary
Deposit Accounts
Opening
Ending
Description
Number
Balance
Total Credits
Total Debits
Balance
Business Checking
$32,133.42
$7,550,000.00
$7,381,076 71
$201,056.71
Total
$201,056.71
GOVERNMENT
EXHIBIT
501
S2 20 Cr. 330 (AJN)
Confidential Treatment Requested by
JPM-SDNY-00008788
JPMorgan Chase
EFTA00020592

=== Page 2 ===
June 01, 2007-
AIR GHISLAINE INC
June 29, 2007
JPMorgan
Primary Account Number:
Private Bank
Page 2 of 4
Business Checking
Account Number
AIR GHISLAINE INC
Summary
Opening Balance
$32,133.42
Deposits and Credits
$7,550,000.00
Checks, Withdrawals and Debits
$7,381,076.71
Ending Balance
$201,056.71
Activity
Date
Description
Debit
Credits
Balance
Opening Balance
$32,133.42
Jun 12
Book Transfer Credit
$50,000.00
$82,133.42
B/O BELL HELICOPTER TEXTRON
FT WORTH TX 76101-
REF 417 DEPOSIT REFUND
Jun 18
Internal Funds Transfer
$7,400,000.00
$7,482,133.42
FUNDS TRANSFERRED FROM DDA AC# 7391
16312 TO DDA AC#
S reque
sted
Jun 18
Book Transfer
$7,352,825.00
$129,308.42
A/C: SIKORSKY AIRCRAFT CORP
STRATFORD CT 06614-1378
ORG /00000000000739474324
AIR GHISLAINE INC
REF RE PURCHASE OF A GREEN HELICOP
TER SIKORSKY S76C AND DOWNPAYMENT O
N EXECUTIVE FINISH
Jun 22
Internal Funds Transfer
$100,000.00
$229,308.42
FUNDS TRANSFERRED FROM DDA AC# 7391
16312 TO DDA AC#
As reque
sted
Jun 22
Check Paid # 1036
$2,570.00
$226,738.42
Jun 25
Check Paid # 1037
$5,487.59
$221,250.83
Jun 25
Check Paid # 1038
$14,706.53
$206,544.30
Jun 25
Check Paid # 1039
$5,487.59
$201,056.71
$7,381,076.71
$7,550,000.00
Ending Balance
$201,056.71
Checks Paid
Check
Date
Amount
Check
Date
Amount
Check
Date
Amount
1036
Jun 22
$2,570.00
1038
Jun 25
$14,706.53
1037
Jun 25
$5,487.59
1039
Jun 25
$5,487.59
Confidential Treatment Requested by
JPM-SDNY-00008789
JPMorgan Chase
EFTA00020593

=== Page 3 ===
June 01,2007-
AIR GHISLAINE INC
June 29, 2007
JPMorgan
Primary Account Number:
Private Bank
Page 3 of 4
Business Checking
Account Number
(cont.)
AIR GHISLAINE INC
Total Checks
$28,251.71
Enclosed Checks: 4
Fees and Charges for Business Accounts
We value your relationship with JPMorgan Private Bank. You were not charged for
services this statement period. Thank You.
Confidential Treatment Requested by
JPM-SDNY-00008790
JPMorgan Chase
EFTA00020594

=== Page 4 ===
June
01, 2007
AIR GHISLAINE INC
June
29, 2007
JPMorgan
Primary Account Number
Private Bank
Page 4 of 4
Important Information about Your Statement
Accounts are subject to the General Terms For Accounts and Services and applicable appendices and account agreements Your accounts, unless
otherwise indicated on the statement, are held by JPMorgan Chase Bank, N.A. (the "Bank").
Deposit accounts held at the Bank, including checking, savings, CD, and money market accounts, are FDIC insured
In Case of Errors or Questions About Your Electronic Funds Transfers (personal accounts only)
Telephone or write to the Bank if you think your statement or receipt is wrong, or if you need more information about an electronic Transaction on
a statement or receipt. The phone number for inquiries is printed on the front of this statement The address for inquiries appears below. We
must hear from you no later than 60 days after we sent you the FIRST statement on which the error or problem appeared
Tell us your name and account number.
Please direct all inquiries to your Morgan Account Officer at
Describe the error or the transfer you are unsure about,
JPMorgan Private Bank Client Service
and explain as clearly as you can why you believe it is an
500 Stanton Christiana Road, 1/OPS3
error or why you need more information
Newark, DE 19713-2107
Tell us the dollar amount of the suspected error
We will investigate your complaint and will correct any error promptly. If we take more than 10 business days to do this (20 business days for
transactions outside the U.S. and point-of-sale transactions), we will recredit your account for the amount you think is in error so that you will
have use of the money during the time it takes us to complete our investigation.
In Case of Errors or Questions About Non Electronic Transfers
Please examine your account at once If you feel an error has taken place or have questions concerning a non-electronic transaction, telephone or
write us within 30 days. The phone number is printed on the front of this statement The address appears above If no report is received within
this period, your account will be considered correct
Mutual Funds/Securities
Securities (including Mutual Funds) and annuities are not bank deposits and are not FDIC insured nor are they obligations
of or guaranteed by JPMorgan Chase Bank, N.A. or its affiliates or any federal or state government or government agency or
government sponsored agency. Securities (including mutual funds) and annuities involve investment risks, including the
possible loss of the principal amount invested.
The distributor of the JPMorgan Funds is JPMorgan Distribution Services, Inc., which is an affiliate of JPMorgan Chase Bank, N.A.. JPMorgan
Chase Bank, N.A., and its affiliates receive compensation from JPMorgan Funds for providing services. Read the JPMorgan Funds prospectuses
carefully for details, including fees and expenses, before investing or sending money.
JPMorgan Select Shares of the Connecticut Daily Tax Free Income Fund, Inc. and JPMorgan Select Shares of the New Jersey Daily Municipal
Income Fund, Inc. are not part of, or affiliated with, the JPMorgan Family of Mutual Funds Reich & Tang Distributors Inc. and Reich & Tang
Asset Management L.P., which are unaffiliated with JPMorgan, are the funds' distributors and investment advisor, respectively. Reich & Tang
Distributors Inc. is a member NASD.
IRA Accounts
Accounts where the Bank serves as trustee or as discretionary investment manager for an ERISA plan or an IRA that hold Fiduciary Shares (as
described below) do not bear any portion of investment, administrative, custodian or other charges paid to the Bank or its affiliates for services to
the applicable JPMorgan Funds since these charges are subject to rebate as defined below. For accounts where the Bank serves as mustee, or
discretionary investment manager for an ERISA plan or an IRA, which hold shares in the JPMorgan Funds other than Fiduciary Shares, the Bank
receives fees for services from the JPMorgan Funds but waives account fees with respect to the funds so held Fiduciary Shares are shares in the
Select Shares class of JPMorgan Tax Aware Large Cap Value Fund, JPMorgan US Equity Fund, JPMorgan Tax Aware US Equity Fund,
JPMorgan Tax Aware Large Cap Growth Fund, JPMorgan Mid Cap Equity Fund, JPMorgan Trust Small Cap Equity Fund, JPMorgan Fleming
International Equity Fund, JPMorgan Short Term Bond Fund II, JPMorgan Bond Fund II, JPMorgan Tax Aware Enhanced Income Fund,
JPMorgan Tax Aware Short-Intermediate Income Fund, JPMorgan Intermediate Tax-Free Income Fund, JPMorgan Tax-Free Income Fund,
JPMorgan California Bond Fund, JPMorgan NY Intermediate Tax Free Income Fund and JPMorgan NJ Tax Free Income Fund held in the Bank's
trust accounts or in the Bank's investment management accounts for ERISA plans or IRAs. "Rebate" means an amount returned by the Bank to
the account which holds the Fiduciary Shares. The rebate amount represents the portion of servicing fees paid to the Bank by the mutual fund
with respect to Fiduciary Shares.
Confidential Treatment Requested by
JPM-SDNY-00008791
JPMorgan Chase
EFTA00020595


c1: EFTA00021303
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021303.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
)
(Briefly describe the property to be searched
)
or identify the person by name and address)
)
Case No.
See Attachment A
)
)
)
SEARCH AND SEIZURE WARRANT
To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Southern
District of
New York
(identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before
July 7, 2019
(not to exceed 14 days)
in the daytime 6:00 a.m. to 10 p.m.
at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USMJ Initials
I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box)
for
days (not to exceed 30).
Juntil, the facts justifying, the later specific date of
Date and time issued:
7.7.19 2:03a.m
Bobattles Judge's signature
City and state: New York, NY
Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and title
EFTA00021303

=== Page 2 ===
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Case No.:
Date and time warrant executed:
Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
EFTA00021304

=== Page 3 ===
ATTACHMENT A
I. Premises to be Searched-Subject Premises
1.
The premises to be searched (the "Subject Premises") are described as a multi-story
single-family residence located at 9 East 71st Street, New York, New York, and include all locked
and closed containers found therein. A photograph of the front entrance to the Subject Premises
is included below:
Google
II. Items to Be Seized
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses
This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of
violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors) and 371
(sex trafficking conspiracy) (the "Subject Offenses") described as follows:
i. Any and all taxidermied dogs.
ii. Any and all massage tables and massage paraphernalia.
iii. Any and all busts or three-dimensional representations of female human
torsos.
iv. Any and all photos or representations depicting nude or partially nude
women located in the Massage Room, as defined herein.
V. Any and all sex toys and sex paraphernalia located in the Massage
Room, as defined herein.
2017.08.02
EFTA00021305

=== Page 4 ===
vi. A binder labeled "PB Girls" and any other documents or
communications with or regarding victims or potential victims of the
Subject Offenses.
2
2017.08.02
EFTA00021306


c1: EFTA00023456
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023456.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Accepted: Re: [EXTERNAL] RE: Touhy Request in United States V. Ghislaine Maxwell, S2
20 Cr. 330 (AJN)
Date: Fri, 29 Oct 2021 13:18:47 +0000
Importance: Normal
Attachments: unnamed
EFTA00023456


c1: EFTA00020685
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020685.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: "Moyne, Parvin"
Cc: Andrew Stemmer
, "Moyer, Thomas"
"DiPiero, Joseph"
Subject: RE:
Date: Thu, 05 Sep 2019 21:59:03 +0000
Received, thanks. And yes, if you could please send the other payments you've identified to those individuals and/or
entities, as well as any made to
or
(in addition to
) that would be very
helpful. We're working through the returns but the volume is obviously significant.
thanks again,
From: Moyne, Parvin
Sent: Wednesday, September 04, 2019 22:31
To:
Cc: Andrew Stemmer
>; Moyer, Thomas
>; DiPiero, Joseph
Subject:
The wire transfer records are located at DB-SDNY-0000478. Here is the relevant information for the requested
transfers:
WIRE DETAILS /
DATE
RECIPIENT
AMOUNT
BANK
ROUTING #
ACCOUNT #
INSTRUCTIONS
1/28/2015
$50,000
JP Morgan
N/A
021000021
4/22/2015
$50,000
JP Morgan
N/A
021000021
9/24/2015
$23,625
JP Morgan
N/A
021000021
11/30/2018
Aviloop
$100,000
TD Bank
011400071
N/A
LLC
Bank of
12/3/2018
$250,000
N/A
America
026009593
We have identified other payments to the same individuals and entities, which we can also send if helpful.
Best,
Parvin
Original message
From:
EFTA00020685

=== Page 2 ===
Date: 9/4/19 8:52 PM (GMT-05:00)
To: "Moyne, Parvin"
N
Andrew Stemmer
Cc: "Moyer, Thomas"
)"
Subject: RE: SDNY production, follow up
EXTERNAL Email
Parvin, Andrew,
In connection with part of Deutsche Bank's production, we have a follow-up request regarding certain wire
transfer records, specifically from the Butterfly Trust Account, as reflected in the attached. We're looking to get
the wire detail information for case numbers:
2021929, 12/03/18, $250,000, to
2021539, 11/30/18, $100,000, to Aviloop LLC
1385874, 04/22/15, $50,000, to
1339985, 01/28/15, $50,000, to
1462811, 09/24/15, $23,625.44, to
In particular, we're requesting the receiving bank name and account number information for each of the above
transactions, as well as any other associated details. Could you please provide that information? Or if you
already have, could you please point us in the right direction-I've looked through the production index to try to
track it down but wasn't successful.
thanks,
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
EFTA00020686


c1: EFTA00023037
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023037.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: FW: [EXTERNAL] Ghislaine Maxwell- 02879-509
Date: Tue, 12 Oct 2021 14:48:51 +0000
FYI
From: BOBBI C STERNHEIM
Sent: Tuesday, October 12, 2021 10:25 AM
To:
is
Subject: [EXTERNAL] Ghislaine Maxwell- 02879-509
Good morning-
The government has sent a hard drive to the MDC via Federal Express for Ms. Maxwell.
Upon arrival, it must IMMEDIATELY be given to Ms. Maxwell.
Time is of the essence.
Please inform me when it arrives.
Thank you-
Bobbi
Please note my new office address and preferred email address:
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
225 Broadway, Suite 715
New York, NY 10007
Main:
Cell:
Fax:
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim that may be
confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this
message. Thank you.
EFTA00023037


c1: EFTA00022088
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022088.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Request #1 (8/13/19)
(1) The signed log in the Special Housing Unit at MCC that shows when prison staff did rounds
on July 22 and 23, and Aug. 9 and 10. - the sign-in log in the SHU is signed by supervisors
when they visit the SHU and does not contain times. Both the log and the 30-minute round
forms and count slips are subject to the protective order in the Noel case and should not be
produced ahead of trial.
(2) All quarter entries (showing which cells he was housed in) for Jeffrey Epstein at MCC. I
don't see why this necessarily needs to be held back; but at the same time I think it's entirely
defensible to not produce piecemeal the BOP records related to Epstein prior to trial.
(3) The CIM Clearance and Separatee data sheet for Jeffrey Epstein at MCC. I don't believe he
had any separates. I don't feel strongly about the CIM clearance.
(4) The chronological disciplinary records for Jeffrey Epstein at MCC. This would only include
the 7/23 suicide attempt, which should not be disclosed prior to trial because we may have
witnesses testify about it. I would think this could be released after trial.
(5) The intake screening form for Jeffrey Epstein at MCC.
(6) The security designation records for Jeffrey Epstein at MCC.
(7) The inmate profile for Jeffrey Epstein at MCC.
(8) All incident reports related to Jeffrey Epstein at MCC.
(9) All medical reports related to Jeffrey Epstein at MCC.
I do not think we should produce the above, which are subject to the Protective Order, could
likely be produced in some fashion after trial, and relate to topics that witnesses will testify
about at trial.
(10) The signed visitor log for Jeffrey Epstein at MCC.
He did not have any visitors other than legal visitors - query whether this can be produced.
(11) Documents showing when MCC staff held meetings regarding Jeffrey Epstein, and who
attended.
(12) All records generated from the meeting at MCC during which it was decided that Jeffrey
Epstein would be taken off suicide watch.
(13) The Post-Watch report compiled in order to take Jeffrey Epstein off suicide watch.
(14) The overtime sign-up sheets for the Special Housing Unit (9 South) at MCC for Aug. 9 and
10, and on July 22 and 23.
(15) Documents showing which staff were augmented at MCC and what positions they worked
in on Aug. 9 and 10, and on July 22 and 23.
I do not think we should produce the above, which are subject to the Protective Order, could
likely be produced in some fashion after trial, and relate to topics that witnesses will testify
about at trial.
EFTA00022088

=== Page 2 ===
Request #2 (8/13/19)
(1) All video camera footage at MCC pertinent to the Jeffrey Epstein suicide and the first suicide
attempt.
(2) All BOP documents pertaining to Jeffrey Epstein's suicide and first suicide attempt.
(3) All BOP documents, including email correspondence and meeting minutes, pertaining to the
decision to remove Jeffrey Epstein from suicide watch.
(4) All BOP special investigation reports mentioning Jeffrey Epstein.
(5) All BOP correspondence with the U.S. Attorney's Office regarding Jeffrey Epstein.
I do not think we should produce the above, which are subject to the Protective Order, could
likely be produced in some fashion after trial, and relate to topics that witnesses will testify
about at trial.
Request #3 (12/19/19)
(1) The full log of Mr. Epstein's phone calls to and from the MCC. Does not exist.
(2) All email correspondence to and from Mr. Epstein while he was at the MCC (including
any correspondence through the Corrlinks system or any other email system he had
access to.) Does not exist.
EFTA00022089


c1: EFTA00022059
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022059.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(USANYS)"
(USANYS)"
i
(USANYS)"
i
"Potter,
(USANYS)"
Cc:
(USANYS)"
(USANYS)"
(USANYS) 2"
(USANYS)"
i
,
(USANYS) 1"
Subject: FW: MLA Request: Material Witness PA 182-73090
Date: Tue, 07 Apr 2020 18:52:06 +0000
Attachments: Cover_Letter_73090_Witness_PA.pdf; Material_Witness_PA_Final.pdf
See below and attached. The MLA request regarding Prince Andrew has officially been delivered to the UK.
From:
(London)
Sent: Tuesday, April 7, 2020 10:53 AM
To:
(USANYS)
is
(USANYS)
is
(USANYS)
Cc:
(CRM)
is
(London)
i
(CRM)
Subject: MLA Request: Material Witness PA 182-73090
-
The MLA request was forwarded this morning to the UK Central Authority at the Home Office. Each person to
whom it was sent is noted on the cover letter. I also swapped emails with Philomena Creffield (she is head of the
MLA unit at the UKCA) this morning regarding our request to keep a written record of each person who sees
the MLA request.
Their initial reaction was one of surprise regarding its timing. The pandemic in London is expected to peak in
the next week or two and the UKCA is operating at emergency staffing levels. We talked it through, and I
explained that while this is an important case, we understood that everyone is operating at reduced capacity, and
we would adjust our expectations regarding response time accordingly. I also noted that we have been regularly
forwarding new MLA requests to the UK throughout this period (just not requests with such high-profile
subjects). I also pointed out that while the timing is very unfortunate, it did not have to be this way. I explained
that the case team had been trying to contact the witness's representatives to obtain a voluntary interview for
months without any success.
Here is some general information about the MLA process:
The cover letter and mutual legal assistance request were sent to the UK Central Authority (UKCA) on April 7, 2020, via
email. Lawyers at the UKCA will conduct an initial review of the request for compliance with the MLA Treaty, and then
assign it out to one or more law enforcement agencies to gather the requested evidence. The UKCA review can take
anywhere from 7-30 days. In complex cases, it can take longer. We will provide notice to you when the request is
assigned to a law enforcement agency for execution. (Our operating assumption is that it will be assigned to the London
Metropolitan Police to execute -- and likely to the same unit which responded to
initial complaint.)
It usually takes several months for the UK law enforcement agency to assess the request, obtain the legal process, gather
the evidence, provide that evidence to the UKCA, which will in turn provide the evidence to our office. In this case, the
law enforcement agency will make another assessment of the legal basis for the request and determine whether legal
EFTA00022059

=== Page 2 ===
process (such as a judicial order) is necessary to execute the request. If the witness agrees to an interview and agrees to
turn over documents, then legal process will not be required. If he declines, then they will need to obtain legal process.
A decision by the UKCA to approve an MLA request, and a decision by the law enforcement agency to execute the MLA
request can be challenged in a process called "Judicial Review" or "JR". If a witness seeks to resist the production of
evidence or an interview, the first reaction is typically delay. The second reaction is to file a JR action. If that happens, I
can walk you through that lengthy process.
Our practice is to let the UK execution process run for 90 days before making a status inquiry. After that, we will typically
inquire every 30 days unless the UKCA has informed us that it is a particularly difficult matter and inquiring every 30 days
would be fruitless. This is a unique case, so we will likely inquire at least monthly going forward.
In the event that we receive partial results from the UKCA (such as in cases where multiple law enforcement agencies
have been assigned to execute your request), we will typically provide those partial results to you shortly after we receive
them from the UKCA.
A few requests:
Critical Evidence: If a limited portion of your request is critical to your case and a prompt response would substantially
assist your case preparation, please let us know. Please identify the specific requested evidence and the date by which it
would particularly assist. We assume that everything you ask for is important, so there is no need to reiterate that.
Trial Dates: If you have a trial or other specific deadline, please let us know so we can inform the UKCA and track your
matter with an eye to that deadline.
Filing MLA Requests: Please do not file with a court a copy of the attached completed MLA request. This has backfired
in a number of cases in the past and poses substantial risks. (Please call if you are considering such a filing.) By contrast,
if you file a motion pursuant to 18 U.S.C. $3292 you may file the cover letter transmitting the request (but not the request
itself).
Withdrawal of your request: Should you no longer need the evidence requested, such as in the event of a plea, please
notify our office as soon as possible so that we may withdraw the request and close our file.
U.S. Department of Justice Attaché
U.S. Embassy London
Mobile:
EFTA00022060


c1: EFTA00020784
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020784.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "cmecf@ca2.uscourts.gov" <cmecf@ca2.uscourts.gov>
To:
Subject: 21-58 United States of America V. Maxwell "Motion Order FILED denying for bail"
Date: Tue, 27 Apr 2021 17:57:03 +0000
***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits
attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of
all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees
apply to all other users. To avoid later charges, download a copy of each document during this first
viewing.
Court of Appeals, 2nd Circuit
Notice of Docket Activity
The following transaction was filed on 04/27/2021
Case Name:
United States of America V. Maxwell
Case Number: 21-58
Document(s): Document(s)
Docket Text:
MOTION ORDER, denying motion for bail [39] filed by Appellant Ghislaine Maxwell, by PNL, RJL, RJS,
FILED. [3087715][86] [21-58, 21-770]
Notice will be electronically mailed to:
Notice will be stored in the notice cart for:
Quality Control 1
The following document(s) are associated with this transaction:
Document Description: Motion Order FILED
Original Filename: 21-58.pdf
Electronic Document Stamp:
[STAMP acecfStamp_ID=1161632333 [Date=04/27/2021] [FileNumber=3087715-0]
[c4dae9d83e3602096564248f5bfcc0e89b9f8c55fe4ec1014f3c2db1a909f4f7c8b360f2544b2115306751b7aa82b9
4f70f4198d95fcdcb8ef868b204742b03e]]
EFTA00020784


c1: EFTA00023136
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023136.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Subject: FW: Call re
Date: Fri, 27 Mar 2020 21:30:52 +0000
Attachments: [Compare_New]_2020.03.27
draft_submission.pdf
Original Message
From:
)
Sent: Friday, March 27, 2020 17:28
To:
)
Subject: FW: Call re
Original Message
From: Kathleen E. Cassidy
Sent: Friday, March 27, 2020 16:30
To:
)
i
)
Cc: Susan Necheles
>; ; Samidh Guha
;
Subject: RE: Call re
Attached is our most recent draft for discussion purposes.
Thanks,
Kate
Original Message
From:
)
Sent: Friday, March 27, 2020 1:57 PM
To: Kathleen E. Cassidy
i
)
Cc: Susan Necheles
; Samidh Guha
i
;
Subject: RE: Call re
Confirmed, thanks very much.
Original Message
From: Kathleen E. Cassidy
Sent: Friday, March 27, 2020 1:39 PM
To:
)
Cc: Susan Necheles
Samidh Guha
;
)
)
Subject: Re: Call re
Yes we can all do 3pm tomorrow. We can use the same call-in
pin
Sent from my iPhone
EFTA00023136

=== Page 2 ===
> On Mar 27, 2020, at 12:25 PM,
)
wrote:
V
> Kate,
V
> Would it work to plan to have a call tomorrow at 3:00? That would give us about a day to review and internally
discuss. Or if that timing doesn't work on your side, please let us know -- we're flexible on timing, especially
since it's a weekend and given all the circumstances.
>
>
thanks,
V
>
>
Original Message
>
From: Kathleen E. Cassidy
> Sent: Friday, March 27, 2020 11:43
> To:
>
Cc: Susan Necheles
;
Samidh Guha
V
>
>
Subject: RE: Call re
V
>
> Sorry for the delay -- we plan to send you a revised draft submission in the early afternoon today. After you
have had a chance to review, can we discuss? Either later today, or perhaps more realistically over the weekend?
> Thanks, Kate
V
>
Original Message
> From:
> Sent: Wednesday, March 25, 2020 1:51 PM
> To: Kathleen E. Cassidy
>
Cc: Susan Necheles
>; Samidh Guha
V
>
>
Subject: RE: Call re
V
>
Great thank you!
>
V
Original Message
V
From: Kathleen E. Cassidy
> Sent: Wednesday, March 25, 2020 13:51
> To:
V
Cc: Susan Necheles
>; Samidh Guha
V
>
>
Subject: Re: Call re
V
V
Yes we can use the same call in number.
>
>
Sent from my iPhone
V
On Mar 25, 2020, at 1:21 PM,
)
wrote:
>> I know we were bandying about the idea of a zoom discussion yesterday but I'm actually going to be away
from a computer this afternoon - alright to do a call-in to the same conference number as yesterday?
EFTA00023137

=== Page 3 ===
Original Appointment
From: Kathleen E. Cassidy
>>
Sent: Tuesday, March 24, 2020 20:15
>>
To: Susan Necheles; Samidh Guha;
);
);
)
Subject: Call re
When: Wednesday, March 25, 2020 16:00-17:00 (UTC-05:00) Eastern Time (US & Canada).
Where:
https://zoom.us/j/143912742?pwd=ekdqQkpjeGQ4bWNzRkNQZmtIUWFFdz09
>>
gedalia Stern is inviting you to a scheduled Zoom meeting.
>>
Join Zoom Meeting
https://zoom.us/j/143912742?pwd=ekdqQkpjeGQ4bWNzRkNQZm1IUWFFdz09
>>
Meeting ID: 143 912 742
Password: 704696
>>
One tap mobile
+19292056099,143912742# US (New York) 13126266799,, 143912742# US
>> +(Chicago)
>>
>>
Dial by your location
>> +1 929 205 6099 US (New York)
>> +1 312 626 6799 US (Chicago)
>> +1 346 248 7799 US (Houston)
>> +1 669 900 6833 US (San Jose)
>> +1 253 215 8782 US
>> +1 301 715 8592 US
>>
Meeting ID: 143 912 742
>>
Find your local number: https://zoom.us/u/acaYAcAEbj
EFTA00023138


c1: EFTA00020830
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020830.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
)"
To:
"
)"
Cc: "
(USANYS)"
Bcc: "USAHUB-USAJournal111"
Subject: Re: JE iPhone review
Date: Sat, 07 Nov 2020 04:52:22 +0000
Embedded: Re:_JE_iPhone_review.msg
Sender:
Subject: Re: JE iPhone review
Message-Id: <563A6E10-78B5-4227-A85A-0B02018E4847@usa.doj.gov>
To:
Cc:
EFTA00020830


c1: EFTA00021202
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021202.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: The Washington Post <email@washingtonpost.com>
To:
Subject: The Daily 202: Five things to watch when Bob Mueller testifies
Date: Wed, 26 Jun 2019 13:28:11 +0000
If you're having trouble reading this, click here.
The Daily 202
Share:
fa
lis Listen to The Big Idea
Five things to watch when Bob Mueller testifies
'The report is my testimony': Mueller would not provide Congress new information
ITEM.
BYLINE
BY JAMES HOHMANN
TEXT
with Joanie Greve and Mariana Alfaro
THE BIG IDEA: Bob Mueller thought his public statement last
month could get him out of testifying before Congress about
his 448-page report and 22-month investigation. He thought
wrong.
Complying with a subpoena issued yesterday, the former special
counsel has agreed to appear in back-to-back public hearings on
July 17 before two House committees. Intelligence Chairman Adam
Schiff (D-Calif.) and Judiciary Chairman Jerry Nadler (D-N.Y.)
needed to issue a subpoena to persuade Mueller to appear, but the
duo pledged in a letter that they will work with him to address his
"legitimate concerns about preserving the integrity" of his probe and
EFTA00021202

=== Page 2 ===
said they will respect his desire not to discuss the "several criminal
investigations" that he referred to other Justice Department offices,
which are ongoing.
Here are five things to watch for at the hearing three
Wednesdays from now:
What you need to know about Trump, Mueller and obstruction of justice
1) Will Mueller say anything he hasn't said already?
Don't count on it.
"The report is my testimony," the former special counsel said on
May 29. "Any testimony from this office would not go beyond our
report. I would not provide information beyond that which is
already public in any appearance before Congress."
The 74-year-old is no novice. It seems exceptionally unlikely that
Mueller will be baited into saying something he doesn't want to say.
He's testified before Congress more than 50 times, including during
high-profile hearings as FBI director after the 9/11 attacks and the
2013 Boston Marathon bombings. The C-SPAN archive includes
more than 140 hours of footage of him fielding questions from
sometimes hostile lawmakers.
"Mueller is no longer a Justice Department employee, and after the
special counsel's office formally closed last month, he and his
personal representatives had been negotiating directly with the
committee. Those who know him well said that it was virtually
impossible that he would ignore or reject a subpoena," per Rachael
Bade, Matt Zapotosky and Karoun Demirjian. "Still, Mueller is
EFTA00021203

=== Page 3 ===
unlikely to answer Democrats' biggest question: whether he or his
team thought there was sufficient evidence to charge President
Trump with obstruction, were he not president."
He said during his brief remarks at the Justice Department that if his
office "had confidence that the president clearly did not commit a
crime, we would have said so," and he noted that the Constitution
"requires a process other than the criminal justice system to
formally accuse a sitting president of wrongdoing."
On the other hand: Even if Mueller just reads directly from his
report, it could have a huge impact. Most Americans and even many
lawmakers have not read the whole thing.
From a former FBI special agent who now teaches at Yale:
The former White House counsel who flipped on Richard Nixon said
Mueller can change the conversation:
Nixon's White House counsel says Mueller provided House committee with 'a roadmap'
2) Can Democratic leaders keep expectations in check and
prevent the hearings from becoming a circus?
Privately, many House Democrats and their aides worry they will not
be able to. This is going to be a television extravaganza. Cable
channels on the right and left will cover Mueller's appearance wall
to wall. The networks will likely preempt regularly scheduled
programming. But if Mueller doesn't say anything groundbreaking or
EFTA00021204

=== Page 4 ===
explosive despite weeks of hype, the narrative could be that his
appearance was a let down for Democrats.
Moreover, it's politically imperative for Democrats that they look like
they are motivated by a pursuit of the truth rather than a partisan
vendetta against the president. Underscoring why that is, Trump
cried "Presidential Harassment!" last night when news broke of
Mueller's appearance.
Grandstanding lawmakers pulling sophomoric stunts could play into
Trump's hands. Think of Rep. Steve Cohen eating Kentucky Fried
Chicken last month when Attorney General Bill Barr didn't show up
for a hearing.
An Obama-era Justice Department spokesman tried to keep
expectations check:
A Democratic senator from Hawaii emphasized that it will take an
election to replace Trump:
Asked about Mueller testimony, Trump pivots to Mueller's 'conflicts' of interest
3) Will Trump's Republican allies successfully cast doubt on
Mueller's credibility and stain his sterling reputation? Or will
they come across as partisan and unserious about his
conclusions?
EFTA00021205

=== Page 5 ===
"Bob Mueller better be prepared," Rep. Mark Meadows (R-N.C.) told
Laura Ingraham on Fox News last night. "Because I can tell you, he
will be cross-examined for the first time and the American people
will start to see the flaws in his report."
"The first thing he needs to answer is his own conflicts of interest,"
added Trump lawyer Jay Sekulow on Sean Hannity's Fox show.
Mueller's unwillingness to engage in a tit-for-tat with Trump and Co.
throughout his probe kept him above the fray, but it also allowed the
president's boosters to make scurrilous charges about the Vietnam
veteran's integrity without strong pushback. Does he finally stand up
for himself? Or does he cling to the idea that the quality of his work
product speaks for itself?
Rep. Justin Amash (R-Mich.), the only GOP lawmaker who has
endorsed impeachment, does not sit on either committee so he
won't get a round of questioning.
Senate Judiciary Committee Chairman Lindsey Graham (R-S.C.)
continues to resist calls to hold hearings on the Mueller report in the
other chamber. "It is 'case closed' for me," Graham told Hannity on
Fox last night. "They can do anything they want to in the House,
and I think it will blow up in their face.
The conclusions can't
change."
How Barr appeared to misrepresent Mueller's findings
4) Does Mueller's appearance make it easier or harder for
Nancy Pelosi to contain calls for impeachment from her
caucus?
EFTA00021206

=== Page 6 ===
"Members of Congress must honor our oath and our patriotic duty to
follow the facts, so we can protect our democracy," the speaker said
in a statement last night.
Nearly 80 House Democrats are now on the record calling for
opening impeachment proceedings against Trump. Mueller's sole
public appearance in May didn't include any new information, but it
nonetheless offered a justification for a stream of Democratic
presidential candidates to call for the president's impeachment.
Something similar could happen again. More House Democrats
could use whatever Mueller says as cover to change their positions
- or they could oppose impeachment on the grounds that oversight
is being conducted without it.
The answer probably depends primarily on whether Mueller's
testimony moves the needle in the polls. As Pelosi loves to say,
"Public sentiment is everything."
Andrew Goldstein, a lead prosecutor for Mueller, walks through
the rain outside the building where the Mueller team did its work in
March. (J. Scott Applewhite/AP)
Andrew Goldstein, a lead prosecutor for Mueller, walks through the rain outside the building where
the Mueller team did its work in March. (J. Scott Applewhite/AP)
5) Will any of Mueller's lieutenants appear?
"An unspecified number of the special counsel's senior deputies are
expected to accompany their former boss and testify in closed
session when Mueller appears next month," Politico's Darren
Samuelsohn and Kyle Cheney report. "Schiff declined Tuesday
night to identify the deputies, and it was also unclear if they would
EFTA00021207

=== Page 7 ===
be appearing under subpoena. Democrats also haven't precluded
bringing the former Mueller lawyers back for additional rounds. 'I
think that's likely to happen after Mueller testifies,' said Rhode
Island Rep. David Cicilline, another Judiciary Committee Democrat.
'There are additional witnesses. But he's the principal in terms of
the contents of the report."
Mueller's team has been scattering. "Andrew Goldstein, a senior
assistant special counsel under Mueller, will join the Cooley law firm
as a litigation partner working in New York and Washington,"
Zapotosky reported on Monday. "On Friday, the firm Paul Weiss
announced it would add Jeannie Rhee, another senior member of
Mueller's team who had left the WilmerHale firm to work on the
special counsel investigation. The Justice Department revealed this
week that Michael Dreeben, a deputy solicitor general who has
argued more than 100 cases before the Supreme Court and took a
sabbatical to work with Mueller, would be leaving the department.
Last month, the firm Davis Polk announced it would add Greg
Andres, the senior assistant special counsel who led the
prosecution of former Trump campaign chairman Paul Manafort, to
its litigation department in New York.
Andrew Weissmann,
another senior assistant special counsel who is now a fellow at New
York University School of Law, is writing a book."
The Trump International Hotel is located at 1100 Pennsylvania
Ave NW. (Jonathan Newton/The Washington Post)
The Trump International Hotel is located at 1100 Pennsylvania Ave NW. (Jonathan Newton/The
Washington Post)
EFTA00021208

=== Page 8 ===
-- No matter what happens, Mueller's testimony won't clear the
thicket of thorny legal issues facing Trump. There was a
significant development yesterday, for example, in one of the
emoluments challenges:
"Rejecting a request from President Trump, a federal judge in
Washington on Tuesday cleared the way for nearly 200
Democrats in Congress to continue their lawsuit against him
alleging that his private business violates an anti-corruption
provision of the Constitution," Ann Marimow, Jonathan O'Connell
and Carol Leonnig report. "U.S. District Judge Emmet G. Sullivan
declined to put the case on hold and said lawmakers could begin
this week seeking financial information, interviews and other
records from the Trump Organization.
Sullivan ordered the two
parties to begin the process of requesting records and other
information as part of a three-month discovery period from Friday to
Sept. 27. The Trump administration still can try to delay or block
Democrats in Congress from issuing subpoenas for the president's
closely held business information by appealing directly to the U.S.
Court of Appeals for the D.C. Circuit to intervene. Justice
Department spokeswoman Kelly Laco said the government would
appeal."
The emoluments clauses bar the president from accepting gifts or
payments from foreign or state governments. The cases, which
seem destined for the Supreme Court, mark the first time that
federal judges have interpreted these clauses. Trump is being sued
by the members of Congress in one case and states in the other. In
the second case, brought by the attorneys general of the
District of Columbia and Maryland, a federal judge also denied
the Trump administration's request for an immediate appeal.
EFTA00021209

=== Page 9 ===
But the U.S. Court of Appeals for the 4th Circuit, which is
based in Richmond and hears Maryland-related federal
appeals, agreed to review the case and temporarily blocked
subpoenas for financial records and other documents related to
Trump's D.C. hotel. The 4th Circuit heard oral argument in March
and could issue a ruling at any time.
The Daily 202's BIG IDEA > Get James' insight into Washington every weekday on your
smart speaker or favorite podcast player.
Subscribe on Amazon Echo, Google Home, Apple HomePod and other podcast
players.
Welcome to the Daily 202, PowerPost's morning briefing for decision-makers.
Sign up to receive the newsletter.
WHILE YOU WERE SLEEPING:
EFTA00021210

=== Page 10 ===
A promotional poster for an NRATV show featuring Oliver North
hangs during the group's annual meeting in Indianapolis. (Daniel
Acker/Bloomberg)
A promotional poster for an NRATV show featuring Oliver North hangs during the group's annual
meeting in Indianapolis. (Daniel Acker/Bloomberg)
-- The National Riffle Association shut down NRATV. The New
York Times's Danny Hakim reports: "The N.R.A. on Tuesday also
severed all business with its estranged advertising firm, Ackerman
McQueen, which operates NRATV, the N.R.A.'s live broadcasting
media arm While NRATV may continue to air past content, its live
broadcasting will end and its on-air personalities - Ackerman
employees including Dana Loesch - will no longer be the public
faces of the N.R.A. It remained unclear whether the N.R.A. might try
to hire some of those employees, but there was no indication it was
negotiating to do so. 'Many members expressed concern about
the messaging on NRATV becoming too far removed from our core
mission: defending the Second Amendment,' Wayne LaPierre, the
N.R.A.'s longtime chief executive, wrote in a message to members
that was expected to be sent out by Wednesday.
Ackerman, in its
own statement, said it was 'not surprised that the N.R.A. is unwilling
to honor its agreement to end our contract and our long-standing
relationship in an orderly and amicable manner."
-- An employee at a high-end Chicago cocktail bar was
questioned by the Secret Service last night after allegedly
spitting in Eric Trump's face, per Tim Elfrink and Mark Guarino.
EFTA00021211

=== Page 11 ===
The president's son confirmed the incident at the Aviary to
Breitbart News early this morning. "When somebody is sick
enough to resort to spitting on someone, it just emphasizes a
sickness and desperation and the fact that we're winning," the
35-year-old told the right-wing site.
The Chicago Police Department's spokesman referred
questions to the Secret Service, which did not immediately
comment.
Rep. Duncan Hunter, wife charged with spending campaign money on personal expenses
GET SMART FAST:
1. Rep. Duncan Hunter (R-Calif.) illegally misused campaign
funds to facilitate extramarital affairs with at least five
women, according to a new court filing from the Justice
Department. Federal prosecutors want to show jurors evidence
that Hunter took money from his campaign account to pay for
dinners, drinks and trips with women he was romantically
involved with - including an employee of his congressional
office, a staffer to a member of House GOP leadership and
three different lobbyists. A Democrat running against Hunter in
2020 said "he's literally in bed with lobbyists." Hunter, who
promises to fight the charges in court, declined to respond to
any of the allegations. (Matt Zapotosky and Hailey Fuchs)
2. Federal prosecutors are fighting efforts to throw out the
lenient non-prosecution agreement that Labor Secretary
Alex Acosta, as a prosecutor, offered to alleged sex
trafficker Jeffrey Epstein. The Justice Department told a
federal judge that Epstein's alleged victims, who were not
EFTA00021212

=== Page 12 ===
properly notified about what they view as a sweetheart deal,
have no right to remedies from the government because the
Crime Victims' Rights Act does not outline specific penalties.
(Miami Herald)
3. The National Security Agency ended a controversial
counterterrorism program after learning that millions of
Americans' phone records had been collected in error. The
agency said its purged the records in what was the second
instance of "over-collection" recorded by the NSA last year.
(Ellen Nakashima)
4. A new Alabama law severs the parental rights of those
convicted of first-degree rape. The ability of convicted rapists
in the state to seek custody of children conceived through their
assaults gained renewed attention after Alabama passed a law
outlawing abortion in nearly all circumstances, including
instances of rape and incest. (Emily Wax-Thibodeaux)
5. A court has ruled that the Office of Personnel Management
is responsible for the 2015 hack of of 22 million people's
personal information. According to a federal appeals court,
the office ignored repeated warnings from its inspector
general's office that the databases were vulnerable. (Eric Yoder)
6. Two U.S. service members were killed in Afghanistan. No
more information is known about them at this stage, including
how they died. (CNN)
7. Illinois became the 11th state to legalize marijuana for
recreational use. The legalization will also let nearly 800,000
EFTA00021213

=== Page 13 ===
people with criminal records for purchasing or possessing 30
grams of marijuana or less expunge their records. (AP)
8. An effort to boost lawmaker pay has been nixed after
backlash. House Majority Leader Steny Hoyer's plans were
met with bipartisan protest. (Mike DeBonis and Karoun
Demirjian)
9. Tiffany Cabán, a liberal public defender backed by Rep.
Alexandria Ocasio-Cortez, declared victory in the Queens
district attorney Democratic primary. Cabán had a lead of
just over 1,000 votes over her closest challenger with 99
percent of precincts reporting in a race that became a national
proxy battle. It's a blow for Greg Meeks and the Democratic
establishment in New York. (CBS News)
10. Three men were killed at a Ford dealership in California. A
witness said that the shooter, whose body police found with an
apparently self-inflicted gunshot wound, had been fired that day
and came back to shoot two managers. (Mercury News)
11. Paris is installing temporary water fountains and keeping
pools open late to combat a massive heat wave hitting
Europe. Temperatures across the continent are expected to
rise up to 35 degrees Fahrenheit above normal, but France is
being particularly cautious given the 15,000 deaths the country
saw during a similar heat wave in 2003. (Claire Parker)
12. The number of Americans who say they have never
attended religious services has nearly doubled since 2000.
According to the most recent NBC-Wall Street Journal poll, 26
percent of Americans report never having attended religious
services, compared to 14 percent in 2000. Among those
EFTA00021214

=== Page 14 ===
between the ages of 18 and 34, the figure is even higher at 36
percent. (Wall Street Journal)
13. Jan Meyers, the first Republican woman elected to
Congress from Kansas, died at 90. A moderate who
represented a stretch of northeast Kansas from 1985 to 1997,
Meyers rose through the ranks of the House to become chair of
the Small Business Committee. (Harrison Smith)
14. A YouTube star was found dead in New York's East River
following a number of erratic videos and police
confrontations. Desmond Amofah, known as Etika, was
famous for his gaming channel, which he had recentuly turned
into a venue for rants and confrontations with police officers.
(Avi Selk)
15. Breakdancing might make its first appearance at the
Olympics soon after the International Olympic Committee
voted in favor of a proposal that could bring the dance
style to the 2024 Summer Games in Paris. Skateboarding,
climbing/bouldering and surfing are also among the activities
proposed to be added to the events program. (CNN)
The bodies of Salvadoran migrant Oscar Alberto Martínez
Ramírez and his nearly 2-year-old daughter Valeria lie on the bank
of the Rio Grande in Matamoros, Mexico, on Monday after they
drowned trying to cross the river to Brownsville, Texas. (Julia Le
Duc/AP)
The bodies of Salvadoran migrant Oscar Alberto Martinez Ramírez and his nearly 2-year-old
daughter Valeria lie on the bank of the Rio Grande in Matamoros, Mexico, on Monday after they
drowned trying to cross the river to Brownsville, Texas. (Julia Le Duc/AP)
THE IMMIGRATION WARS ARE KILLING PEOPLE:
EFTA00021215

=== Page 15 ===
-- The image of the drowned bodies of a Salvadoran man and
his baby daughter lying face down on the bank of the Rio
Grande after attempting to cross the border has sparked
outrage as Trump's policies continue putting the lives of
migrants at risk. From the AP's Peter Orsi and Amy Guthrie: "Her
arm was draped around his neck suggesting she clung to him in her
final moments. The searing photograph of the sad discovery of their
bodies [see above] highlights the perils faced by mostly Central
American migrants fleeing violence and poverty and hoping for
asylum in the United States. Óscar Alberto Martínez Ramírez,
frustrated because the family from El Salvador was unable to
present themselves to U.S. authorities and request asylum,
swam across the river on Sunday with his daughter, Valeria. He
set her on the U.S. bank of the river and started back for his
wife, Tania Vanessa Ávalos, but seeing him move away the girl
threw herself into the waters. Martínez returned and was able
to grab Valeria, but the current swept them both away.
"Details of the incident were confirmed Tuesday by a Tamaulipas
government official and by Martínez's mother back in El Salvador,
Rosa Ramírez, who spoke with her daughter-in-law by phone
afterward. Ramírez said her son and his family left El Salvador on
April 3 and spent about two months at a shelter in Tapachula, near
Mexico's border with Guatemala. 'I begged them not to go, but he
wanted to scrape together money to build a home,' Ramírez
said. 'They hoped to be there a few years and save up for the
house.' El Salvador's foreign ministry said it was working to assist
the family including Ávalos, who was at a border migrant shelter
following the drownings. The bodies were expected to be flown to El
Salvador on Thursday. The photo recalls the 2015 image of a
3-year-old Syrian boy who drowned in the Mediterranean near
EFTA00021216

=== Page 16 ===
Turkey, though it remains to be seen whether it may have the
same impact in focusing international attention on migration to
the U.S. U.S. 'metering' policy has dramatically reduced the
number of migrants who are allowed to request asylum, down from
dozens per day previously to sometimes just a handful at some
ports of entry."
-- The House passed a $4.5 billion emergency border aid bill
that includes provisions requiring better treatment of migrant
children in U.S. custody, which were added to secure passage
amid bubbling anger over Trump's handling of the crisis. Mike
DeBonis and Erica Werner report: "The 230-to-195 vote, largely
along party lines, followed a flurry of last-minute negotiations among
Democrats who said they have been horrified by reports of poor
conditions at overcrowded U.S. Customs and Border Protection
facilities where unaccompanied children have been kept. The bill's
passage sets up a high-stakes negotiation with Trump and Senate
Republicans to deliver aid days before a looming deadline.
House Appropriations Committee Chairwoman Nita M. Lowey (D-
N.Y.) unveiled changes to the bill Tuesday morning that would
require CBP to establish new health and safety standards for
migrants in its custody, as well as protocols for dealing with migrant
surges, within 30 days. The changes would also limit children's
stays at 'influx' shelters used by the Department of Health and
Human Services to no more than 90 days and require the
department to report to Congress on their use."
-- Palace intrigue: A week after beginning his reelection
campaign with promises of mass deportations, Trump sent the
agencies responsible for immigration enforcement deeper into
disarray by replacing his interim border chief with a figure he
EFTA00021217

=== Page 17 ===
plucked from cable news punditry last month. "Mark Morgan,
who Trump installed as acting director of U.S. Immigration and
Customs Enforcement in early June, will take over as acting
commissioner of Customs and Border Protection, replacing John
Sanders," per Nick Miroff and Josh Dawsey. "The shake-up
Tuesday comes after weeks of interagency squabbles and political
knifings among agency officials Since April, the president has
purged nearly all of the top officials remaining at DHS from the
beginning of his term, leaving every immigration-related U.S.
agency with an interim leader.
"Immigration hard-liners in recent days have been pushing
Trump to remove acting DHS secretary Kevin McAleenan at the
moment when the policies McAleenan has advanced -
including a deal with Mexico for an unprecedented immigration
crackdown there - are beginning to yield results. U.S.
authorities detained more than 144,000 migrants last month along
the Mexico border, the highest level since 2006, but preliminary
reports indicate fewer have been crossing in recent weeks and
others are being turned back by Mexican military forces. McAleenan
on Tuesday was en route to meetings with officials in Central
America, where the Trump administration is seeking a separate
accord that would allow the United States to send asylum seekers
back to the first foreign nation where they step foot after fleeing their
homelands.
"McAleenan had challenged the feasibility and timing of the
[ICE] raids Morgan had pushed for the 'family op' to go
forward, and it was not clear whether the decision to move him
from ICE to a loftier position at CBP was a consolation for losing out
to McAleenan. One person who has spoken with Trump about
EFTA00021218

=== Page 18 ===
immigration said the president has heard from senior immigration
adviser Stephen Miller and others around him that 'everyone at
DHS is weak."
-- The U.S. returned 100 migrant children to the overcrowded
border facility in Clint, Tex., after trying to find temporary
alternatives - including tents and other border
facilities. Immigration and health authorities say they are
simply out of space. Abigail Hauslohner reports: "Officials from
U.S. Customs and Border Protection, which first takes the migrants
into custody, and from the Department of Health and Human
Services, which runs the migrant children's shelters, characterized
the situation as a dire humanitarian crisis but also defended U.S.
treatment of young migrants as adhering to the law. And universally,
Trump administration officials Tuesday used the moment to urge
Congress to swiftly approve billions of dollars in border funding that
they say would provide bed space and services for children.
A
CBP official said Tuesday that the allegations of child neglect at
Clint were being investigated but also that the child detainees in the
agency's custody receive 'continuous' access to hygiene products
and adequate food while awaiting placement in U.S. shelters
designed for children."
-- A federal appeals court ordered that a Maryland judge take a
fresh look at the new evidence that the Trump administration
had discriminatory intent in adding a citizenship question to
the 2020 Census. Robert Barnes, Felicia Sonmez and Tara
Bahrampour report: "The order was part of last-minute wrangling in
the lower courts, in the Supreme Court and on Capitol Hill as the
justices are set to vote on the issue before the end of their term,
presumably this week.
Solicitor General Noel Francisco,
EFTA00021219

=== Page 19 ===
representing the Trump administration, told the Supreme Court that
the order from the 4th Circuit 'jeopardizes' the census process.
He had said in an earlier letter to the Supreme Court that the claims
in the Maryland case were 'based on a speculative conspiracy
theory that is unsupported by the evidence and legally irrelevant to
demonstrating that Secretary Ross acted with a discriminatory
intent."
-- Reporters are being kept away from the facilities where
migrant children are being held. Paul Farhi reports: "News stories
emerged last week about squalid conditions at a Border Patrol
detention facility housing about 300 migrant children on the U.S.-
Mexico border. Apart from their appalling specifics, the stories
were notable for one element: They were all based on secondhand
accounts. Reporters were unable to see the facilities themselves or
speak to any of the children. Instead, they relied on descriptions
provided by lawyers and advocates who were granted access under
a legal settlement with the Border Patrol.
The blackout on press
access has left Americans largely in the dark about conditions in
government facilities designed to handle migrants who have
crossed the border. Photographs and TV images are rare and often
dated. Rarer still are interviews with federal agency managers and
employees or with the children themselves."
-- Sarah Fabian, the Justice Department lawyer who flippantly
argued in open court that toothbrushes and soap are not
required for the government to provide children sanitary living
conditions, defended herself in a private Facebook post that
one of her friends leaked to NBC. Josh Lederman reports:
"Fabian says she shares 'many people's anger and fear' about the
nation's future. Saying she is 'not an official of any administration,'
EFTA00021220

=== Page 20 ===
Fabian points out that she's a career federal employee who's
served in her role since 2011. Fabian expresses regret that her
comments in the video 'struck a nerve' but argues that selective
editing, combined with a lack of precision in her argument created a
false impression. 'I think that many many people believe I was in
court Tuesday arguing against providing certain hygiene items to
kids,' Fabian writes, adding later: 'I do not believe that's the position
I was representing."
-- Elizabeth Warren called for decriminalizing illegal border
crossings. HuffPost's Roque Planas reports: "Warren joins fellow
2020 contender Julián Castro and several other prominent
Democrats in backing a reform that, if enacted, would give civil
immigration courts exclusive legal control over immigration
enforcement at the border. While Warren has yet to release a
comprehensive immigration platform, her campaign confirmed to
HuffPost that she also now favors repealing the law criminalizing
migration." Make no mistake: Trump will use this as a devastating
cudgel against her if she becomes the Democratic nominee.
Iranian President Hassan Rouhani attends a meeting with the
Health Ministry officials in Tehran. (Iranian Presidency Office via
AP)
Iranian President Hassan Rouhani attends a meeting with the Health Ministry officials in Tehran.
(Iranian Presidency Office via AP)
THE NEW WORLD ORDER:
-- Any prospect of easing tensions between the United States
and Iran seemed increasingly remote yesterday, as threats and
personal insults flew between the two governments. Karen
EFTA00021221

=== Page 21 ===
DeYoung reports: "Any attack on 'anything American,' tweeted the
president - who last week called off a military strike that was to
have been launched after Iran shot down a U.S. drone - will bring
'overwhelming' U.S. force and 'obliteration' of some Iranian assets.
Beneath the din, no new options emerged for avoiding a conflict
that both sides say they do not want, and more doors appeared to
be closing rather than opening. In Washington, even those who fully
and vocally support the administration's 'maximum pressure'
sanctions policy have begun to question whether Trump has a
strategy. Other experts said that Trump's summit strategy with
nuclear-armed North Korea, in which both leaders had reason to
seek the public spectacle of a meeting, but whose governments
have yet to substantively address their differences, would not work
with Iran."
-- South Korea's Moon Jae-in said the U.S. and North Korea are
talking about a third nuclear summit between the two
countries' leaders. From the Wall Street Journal's Timothy W.
Martin: "Mr. Moon didn't provide a timeline for the meeting between
President Trump and North Korean leader Kim Jong Un. He said
the two sides had held 'behind-the-scenes talks, not official
dialogue, after February's Vietnam summit that ended abruptly
without a deal. The South Korean leader's remarks come just days
before President Trump is scheduled to visit Seoul, a trip that is
viewed as an effort to help jump-start talks with Pyongyang."
-- Jared Kushner, the president's son-in-law, presented his
Middle East peace plan but did not reveal how the White House
plans to achieve such a deal. Loveday Morris reports: "The White
House's economic plan envisages $50 billion in regional investment
projects over the next decade, more than half in the West Bank and
EFTA00021222

=== Page 22 ===
Gaza, and the rest in Jordan, Egypt and Lebanon. But the initiative
has been met with widespread skepticism and already has been
rejected by the Palestinian leadership
The White House plan
makes no mention of Palestinian aspirations for statehood or of
ending Israeli occupation of Palestinian territories. Rather, the plan
pulls together previously proposed infrastructure projects, including
a transport link between Gaza and the West Bank as well as
increased capacity at Gaza's power station to address crippling
electricity outages. How the economic projects would be
financed remains unsettled, and the Bahrain meeting is not
intended to raise money, said a U.S. official."
-- The U.S. Air Force veteran who was accused of acting as a
mercenary in Libya's civil war has been freed. Missy Ryan, Josh
Dawsey and Julie Tate report: "Jamie Sponaugle, a 31-year-old
Florida man, was piloting an aircraft near the Libyan capital of
Tripoli on May 7 when his plane went down, according to officials
and individuals familiar with the incident, who spoke on the
condition of anonymity. The Libyan National Army said it shot down
the aircraft, which it said was a Mirage F1 combat jet piloted by a
man The Washington Post is now identifying as Sponaugle, as it
conducted bombing raids against LNA forces in the area. The Post
withheld publication of Sponaugle's detention at the request of U.S.
officials who were working to secure his release."
-- Trump is flying today to the G20 in Japan with most of his
foreign policy gambits hanging in the balance. David Nakamura
and Damian Paletta report: "The president is slated to meet at the
Group of 20 summit in Osaka with key allies and adversaries -
including China's Xi Jinping, Russia's Vladimir Putin, Japan's
Shinzo Abe, Saudi Arabia's Mohammed bin Salman and India's
EFTA00021223

=== Page 23 ===
Narendra Modi - as he seeks to clinch an elusive trade pact with
Beijing, consolidate international support in a tense staredown with
Tehran and navigate a path forward on stalled nuclear talks with
North Korea. The upshot is that 2½ years into his presidency,
Trump is facing a crucial test of his 'America First' agenda, one that
has alienated traditional allies over disputes on trade and defense
spending and set the United States apart from global consensus on
how to deal with climate change and Iran's nuclear program. Having
generally thumbed his nose at multilateral engagements in favor of
a go-it-alone approach, Trump has shown a preference for leader-
to-leader diplomacy and following his gut instincts instead of
rigorous preparation, which have left him in a precarious position."
-- The son of an American jailed in China on spy charges asked
Trump to plead his father's case at the summit. Gerry Shih
reports: "Harrison Li, the son of the New York-based aircraft parts
exporter Kai Li, is calling on Trump to raise the case of his father -
believed to be the only American citizen held in China on state
security charges - during a meeting with Xi this week, when Trump
is expected to seek the release of two Canadians similarly detained
by China's opaque security apparatus.
Harrison Li said Trump
should use his meeting with Xi to intervene on behalf of his father,
whose ordeal has gone largely unnoticed for nearly three years
while the State Department and Li's supporters worked quietly, but
unsuccessfully, to secure his release."
-- Treasury Secretary Steve Mnuchin said the U.S.-China trade
deal is "90 percent" complete. From CNBC's Holly Ellyatt: "He
said he's confident Trump and Xi can make progress in stalled trade
talks at the G-20 meeting this weekend. 'The message we want to
hear is that they want to come back to the table and continue
EFTA00021224

=== Page 24 ===
because I think there is a good outcome for their economy and the
U.S. economy to get balanced trade and to continue to build on this
relationship.' He did not provide any detail on what the final 10% of
an agreement might entail, or what the sticking points are to
completing a deal."
What to expect from Democrats on the crowded debate stage
DEBATE PREP:
-- As the Democratic debates start tonight in Miami, Ashley
Parker looked back at how the 2016 GOP primary kicked off
"the era of the mega-debate - a bigger field of candidates, a
bigger slate of debates, bigger ratings, bigger stakes and a
bigger need for a standout exchange." Parker writes: "The trick
for the Democrats, as with their Republican predecessors, is to find
a way to capture attention and break away from the pack. Trump
didn't necessarily win the debates themselves four years ago,
but he always won the show - and, with it, the White House. 'I
tell people these are not debates,' said former Arkansas governor
Mike Huckabee, who ended his presidential run in February 2016. 'I
was a debater in high school and college, and these are not
debates. These are television shows.' Trump, a former reality TV
star, quickly realized that every circus needs a ringmaster and
appointed himself to the role. Texas Sen. Ted Cruz, one of
Trump's most vocal rivals in 2016, said moderators 'are often
looking for fireworks' - a phenomenon he suspects Democrats will
also encounter."
-- DNC Chairman Tom Perez is facing fires on a number of
fronts as the debates get underway. Michael Scherer reports: "In
EFTA00021225

=== Page 25 ===
just the last month, he has been accused by fellow Democrats of
unfairly changing debate qualifications to exclude the governor of
Montana, setting thresholds that could unjustly remake the race in
September, and treating elected members of Congress as 'second-
class citizens' by denying them a decisive nominating vote at the
2020 Democratic convention. Nearly 100 climate change activists
staged a sit-in at party headquarters Tuesday to demand a debate
on the issue. The Republican National Committee recently
announced raising $75.6 million through the first five months of the
year, more than twice as much as Perez's party, with a greater
share of the money coming from donations under $200. But Perez
is not discouraged. The party, he says, is on track, never mind
the haters."
-- The debates could be a particularly defining moment for
Cory Booker, who has struggled to break out in the crowded
field even though he had been viewed as a likely candidate for
years. The Times's Jonathan Martin and Nick Corasaniti report: "Mr.
Booker is more comfortable 'leading with love,' as he often says in
speeches, and he warns against 'fighting fire with fire' when it
comes to confronting [Trump]. It's an approach that could pay off
with Democratic primary voters, who surveys indicate are far more
eager to find a candidate who wants to unite the country than
merely fight against Republicans. But it does not make for cable
television or social media catnip, which has shaped the early
contours of the race. No other Democratic candidate but him has
such a sophisticated organization and support network in lowa, New
Hampshire and South Carolina but is mired closer to zero than
double digits in most every early nominating state."
EFTA00021226

=== Page 26 ===
-- The debates are unfolding in a city that is already facing the
daily reality of climate change. The Times's Patricia Mazzei
reports from Miami: "[T]he urgency of the climate issue is beginning
to take hold in Florida. That is especially true in the Miami-Fort
Lauderdale area, where 49 percent of respondents, compared with
30 percent elsewhere in the state, said they had made physical
changes to their homes in the past year to protect against sea-level
rise, flooding or extreme weather. The latest daily heat record in
Miami was broken on Sunday, only the third day of summer, when
the temperature reached 95 degrees. The high on Monday, 98
degrees, tied the existing record."
-- Split-screen: Vice President Pence traveled to Miami a day
before the debates started to launch a national "Latinos for
Trump" initiative. Pence called Trump "a great champion of Latino
and Hispanic Americans," citing a decline in Hispanic
unemployment since he took office. "President Trump promised to
get this economy moving again, and President Trump delivered,"
Pence said. "President Donald Trump is the best friend that Latino
and Hispanic businesses have ever had in the White House." When
the vice president touched on border security, the crowd broke out
in chants of "Build the wall." (John Wagner)
E. Jean Carroll poses for a portrait at her home in Warwick, N.Y.
(Eva Deitch for The Washington Post)
E. Jean Carroll poses for a portrait at her home in Warwick, N.Y. (Eva Deitch for The Washington
Post)
THE ME TOO MOVEMENT:
EFTA00021227

=== Page 27 ===
-- The latest sexual assault allegation against Trump has been
greeted with relative silence on Capitol Hill - particularly by
Republicans. Colby Itkowitz, Emily Davies and Hailey Fuchs
report: "The muted reaction to the claim by [magazine columnist E.
Jean Carroll], who said Trump attacked her in a dressing room more
than two decades ago, reflected a sense among resigned
Democrats that the president will never face serious political
damage from accusations of sexual misconduct, which 16 women
have now made. Republicans remained largely silent about
Carroll's allegation. The one political figure who has brought the
most attention to her story is Trump, who has denied it, saying she
was 'not my type.' When asked Tuesday whether Trump's response
was appropriate, [Mitch McConnell] replied, 'I don't have any
comments about that."
-- Other Republicans dismissed Carroll's allegation outright,
specifically citing the assault allegations against Supreme
Court Justice Brett Kavanaugh. "Quite honestly, as somebody
who had a front-row seat to the Kavanaugh hearings, we've seen
allegations that were false," Tillis said. "We'll let the facts go where
they are, but I take [Trump's] statement at face value." "Many times
when folks have made these allegations they're also promoting a
book," said Sen. John Kennedy (R-La.). "All I would say: We live in
an environment where people can come forward. That's good. But
allegations like this have to be cautiously reviewed," said Sen.
Lindsey Graham (R-S.C.), adding that he has "no reason not to"
believe Trump. (Politico)
-- Two Republican senators - Joni Ernst (lowa) and Mitt
Romney (Utah) - called for Carroll's allegations to be
investigated. "I think anybody that makes an accusation like that,
EFTA00021228

=== Page 28 ===
they should come forward," Ernst said when asked about Carroll's
claim. "But obviously there has to be some additional information.
They need to interview her. They need to visit with him." Romney
called for an "evaluation" of the accusation but added that he didn't
know who should conduct it, "whether it's Congress or whether it's
another setting, I'm not sure." (CNN)
Stephanie Grisham will replace Sanders as press secretary
ALL THE PRESIDENT'S MEN AND WOMEN:
-- Stephanie Grisham, the first lady's communications director,
will replace Sarah Sanders as White House press secretary.
John Wagner reports: "The move was first announced by [Melania]
Trump in a tweet and later confirmed by White House officials. In
addition to succeeding Sanders, Grisham will also take on the
duties of White House communications director, a job that has been
vacant since March. 'She has been with us since 2015 - @potus & I
can think of no better person to serve the Administration & our
country,' the first lady said in her tweet. Grisham, 42, is one of
Trump's last remaining campaign aides serving in the White House.
Before becoming the first lady's communications director in March
2017, she worked in the West Wing as a deputy to Trump's first
press secretary, Sean Spicer."
-- House Republicans are preparing to go after a Trump
appointee who used to work for them on the Hill after he
released a report that said White House counselor Kellyanne
Conway should be fired for blatantly violating the Hatch Act.
Rachael Bade and Lisa Rein report: "Henry Kerner, head of the
Office of Special Counsel, is scheduled to testify Wednesday about
EFTA00021229

=== Page 29 ===
his report. Democrats on the House Oversight Committee, who
invited Conway to testify, plan to vote to subpoena her if she fails to
show for the hearing, as expected. Republicans are intent on using
the session to question the credibility and judgment of Kerner, one
of the panel's top investigators for more than three years when
Republicans were in charge. After Kerner takes the witness seat,
Republicans plan to argue he applied the law unfairly in Conway's
case, pointing to what they say were similar statements by top
Obama administration political appointees."
-- "Sean Lawler, a State Department official whose title is chief
of protocol, is departing amid a possible inspector general's
probe into accusations of intimidating staff and carrying a
whip in the office," per Bloomberg's Jennifer Jacobs and Daniel
Flatley. "The protocol chief assists the president on overseas trips,
and when foreign leaders visit the White House, by making
introductions and briefing the president on protocol. Lawler, a fixture
in the Oval Office during dignitaries' visits, served as the president's
liaison to the diplomatic corps at the State Department. Trump
has little fondness for Lawler, and repeatedly asked why he still
worked at the White House."
-- The Justice Department sued Omarosa Manigault Newman
for failing to file a legally required personal financial disclosure
report after she was fired two years ago. Politico's Josh Gerstein
reports: "The lawsuit says Manigault Newman never filed the report
required from departing senior staffers and largely ignored
numerous requests from White House lawyers to submit the report
following her acrimonious departure from her post as
communications director in the Office of Public Liaison. The suit,
filed Tuesday in U.S. District Court in Washington, asks a judge to
EFTA00021230

=== Page 30 ===
order Manigault Newman to file the report and to pay a civil penalty
of $50,000 for 'willfully' defying the ethics mandate."
Joe Biden greets supporters during the South Carolina
Democratic Convention in Columbia, S.C. (Tracy Glantz/The State
via AP)
Joe Biden greets supporters during the South Carolina Democratic Convention in Columbia, S.C.
(Tracy Glantz/The State via AP)
MORE ON 2020:
-- Joe Biden continues to play down his leadership role
in laying the groundwork for policies of mass incarceration
that continue to devastate black communities. The Times's
Sheryl Gay Stolberg and Astead W. Herndon call him out: "Mr.
Biden apologized in January for portions of his anti-crime
legislation, but he has largely tried to play down his involvement,
saying in April that he 'got stuck with' shepherding the bills because
he was chairman of the Senate Judiciary Committee. But an
examination of his record - based on newly obtained
documents and interviews with nearly two dozen longtime
Biden contemporaries in Washington and Delaware -
indicates that Mr. Biden's current characterization of his role is
in many ways at odds with his own actions and rhetoric.
While Mr. Biden has said in recent days that he and [Mississippi
Sen. James ] Eastland 'didn't agree on much of anything,' it is clear
that on a number of important criminal justice issues, they did. As
early as 1977, Mr. Biden, with Mr. Eastland's support, pushed for
mandatory minimum sentences that would limit judges' discretion in
sentencing. But perhaps even more consequential was Mr. Biden's
EFTA00021231

=== Page 31 ===
relationship with [South Carolina Sen. Strom] Thurmond, his
Republican counterpart on the judiciary panel, who became his co-
author on a string of bills that effectively rewrote the nation's
criminal justice laws with an eye toward putting more criminals
behind bars."
-- Bernie Sanders has pointed to Germany's tuition-free
universities as an example that America should follow, but
such a system involves trade-offs. Michael Birnbaum reports:
"[T]here is little magic to how European countries keep costs down
for their students: Even though most impose far higher income
taxes than the United States does, they still spend less money
on education. [The German university RWTH Aachen] has no
grand athletic center.
Professors' salaries cannot compete with
those at top American universities, although they may carry double
the teaching load, making it difficult to hire U.S. stars. Its dormitories
are modest brick affairs. Some lecture halls are dingy and don't
seem to have been updated much since the 1950s, when they were
built from Germany's post-World War Il rubble. Some of its lectures
top 1,000 students."
-- Pete Buttigieg has spoken little of his time spent in Iraq and
Afghanistan as a consultant for McKinsey between 2007 and
2010. ABC News's Lee Ferran and Ali Dukakis report: "In his
memoir, 'Shortest Way Home,' he mentions his involvement in
domestic projects for the firm like doing energy efficiency research
in the U.S., and goes into particular detail about one that involved
analyzing North American grocery prices. But when it comes to his
work abroad with McKinsey, he only drops hints about working on
'war zone economic development to help grow private sector
employment' in Iraq and Afghanistan. He also refers to a 'safe
EFTA00021232

=== Page 32 ===
house' in Baghdad. The book doesn't say exactly when or how long
Buttigieg was in either country. And beyond that, details are scarce -
- by design."
-- Warren unveiled a $20 billion proposal to federalize national
elections. Annie Linskey reports: "Warren proposes buying new
voting machines for all of the roughly 8,000 election jurisdictions in
the country, mandating automatic and same-day voter registration
and giving all voters access to 15 days of early voting and voting by
mail. Her plan would also bar purges of voter lists, with exceptions
for 'death, change of address, or loss of eligibility to vote.' And it
would provide financial incentives for states to adopt the new
federal standards for local elections. Republicans would almost
certainly fight such a proposal, which at a minimum would require
major legislation by Congress."
-- A new Pew poll shows stark partisan divisions in how
Americans view capitalism and socialism. The Pew Research
Center's Hannah Hartig reports: "Overall, a much larger share of
Americans have a positive impression of capitalism (65%) than
socialism (42%) There are large partisan differences in views of
capitalism: Nearly eight-in-ten Republicans and Republican-leaning
independents (78%) express somewhat or very positive reactions to
the term, while just over half of Democrats and Democratic leaners
(55%) say they have a positive impression. But these differences
are dwarfed by the partisan gap in opinions about socialism. More
than eight-in-ten Republicans (84%) have a negative impression of
socialism; a 63% majority has a very negative view. Nearly two-
thirds of Democrats (65%) have a positive view of socialism,
but only 14% have a very positive view."
EFTA00021233

=== Page 33 ===
-- Some Democrats believe Stacey Abrams holds the key for
victory and are reaching out to her in hopes of copying her
tactics and to win her blessing. Cleve R. Wootson Jr. and
Vanessa Williams report: "But if Abrams is becoming an oracle for
Democrats, she's an emerging target for Republicans. At a Capitol
Hill hearing Tuesday, she was challenged by Rep. Douglas A.
Collins (R-Ga.), who complained that her celebrity supporters are
maligning the state by claiming that she would be governor 'if
Georgia wasn't racist.' Collins also pressed Abrams on whether she
had pushed for noncitizens to vote, which she strongly denied.
Abrams's unmistakable presence hangs over the Democratic
presidential race, and not just because she hasn't quite ruled out
running. Many black and liberal voters find Abrams a moving,
authentic figure - with her unapologetic style, tough childhood and
long devotion to voting rights - while many of the presidential
candidates are struggling to win over the black community."
-- Trump endorsed Sen. Thom Tillis (R-N.C.), who is facing two
GOP primary challengers in North Carolina. Tillis "has really
stepped up to the plate," Trump tweeted last night. "Thom is tough
on Crime, Strong on the Border and fights hard against Illegal
Immigration. He loves our Military, our Vets and our great Second
Amendment. I give Thom my Full and Total Endorsement!" (Felicia
Sonmez)
SOCIAL MEDIA SPEED READ:
Rudy Giuliani sought to downplay the significance of Mueller's
testimony to a PBS correspondent:
EFTA00021234

=== Page 34 ===
A Bernie Sanders-supporting liberal congressman from California
cited Mueller's agreement to appear as a validation of the approach
being pursued by Nadler and Schiff:
A Post economics correspondent has been trying to draw more
attention to the deficit, which continues to be undercovered:
A "Today" show anchor provided this early look at the Democratic
debate stage:
Jay Inslee's campaign manager briefly filled in for him on the debate
stage:
EFTA00021235

=== Page 35 ===
Biden's rapid response director responded to a Washington Post
story about the former vice president's speaking contracts, which
demanded that he be provided a very specific Italian meal before all
his engagements:
Meanwhile, Biden focused on border security:
A Post reporter made this point about the conditions of migrant
detention centers:
A House Democrat criticized the Trump administration's Iran policy:
George Conway, who is married to senior White House adviser
Kellyanne Conway, contrasted Sen. Lindsey Graham's comments
about sexual assault allegations against Trump:
From the former acting attorney general who Trump fired:
Warren added a stop before heading to the first debate tomorrow:
EFTA00021236

=== Page 36 ===
A Post congressional reporter said this about the latest allegations
against Hunter:
A Princeton historian noted this from Hunter's website:
Meanwhile, the Office of Government Ethics gathered for a meeting:
The White House perss secretary endorsed her successor:
And Trump started the day by accusing the Democrats of innaction:
GOOD READS FROM ELSEWHERE:
-- Marshall Project, "First Big Scoop: Student Journalists
Expose High School's Use of Prison Labor," by Eli Hager: "Last
January, at his high school's chorus fundraiser, 17-year-old Spencer
Cliche overheard a chat between a parent and a 'trusted faculty
member.' (As a student journalist, he told me, he does not reveal his
sources.) The seats in the auditorium, Spencer says he heard the
two adults saying, were going to be reupholstered using prison
labor. He didn't think much of it at first. But later in the semester
EFTA00021237

=== Page 37 ===
when his journalism class studied prison issues, he mentioned what
he'd heard to the teacher, Sara Barber-Just, a two-decade veteran
of Amherst Regional High in Massachusetts. Couldn't the fact that
the school was using incarcerated laborers-who may learn useful
skills but are typically paid next to nothing-be a story for the next
edition of the school's quarterly newspaper, he asked?"
-- The Daily Beast, "David Barstow tried to ghostwrite a book
with a top-secret source on the Pulitzer-winning story," by
Lachlan Cartwright: "On April 15, the New York Times staff
gathered in the newsroom, looking up at Executive Editor Dean
Baquet on a crimson staircase where he announced to rapturous
applause that reporters David Barstow, Susanne Craig and Russ
Buettner had won the Pulitzer Prize for their groundbreaking story
on President Trump's taxes. The reporters spoke after Baquet.
Craig paid special tribute to their sources.
Almost
no
one
in
the
room that day was aware that the team was at each other's throats."
-- The New Yorker, "Can Emmanuel Macron Stem the Populist
Tide?" by Lauren Collins: "What is new at the European scale is
that the rise of extremism, especially coming from the far right, is
everywhere,' he said, speaking in English (his choice). 'A few
months ago, a lot of people thought that this new coalition of the far
right could have a majority or could block any majority at the
European Parliament, which didn't happen,' he said. 'This is, for me,
one of the positive outcomes of these elections, even if they were
very much helped by foreign influences."
-- Wall Street Journal, "Buyer Makes a Big Bet His New
Caravaggio Is Really by Caravaggio," by Kelly Crow:
"Michelangelo Merisi, the artist known as Caravaggio, always drew
EFTA00021238

=== Page 38 ===
trouble. The highly anticipated public auction Thursday of a painting
credited to the Italian master, who fled Rome after killing a man,
was scratched when a buyer cut ahead of bidders to get it first.
Even though experts are split over the authenticity of the long-lost
work from 1606, 'Judith and Holofernes,' the anonymous buyer
seemingly had no doubt. 'He made an offer we couldn't refuse,' said
Eric Turquin, an appraiser and auctioneer in Paris who advised on
the deal. The final price late Monday was 'exceptionally more' than
the starting bid of $34 million, he said."
HOT ON THE LEFT:
HOT ON THE RIGHT:
"Sarah Sanders: Farewell
"Ravelry, the Facebook of
happy hour not the
knitting, has banned pro-
'appropriate venue' to
Trump posts over 'open
discuss honesty," from
white supremacy," from
Erik Wemple: "There were
Alex Horton: "Scarves,
smiles, handshakes, hugs
gloves, shawls, caps — if it
and photos as Sarah
can be knit or crocheted,
Sanders, the outgoing
you can probably find a
White House press
design for it on Ravelry. It
secretary, hung out on
just can't resemble [Trump].
Monday night with
Ravelry, an 8-million-strong
colleagues and journalists
social network known as
at a happy hour in a D.C.
the 'Facebook of knitting'
steakhouse. Amid all the
and behemoth of all things
bonhomie, the Erik Wemple
soothingly created with
Blog attempted to sneak in
needlework, has banned all
some business questions
support for Trump and his
for the woman who pretty
administration, it
EFTA00021239

=== Page 39 ===
much ended the tradition of
announced Sunday. It's
daily White House press
another indication that
briefings. Here's the back-
politics has seeped
and-forth: ERIK WEMPLE
everywhere — including
BLOG: Sarah, hi — Erik
forums where you can
Wemple [Blog] with The
discuss which yarn works
Post. How's it going?
best to create crochet
SARAH SANDERS: Good,
bunnies. 'We cannot
are you recording? ERIK
provide a space that is
WEMPLE BLOG: Yes.
inclusive of all and also
SANDERS: Okay. ERIK
allow support for open white
WEMPLE BLOG: Are you
supremacy,' the site said.
helping out with choosing
'Support of the Trump
your successor?
administration is undeniably
SANDERS: Hey, Erik, I'm
support for white
just here to visit. I'm not
supremacy.' But they
going to do [inaudible].
also stressed the site was
ERIK WEMPLE BLOG: Do
not endorsing Democrats
you feel you were honest
and shunning Republicans
with the media? SANDERS:
with its move."
Hey, Erik, I just don't think
this is the appropriate
venue, but I appreciate you
being here tonight."
DAYBOOK:
EFTA00021240

=== Page 40 ===
Trump will speak at the Faith & Freedom Coalition 2019 Road To
Majority Policy Conference before flying to Osaka, Japan, for the G-
20 summit.
QUOTE OF THE DAY:
"There's not a lock on the door. Any child is free to leave at any
time. But they don't and you know why? Because they're well taken
care of and yes at some point they are going to live with family,
generally not mother or father but some family member, that's a
good thing." — Rep. Michael Burgess (R-Tex.) on the conditions of
migrant detention centers. (MSNBC)
NEWS YOU CAN USE IF YOU LIVE IN D.C.:
-- We are still in the middle of a heat wave, but at least the
humidity is not that bad. The Capital Weather Gang forecasts:
"Our late-June heat wave continues today but still lacks the
oppressive humidity we so often see around here. The heat and
humidity do both step it up a notch tomorrow and especially Friday
and Saturday. We may finally see a bit better chance of a few
showers and storms this weekend."
-- D.C. Council member Jack Evans (D) is now trying to share
his side of the story after the FBI raided his home as part of a
corruption probe. Fenit Nirappil reports: "The events of the last
week, so to speak, have been very inflammatory, and when the
actual facts are heard by everyone, I believe that will change
EFTA00021241

=== Page 41 ===
everyone's mind,' Evans said. 'It is only fair, and it only gives me
due process to be able to tell my side of my story and answer any
questions anyone might have.' Evans declined to answer questions
from reporters. The D.C. Council is preparing to launch an internal
investigation into Evans and remove him as chairman of the
Committee on Finance and Revenue. After Evans's comments,
Council Chairman Phil Mendelson (D) agreed to allow Evans to
present his arguments at a public meeting next Tuesday."
-- The Trump administration has hired two private fireworks
firms to put on an extended pyrotechnics display as part of the
president's Fourth of July show. Juliet Eilperin and Michael E.
Ruane report: "The approximately 35-minute show will more than
double the length of the traditional fireworks event, according to
administration officials, and will include an elaborate display
illuminating a mile-long stretch of sky above the Lincoln Memorial.
Phantom Fireworks and Grucci Fireworks will donate equipment
and personnel worth $750,000, according to the two companies."
-- The Metro plans to extend its July Fourth rush-hour service.
You received this email because you signed up for The Daily 202 or because it is included in your subscription.
(Luz Lazo)
Manage my email newsletters and alerts I Unsubscribe from The Daily 202
VIDEOS OF THE DAY:
Privacy Policy Help
Seth Meyers had some strong words for Trump, who said he didn't
rape a woman because she was not his "type":
Stephen Colbert condemned the conditions migrant children are
being put under by the administration:
EFTA00021242

=== Page 42 ===
Tyler Perry's speech at the BET Awards brought the entire crowd to
its feet:
And a video of a man with dementia remembering a song he
composed went viral:
EFTA00021243


c1: EFTA00023221
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023221.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Susan Necheles
Cc: "Kathleen E. Cassidy"
)"
(USANYS)"
,
Subject: Re: Draft Statement
Date: Fri, 11 Dec 2020 00:24:48 +0000
Thanks very much- is there a particular time that works best for your team, maybe in the morning?
Sent from my iPhone
On Dec 10, 2020, at 7:11 PM, Susan Necheles
wrote:
Wow. Strange. I am available except 11-12.
Susan R. Necheles
Sent from my iPhone
On Dec 10, 2020, at 6:46 PM,
)
wrote:
Hi all,
Are you available for a call tomorrow? It would be very helpful to speak with you before the weekend, if you have
time. We're available for a call anytime except from 11-12 tomorrow.
Thanks very much,
From: Kathleen E. Cassidy
Sent: Monday, November 16, 2020 8:39 PM
To:
Cc:
>;
(USANYS)
i
;
Susan Necheles
is
Subject: Re: Draft Statement
Hi all, sorry for the delay. Would a call tomorrow at 11 or 2 work?
Thank you,
Kate
Sent from my iPhone
On Nov 13, 2020, at 2:08 PM,
wrote:
No worries at all- happy to talk Monday instead. Whenever you have a sense of timing, just let us know. Thanks,
and hope everyone has a nice weekend.
Sent from my iPhone
EFTA00023221

=== Page 2 ===
On Nov 13, 2020, at 1:39 PM, Kathleen E. Cassidy
wrote:
All: I apologize but Susan has had a personal situation arise for this afternoon - can we push our call back to
Monday? Thanks for your understanding.
From:
Sent: Friday, November 13, 2020 9:59 AM
To: Kathleen E. Cassidy
Cc:
in
(USANYS)
>; Susan Necheles
in
Subject: Re: Draft Statement
That works, thanks. Talk to you then.
Sent from my iPhone
On Nov 13, 2020, at 9:09 AM, Kathleen E. Cassidy
wrote:
Great, should we use the same call-in number as the other day?
From:
Sent: Friday, November 13, 2020 9:03 AM
To: Kathleen E. Cassidy
Cc:
in
(USANYS)
>; Susan Necheles
is
Subject: Re: Draft Statement
That works for us, thanks.
Sent from my iPhone
On Nov 12, 2020, at 10:15 PM, Kathleen E. Cassidy
wrote:
How about 2:30?
From:
Sent: Thursday, November 12, 2020 7:48 PM
To: Kathleen E. Cassidy
Cc:
in
(USANYS)
>; Susan Necheles
>;
Subject: Re: Draft Statement
Hi Kate,
We'd be happy to discuss- unfortunately, we're not available at 1 p.m. tomorrow, but we are free anytime
before 11 or between 2 and 4.
Thanks,
Sent from my iPhone
On Nov 12, 2020, at 5:23 PM, Kathleen E. Cassidy
wrote:
and
Attached is the civil complaint that we discussed on the phone yesterday, which contains the allegation about
the incident in the townhouse.
We have also had some further discussion amongst ourselves after our call yesterday and would like to
schedule a follow-up call with you. Would tomorrow at 1pm work for you all?
Best,
Kate
EFTA00023222

=== Page 3 ===
From:
Sent: Wednesday, November 11, 2020 12:19 PM
To: Kathleen E. Cassidy
Cc:
is
(USANYS)
>; Susan Necheles
is
Subject: Re: Draft Statement
Thanks very much for sending. Our team has reviewed your draft and is prepared to go forward with the call
at 12:30pm today.
Best,
On Nov 11, 2020, at 12:08 PM, Kathleen E. Cassidy
wrote:
All:
We want to give you a draft of our suggested changes (attached) before our conversation this afternoon. We
realize the time is short before our scheduled call, so if you do not have sufficient time to review it in
advance of our call, we are happy to push the time for our call back until after you have had a chance to
review it.
We have tried to work within the framework you provided. There are some allegations which we do not
believe are accurate. Given the long passage of time, however, we understand that there might be different
recollections about what occurred. We have tried to set forth both views of what occurred. We understand
that you do not want a Fatico hearing and are willing to agree that we will not ask for a Fatico hearing to
attempt to resolve the different recollections.
With respect to the specific allegations about
being present during massages when girls were sexually
assaulted,
does not believe she was ever present during any of these incidents and believes that the
girls misremember the circumstances. We note that these events occurred a long time ago and were
emotionally charged, a circumstance which can cause people to have faulty memories.
Indeed, we think that some of the evidence seems to contradict the victim's claims that
was present
when they, as minors, were sexually molested by Epstein.
Specifically, based on allegations in a lawsuit, one of the victims referred to in the statement of facts states
that she was abused on Epstein's ranch when she was a minor and that
was present. But flight logs
reflect that the first time that the victim was on a flight to or from the ranch where she states the abuse
occurred was in April 2003, after the victim was 18 years old. Moreover, the victim's attorney has also stated
that a photo of the victim and Epstein in which the victim is smiling, taken in December 2002, was taken
before the victim knew that Epstein would sexually abuse her. This appears to contradict the victim's
allegation that in the summer of 2002 she was flown to the ranch and abused by Epstein in the presence of
To be clear, we are not asserting that this victim is lying about Epstein abusing her. Our point is simply that
this occurred 18 years ago and that she appears to be confused about the timing of events and who was
present.
Another victim claims that that
walked in on an incident where the victim was performing
on
Epstein in his New York townhouse. This victim has named
as a defendant in her civil suit and has
alleged that this incident occurred in 2005. During this time period,
worked out of Maxwell's home
and spent little time in Epstein's townhouse. Staff, including
were never allowed to roam the halls or
go into private areas of Epstein's Manhattan home unless they were summoned there.
never walked in
on someone when that person was giving Epstein
and believes that this victim must be confusing
her with someone else.
EFTA00023223

=== Page 4 ===
does not doubt that Epstein abused these women, as he did with almost all young women and girls
he came into contact with, but the available evidence does not support the assertion that
was
present for or witnessed any sexual abuse of these victims while they were minors. Accordingly, we do not
object to allowing these women telling their stories but we cannot agree that the allegations in their stories
concerning
are correct.
Let us know what would work best for a call.
Thanks,
Kate
Kate Cassidy
Necheles Cassidy LLP
Mobile
<2020.10.11 Defense edited SOF.docx>
<2019.11.20 Complaint
V. Indyke (Estate of Epstein) 19cv10758.pdf>
EFTA00023224


c1: EFTA00021906
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021906.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: White Collar Law360
To:
Subject: Cohen Wins Release As Judge Says US Retaliated Over Book
Date: Fri, 24 Jul 2020 07:25:50 +0000
Law360 White
Collar
WHITE COLLAR
Friday, July 24, 2020
Follow Law360
TOP NEWS
Law360 Rising Stars
New Epstein Docs Unsealed As Maxwell Fails To Gag Boies
Former Jeffrey Epstein associate Ghislaine Maxwell suffered a pair of
courtroom setbacks Thursday morning, losing a bid to gag federal
prosecutors and lawyers for witnesses in her sex trafficking case, and failing
to convince a judge in a defamation suit to keep a trove of documents under
seal.
LAW FIRMS
Read full article
EFTA00021906

=== Page 2 ===
FFTA

=== Page 3 ===
EFTA00021908

=== Page 4 ===
EFTA00021909

=== Page 5 ===


c1: EFTA00020493
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020493.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
OFFICIAL RECORD
Intake (Rev. 5-23-17)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Intake
Date: 08/20/2020
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Drafted By:
Date/Time Received: 08/20/2020 10:31 AM EDT
Details:
On 08/20/2020, at 10:31:12 AM Eastern Time,
,
date of birth
,
Home telephone number
Residential address
Essex, New York 12739, called the FBI National
Threat Operations Center (NTOC) to report he was contacted by
,
date of birth
,
home address
Manhattan, New York 10023, who is a victim of Jeffrey Epstein.
provided the following information:
He provided a background for himself, such as working with prominent
business figures such as Leslie Wexner and Jeffrey Epstein, being
pardoned by a U.S. President, among several other pieces of information.
found
online, and reached out as she is a victim of
Epstein, and she has been in contact with hundreds of other victims. She
is trying to publish a book.
knew about criminal activity which happened in multiple states,
on airplanes, etc.
claimed there were films of men who were
recorded. These men are prominent figures such as Epstein, President Bill
Clinton, and President Donald Trump. Maxwell is also on the tapes.
UNCLASSIFIED
EFTA00020493

=== Page 2 ===
UNCLASSIFIED
Re: 50D-NY-3027571, 08/20/2020
questioned
,
wanting to know who hired Epstein at Bear.
UNCLASSIFIED
2
EFTA00020494


c1: EFTA00021115
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021115.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
(USANYS)"
Bec: "USAHUB-USAJournal111"
Subject: RE: Epstein priv review -- 1B72 released and update
Date: Wed, 04 Nov 2020 16:05:41 +0000
Embedded: RE:_Epstein_priv_review__1B72_released_and_update.msg
Sender:
Subject: RE: Epstein priv review -- 1B72 released and update
Message-Id:
<SN5P110MB05422F9B4D8B7DC653E590FD92EF0@SN5P110MB0542.NAMP110.PROD.OUTLOOK.CO
M>
To:
To:
EFTA00021115


c1: EFTA00022539
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022539.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE:
Date: Thu, 25 Jul 2019 14:40:12 +0000
Yup
From:
Sent: Thursday, July 25, 2019 10:39 AM
To:
Subject:
A week after being denied bail, Jeffrey E. Epstein was found unconscious in his
cell on Tuesday at a federal jail in Manhattan with marks on his neck, and prison
officials were treating the incident as a possible suicide attempt, a law
enforcement official who had been briefed on the matter said.
Mr. Epstein's injuries were not serious, said the official, who requested his name
not be published because he was not authorized to speak on the matter. The
Bureau of Prisons did not immediately respond to requests for information.
https://www.nytimes.com/2019/07/25/nyregion/jeffrey-epstein-injured-jail.html?
action=click&module=Top%20Stories&pgtype=Homepage
EFTA00022539


c1: EFTA00020968
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020968.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
=
(NY) (FBI)"
To:
)"
Subject: Accepted:
proffer (re abuse)
Date: Wed, 04 Dec 2019 17:28:00 +0000
Importance: Normal
Attachments: unnamed
EFTA00020968


c1: EFTA00020729
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020729.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 1 of 28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 1 of 28
EXHIBIT 1
EFTA00020729

=== Page 2 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 2 of 28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 2 of 28
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80736-CIV-MARRA
JANE DOE #1 and JANE DOE #2,
Petitioners,
VS.
UNITED STATES OF AMERICA,
Respondent.
/
DECLARATION OF
JANE DOE 3
1.
The Court is familiar with me from my previous declaration in this case. I am currently
31 years old and want to become a part of the case to enforce my rights and possibly allow
criminal prosecution of Jeffrey Epstein and others who abused underage girls.
2.
I have seen a Government filing saying that I waited too long before trying to become a
part of this case. I don't think that the Government's position tells the full story about me. In
fact, I believe the Government is hiding some of the things that it knows about me and about
other powerful people involved in this case. I am filing this declaration so that the Court will
have more facts to make the decision about whether to let me come into the case.
3.
In its latest filing, the Government seems to be questioning why I was afraid and did not
come forward to speak more quickly. To understand my reasons, it is important that I share at
least some additional information about why I was so fearful after my abuse by Epstein and
others.
4.
The Court can best understand my situation by looking at my previous declaration and
then understanding why I was afraid of Epstein, how I eventually escaped from him, and how I
was forced to hide from him and others.
5.
I first met Epstein when I was 15 years old. I have told the Court about some of my
sexual and physical abuse in my earlier declaration.
6.
As a result of that abuse and my considerable interactions with Epstein and his friends, I
knew that Epstein was connected to some of the most powerful people in the world, including a
member of the British Royal family, a former President of the United States, and other very
powerful lawyers, politicians and businessmen. I was afraid of what would happen if I tried to
escape from Epstein or report him to law enforcement.
EFTA00020730

=== Page 3 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 3 of 28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 3 of 28
13.
Part of my fear comes from physical abuse that I suffered when Epstein forced me to
have sex with other people. Without going into the details of the sexual activities I was forced to
endure, there were times when I was physically abused to the point that I remember fearfully
thinking that I didn't know whether I was going to survive.
14.
Jeffrey Epstein knew about this physical and sexual abuse because I would detail it for
him as part of my debriefing. Epstein didn't care. Epstein said things like, "You get that
sometimes." I told him how much I hated having to be with some people, but Epstein still sent
me back. I had no choice.
15.
I give the Court this information so that it can better understand why I was so afraid of
Epstein and what he could do to me. I could provide more details to the Court, if the Court needs
more details on this issue. I also wanted to provide this information to the Court because I have
been accused of being a "serial prostitute." I don't think that is a fair way to describe my
situation, given that I was so young and so many powerful people were forcibly abusing me.
2
EFTA00020731

=== Page 4 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 4 of 28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 4 of 28
17.
After years of abuse and being lent out, I began to look for a way to escape. I had been
first forced into all this because I wanted to be a massage therapist. Epstein had taken me into
his clutches through promises and talk. But once he had me under his control, I felt trapped.
18.
I kept asking Epstein for my promised training and education. Epstein finally got me a
plane ticket to Thailand to go to Chaing Mai to learn Thai massage. This sounded like my
chance to escape. In September 2002, I packed my bags for good. I knew this would be my only
opportunity to break away from Epstein.
19.
On September 27, 2002, I flew from JFK in New York to Chaing Mai, Thailand. I
arrived around September 29 for my training. But Epstein was going to get something out of this
as well. I was supposed to interview a girl to bring back to the United States for Epstein.
20.
Exhibit 1 is a list of room charges in Thailand, with the charges going to Epstein's
account. This exhibit shows Epstein's telephone numbers and is evidence that he paid for my
hotel in Thailand.
21.
Exhibit 2 is a set of documents showing my itinerary and flight plans for me going to
Thailand, paid for by Epstein.
22.
I did the massage training in Chiang Mai. I met a truly great and special guy and told him
honestly what I was being forced to do. He told me I should get out of it. I told him that the
people I was working for were very powerful and that I could not disobey them without risking
my life. He told me he would protect me, and I had confidence in him. I saw my opportunity to
escape and to be with someone who truly loved me and would protect me. To make a long story
short, I married him and flew to Australia.
23.
I called Epstein and told him I was not coming back. He asked why? I said "I've fallen
in love." And Epstein basically just said "good luck and have a good life." I could tell he was
not happy. I was very afraid of what he was going to do to me. I thought Epstein or one of his
powerful friends might send someone to have me killed.
24.
I stayed in Australia from that point on, with my husband and away from the life I had
been forced to live as Epstein's sex slave. I was in Australia from late 2002 to October 2013. To
be clear, I was never in the United States during these years, not even for a short trip to visit my
mother. And my absence from the United States was not voluntary - I was hiding from Epstein
out of fear of what he would do to me if I returned to the United States.
3
EFTA00020732

=== Page 5 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 5 of 28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 5 of 28
25.
In around 2007, after not hearing from anyone for years, out of the blue I was contacted
by someone who identified himself with a plain sounding name and claimed he was with the
FBI. It seemed very odd for someone doing an official criminal investigation to just call up on
the phone like that. I hadn't heard Epstein's name for years. I didn't know who this person was
and what it was really about. I wasn't sure what was going on.
26.
This man said he was looking into Jeffrey Epstein. The man asked if I had been involved
with Epstein. My first instinct was to say nothing; because I wasn't sure he was really with the
FBI or any authorities. I did answer a few basic questions, telling him that I knew Jeffrey
Epstein and met him at a young age. The whole conversation didn't feel like it was right. This
man never offered to come and meet with me in person. He instead asked me right off the bat
about Epstein's sexual practices. I thought it would be strange for a real law enforcement officer
to behave that way. I became increasingly uncomfortable and suspicious about who was actually
calling me.
27.
The way the conversation was going made me doubt whether I was really talking to an
FBI agent. It did not seem very official. I became very uncomfortable, so I told him nothing
more about Epstein. The conversation probably didn't even last three minutes. The conversation
immediately triggered all of the fears of Epstein and his powerful friends that had caused me to
escape the first time. If the call accomplished anything, it only put me back in fear and told me
that I could be found quite easily and had nobody official protecting me.
28.
I suspected that the man who called me was working for Epstein or one of Epstein's
powerful friends. If the man who called me was really an FBI agent and was interested in what I
knew about Epstein, I thought he would have made some effort to see me personally. I believed
that if this was really an agent who was investigating Epstein, then he knew who I was and how I
fit into Epstein's sexual crimes in many different places. Such an agent would send someone to
meet me in person (who could provide potential protection from Epstein). He never did.
29.
Getting a call from this supposed FBI Agent made me very scared. I had left that old life
behind me and started a new life in a new country in hopes that the powerful people whose
illegal activities I knew all about would never find me. And now I had been tracked down by
someone and was frightened.
30.
Shortly after this purported FBI call, I was contacted by someone who was clearly
working for Epstein. This person discussed an investigation into Epstein, and said that some of
the girls were saying Epstein had sexual contact with them. After they made those allegations,
they were being discredited as drug addicts and prostitutes. But, on the other hand, if I were to
keep quiet, I would "be looked after." The fact that this call came in right after the FBI call
reinforced my concern that the man I had talked to earlier was not really working for the FBI, but
was really working for Epstein. I didn't think that the FBI and Epstein would both be working
together and would both get my phone number at almost exactly the same time. I played along
and told this person that I had gotten a call from the "FBI" but that I didn't tell them anything.
The person was pleased with that.
4
EFTA00020733

=== Page 6 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 6 of 28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 6 of 28
31.
A short time later, one of Epstein lawyers (not Alan Dershowitz) called me, and then got
Epstein on the line at the same time. Epstein and his lawyer basically asked again if I was going
to say anything. The clear implication was that I should not say anything. The way they were
approaching me, I was afraid of what would happen if I didn't keep quiet. My thought was that if
I didn't say the right things, I might get hurt.
32.
I promised Epstein and his lawyer that I would keep quiet. They seemed happy with that
and that seemed to me the way to most likely keep me and my family safe. And I did what
Epstein and his lawyer told me - I kept quiet.
33.
I now understand that Epstein reached a non-prosecution agreement with the federal
government in 2007 and pled guilty to two state crimes in June 2008. No one told me anything
about those events until much later. In fact, nobody called or came to see me to explain what a
non-prosecution agreement was, what crimes Epstein could have been charged with, why he was
not being charged with the crimes he committed, or anything whatsoever about the case. I was
never offered a chance to meaningfully confer with the prosecutor for the Government, and I was
never notified of any hearing that could affect me or my rights as a crime victim to ever bring
charges.
34.
On September 3, 2008, the FBI sent a victim notification letter to me. This was the first
written communication I had received from the FBI. The letter was attached as Exhibit 1 to my
earlier statement. This kind of written communication, on official FBI stationary, is the way that
I thought the FBI really communicated with people that they wanted to talk to. The fact that I got
this official letter from them made me wonder even more whether that the call I had received
earlier was really from the FBI. The letter that I got did not mention that anyone from the FBI
had ever called me before.
35.
The letter started off with the sentence: "By virtue of this letter, the United States
Attorney's Office for the Southern District of Florida provides you with the following notice
because you are an identified victim of a federal offense." That sentence (among others) made it
seem like this was the first time the FBI was officially contacting me. That was the first time I
was told about my rights as a crime victim.
36.
I did not know what was happening about any criminal prosecution of Epstein at this
time. I wanted him prosecuted. And given his constant illegal sexual behavior, I thought it was
obvious that he should be prosecuted. But after reading the letter, I was confused. The letter did
not explain what was actually happening or what role, if any, that I could play. In fact, the letter
thanked me for my assistance during the investigations, yet it wasn't clear what that was
referring to.
37.
Also, the letter did not directly say that Epstein's crimes against me were not going to be
prosecuted. It just said that "the United States has agreed to defer federal prosecution in favor of
this state plea and sentence
I did not know what that meant. The letter did not inform me
how it applied to me. The letter also said that there was "litigation between the United States
and two other victims regarding the disclosure of the entire agreement between the United States
and Mr. Epstein." Understanding more about that case now, I realize that the letter did not
5
EFTA00020734

=== Page 7 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 7 of 28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 7 of 28
explain that the real purpose of that litigation was not to get "disclosure of the entire agreement"
but instead to get criminal charges filed against Epstein and to uphold the rights of Epstein's
victims. I wish that the Government had told me that was what was really going on.
38.
I saw on the letter that I could call a lawyer. The letter also mentioned Jack Goldberger,
who I knew to be Epstein's attorney, which scared me. I first got in touch with the attorneys at
the Podhurst Orseck firm. My lawyers filed a lawsuit against Epstein for me, which mentioned
that I was abused by Epstein and other powerful people. I was hoping that the information I
gave as part of my lawsuit might help to put Epstein away in prison -- where he belongs. But the
lawsuit ended up just being about money, which Epstein paid to settle.
40.
At this point, since nothing else seemed to be working to get Epstein and his associates
held accountable, I wanted to try by myself to get a message out to the public about what terrible
things Epstein and his friends had done to me and other girls. I was very disturbed about how no
one was prosecuting Epstein for these crimes. I was also very scared. It seemed that law
enforcement was not doing anything with the information they knew about me, which left me
and my family more vulnerable and scared.
41.
The journalist printed an article using some of the information I told her. Shortly after
the article was published, I talked on the phone to Marie Villafaña, a federal prosecutor from
Florida. I had seen her name on the official letter from the FBI, so she seemed legitimate.
Villafaña seemed very interested in my case and seemed like she really wanted to do something.
42.
Within a few weeks of the newspaper article being published, two FBI agents also called
me in Australia and then came to meet me. In around March 2011, they met me at the U.S.
Consulate in Sidney. They seemed to be very professional and hard working. I thought to myself
that I had finally gotten the attention of the people that I wanted to and that these people would
do the right things against Epstein and the other criminals. I also thought that they could protect
me.
43.
When I met with the agents, they mainly focused on Epstein. But while there, I provided
them some information about some of the others who were involved in illegal acts as well. I was
aware that a false statement to these law enforcement officers was a crime and I told the truth -
giving them the information that I could recall at the time about the individuals they inquired
about.
44.
The agents were clearly prepared to meet me and already knew a lot about Epstein's
crimes. The agents appeared to be very good at investigating and seemed like they really knew
how to piece together the whole story. But at the same time, they seemed like they were being
blocked from doing what they wanted to do - which I thought was to arrest Epstein and his
powerful friends for all of their illegal sexual crimes.
6
EFTA00020735

=== Page 8 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 8 of 28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 8 of 28
45.
During my interview with the real FBI agents, I told them about my contact from the
purported FBI agent. They did not tell me that it had been a legitimate call from the FBI.
46.
The interview I did with these FBI agents was very stressful for me. My meeting lasted
for several hours. It was not easy to talk about all these difficult things, but I went through it. I
was crying at points in the interview. The interview also placed stress on my marriage, because
my husband had to listen to all the terrible things that happened to me. It was difficult for me to
have to discuss being passed around as a sex object among powerful people. It was very hard for
both of us.
47.
The agents had come from Florida to meet with me in Australia and took my information
which gave me reason to believe that Epstein could still be prosecuted for the crimes he
committed against me. I was not told even at that point that he could not be prosecuted for the
crimes he committed in Florida. I was not told about the CVRA case or that there was any other
option for me to enforce my rights. In fact, by the agents meeting with me I believed I was doing
exactly what I needed to do to enforce my rights and assist in the prosecution.
48.
I have seen the Government's recent brief trying to keep me from joining this case. In
that brief, the Government says about me "the Government is aware that petitioners' counsel
have been representing her [that is, me] since at least as early as March 2011." This is
completely untrue, and I think the Government knows it is untrue. I was not represented by legal
counsel in March 2011. The Government has to know that I didn't have an attorney then,
because I didn't have an attorney when I met the agents in Sydney. I don't understand why the
Government is giving false facts to the court.
50. In around April 2011, as a follow-up to my earlier call with Brad Edwards, I got a
telephone call from him and another attorney, Jack Scarola. They just wanted general
information about whether various people had information relevant to the lawsuit. They told me
that they were taping the conversation, and I had no problem with that. I cooperated with them
and gave them information about which people had information relevant about Epstein's crimes.
Because it was over the phone and we did not know each other very well, they were very polite
and did not ask me a lot of details about specifically who I had sex with and what sexual
activities I was forced to participate in. It was a general, background interview.
51.
As the months following the FBI meeting in Sydney passed, I was trying to be patient but
I began wondering what was going on about prosecuting Epstein. I continued to be very
confused about what was happening. I was hoping that some kind of prosecution would come
out of it. But when nothing came of it, I got very upset. I wanted to do something to stop
Epstein and the other people he associates with from sexually abusing girls. Law enforcement
7
EFTA00020736

=== Page 9 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 9 of 28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 9 of 28
had taken my detailed statements, but nothing seemed to be happening. I wasn't sure what to do.
While I wanted to do all that I could to get justice for what had happened to me, it was very hard
for me to figure out how to get something done in the United States while I was living in a
foreign country; especially after I had already gave information to the FBI that I believed they
were using to investigate and eventually arrest Epstein.
52.
In October 2013, I returned to the United States for the first time since I had left for
Thailand.
53.
In April 2014, I decided to get back in touch with the FBI. In Sydney, the FBI had
seemed like they wanted to be helpful to me, and I have great respect for the FBI agents who met
me. It appeared to me they wanted to do the right thing in this case. But my feeling was once
the agents collected information about crimes committed against me, someone else stepped in
and blocked them from getting charges filed. I also thought that Marie Villafaña really wanted
to do the right thing and hold Epstein accountable for the horrible crimes he committed. But, it
seemed like the hands of Villafaña and the FBI were always tied by someone else with more
authority.
54.
I have never been able to figure out who was (and still is) stopping a prosecution. I also
haven't been able to figure out who is trying to stop me from being able to participate in a court
case to a have a judge determine whether my rights have been violated. It doesn't seem fair to
me that the Government can argue that I don't even get the opportunity for a judge review the
issue. To me, this is further verification of Epstein's power, which continues to make me very
scared.
55.
I have asked the FBI to show me the video surveillance and other pictures of me that I
believe they have in their possession. They said that I would have to go to the prosecutors to get
them. But the prosecutors will not share anything with me. I believe that the prosecutors have
lots of information that will support what I have been saying about Epstein and his associates.
56.
Based on my knowledge of Epstein and his organization, as well as discussions with the
FBI, it is my belief that federal prosecutors likely possess videotapes and photographic images of
me as an underage girl having sex with Epstein and some of his powerful friends. I don't
understand why they aren't moving forward with what the FBI has given to them. I also don't
understand why these pictures haven't been given to me nor why law enforcement officers from
any other jurisdictions have never contacted me.
57.
It was not until 2014 that I first understood about the way in which Jane Doe No. 1 and
Jane Doe No. 2 were trying to invalidate the non-prosecution agreement to allow prosecution of
Epstein for crimes he committed against them, and me. I had never really heard anything
significant about this case while I was in Australia, and it was hard to get information about what
was happening in Florida while I was overseas. Once I heard about the case, I quickly wanted to
become a part of it.
58.
In light of the way everything has played out, I believe that my rights as a crime victim
have been violated. It was never my choice to become the victim of crimes by Epstein and the
8
EFTA00020737

=== Page 10 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 10 of
28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 10 of
28
people he forced me to have sex with. Epstein dragged me into his web when I was very young
and, after that, it was hard for me to escape. After I ran away to Australia, it appears that Epstein
reached an agreement in 2007 with the federal prosecutors in Florida blocking him from being
prosecuted for the crimes he committed against me.
59.
When Epstein pled guilty to two low level crimes in 2008 as part of his agreement, no
one told me what was happening or that this plea had anything to do with preventing prosecution
of crimes against me or the hundreds of other girls he abused. Nobody told me that I could speak
to the Judge or that a hearing was even taking place.
60.
Based on all the facts I have described here, I believe some kind of major cover-up is
going on to protect Epstein. As I look back on what Epstein and his friends have done, I see a lot
of powerful people who knew what they were doing to me and other girls was wrong. But they
also seemed to think that they were above the law and they had nothing to worry about. From
what I can see, that turned out to be true. There are less powerful people -- like the FBI agents
and Marie Villafana - that seem like they are trying to get the right thing done. But nothing
happens.
61.
Because nothing is being done, it makes me think that Epstein was right when he told me
he had so many people in his pocket. Maybe those people are still helping him escape being
prosecuted for what he did against me. The justice system doesn't seem to respond to the
victims in this case. It seems to favor those who have the most money and power and influence.
62.
I am also worried that this is a very dangerous circuit. By standing up for what is right,
I'm worried that Epstein, or others named here, will come after me. I wonder where this is going
to go if the United States government is not on my side. I am intent on seeing this through so
that Epstein isn't allowed to hurt other young girls. I can't stop abuse everywhere in the world.
But if I help one victim then I have made a positive difference.
63.
In April 2014, I asked two good attorneys - Brad Edwards and Paul Cassell - to see if
they could help me bring Epstein and his friends to justice. They agreed to add me to the
existing case. They explained to me that the lawsuit was not asking to get money from Epstein
or others. I understand and have always understood that the goal of the case is to simply enforce
my rights as a crime victim - rights that were wrongly taken from me.
64.
I want Epstein and the others who committed crimes against me to be punished fairly -
the way other less powerful would be. I also want to be added to the suit filed by the two girls,
Jane Doe Number 1 and Jane Doe Number 2, and I want to have rights the way a victim of a less
wealthy and powerful criminal would have.
65.
Epstein and his friends sexually and physically abused many other girls. They did this in
many places around the world. I personally observed this. There are also many people who
could confirm what I am saying. I hope that these people will come forward and tell the truth. I
hope that they will call my attorney in Fort Lauderdale, Florida - Brad Edwards - so that all
ofthe information can be presented to the court about what has happened to me and others.
9
EFTA00020738

=== Page 11 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 11 of
28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 11 of
28
66.
Because of how often Epstein and others were having sex with young girls, and how
much it was a centerpiece of their lives, I doubt they have just stopped. It also seems to me that,
when I knew them, they believed that they were above the law - too powerful to be prosecuted.
That feeling has no doubt been reinforced by the fact Epstein has escaped real punishment with
his plea bargain, and the others with whom he traveled have completely escaped. I hope that I
can join this case and try to bring them to justice.
67. I declare under penalty of perjury that the foregoing is true and correct.
Executed this 5th day of February, 2015. (Location of signature left undisclosed for
security reasons)
JANE DOE 3
10
EFTA00020739

=== Page 12 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 12 of
28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 12 of
28
EXHIBIT 1
EFTA00020740

=== Page 13 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 13 of
28
Case
9:08-cv-80736-KAM
Document
310-1
Entered on FLSD Docket 02/06/2015 Page 13 of
28
ROYAL PRINCESS
CHANG Mar
112 Charg Klan Boad, T.Ching Klan, A.Muang. Chilang Mal 50100, That
Tel: (053) 281-013 Fax: (053) 281-044
whin relations this
J. EPSTEIN
Royal Princess, Chiang Mai, 18/10/02 12:51
112 assume adidas 50100
188785
Imc (053) 281-033 Image (053) 281-044
50 14 02627
Room No.
: 923
Page No. : 1
3 10 61770 2
Arr. Date : 29/09/02
Dept Date : 19/10/02
Guest
: 1
Cashier
: 11 CHFGAGNT03
Guest Name :
DOE 3
USA
USA
DATE
DESCRIPTION
CHARGE
CREDIT
08/10
Room Charges
2700.00
08/10
Service charge 10%
270.00
08/10
Government Tax
207.90
08/10
Provincial Tax (Rm)
21.60
09/10
Room Charges
2700.00
09/10
Service charge 10%
270.00
09/10
Government Tax
207.90
09/10
Provincial Tax (Rm)
21.60
09/10
Room Service B/F #923 : CHECK #2098
376.64
09/10
Minibar #923 :
120.00
09/10
Long Distance #923 : 061923497
45.00
09/10
Overseas #923 : 001121275098
384.00
09/10
Overseas #923 : 001156179290
177.00
09/10
Overseas #923 : 001121275098
177.00
10/10
Room Charges
2700.00
10/10
Service charge 10%
270.00
10/10
Government Tax
207.90
10/10
Provincial Tax (Rm)
21.60
10/10
Room Service B/F #923 : CHECK #2106
129.47
10/10
Local Call #923 : 053278900
10.00
10/10
Overseas #923 : 001121275098
177.00
10/10
Overseas #923 : 001121275098
118.00
11/10
Room Charges
2700.00
11/10
Service charge 10%
270.00
11/10
Government Tax
207.90
11/10
Provincial Tax (Rm)
21.60
11/10
Long Distance #923 : 017462088
15.00
11/10
Long Distance #923 : 017462088
15.00
11/10
Long Distance #923 : 017462038
15.00
11/10
Long Distance #923 : 017462088
15.00
11/10
Overseas #923 : 001121275098
266.00
11/10
Overseas #923 : 001121275098
59.00
11/10
Laundry/Valet 01699 pia
1912.70
12/10
Room Charges
2700.00
12/10
Service charge 10%
270.00
12/10
Government Tax
207.90
Guest's signature
Date
EFTA00020741

=== Page 14 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 14 of
28
Case
9:08-cv-80736-KAM
Document
310-1
Entered on FLSD Docket 02/06/2015 Page
14
of
28
ROYAL PRINCESS
CHILNE Mat
112 Charge Klan Read, T.Chang Klan, A.Muang, Chilag Mal 50100. That
Tel: (053) 201-033 Fax (053) 201-044
with this
J.EPSTEIN
Royal Princess, Chiang Mai, 18/10/02 12:51
112 a $0100
188785
Inc (053) 281-033 Insure: (053) 281-044
- 50 14 02527
Room No.
: 923
Page No. : 2
0 10 I 61770 2
Arr. Date : 29/09/02
Dept Date : 19/10/02
Guest
: 1
Cashier
: 11 CHFGAGNT03
Guest Name :
DOE 3
USA
USA
DATE
DESCRIPTION
CHARGE
CREDIT
12/10
Provincial Tax (Rm)
21.60
12/10
Long Distance #923 : 019980563
30.00
12/10
Overseas #923 : 001171983648
913.00
12/10
Overseas #923 : 001121275098
30.00
12/10
Overseas #923 : 001121275098
89.00
13/10
Room Charges
2700.00
13/10
Service charge 10%
270.00
13/10
Government Tax
207.90
13/10
Provincial Tax (Rm)
21.60
13/10
Room Service B/F #923 : CHECK # 117
153.01
13/10
Long Distance #923 : 069156556
45.00
13/10
Long Distance #923 : 069156556
30.00
13/10
Long Distance #923 : 069156556
15.00
13/10
Overseas #923 : 001156179290
30.00
13/10
Overseas #923 : 001156124844
30.00
13/10
Overseas #923 : 001156179045
560.00
13/10
Overseas #923 : 001156179835
30.00
13/10
Overseas #923 : 001121275098
30.00
13/10
Overseas #923 : 001156179290
59.00
13/10
Overseas #923 : 001156179855
384.00
13/10
Overseas #923 : 001156179045
89.00
14/10
Room Charges
2700.00
14/10
Service charge 10%
270.00
14/10
Government Tax
207.90
14/10
Provincial Tax (Rm)
21.60
14/10
Room Service B/F #923 : CHECK # 129
294.25
14/10
Minibar #923
:
290.00
14/10
Overseas #923 : 001121275098
59.00
14/10
Overseas #923 : 001156130954
59.00
14/10
Overseas #923 : 001121275098
59.00
14/10
Overseas #923 : 001156179290
30.00
15/10
Room Charges
2700.00
15/10
Service charge 10%
270.00
15/10
Government Tax
207.90
15/10
Provincial Tax (Rm)
21.60
15/10
Minibar #923 :
120.00
Guest's signature
Date
EFTA00020742

=== Page 15 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 15 of
28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 15 of
28
ROYAL PRINCESS
CHAM: Mat
112 Ching Klan Read, T.Ching Klas, A.Muarg. Ching Mai 50100. Thata
Tel: (053) 281.033 Fax: (053) 281-044
vivn this (RM)
J.EPSTEIN
Royal Princess, Chiang Mai, 18/10/02 12:51
112 assume nails additional 40100
In: (053) 281-033 Insan: (053) 231-044
188785
50 14 02627
Room No. : 923
Page No. : 3
a 10 I 61770 2
Arr. Date : 29/09/02
Dept Date : 19/10/02
Guest
: 1
Cashier : 11 CHFGAGNT03
Guest Name :
DOE 3
USA
USA
DATE
DESCRIPTION
CHARGE
CREDIT
15/10
Overseas #923 : 001156179290
796.00
15/10
Overseas #923 : 001156165548
118.00
15/10
Overseas #923 : 001121275098
354.00
16/10
Room Charges
2700.00
16/10
Service charge 10%
270.00
16/10
Government Tax
207.90
16/10
Provincial Tax (Rm)
21.60
16/10
Poolside p.m. #923 : CHECK # 621
29.43
16/10
Room Service B/F #923 : CHECK # 143
282.48
16/10
Room Service B/F #923 : CHECK 0 147
918.06
16/10
Minibar #923 :
180.00
16/10
Local Call #923 : 053224979
10.00
16/10
Overseas #923 : 001121275098
89.00
16/10
Overseas #923 : 001121275098
325.00
16/10
Overseas #923 : 001121275098
148.00
16/10
Overseas #923 : 001121275098
118.00
16/10
Overseas #923 : 001121275098
295.00
16/10
Overseas #923 : 001171983632
30.00
16/10
Overseas #923 : 001156179045
30.00
16/10
Overseas #923 : 001121275096
59.00
17/10
Room Charges
2700.00
17/10
Service charge 10%
270.00
17/10
Government Tax
207.90
17/10
Provincial Tax (Rm)
21.60
17/10
Room Service B/F #923 : CHECK #2160
306.02
17/10
Room Service B/F #923 : CHECK # 161
94.16
17/10
Room Service B/F #923 : CHECK # 162
94.16
17/10
Minibar #923 :
160.00
17/10
Overseas #923 : 001121275098
30.00
17/10
Overseas #923 : 001121275098
148.00
17/10
Overseas #923 : 001161974392
30.00
17/10
Overseas #923 : 001156179045
59.00
17/10
Overseas #923 : 001171983632
471.00
17/10
Overseas #923 : 001121275098
89.00
18/10
Room Charges
2700.00
18/10
Service charge 10%
270.00
Guest's signature
Date
EFTA00020743

=== Page 16 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 16 of
28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 16 of
28
ROYAL PRINCESS
CHEANG Mai
112 Chang Klan Road, T.Chang Klan, A.Muarg. Ching Mal 50100, Thata
Tel: (053) 281-033 Fax: (053) -044
whin this
J.EPSTEIN
Royal Princess, Chiang Mai, 18/10/02 12:51
112 assist united 50100
188785
Inc (053) 251-033 Issume (053) 281-044
so 14 02527
Room No. : 923
Page No. : 4
1 3 10 1 61770 2
Arr. Date : 29/09/02
Dept Date : 19/10/02
Guest
: 1
Cashier : 11 CHFGAGNT03
Guest Name :
DOE 3
USA
USA
DATE
DESCRIPTION
CHARGE
CREDIT
18/10
Government Tax
207.90
18/10
Provincial Tax (Rm)
21.60
18/10
Room Service B/F #923 : CHECK # 171
294.25
18/10
Room Service B/F #923 : CHECK # 172
188.32
18/10
Overseas #923 : 001612974392
207.00
18/10
Cash PHET
48587.45
Total
48587.45
48587.45
Balance
0.00 Baht
Total including VAT
48349.85 Baht
Total without VAT
237.60 Baht
Folio amount net
45424.38 Baht
VAT 7.00%
3163.07 Baht (48349.85)
TAX IO NO. 3101617702
RD NO.
501491000235
TAX INVOICE NO. 13489
TAX INVOICE(ABB)
Guest's signature
Date
EFTA00020744

=== Page 17 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 17 of
28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 17 of
28
ROYAL PRINCESS
CHANG MAI
112 Chang Klan Road, T.Chang Klas, A.Muang. Ching Mal 50100, Thath
Tel: (053) 281-033 Fax: (053) 281-044
uptn thrie (NWIUM)
J.EPSTEIN
Royal Princess, Chisng MNI, 08/10/02 14:14
112 0.00 50100
Inc (053) 281-033 Insurn: (053) 261-044
187916
50 14 02527
Room No.
: 923
Page No.
: I
3 10 I 61770 2
Arr. Date : 29/09/02
Dept DATE : 19/10/02
Guest
; 1
Cashier : 11 CHEGAGHT03
Guest Name :
DOE 3
USA
USA
DATE
DESCRIPTION
CHARGE
FREDIT
29/09
Room Charges
2700.00
29/09
Service charge 10%
270.00
29/00
Government Tax
207.90
29/09
Provincial TAX (Rm)
21.60
29/09
Overseas #923 ! 001156179290
118.00
30/09
Room Charges
2200.00
30/09
Service charge 10%
270.00
30/09
Government TSN
207.90
30/09
Provincial Tax (Rin)
21.60
30/09
overseas #233 : 001156179290
737.00
20/09
Overseas 4923 : 001171988632
30.00
30/09
Overseas #923 : 001171983648
472.00
30/09
Overseas 0923 : 001188179045
00.00
NO/09
Overseas #923 : 001181752000
30.00
30/09
Overseas #923 : 001156179045
30.00
30/09
Overseas 1923 : 001156373290
325.00
01/10
Room Charges
2700.00
01/10
Service charge 10%
270.00
01/10
Government Tax
207.90
01/10
Provincial Tax (Rm)
71.60
01/10
Overceas 0923 : 001156179290
30.00
01/10
Overseas #923 : 001156174290
325.00
01/10
Overseas #923 : 001156179200
265.00
01/10
Overseas 1923 : 001)56179290
$9.00
02/10
Room Charges
2700.00
02/10
Service charge 10%
270.00
07/10
Government Tax
207.90
02/10
Provincial Tax (1%)
21.60
02/10
PoolsIde 4.8. 4923 : CHECK il 48/
554.96
02/10
Poolside p.m. 1023 : CHECK 1. 40
168.32
02/10
Poolside p.m. #923 : CRECK # 193
138.32
02/16
Kinibai #923 :
170.00
92/10
Overseas 1923 : 001156179290
30.00
03/10
Room Charges
2700.00
03/10
Service charge 10%
270.00
03/10
Government Tax
207.90
Guest's signature
Date
EFTA00020745

=== Page 18 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 18 of
28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 18 of
28
ROYAL PRINCESS
CHIANG Mat
112 Chang Klan Road, T.Chasg Elas, A.Mueng. Chiang Mat 50100, The
Tel: (053) 281-033 Fax: (051) 281-044
whin drink (NHIMM)
J.EPSIELA
Royal Princess, Chiang Mal, 08/10/02 14:14
112 and 60100
187916
Im: (053) 281-033 Iman: (053) 281-044
50 14 02527
Room No.
:
978
Page No.
:
2
3 10 I 61770 2
Arr. Date : 29/09/02
Dept Date : 19/10/02
Guest
: 1
Cashier : U CHEGAGNIOS
Guest Name :
DOE 3
USA
USA
DATE
DESCRIPTION
CHARGE
CREWIT
03/10
Provincial Tax (RM)
21.60
03/10
Overseas 1973 : 001156179290
207.00
00/10
Uverseas #923 : 001158179045
296.00
03/10
Overseas #923 4 001156178290
202.00
04/10
Room Charges
2/00.00
04/10
Service charge 10%
270.00
04/10
Government Tax
207.90
04/10
Provincial Tex (RA)
21.60
04/10
Poolside p.m. #923 : CHECK il 508
188.32
08/10
#923 : 001156178290
1031.00
04/10
Overseas 1923 : 001156179290
2001.00
04/10
overseas uses : 001156179290
207.00
03/10
Room Charges
2700.00
05/10
Service charge 105
270.00
05/10
Government Tax
207.00
05/10
Provincial Tax (199)
21.60
05/10
Local Call #923 : 053222616
10.00
05/30
local Call $923 05-321153
10.00
05/10
Overseas #923 : 041180430615
118.00
05/10
Overleas C973 : 001566179290
412.00
05/10
Overseas #923 : 001156179290
1884.00
06/10
Overseas 1923 : 001156179240
1081.00
08/10
Room Charges
2700.00
06/10
Service charge 10%
270.00
06/10
Government Tax
207.90
06/10
Provincial Tax (Rm)
21.60
06/10
Poolside p.m. 426517 HCO
363.10
00/10
Poolside p.m. $23521 NOO
376.64
05/10
Local Call #928 : 053222615
10.00
06/10
Overteas #923 : 001156179280
59.00
07/10
Room Charges
2700.00
07/10
Service charge 10%
270.00
07/10
Government Tax
207.90
07/10
Provincial Tax (kei)
21.60
07/10
Minther 41616 pin
220.00
a
07/10
Long Dislance 1923 : 061923497
15.00
Guest's signature
Date
EFTA00020746

=== Page 19 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 19 of
28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 19 of
28
ROYAL PRINCESS
CHIANG Mas
112 Chang Klan Road, T.Chang Klan, A.Mang, Ching Mal 50100, Thather
Tel: (053) 201-033 Fax: (053) 281-044
when receivings thrie (митин)
1.EPSTEIN
Royal Princess, Chiang Nai, 08/10/02 14:14
112 eshime n.wine 80100
137916
Im (053) 281-033 Imme (053) 281-044
so 14 02527
-
Reom No. i 923
Page No. : 3
3 10 I 61770 2
Arr. Date : 29/09/02
Dept Date : 19/10/02
Guest
: 1
Cashier : 11 CHEGAGNTOS
Guest Maine :
DOE 3
USA
USA
DATE
DESCRIPTION
CHARGE
CARD
07/10
Overseas #923 : 001156179290
207.00
07/10
Overseas 1923 : 001156179290
1090.00
07/10
Overseas #923 : 001121275098
295.00
07/10
Oversess #928 : 001156178290
148.00
08/10
Overseas 1923 : 001156179290
913.00
08/10
Cash PHAN
44677.16
Total
44677.16
14677.16
0.00 BANK
Total including VAI
Bahl
TOTAL Ofthout VAT
Beht
Pulio AMOUNT not
Balic
VAT 7.00%
2910.00 belit (44462.76)
TAX in no. 3101017702.
RD NO. 501491000245
TAX DAVOICE RO. 13026
TAX INVOICE (ABB)
Guest's signature
Date
EFTA00020747

=== Page 20 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 20 of
28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 20 of
28
ROYAL PRINCESS
CHANGE Mat
112 Ching Klan Road, T.Charg Klan, A.Mearg. Ching Ma 50100, Thatle
Tel: (053) 281-033 Fax: (053) 281-044
visin this (нитим)
J.EPSTEIN
Royal Princess, Chiang Mai, 19/10/02 13:07
112 50100
Ins: (083) 281-033 Insure (053) 281-044
50 14 02527
Room No. : 923
Page No. : 1
3 10 I 61770 2
Arr. Date : 29/09/02
Dept Date : 19/10/02
Guest
: 1
Cashier : 11 CHFGAGNT03
Guest Name : DOE 3
USA
USA
DATE
DESCRIPTION
CHARGE
CREDIT
18/10
Room Service B/F #923 : CHECK # 171
294.25
18/10
Room Service B/F #923 : CHECK # 172
188.32
18/10
Long Distance #923 : 098181318
15.00
18/10
Long Distance #923 : 098183189
60.00
18/10
Overseas #923 : 001612974392
207.00
18/10
Overseas #923 : 001612974392
384.00
18/10
Overseas #923 : 001156184460
833.00
19/10
Room Service B/F #923 : CHECK # 183
400.18
19/10
Minibar
220.00
Total
2651.75
Balance
2651.75 Baht
Total including VAT
2601
Folio amount net
247
VAT 7.00%
Delit (2651.75)
TAX 1D NO. 31016177
RO NO.
501491000
TAX INVOICE (ABB)
Guest's signature
Date
EFTA00020748

=== Page 21 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 21 of
28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 21 of
28
EXHIBIT 2
EFTA00020749

=== Page 22 ===
DOE 3
28
Travel Documents
TOTAL
FOR:
PARIS
SHOPPERS
DAIL)
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 22 of
28
Signature
Jane Doe 3
SATAN
TRAVEL, INC
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 22 of
303 FIFTH AVENUE Sum 1007
New York, NY 10016
Ta (212) 779-6800
FAX . (212) 779-8397
1010 VERMONT AVENUE N. SUITE mon
New JERSEY Tel (732) 287-6300
WASHINGTON, DC 20005
Tou. FREE 800-216-9025
Ta. (202) 393-7771
E-MAIL: shoppertvi@aol.com
FAX (202) 393-7007
WEIL: www.shopperstravel.com
EFTA00020750

=== Page 23 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 23 of
28
Case
9:08-cv-80736-KAM
Document
310-1 Entered on FLSD Docket 02/06/2015 Page 23 of
28
CAREFULLY
Please checkeyour documents when you receive them. Cat - . you have any questions.
HOTELS - vounly confirmed on payment basels. if you cence or change plans, please notify your
CHECK-N Minimum check time for domestic lights b 00 minutes and for International Sights . 2 hours
hotel by 400 P.M. local time to avoid maridatory payment. Result hotels may require 72 have
alvance notica.
RECORDEM your return of continuing fights 48 has for doseste and 72 hours for international fature to
IMPORTANT X you # an sides ticket or manager check in country with your confirmed School and the
Line any reservisions may result in adomate carcetain of M continuing and return reeriations Recordemation
. mandatory in Canada Marks Howel and all international desiretions
that Pm sining shows no menator for you do not love the counter Check your the if the ter shows
"OR" for the Bight in question the sirline must accommodate you on that fight, or # that is not pussible May -
These lives, tights and fives Are tesal on current with N at subject to charge what notice
other find you a substitute fight If pay you denied boarding commission If necessary milk to april to
# supervisor
EXCURSION AND PROMOTIONAL FARES Most discount lares Invoive certain restrictions A Charge in
DISCLAIMER OF LIABILITY This Trevel Agency is acting - informediary or - agency has suppliers in
corrients) Nightst or reving(s) could result in a card remarding a full has Ottain agency or sizing -
beiling services, or - accepting reservations or backings for services which are not directly supplied by
before making charges.
this Travel Agency (such - * carriege, hotel accommodations, ground transportation, manis, tours,
THIS TICKET HAB VALUED you change your licksing an rouls INSIST that the remaining value of the migiul
cruties, visit. This Travel Agency, therefore, shall not be responsible for breach of contract or any
ticket be applied loward the - of the leve Michel with alther additional - - refund of any difference
Infertional or careless actions or ordersions on pert of such suppliers, which result in any leas, damage,
being made I necessary
daily, or Injury no you If your companions or group members. Unless the term "paranted" .
specifically stated in writing de your the Invoice or reservation / M de not guarantee any of
the person soing the licketing reluted your request, ribtain name or an Contification and arrive Ltd of details
such suppliers' reles, bookings or reservations Your relation of Schools, reservedors or beekings after
upon return
issuance the constitute consent of the above, and an agreement on your part to convey the contacts
heref to your Insul companions or group members. This Travel Agency herein gives notice that if cannot
TICKET Canceled of unused the must to naturned for proper credit Lost, or destroyed Schots must
be held responsible for any disruption of travel and/or related services in "Troubled area," doe to
be paid la unl refund la received from the issuing carrier, subject to M sittine imposed arrivice charge
Monetary Cities, Political or Social Unrest, Labor Problems, Mechandel or Construction Difficulties,
Câmatic Albertations, Local Laws, Diseases, - Nevel Conditions, Including Terrorist Authitties,
WE STRONGLY RECOMMEND TRAVEL INSURANCE
I
-
SHOPPERS TRAVEL, INC.
SHOPPERS TRAVEL
AGENT RS/RS BOOKING REF ZXLL07
303 5TH AVENUE
NEW YORK
NY10016
DOE 3
212 779 8800
J EPSTEIN
457 MADISON AVE
4TH LOOR
TERMS: PAYMENT DUE UPON PRESENTATION
NEWYORK NY 10027
ATT:KIMBERI V
RECORD
AIRLINE
FLT
CL
DATE
FROM
TO
LV
AR
ST
DATE: SEP 27 2002
SINGAPORE AIRLINES
27SEP NEW YORK NY
SINGARORE
945P
635A
SQ 25
Q
FRI
JOHN F KENNEDY
CHANGI
29SEP
NON SMOKING
TERMINAL 1
TERMINAL 2
MEAL
1 STOP
RESERVATION CONFIRMED
20:50 DURATION
NEW YORK
FRANKFURT
FRANKFURT
SINGAPORE
AIRCRAFT: BOEING 747-400
SINGAPORE
AIRLINES
29SEP SINGAPORE
BANGKOK
850A
1010A
SQ 62
Q
SUN
CHANGI
BANGKOK INTL
NON SMOKING
TERMINAL 2
TERMINAL 2
MEAL
NON STOP
RESERVATION CONFIRMED
2:20 DURATION
AIRCRAFT:
BOEING 747-400
R
THAI AIRWAYS INTL
29SE BANGKOK
CHIANG MAI
1215P
125P
TG 110
Y
SUN
BANGKOK INTL
INTERNATIONAL
NON SMOKING
TERMINAL DOM
NON STOP
RESERVAT ION, CONFIRMED
1:10 DURATION
AIRCRAFT AIRBUS INDUSTRIE A300-600/600C
HOTEL
29SEP ROYAL PRINCESS CHIANGMAI
1,90CT BOAD
AMPHUR MUANG
CHIANG MAIL 50109
HARRAND
EFTA00020751

=== Page 24 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 24 of
28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 24 of
28
SHOPPERS TRAVEL, INC.
SHOPPERS TRAVEL
AGENT RS/RS BOOKING REF ZXLL07
303 5TH AVENUE
NEW YORK
NY10016
DOE 3
212 779 8800
J EPSTEIN
457 MADISON AVE
TERMS: PAYMENT DUE UPON PRESENTATION
4TH FLOOR
NEWYORK NY 10027
RECORD
ATT:KIMBERI V
AIRLINE
FLT
CL
DATE
FROM
TO
LV
AR
ST
DATE: SEP 27 2002
SINGAPORE AIRLINES
27SEP NEW YORK NY
SINGAPORE
945P
635A
SQ 25
Q
FRI
JOHN F KENNEDY CHANGI
29SEP
NON SMOKING
TERMINAL 1
TERMINAL 2
MEAL
1 STOP
RESERVATION CONFIRMED
20:50 DURATION
NEW YORK
FRANKFURT
FRANKFURT
SINGAPORE
AIRCRAFT: BOEING 747-400
SINGAPORE
AIRLINES
29SEP
SINGAPORE
BANGKOK
850A
1010A
SQ 62
Q
SUN
CHANGI
BANGKOK INTL
NON SMOKING
TERMINAL 2
TERMINAL 2
MEAL
NON STOP
RESERVATION CONFIRMED
2:20 DURATION
AIRCRAFT:
BOEING 747-400
THAI AIRWAYS INTL
29SEP BANGKOK
CHIANG MAI
1215P
125P
TG 110
Y
SUN
BANGKOK INTL
INTERNATIONAL
NON SMOKING
TERMINAL DOM
NON STOP
RESERVATION CONFIRMED
1:10 DURATION
AIRCRAFT: AIRBUS INDUSTRIE A300-600/600C
HOTEL
29SEP ROYAL PRINCESS CHIANGMAI
1900T 112 THINGLEN ROAD
AMPHOR MUANO
CHIANG MAIL 50100
THAILAND
TELEPHONE: 66 53281033-43
FAX: 66 53281044
TELEX: NONE
CONFIRMATION: 102520345
REFERENCE: A03A00
SINGLE ROOM TWIN BED
RATE: COR THB 2700.00 PER NIGHT
GUARANTEE GIVEN
CANCELLATION POLICY:
BY 1600 22SEP2002 LOCAL PROPERTY TIME
VISIT OUR SITE HTTP://www.shopperstravel.com E-Mail: Info@shopparstravel.com
303 FIFTH AVENUE SUITE 1007 NEW YORK, N.Y. 10016
TEL. (212) 779-8800 FAX (212) 779-8397
NEW JERSEY TEL (732) 287-6300
PLEASE RECONFIRM FLIGHTS AND TIMES IN CASE OF SCHEDULE CHANGES
THANK YOU
24 HOUR PRIOR FOR DOMESTIC TRAVEL 72 HOURS PRIOR FOR INTERNATIONAL TRAVEL
EFTA00020752

=== Page 25 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 25 of
28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 25 of
28
SHOPPERS TRAVEL, INC.
SHOPPERS TRAVEL
AGENT RS/RS BOOKING REF ZXLL07
303 5TH AVENUE
NEW YORK
NY10016
DOE 3
212 779 8800
J EPSTEIN
457 MADISON AVE
TERMS: PAYMENT DUE UPON PRESENTATION
4TH FLOOR
NEWYORK NY 10027
RECORD
ATT:KIMBERL V
AIRLINE
ELT
CL
DATE
FROM
TO
LV
AR
ST
DATE:
SEP 27 2002
THAI AIRWAYS INTL
19OCT CHIANG MAI
BANGKOK
315P
425P
TG 113
Y
SAT
INTERNATIONAL
BANGKOK INTL
NON SMOKING
TERMINAL DOM
NON STOP
RESERVATION CONFIRMED
1:10 DURATION
AIRCRAFT: AIRBUS INDUSTRIE A300-600/600C
SINGAPORE AIRLINES
19OCT BANGKOK
SINGAPORE
630P
955P
SQ 67
Q
SAT
BANGKOK INTL
CHANGI
NON SMOKING
TERMINAL 2
TERMINAL 2
MEAL
NON STOP
RESERVATION CONFIRMED
2:25 DURATION
AIRCRAFT:
BOEING 747-400
SINGAPORE AIRLINES
190CT
SINGAPORE
NEW YORK NY
1150P
1040A
SQ 26
Q
SAT
CHANGI
JOHN F KENNEDY
200CT
NON SMOKING
TERMINAL 2
TERMINAL 1
MEAL
1 STOP
RESERVATION CONFIRMED
22:50 DURATION
SINGAPORE
FRANKFURT
FRANKFURT
NEW YORK
AIRCRAFT: BOEING 747-400
AMERICAN AIRLINES
200CT NEW YORK NY
MIAMI FL
250P
606P
AA 1701
N
SUN
JOHN F KENNEDY MIAMI INTL
NON SMOKING
TERMINAL 8
NON STOP
RESERVATION CONFIRMED
3:16 DURATION
AIRCRAFT: BOEING 757-200/300
MISCELLANEOUS
27JUL CHIANG MAI
SUN SHOPPERS TRAVEL
RESERVATION NUMBER(S) AA/DFNKAZ SQ/JC5MU4 TG/L2QHI4
THIS TICKET IS NONREFUNDABLE/NONCHANGEABLE
PENALTY MAY APPLY FOR ANY CHANGE/CANCELLATION
CHECKIN 2 HOURS BEFORE SCHEDULED DEPARTURE
RECONFIRM RETURN SITE IGHTS 72HOURS IN ADVANCE fo@shopperstravel.com
WE SUGGEST YOU CARRYo3 SOITE YORK, N.Y.10016
INTERNATIONAL TRAVEL 1779397
IT IS YOUR RESPONSIBILITY TEM 17321 281-300
PLEASE RECONFIRM FLIGHTS AND TIMES IN CASE OF SCHEDULE CHANGES
THANK YOU
24 HOUR PRIOR FOR DOMESTIC TRAVEL 72 HOURS PRIOR FOR INTERNATIONAL TRAVEL
2
EFTA00020753

=== Page 26 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 26 of
28
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 26 of
28
SHOPPERS TRAVEL, INC.
SHOPPERS TRAVEL
AGENT RS/RS BOOKING REF ZXLL07
303 5TH AVENUE
NEW YORK
NY10016
DOE 3
212 779 8800
J EPSTEIN
457 MADISON AVE
TERMS: PAYMENT DUE UPON PRESENTATION
4TH FLOOR
NEWYORK NY 10027
RECORD
ATT:KIMBERL y
AIRLINE
FLT
CL
DATE
FROM
TO
EV
AR
ST
DATE: SEP 27 2002
CONSULATE ABOUT YOUR VISA TO THE COUNTRIES YOU
ARE TRAVELLING/TRANSITTING
SHOPPERS TRAVEL, INC IS NOT RESPONSIBLE FOR TICKETS
LOST, OR DELAYED IN THE MAIL
***PLEASE CARRY A VALID PHOTO ID****
THANK YOU, KNOW THAT YOU HAVE A CHOICE AND
WE APPRECIATE YOU CHOOSING SHOPPERS TRAVEL, INC
VISIT OUR WEB SITE AT WWW.SHOPPERSTRAVEL.COM
HAVE A NICE TRIP
R
Name Corporation
TATXU
VISIT OUR SITE HTTP://wwwshopperstravel.com E-Mail: Info@shopperstravel.com
303 FIFTH AVENUE SUITE 1007 NEW YORK, N.Y. 10016
TEL. (212) 779-8800 FAX (212) 779-8397
NEW JERSEY TEL (732) 287-6300
37
PLEASE RECONFIRM FLIGHTS AND TIMES IN CASE OF SCHEDULE CHANGES
THANK YOU
- 24 HOUR PRIOR FOR DOMESTIC TRAVEL - 72 HOURS PRIOR FOR INTERNATIONAL TRAVEL
EFTA00020754

=== Page 27 ===
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 27 of
28
Case
9:08-cv-80736-KAM
Document
310-1
Entered
on
FLSD
Docket
02/06/2015
Page
27
of
28
1.
Please check your documents when you receive them Call us if you
11. We reserve the right to arge processing fees in the event of
have any questions
refunds. cancellations or special SGIV cas
2. CHECK-IN - Minimum check-in time for domestic flights is 60
12 DISCLAIMER OF LIABILITY This Travel Agency is acting as #
minutes and for international flights. 2 hours.
more agent for suppliers In selling travel-related services, or In
3.
RECONFIRMATION the use and time of flights al least
accepting reservations or bookings for services that are not di-
24 hours for domestic and 72 hours for international. Recontirmation
reclly supplied by this travel agency (such as air and ground
is mandatory In Florida, Canada, Mexico, Hawali and all International
transportation, hotel accommodations, meals, tours, crulses, etc.).
destinations. F allure to use any reservations may result in automatic
This agency, therefore, shall not be responsible for breach of
cancellation of all continuing and return reservations
contract or any Intentional or careless actions or omissions on part
of such suppliers, which result in any loss, damage, delay, or Injury
4
EXCURSION AND PROMOTIONAL FARES discountifares
to you or your travel companions or group members Unless the
involve certain restrictions. A change carrier(s), light(s). time(s) or
term "guaranteed" is specifically stated in writing on your tickets,
routing(s) could result in a carrier demanding a full fare Obtain
Invoice, or reservation itinerary, we do not guarantee any of such
agency or alrline assistance before making any changes
suppliers' rates, bookings; reservations, connections, scheduling,
or handling of personal effects. Travel agent shall not be respon-
5.
If your plans change enroute, apply the value of your tickets toward
sible for any Injuries, damages, or losses caused to any traveler In
a reissued one. It is not necessary to purchase a new ticket If a
connection with terrorist activities, social or labor unrest, me-
refund is due, obtain a receipt from the airline
chanical or construction faltures or difficulties, diseases, local
6.
These times, flights and fares are based on current tariffs that are
laws, Elimatic conditions, criminal acts or abnormal conditions or
subject to change without notice.
developments, or any other actions, omissions, or conditions
outside the travel agent's control. Traveler assumes complete and
7. Cancelled or unused tickets must be returned for proper
full responsibility for, and hereby releases the agent from any duty
credit to your account. Lost, stolen or destroyed lickets must be paid
of, checking and verifying any and all passport, visa, vaccination,
for until refund is received from the Issuing carrier; subject to an
or other entry requirements of each destination, and all safety or
airline imposed service charge.
security conditions at such destinations, during the length of the
proposed travel. For Information concerning possible dangers at
B. HOTELS are usually confirmed on a guaranteed payment basis If
International dealinations, contact the Travel Advisory Section of
you cancel or change plans, please notify your hotel(s) within the
the U.S. State Department. For medical information, call the Public
time period specified by that hotel.
Health Service. By embarking upon his/her travel, the traveler
9. TOUR/PACKAGE PRICES are subject to change without notice due
voluntarily assumes all risks Involved in such travel, whether
to currency fluctuations, tariff changes or increase in operational
expected or unexpected. Truveler Is hereby warned of such risks,
costs. In addition, group tours/packages are based on a Minimum
and is advised to obtain appropriate Insurance coverage against
Number of passengers travelling: if the number of passengers falls
them. Traveler's retention of tickets, reservations, or bookings
below the minimum required, a surcharge may be imposed on all
after Issuance shall constitute a consent to the above, and an
agreement on his her part to convey the contents hereto to his/her
passengers.
travel companions or group members.
10. IMPORTANT!!! If you arrive at an airline ticket or passenger check
in counter with your confirmed ticket and find that the airline shows
13 Proof of identity is required for International travel Without proper
no reservation for you do not leave the counter Check your ticket.
identification, a passport and necessary visas you will not be purmit
If the status box shows "OK" for the flight in question, the airline must
led to depart. It is your responsibility to verify your necessary travel
accommodate you on that Right, or If that is not possible. they must
documents
other find you a substitute night or pay you denied boarding compen
shtion. II necessary ask to speak to a supervisor.
WE STRONGLY RECOMMEND RAVEL INSURANCE
WHAT YOU SHOULD KNOW ABOUT THE POSSIBILITY OF AIRLINE BANKRUPTCIES.
Hopefully there will not be any more airline bankruptcies, but it has to be recognized that they might occur You should know how they might affect you
1.
If an airline declares bankruptcy, il is not obligated to carry you or to
3.
If an airline declares bankrupicy it might continue service, limit
refund tickets Issued before the bankruptcy.
service, or stop completely. Other airlines might scrept passengers
under limited circumstances or may reluse to epr any passengers
2
Travel agents are not allowed to refund tickets on airlines which have
from the defaulted came
declared bankruptcy, Money given to a travel agent immediately
becomes the property of the airlines and we are required by laws to
4
Meanwhile there are fine travel insurance plans available for passen
comply with the airlines' orders.
gers to protect them inlves in CASB of airling bankruptcies
IMPORTANT NOTICE
This agency and its agents have endeavored to secure the lowest possible fare, suitable for your travel requirements, based on space available at the time
of booking. accessible sources of Information, and knowledge of agents involved.
This agency cannot guarantee, in VIEW of the deregulation of airline fares, that the fare indicated on ticket. will be the lowest possible fare at departure date.
Please contact this agency before departure If you wish to rechnck any newly introduced fare, that may correspond with your specific travel requirements.
PLEASE NOTE that retention of tickets, reservations or backings after issuance shall constitute a copture = of all the provisions in the conditions listed
hereto, as well as those terms and conditions set forth in the announcements and circulars of the tour/package, cruise or service
EFTA00020755

=== Page 28 ===
Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 28 of
28
Your Travel Check List
General List:
His Check List:
Her Check List:
Tickets
First Aid supplies
Bathing trunks
Belts
Passport
Camera and film
Beach jackets
Blouses
Vaccination certificate
Clock
Cuff links, tie clasp
Coat
28
Wallet
Clothesline and clips
Gloves
Cosmetic supplies
Trevelers checks
Comb
Handkerchiefs, scarves
Dresses
Itinerary
Deodorant
Hat
GI ves
Reservations
Needles and thread
Pajamas
Handbag, press and travel
Phone numbers
Plastic bags
Raincoat or topcoat
Hats
Prescriptions (duplicates)
Robe
Hose
Safety pins
Scarf
Jewelry
Soap, laundry and bath
Shaving supplies
Linger 9
Spot remover
Shirts
Raincoat and boots
Suntan lotion
Shoes socks
Robe or beach cost
Tooth brush
Slacks
Scarf, he dkerchiefs
Tooth paste
Slippers or thongs
Shoes, dress and walking
Umbrella
Suits (one dark for evening)
Shower cap
Calling cards
Ties
Slippers, scuffs, or beach thongs
Business literature
Underwear
Swim suit
Pen and paper
Sweaters
Addresses and stamps
Suits
Glasses
Medicines
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 28 of
Aspirin
Sun glasses
EFTA00020756


c1: EFTA00021169
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021169.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: GhislaineDMarrestcoverage.pdf
Date: Fri, 03 Jul 2020 12:57:07 +0000
Attachments: GhislaineDMarrestcoverage.pdf; ATT00001.txt
Our NY-based Daily Mail reporter sent us this pdf of the print edition coverage of the Maxwell arrest and press
conference. It's awfully big "across the pond."
EFTA00021169


c1: EFTA00022545
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022545.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Updates
Date: Tue, 30 Jul 2019 22:24:17 +0000
Fine by me.
From:
Sent: Tuesday, July 30, 2019 4:43 PM
To:
Subject: Updates
Proposed division:
TD
RC
Epstein
Chief, Public Corruption Unit
United States Attorney's Office for the
Southern District of New York
1 St. Andrew's Plaza
EFTA00022545


c1: EFTA00021031
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021031.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
Cc:
)"
)"
)"
Subject: Re: [EXTERNAL] 20CR330 U.S. V GHISLAINE, MAXWELL
Date: Mon, 22 Nov 2021 18:30:50 +0000
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!
EFTA00021031


c1: EFTA00023012
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023012.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Maxwell reply in
case
Date: Sat, 05 Sep 2020 00:52:17 +0000
Attachments: 2020.09.04_GM_reply_in_support_of_motion_to_stay_civil_case.pdf
Attached is the reply letter Maxwell's counsel filed in further support of her motion to stay
case.
Alarmingly, they come out and say that they believe she is one of the victims named in the indictment, teetering
dangerously close to a violation of the protective order in our case.
My plan is still to file our letter in support of a stay as is this evening. Please let me know if anyone would like to discuss
or revise our letter further before filing.
Thanks,
EFTA00023012


c1: EFTA00021279
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021279.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: RE: Daily Beast has it
Date: Sun, 07 Jul 2019 01:38:24 +0000
Importance: Normal
The FBI already called Kaplan Hecker without our knowledge, earlier (along with two other victims and their attorneys).
l'll call her as well, though.
From:
Sent: Saturday, July 06, 2019 21:37
To:
Subject: Re: Daily Beast has it
I think you should reach out to
tonight
Sent from my iPhone
On Jul 6, 2019, at 9:10 PM,
wrote:
Yeah they're literally just leaking the press release -
The case is being handled by the Public Corruption Unit of the Southern District of
New York, with assistance from the district's human-trafficking officials and the
FBI.
and the sealed indictment -
according to details of the arrest and indictment shared by two officials.
From:
Sent: Saturday, July 06, 2019 21:08
To:
Cc:
Subject: Re: Daily Beast has it
And now is reporting that it's our unit
Sent from my iPhone
On Jul 6, 2019, at 8:06 PM,
wrote:
https://www.thedailybeast.com/jeffrey-epstein-arrested-for-sex-trafficking-of-minors-source
FBI is leaking the content of the indictment.
Assistant U.S. Attorney
EFTA00021279

=== Page 2 ===
Southern District of New York
EFTA00021280


c1: EFTA00022542
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022542.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
PTS DETAILS
Person
Appearance
USMS No
Weight
Height
185
6" 0'
Last Name
EPSTEIN
Colors: Eye
Hair
BLUE
BROWN
First Name
JEFFREY
Sex
Race
MALE
WHITE/WHITE HISPANIC
Middle Name
EDWARD
Address
Numbers
Street Address
9 EAST 71ST
FBI No
State
Zip
NY
10021
SSN
City
NEW YORK
Alien No
Other
Citizenship
US
Marital Status
SINGLE
Birth
Phone
DOB
Original Location
POB City
State
Import Date
7/11/2019
Mugshots
Arrest
Date
Agency Code
Agency Name
Remark
Location
FBI208
FEDERAL BUREAU OF INVESTIGATION
7/8/2019
Offenses
Most Foul
Disposed No
Disposed Remarks
Remarks
Initial Offense
Final Offense
Y
NOT YET DISPOSED
18 USC 371 SEX TRAFFICKING CONSPIRACY
SEX OFFENSE
-1
Status
Stat Code
Description
Start Date
Custody Date
Release Date
Remarks
ARREST
NORMAL INTAKE/ARREST/COURT CASE
7/8/2019
7/8/2019
WT-TRIAL
WAITING FOR TRIAL TO COMPLETE
7/8/2019
WT-CASE-RESOLVE
WAITING FOR CASES TO RESOLVE
7/8/2019
Aliases
First Name
Last Name
Middle Name
Remarks
JEFFREY
E
EPSTEIN
Locales
NONE GIVEN OR AVAILABLE AT DOWNLOAD
Oddities
NONE GIVEN OR AVAILABLE AT DOWNLOAD
Vehicles
NONE GIVEN OR AVAILABLE AT DOWNLOAD
Page: 1 of 2
Date: 7/29/2019
USMS Number:
EFTA00022542

=== Page 2 ===
License
License No
Type
State
VI
Other Numbers
Type
Disp
Number
PASSPORT NUMBER
PASSPORT NUMBER
PASSPORT NUMBER
ORIGINATING POLICE OR IDENTIFICATION NUMBER
SOCIAL SECURITY NUMBER
Employers
Employer Name
Street Address
City
State
Zip Code
Point of Contact
Occupation
Remarks
Start Date
End Date
BANKER
SOUTHERN TRUST COMPANY
SELF EMPLOYED
Kinfolks
Relation
Last Name
First Name
DOB
Age
Street Address
City
State
Zip Code
Phone
Remarks
BROTHER
EPSTEIN
MARK
Financial
NONE GIVEN OR AVAILABLE AT DOWNLOAD
Military
NONE GIVEN OR AVAILABLE AT DOWNLOAD
Remarks
NONE GIVEN OR AVAILABLE AT DOWNLOAD
Page: 2 of 2
Date: 7/29/2019
USMS Number:
EFTA00022543


c1: EFTA00021036
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021036.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
November 23, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today the Government is producing additional materials, including Jencks Act and
Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced
case. Enclosed please find an index detailing the materials included in today's production.
The Government is also producing today certain materials relating to individuals the
Government does not currently intend to call as witnesses at trial in the above-referenced case.
These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the
Government does not expect to call these individuals to testify at trial. Instead, these materials
contain, among other things, certain witness statements. Enclosed please find an index detailing
these materials. This production should not be taken to indicate that the Government believes it
has any obligation to provide all of these materials; rather, we make this production as a courtesy.
Moreover, although the Government presently does not intend to call the individuals listed in the
enclosed index, we reserve the right to do so and will notify you should the Government determine
that it intends to call any of these individuals at trial.
EFTA00021036

=== Page 2 ===
Page 2
Please note that this letter, the enclosed index, and the enclosed materials are governed
by the July 31, 2020 Protective Order in this case. In particular, the materials are designated
as "confidential" under the Protective Order. The index is itself designated as "confidential,"
because it includes information regarding records designated as "confidential" under the
Protective Order. The Department of Justice directed this office to cease the dissemination of
materials marked with the word "confidential" in order to avoid potential confusion with markings
reserved for classified documents. Accordingly, in order to note the appropriate designation of
this production under the operative Protective Order in this case, the materials being produced
today are marked with the following label: "SUBJECT TO PROTECTIVE ORDER
PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs
of the Protective Order that govern today's production.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by: s/
Assistant United States Attorneys
EFTA00021037


c1: EFTA00021791
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021791.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: FW: Interview of Security on Premises
Date: Tue, 07 Jul 2020 18:25:49 +0000
Attachments: U_FOUO_Interview_of
pdf
Will, could you please create a folder for
in the witnesses folder, save the attached with our
naming convention, and update the interview tracker? Thx.
Original Message
From:
Sent: Thursday, July 02, 2020 18:02
To:
Cc:
Subject: Interview of Security on Premises
Hi all,
I wanted to get this out to you so you had it. It's the interview of the individual who provided Maxwell security
on the premises.
Have a good night!
EFTA00021791


c1: EFTA00021321
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021321.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
)"
Subject: Fwd: New York search warrant materials
Date: Wed, 09 Oct 2019 00:15:10 +0000
Have we heard anything from them since this?
Sent from my iPhone
Begin forwarded message:
From:
(NY) (FBI)"
Date: September 30, 2019 at 3:22:53 PM EDT
To:
)"
(NY) (FBI)"
Cc:
)"
)"
Subject: New York search warrant materials
So the short answer is that the load files are not completed yet. One machine alone had over 800,000 emails.
The limitation of the load files is that they can only be generated with 25,000 entries at a time. So I got out as
quickly as I could what fit that bill. Now along has come all the stuff from the Island that had an expiration
date, so that took priority. I can now go back and try to generate the stuff that has yet to be processed into load
files, but the process is slow and painful. Just as an FYI, all the content is available for taint review in FTK
right now.
Senior Forensic Examiner
cell
desk
On Sep 30, 2019 3:13 PM,
(NY) (FBI)"
wrote:
Hey
,
I've copied
here who has handled all of the Epstein evidence that was sent to CART. He should
be able to answer your questions regarding what he's processed.
On Sep 30, 2019 1:57 PM,
)"
wrote:
The taint team here apparently received materials from the search of the New York house but it's way fewer
documents than we would have expected. Can you please let us know exactly how many electronic devices
(phones, computers, hard drives, thumb drives, and/or discs) were sent to CART for processing, and how many
were in fact processed and sent back to us? Or if it's easier to just put us in touch with the CART people directly,
that's fine too. My understanding was that they were processing the materials in the attached, which appears to
EFTA00021321

=== Page 2 ===
list approximately 38 computers and/or electronic storage devices seized along with an additional approximately 55
CDs.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00021322


c1: EFTA00020783
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020783.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To: Alex Conlon
Cc: Alexandra Elenowitz-Hess
Subject: Re: Scheduling a proffer
Date: Wed, 03 Apr 2019 19:07:21 +0000
Importance: Normal
That's great, thanks - and Jenna is fantastic, happy to have her involved. Just to clarify, and to help with our
scheduling, I take it we'll start with an attorney proffer? Or let me know if I misinterpreted and we're talking
about a meeting with the client. Either one totally fine but wanted to confirm- let me know and I'll circle back
in timing, and will also send you a copy of our standard proffer agreement so you have it for your meeting with
her this afternoon.
Two other quick things - first, we know your client as
but I think you mentioned her name has
changed? Could you please let me know her current last name?
And second, one very helpful thing for us would be to have any phone numbers she utilized with Epstein or
anyone associated with him at that time, and/or numbers for him or others she communicated with in connection
with him. Primarily, that could help to corroborate and confirm her recollections, and it's something we don't
need to talk to her directly about to get started working on. If you think it would concern her to provide that at
this stage, no problem at all, we can circle back to it later, but wanted to mention it.
thanks,
On Apr 3, 2019, at 14:30, Alex Conlon
wrote:
Hi there,
Sorry for the delay on our end. Robbie is going to be out of town, but Alex Hess (cc'd here) and I, and our colleague
Jenna Dabbs (former member of your office), would love to do a proffer with you tomorrow or Friday. We can do it by
phone or in person, but would prefer to do it in person.
On Thursday, we are available from 9 to 11AM or after 4PM. On Friday, we are available any time after 11AM.
What works best for you?
Thanks!
Conlon Kaplan Hecker & Fink LLP
This email and its attachments may contain information that is confidential and/or protected from disclosure by the attorney-client, work product or other
applicable legal privilege. If you are not the intended recipient of the email, please be aware that any unauthorized review, use, disclosure,
dissemination, distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in
error, please notify the sender immediately and destroy all copies of the message from your computer system. Thank you.
EFTA00020783


c1: EFTA00021664
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021664.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
(NY) (FBI)"
Subject: RE: Epstein Account Documents
Date: Thu, 07 Oct 2021 21:41:20 +0000
Thanks,
Can you let me know when you have time for a call? I'm having a hard time matching these up to the two
accounts. Thanks!
From:
Sent: Thursday, October 7, 2021 5:27 PM
To:
Cc:
(USANYS)
is
(USANYS) [Contractor]
Subject: RE: Epstein Account Documents
I have uploaded the documents I was able to find in the Epstein Account Document Folder in DOJ USA File Exchange site.
You should already have access to that folder.
I also came across two documents requesting removal for Ghislaine Maxwell from the Hyperion Air, Jeffery Epstein and
JEGE accounts, I have already provided those accounts documents. I also came across a memo requesting removal of
Ghislaine Maxwell from NES LLC Account #
I was unable to come across documents for that account. Those
removal memos have been placed in the Epstein Accounts Document folder as well.
If you have any questions, please call me.
Thanks
From:
Sent: Thursday, October 7, 2021 12:57 PM
To:
(NY) (FBI)
Cc:
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Epstein Account Documents
Thanks! Could you please send me the account opening/signature/KYC documents for the two accounts attached here?
From:
Sent: Thursday, October 7, 2021 7:38 AM
To:
Cc:
(USANYS)
is
(USANYS) [Contractor]
Subject: RE: Epstein Account Documents
I have uploaded the account statement to DOJ USA File Exchange site. I have give you,
and
access rights to the
folder.
If you have any questions, please contact me.
EFTA00021664

=== Page 2 ===
Best
From:
Sent: Wednesday, October 6, 2021 4:12 PM
To:
(NY) (FBI)
Cc:
(USANYS)
Subject: [EXTERNAL EMAIL] - RE: Epstein Account Documents
Hi
Thanks very much. Could you please send us the account statements for a few months after these documents were
executed? It would be helpful to see the balances.
Thanks!
From:
Sent: Monday, October 4, 2021 8:27 AM
To:
Subject: Epstein Account Documents
As a follow up to our conversation regarding Epstein accounts where Ghislaine Maxwell was a signer on the account, I
have compiled the attached documents for your review.
If you have any question, please contact me.
Best
Forensic Accountant
FBI New York Field Office
EFTA00021665


c1: EFTA00020837
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020837.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: Epstein investigation
(
Date: Tue, 25 Feb 2020 16:42:39 +0000
Sigrid,
That works for us, thanks very much - we'll plan for 2:00 on the 4th.
And the street address is 1 St. Andrews Plaza, though for purposes of using Google Maps, it's often easier to get
directions to 5 Centre Street - if you let her know the building is through an archway and just to the left of a
very large outdoor red sculpture. And of course she should feel free to calm us if she needs any assistance with
directions or transportation.
Thanks,
On Feb 25, 2020, at 09:03,
wrote:
Hello
I spoke to
and she and I can meet with you on Wednesday, March 4th at 2:00 p.m. Please confirm that works
for your team. Can you also please send me the street address for your building so I can get that to
Best,
Sigrid
Sigrid McCawley
Partner
BOIES SCHILLER FLEXNER LLP
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
www.bsfllp.com
From:
Sent: Monday, February 24, 2020 4:45 PM
To:
Cc:
Subject: RE: Epstein investigation
(
CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
EFTA00020837

=== Page 2 ===
Sigrid,
Thank you again for speaking with us this afternoon, we appreciate it. As discussed, we wanted to follow up with you
via email about a possible meeting with Ms.
-it sounded like it might be convenient to do a meeting next
week while you're in New York, if that would work for her? If so, if you could give us the dates and time ranges that
might be possible, we can coordinate on scheduling on our end as well. And of course as always we're happy to address
any questions that you or she might have in advance.
thanks very much,
Assistant U.S. Attorney
Southern District of New York
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
EFTA00020838


c1: EFTA00020445
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020445.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
Subject: FW: Epstein Case
Date: Tue, 03 Sep 2019 19:05:05 +0000
Importance: Normal
Attachments: 2019.08.28_Letter_to_OCME.pdf
Hi
As discussed, attached is the letter we submitted asking them to withhold certain documents. They came back today
asking us to tell us what specific documents we want them to withhold, which I can do once I have the file. l'll keep you
posted, thanks.
From:
(OCME)
Sent: Tuesday, September 3, 2019 2:26 PM
To:
Cc:
Subject: RE: Epstein Case
I have now had the opportunity to discuss this request with both
and our Chief Information Officer, and I am
renewing my request that you provide a list of the specific documents and other materials that you are requesting the
OCME not disclose. Additionally, I would appreciate the opportunity to speak with you briefly concerning the document
that you have requested that OCME destroy, and that OCME has deactivated in the manner that I described to you last
week. Please let me know when would be convenient for you; thanks.
Office of Chief Medical Examiner
421 E. 26th Street
New York, NY 10016
Tel:
The information contained in this e-mail communication may be confidential and/or legally privileged and is for the use of the intended
recipient only. If you are not the intended recipient, or an authorized employee or an agent responsible for delivering it to the intended
recipient, the dissemination, distribution or reproduction of this communication or its contents (including any attachments) is prohibited.
If you have received this communication in error, please notify us immediately by telephone or reply e-mail and permanently delete it and
any copies from your system files.
From:
Sent: Wednesday, August 28, 2019 10:28 AM
To:
(OCME)
Cc:
Subject: Epstein Case
Hi Florence,
Per our discussion, please see attached.
We are also requesting that OCME destroy its copy of the draft interview report, dated August 12, 2019, relating to the
FBI's interview of
EFTA00020445

=== Page 2 ===
Please let us know if you have any questions. Thank you.
Assistant United States Attorney
Southern District of New York
EFTA00020446


c1: EFTA00023226
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023226.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
SANYS)"
(USANYS)"
Cc:
)"
Subject: RE: Tartaglione / Epstein
Date: Fri, 06 Dec 2019 17:08:23 +0000
Nick and I need to compile the witness statements anyway in the next week or so, so we will do that and send you all of
the inmate notes, and the relevant MCC employee notes (who talked about the July 23 attempt).
From:
(USANYS)
Sent: Friday, December 6, 2019 10:43 AM
To:
(USANYS)
V.
(USANYS)
Cc:
Subject: RE: Tartaglione / Epstein
No deadline. I'm also happy to make this as easy as possible for you guys, if you want to give me access to the drive and
point me to the interview folder. We obviously won't produce anything without running it by you, but don't want this to
be any extra work for you guys.
Co-Chief, Narcotics Unit
From:
(USANYS)
Sent: Friday, December 6, 2019 10:32 AM
To:
(USANYS)
is
(USANYS)
Cc:
)
Subject: RE: Tartaglione / Epstein
Just a bail application. We interviewed a lot of people so this isn't a particularly quick request. Do you have a deadline?
From:
(USANYS)
Sent: Friday, December 6, 2019 10:30 AM
To:
(USANYS)
(USANYS)
Cc:
)
Subject: RE: Tartaglione / Epstein
Hey guys - just following up, though it sounds like you're busy with defendants fleeing
Co-Chief, Narcotics Unit
From:
(USANYS)
Sent: Tuesday, December 3, 2019 3:25 PM
To:
(USANYS)
is
(USANYS)
Cc:
Subject: Tartaglione / Epstein
EFTA00023226

=== Page 2 ===
Hey Guys - we continue to get requests from the Tartaglione defense team related to the Epstein investigation. In light of
a recent request, can we please review your notes from inmates in the SHU on the date of the attempted suicide to
determine if there are any inmates who gave statements that corroborate Tartaglione's account that he saved Epstein's
life? We think this could arguably be penalty-phase Brady, so we'd like to review this in the first instance, and then discuss
with you any disclosures we think need to be made.
Co-Chief, Narcotics Unit
United States Attorney's Office
Southern District of New York
One Saint Andrew's Plaza
New York, New York 10007
EFTA00023227


c1: EFTA00021573
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021573.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "Hamilton,
) [Contractor]"
To:
"
)"
Cc:
(NY) (FBI)"
)"
,
)"
Subject: Re: financial documents (Epstein)
Date: Thu, 18 Jul 2019 13:16:23 +0000
Will do. I will let you know if it won't be ready in time.
On Jul 17, 2019, at 20:46,
)
wrote:
Tomorrow morning could you please burn the following folders to
disc:
\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY
investigation\Subpoena Returns\American Express
\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY
investigation\,Subpoena Returns\Deutsche_Bank
and put the disc in an envelope addressed to:
Special Agent
Detective
If it's possible to get the disc by 11:30, we'll give the disc to Mandy and Paul at the conference, or if not, if you could put
the envelope with security and reply all that it's ready, they can pick up when convenient.
thanks,
Assistant U.S. Attorney
Southern District of New York
212.637.2415
EFTA00021573


c1: EFTA00021112
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021112.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: "etravelservices@cwtsatotravel.com" <etravelservices@cwtsatotravel.com>
To:
Subject: Travel Authorization 10982122 approved by
, now awaiting further
approval
Date: Thu, 06 Feb 2020 20:27:11 +0000
Importance: Normal
Dear
Travel authorization 10982122 has been approved by
, now awaiting further
approval.
Trip ID: 10982122
Traveler name:
Purpose: R20NYS13340 - Epstein investigation (2018R01618) - Witness Interviews
Destination: Stockholm, Sweden
Dates: 2020-02-03 - 2020-02-06
Current status: Pending Authorization Approval
E2 Single Sign On Login (within DOJ Network Only):
https://dojnet.doj.gov/jmd/fs/e2-redirect.html
E2 Manual Login (User ID and Password):
https://e2.gov.cwtsatotravel.com
Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
Please note: Replies to this mailbox are not monitored.
Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your
email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the
emails that you receive from us.
Reference ID# T0007
This e-mail and any attachments may contain confidential and/or proprietary information. If you received this e-
mail in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments;
any further use of such e-mail or attachments is strictly prohibited.
EFTA00021112


c1: EFTA00022629
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022629.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USMS)"
To:
(USANYS)"
Subject: FW: Jeffrey Epstein 19 cr 490
Date: Mon, 12 Aug 2019 16:53:13 +0000
Importance: High
Attachments: Aug_12_letter.pdf
FYI
United States Marshal
Southern District of New York
New York, NY 10007
Original Message
From:
mailto:
On Behalf Of
Sent: Monday. August 12, 2019 12:47 PM
To
Cc:
;
Subject: Jeffrey Epstein 19 cr 490
Importance: High
Please see attached letter from Judge Richard M. Berman.
(See attached file: Aug 12 letter.pdf)
EFTA00022629


c1: EFTA00023408
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023408.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Epstein-Related FOIA Requests
Start Date: 2020-02-25 16:30:00 +0000
End Date: 2020-02-25 17:00:00 +0000
Location:
Office
Class: X-PERSONAL
Comment:
Date Created: 2020-02-25 08:17:28 +0000
Date Modified: 2020-02-25 08:17:28 +0000
Priority: 5
DTSTAMP: 2020-02-21 16:42:27 +0000
Attendee:
EFTA00023408


c1: EFTA00021277
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021277.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: Re: Daily Beast has it
Date: Sun, 07 Jul 2019 01:17:35 +0000
Importance: Normal
NY Times has it: https://www.google.com/amp/s/www.nytimes.com/2019/07/06/nyregion/jeffrey-epstein-
arrested-sex-trafficking.amp.html
On Jul 6, 2019, at 9:13 PM,
wrote:
Miami Herald has it now too
https://www.google.com/amp/s/amp.miamiherald.com/news/state/florida/article232374872.html
Sent from my iPhone
On Jul 6, 2019, at 9:10 PM,
wrote:
Yeah they're literally just leaking the press release -
The case is being handled by the Public Corruption Unit of the Southern District of
New York, with assistance from the district's human-trafficking officials and the
FBI.
and the sealed indictment -
according to details of the arrest and indictment shared by two officials.
From:
Sent: Saturday, July 06, 2019 21:08
To:
Cc:
Subject: Re: Daily Beast has it
And now is reporting that it's our unit
Sent from my iPhone
On Jul 6, 2019, at 8:06 PM,
wrote:
https://www.thedailybeast.com/jeffrey-epstein-arrested-for-sex-trafficking-of-minors-source
FBI is leaking the content of the indictment.
EFTA00021277

=== Page 2 ===
Assistant U.S. Attorney
Southern District of New York
EFTA00021278


c1: EFTA00023254
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023254.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Tentative: Maxwell - Discuss Images from Epstein Devices
Start Date: 2020-10-16 14:00:00 +0000
End Date: 2020-10-16 14:30:00 +0000
Location: Dial-in:
Code:
Class: X-PERSONAL
Comment:
Date Created: 2020-10-16 13:15:54 +0000
Date Modified: 2020-10-16 13:15:54 +0000
Priority: 5
DTSTAMP: 2020-10-16 13:05:09 +0000
Attendee:
EFTA00023254


c1: EFTA00020894
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020894.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: FW: EMail 1 of 2: EPSTEIN
signed application/affidavit
Date: Thu, 29 Oct 2020 15:50:43 +0000
Attachments: 20_MAG_11668
.pdf; 20_MAG_11668.1
pdf
Inline-Images: image001.jpg
Good Morning
Your signed Warrants are attached.
UNTED STATES DISTRICT COURT
Arraignment Unit Clerk
United States District Court
Southern District of New York
DEPARTMENT
New York, NY 10007
OF
From
Sent: Wednesday, October 28, 2020 7:18 PM
To:
Cc:
Subject: FW: EMail 1 of 2: EPSTEIN
signed application/affidavit
From
Sent: Tuesday, October 27. 2020 7:18 PM
To:
Subject: EMail 1 of 2: EPSTEIN
signed application/affidavit
USDC-SDNY
Sent from my mobile device
EFTA00020894


c1: EFTA00021038
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021038.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
United States v. Ghislaine Maxwell
20 Cr. 330 (AJN)
Government Exhibit Index
11/23/2021
0 Series
Message Pads
GX
Description
Bates Range/Identifier
Produced to Defense
GX-1
Physical Message Pad#
2021.10.11
GX-1-A
Message Pad Cover#
SDNY_GM_00165559
2021.10.11
GX-1-B
Message Pad Excerpt#
SDNY GM 00165560
2021.10.11
GX-1-C
Message Pad Excerpt#
SDNY GM 00165562
2021.10.11
GX-1-J
Message Pad Excerpt#
SDNY GM 00165584
2021.10.11
GX-1-K
Message Pad Excerpt#
SDNY GM 00165587
2021.10.11
GX-1-M
Message Pad Excerpt#
SDNY GM 00165610
2021.10.11
GX-1-0
Message Pad Excerpt#
SDNY GM 00165622
2021.10.11
GX-1-P
Message Pad Excerpt#
SDNY GM 00165625
2021.10.11
GX-2
Physical Message Pad#
2021.10.11
GX-2-A
Message Pad Cover#
SDNY GM 00165629
2021.10.11
GX-2-C
Message Pad Excerpt#
SDNY GM 00165643
2021.10.11
GX-2-D
Message Pad Excerpt#
SDNY GM 00165644
2021.10.11
GX-2-E
Message Pad Excerpt#
SDNY GM 00165646
2021.10.11
GX-2-F
Message Pad Excerpt#
SDNY GM 00165647
2021.10.11
GX-2-G
Message Pad Excerpt#
SDNY GM 00165648
2021.10.11
GX-2-H
Message Pad Excerpt#
SDNY GM 00165649
2021.10.11
GX-2-I
Message Pad Excerpt#
SDNY GM 00165650
2021.10.11
GX-2-J
Message Pad Excerpt#
SDNY GM 00165651
2021.10.11
GX-2-K
Message Pad Excerpt#
SDNY GM 00165652
2021.10.11
GX-2-L
Message Pad Excerpt#
SDNY GM 00165653
2021.10.11
GX-2-M
Message Pad Excerpt#
SDNY GM 00165654
2021.10.11
GX-2-N
Message Pad Excerpt#
SDNY GM 00165655
2021.10.11
GX-2-0
Message Pad Excerpt#
SDNY GM 00165658
2021.10.11
GX-2-P
Message Pad Excerpt#
SDNY GM 00165659
2021.10.11
GX-2-Q
Message Pad Excerpt#
SDNY GM 00165660
2021.10.11
GX-2-R
Message Pad Excerpt#
SDNY GM 00165663
2021.10.11
GX-2-S
Message Pad Excerpt#
SDNY GM 00165669
2021.10.11
GX-2-T
Message Pad Excerpt#
SDNY GM 00165670
2021.10.11
GX-2-U
Message Pad Excerpt#
SDNY GM 00165674
2021.10.11
GX-2-V
Message Pad Excerpt#
SDNY GM 00165677
2021.10.11
GX-2-W
Message Pad Excerpt#
SDNY GM 00165682
2021.10.11
GX-3
Physical Message Pad#
2021.10.11
1
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA00021038

=== Page 2 ===
GX-3-A
Message Pad Cover#
SDNY GM 00165684
2021.10.11
GX-3-B
Message Pad Excerpt#
SDNY GM 00165688
2021.10.11
GX-3-C
Message Pad Excerpt#
SDNY GM 00165689
2021.10.11
GX-3-D
Message Pad Excerpt#
SDNY GM 00165690
2021.10.11
GX-3-E
Message Pad Excerpt#
SDNY GM 00165692
2021.10.11
GX-3-F
Message Pad Excerpt#
SDNY GM 00165694
2021.10.11
GX-3-G
Message Pad Excerpt#
SDNY GM 00165699
2021.10.11
GX-3-H
Message Pad Excerpt#
SDNY GM 00165700
2021.10.11
GX-3-I
Message Pad Excerpt#
SDNY GM 00165701
2021.10.11
GX-3-J
Message Pad Excerpt#
SDNY GM 00165703
2021.10.11
GX-3-K
Message Pad Excerpt#
SDNY GM 00165704
2021.10.11
GX-3-L
Message Pad Excerpt#
SDNY GM 00165706
2021.10.11
GX-3-M
Message Pad Excerpt#
SDNY GM 00165709
2021.10.11
GX-3-N
Message Pad Excerpt#
SDNY GM 00165710
2021.10.11
GX-3-0
Message Pad Excerpt#
SDNY GM 00165711
2021.10.11
GX-3-P
Message Pad Excerpt#
SDNY GM 00165714
2021.10.11
GX-3-Q
Message Pad Excerpt#
SDNY GM 00165719
2021.10.11
GX-3-R
Message Pad Excerpt#
SDNY GM 00165729
2021.10.11
GX-3-S
Message Pad Excerpt#
SDNY GM 00165742
2021.10.11
GX-3-T
Message Pad Excerpt#
SDNY GM 00165743
2021.10.11
GX-3-U
Message Pad Excerpt#
SDNY GM 00165744
2021.10.11
GX-3-V
Message Pad Excerpt#
SDNY GM 00165745
2021.10.11
GX-3-W
Message Pad Excerpt#
SDNY GM 00165747
2021.10.11
GX-3-X
Message Pad Excerpt#
SDNY GM 00165731
2021.10.11
GX-3-Y
Message Pad Excerpt#
SDNY GM 00165736
2021.10.11
GX-3-Z
Message Pad Excerpt#
SDNY GM 00165737
2021.10.11
GX-3-AA
Message Pad Excerpt#
SDNY GM 00165738
2021.10.11
GX-3-BB
Message Pad Excerpt#
SDNY GM 00165739
2021.10.11
GX-3-CC
Message Pad Excerpt#
SDNY GM 00165740
2021.10.11
GX-3-DD
Message Pad Excerpt#
SDNY GM 00165741
2021.10.11
GX-3-EE
Message Pad Excerpt#
SDNY GM 00165742
2021.10.11
GX-3-FF
Message Pad Excerpt#
SDNY GM 00165743
2021.10.11
GX-3-GG
Message Pad Excerpt#
SDNY GM 00165744
2021.10.11
GX-3-HH
Message Pad Excerpt#
SDNY GM 00165745
2021.10.11
GX-3-II
Message Pad Excerpt#
SDNY GM 00165747
2021.10.11
GX-3-JJ
Message Pad Excerpt#
SDNY GM 00165749
2021.10.11
GX-3-KK
Message Pad Excerpt#
SDNY GM 00165750
2021.10.11
GX-4
Physical Message Pad#
2021.10.11
GX-4-A
Message Pad Cover#
SDNY GM 00165751
2021.10.11
GX-4-B
Message Pad Excerpt#
SDNY GM 00165752
2021.10.11
GX-4-C
Message Pad Excerpt#
SDNY GM 00165754
2021.10.11
GX-4-D
Message Pad Excerpt#
SDNY GM 00165759
2021.10.11
GX-4-E
Message Pad Excerpt#
SDNY GM 00165761
2021.10.11
GX-4-F
Message Pad Excerpt#
SDNY GM 00165776
2021.10.11
2
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA00021039

=== Page 3 ===
GX-4-G
Message Pad Excerpt#
SDNY GM 00165790
2021.10.11
GX-4-H
Message Pad Excerpt#
SDNY GM 00165798
2021.10.11
GX-4-I
Message Pad Excerpt#
SDNY GM 00165811
2021.10.11
GX-4-J
Message Pad Excerpt#
SDNY GM 00165815
2021.10.11
GX-4-K
Message Pad Excerpt#
SDNY GM 00165817
2021.10.11
10 Series
Birth Certificates
GX
Description
Bates Number/Identifier
Produced to Defense
GX-11
Certified Birth Certificate of Minor Victim-4#
SDNY GM 02765030
2021.10.11
GX-12
Certified Birth Certificate of Minor Victim-1#
SDNY GM 02760681
2021.10.11
GX-13
Certified Birth Certificate of Minor Victim-2#
SDNY GM 02753693
2021.10.11
GX-14
Certified Birth Certificate of Minor Victim-5#
SDNY GM 02765767
2021.10.28
GX-15
Certified Birth Certificate of Minor Victim-6#
SDNY 02760679-SDNY GM 02760680
2021.10.11
GX-16
Certified Birth Certificate of Minor Victim-3#
SDNY GM 02766968
2021.10.28
50 Series
Other Physical Exhibits
GX
Description
Bates Number/Identifier
Produced to Defense
GX-51
Florida Massage Table
2021.10.11
GX-51-A
Photograph of Underside of Florida Massage Table
SDNY_GM_02763005
2021.10.11
GX-51-B
Photograph of Sticker on Florida Massage Table
SDNY_GM_02763006
2021.10.11
GX-51-C
Photograph of Sticker on Florida Massage Table
SDNY_GM_02763007
2021.10.11
GX-52
Black Contact Book
2021.10.11
GX-52-A
Scanned Page from Black Contact Book#
SDNY_GM_02763008-SDNY_GM_02763008
2021.10.11
GX-52-B
Scanned Page from Black Contact Book
SDNY_GM_02763009-SDNY_GM_02763009
2021.10.11
GX-52-C
Scanned Page from Black Contact Book
SDNY_GM_02763010-SDNY_GM_02763010
2021.10.11
GX-52-D
Scanned Page from Black Contact Book
SDNY_GM_02763011-SDNY_GM_02763011
2021.10.11
GX-52-E
Scanned Page from Black Contact Book
SDNY_GM_02763013-SDNY_GM_02763014
2021.10.11
GX-52-F
Scanned Page from Black Contact Book#
SDNY_GM_02763015-SDNY_GM_02763015
2021.10.11
GX-52-G
Scanned Page from Black Contact Book#
SDNY_GM_02763016-SDNY_GM_02763016
2021.10.11
GX-52-H
Scanned Page from Black Contact Book
SDNY_GM_02765768
2021.10.11
GX-53
Box of five costumes
2021.10.11
GX-54
Hard Drive NYC024350
2021.10.11
GX-54-A
Photograph of GX-54
SDNY_GM_02772261
2021.11.16
GX-55
Hard Drive NYC024349
2021.10.11
GX-55-A
Photograph of GX-55
SDNY_GM_02772260
2021.11.16
GX-55-B
Photograph of bag contained within GX-55
SDNY_GM_02772258
2021.11.16
GX-55-C
Photograph of bag contained within GX-55
SDNY_GM_02772259
2021.11.16
GX-56
Hard Drive NYC024383
2021.10.11
GX-57
New York Massage Table
2021.10.11
GX-57-A
Photograph of Underside of New York Massage Table
SDNY_GM_02763019-SDNY_GM_02763019
2021.10.11
GX-57-B
Photograph of Sticker on New York Massage Table
SDNY_GM_02763018-SDNY_GM_02763018
2021.10.11
3
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA00021040

=== Page 4 ===
GX-58
Pair of Boots
2021.10.11
100 Series
Photographs of People
GX
Description
Bates Number/Identifier
Produced to Defense
GX-101
Photograph of Minor Victim-2#
SDNY GM 00166005
2021.10.11
GX-102
Photograph of Minor Victim-2#
SDNY GM 02750527
2021.10.11
GX-103
Photograph of Minor Victim-2#
SDNY GM 02760624
2021.10.11
GX-104
Photograph of Minor Victim-4#
SDNY GM 02753398
2021.10.11
GX-105
Photograph of Females, Including Minor Victim-4#
SDNY GM 02753398
2021.10.11
GX-106
Photograph of Minor Victim-1#
SDNY GM 00165992
2021.10.11
GX-107
Photograph of Minor Victim-1#
SDNY GM 00165995
2021.10.11
GX-108
Photograph of Minor Victim-1#
SDNY GM 00165999
2021.11.11
GX-109
Photograph of Minor Victim-3#
SDNY GM 00166002
2021.10.11
GX-110
Photograph of
SDNY GM 02753621
2021.10.11
GX-111
Photograph of Ghislaine Maxwell
SDNY GM 02753632
2021.10.11
GX-112
Photograph of Jeffery Epstein
SDNY GM 02753623
2021.10.11
GX-113
Photograph of Minor Victim-5#
Made Available for Review
2021.10.11
GX-114
Photograph of Minor Victim-5#
SDNY GM 02753629
2021.10.11
GX-115
Photograph of Ghislaine Maxwell
SDNY GM 02753644-2753692
2021.11.11
200 Series
Photographs and Videos from PBPD Search
GX
Description
Bates Number/Identifier
Produced to Defense
GX-201
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174459
2021.10.11
GX-202
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174460
2021.10.11
GX-203
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174461
2021.10.11
GX-204
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174470
2021.10.11
GX-205
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174471
2021.10.11
GX-206
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174472
2021.10.11
GX-207
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174473
2021.10.11
GX-208
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174381
2021.10.11
GX-209
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174474
2021.10.11
GX-210
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174476
2021.10.11
GX-211
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174477
2021.10.11
GX-212
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174478
2021.10.11
GX-213
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174479
2021.10.11
GX-214
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174480
2021.10.11
GX-215
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174481
2021.10.11
GX-216
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174482
2021.10.11
GX-217
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174483
2021.10.11
GX-218
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174484
2021.10.11
GX-219
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174490
2021.10.11
4
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA00021041

=== Page 5 ===
GX-220
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174491
2021.10.11
GX-221
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174492
2021.10.11
GX-222
Photograph of Exterior at 358 El Brillo Way
SDNY GM 00174493
2021.10.11
GX-223
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174366
2021.10.11
GX-224
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174367
2021.10.11
GX-225
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174368
2021.10.11
GX-226
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174518
2021.10.11
GX-227
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174521
2021.10.11
GX-228
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174524
2021.10.11
GX-229
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174525
2021.10.11
GX-230
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174526
2021.10.11
GX-231
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174527
2021.10.11
GX-232
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174528
2021.10.11
GX-233
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174530
2021.10.11
GX-234
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174532
2021.10.11
GX-235
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174533
2021.10.11
GX-236
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174535
2021.10.11
GX-237
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174536
2021.10.11
GX-238
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174545
2021.10.11
GX-239
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174687
2021.10.11
GX-240
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174688
2021.10.11
GX-241
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174698
2021.10.11
GX-242
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174442
2021.10.11
GX-243
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174444
2021.10.11
GX-244
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174445
2021.10.11
GX-245
Photograph of First Floor Office & Living Room at 358 El Brillo Way#
SDNY GM 00174699
2021.10.11
GX-246
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174446
2021.10.11
GX-247
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174447
2021.10.11
GX-248
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174700
2021.10.11
GX-249
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174704
2021.10.11
GX-250
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174448
2021.10.11
GX-252
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174450
2021.10.11
GX-253
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174451
2021.10.11
GX-254
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174452
2021.10.11
GX-255
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174707
2021.10.11
GX-256
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174726
2021.10.11
GX-257
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174727
2021.10.11
GX-258
Photograph of First Floor Office & Living Room at 358 El Brillo Way*
SDNY GM 00174369
2021.10.11
GX-260
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174425
2021.10.11
GX-261
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174426
2021.10.11
GX-262
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174427
2021.10.11
GX-263
Photograph of First Floor Office & Living Room at 358 El Brillo Way
SDNY GM 00174428
2021.10.11
GX-264
Photograph of Kitchen at 358 El Brillo Way
SDNY GM 00174504
2021.10.11
GX-265
Photograph of Kitchen at 358 El Brillo Way
SDNY GM 00174505
2021.10.11
5
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA00021042

=== Page 6 ===
GX-266
Photograph of Kitchen at 358 El Brillo Way
SDNY GM 00174506
2021.10.11
GX-267
Photograph of Kitchen at 358 El Brillo Way
SDNY GM 00174685
2021.10.11
GX-268
Photograph of Kitchen at 358 El Brillo Way
SDNY GM 00174686
2021.10.11
GX-269
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174594
2021.10.11
GX-270
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174432
2021.10.11
GX-271
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174596
2021.10.11
GX-272
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174599
2021.10.11
GX-273
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174600
2021.10.11
GX-276
Photograph of Master Bedroom at 358 El Brillo Way*
SDNY GM 00174601
2021.10.11
GX-277
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174602
2021.10.11
GX-278
Photograph of Master Bedroom at 358 El Brillo Way*
SDNY GM 00174603
2021.10.11
GX-279
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174604
2021.10.11
GX-280
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174605
2021.10.11
GX-281
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174433
2021.10.11
GX-282
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174434
2021.10.11
GX-283
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174435
2021.10.11
GX-284
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174436
2021.10.11
GX-285
Photograph of Master Bedroom at 358 El Brillo Way*
SDNY GM 00174440
2021.10.11
GX-286
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174453
2021.10.11
GX-287
Photograph of Master Bedroom at 358 El Brillo Way
SDNY GM 00174454
2021.10.11
GX-289
Photograph of Second Floor at 358 El Brillo Way
SDNY GM 00174557
2021.10.11
GX-290
Photograph of Second Floor at 358 El Brillo Way
SDNY GM 00174558
2021.10.11
GX-291
Photograph of Second Floor at 358 El Brillo Way
SDNY GM 00174559
2021.10.11
GX-292
Photograph of Second Floor at 358 El Brillo Way
SDNY GM 00174560
2021.10.11
GX-293
Photograph of Second Floor at 358 El Brillo Way
SDNY GM 00174563
2021.10.11
GX-294
Photograph of Second Floor at 358 El Brillo Way
SDNY GM 00174419
2021.10.11
GX-295
Property Receipts
SDNY GM 02753638-02753643
2021.10.11
GX-296
Video of Walkthrough at 358 El Brillo Way*
SDNY GM 00332873
2021.10.11
GX-297
358 El Brillo Way floorplan
SDNY GM 00328519
2021.11.16
GX-298
358 El Brillo Way floorplan
SDNY GM 00328520
2021.11.16
GX-299
358 El Brillo Way floorplan
SDNY GM 00328521
2021.11.16
300 Series
ESI Photographs
GX
Description
Bates Number/Identifier
Produced to Defense
GX-301
Photograph of Jet
SDNY GM 02753644-2753692
2021.10.11
GX-302
Photograph of Jet
SDNY GM 02753644-2753692
2021.10.11
GX-303
Photograph of Jet Interior
SDNY GM 02753644-2753692
2021.10.11
GX-304
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-305
Photograph of Ghislaine Maxwell
SDNY GM 02753644-2753692
2021.10.11
GX-306
Photograph of Ghislaine Maxwell
SDNY GM 02753644-2753692
2021.10.11
GX-307
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-308
Photograph of Island
SDNY GM 02753644-2753692
2021.10.11
GX-309
Photograph of Minor Victim-3*#
Made Available for Review
2021.10.11
6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA00021043

=== Page 7 ===
GX-310
Photograph of Jeffrey Epstein and
SDNY GM 02753644-2753692
2021.11.11
GX-311
Photograph of Plane (N404CE)
SDNY GM 02753644-2753692
2021.10.11
GX-312
Photograph of Plane (N908JE)
SDNY GM 02753644-2753692
2021.10.11
GX-313
Photograph of Ghislaine Maxwell and Jeffrey Epstein*
Made Available for Review
2021.10.11
GX-314
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-315
Photograph of Jeffrey Epstein and Plane
SDNY GM 02753644-2753692
2021.10.11
GX-316
Photograph of Ghislaine Maxwell,
and
SDNY GM 02753644-2753692
2021.10.11
GX-317
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-318
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-319
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-320
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-321
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-322
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-323
Photograph of Ranch
SDNY GM 02753644-2753692
2021.10.11
GX-324
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-325
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-326
Photograph of Island
SDNY GM 02753644-2753692
2021.10.11
GX-327
Photograph of
SDNY GM 02753644-2753692
2021.10.11
GX-328
Photograph of Zorro Ranch Entryway
SDNY GM 02753644-2753692
2021.10.11
GX-329
Photograph of Jeffrey Epstein and
SDNY GM 02753644-2753692
2021.10.11
GX-330
Photograph of
SDNY GM 02753644-2753692
2021.10.11
GX-331
Photograph of Ghislaine Maxwell,
and
SDNY GM 02753644-2753692
2021.10.11
GX-332
Photograph of Minor Victim-5*#
Made Available for Review
2021.10.11
GX-333
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-334
Photograph of Ghislaine Maxwell and
SDNY GM 02753644-2753692
2021.10.11
GX-335
Photograph of Ghislaine Maxwell and
SDNY GM 02753644-2753692
2021.10.11
GX-336
Photograph of Planes
SDNY GM 02753644-2753692
2021.10.11
GX-337
Photograph of Ghislaine Maxwell on Plane
SDNY GM 02753644-2753692
2021.10.11
GX-338
Photograph of Ghislaine Maxwell
SDNY GM 02753644-2753692
2021.10.11
GX-339
Photograph of Ghislaine Maxwell
SDNY GM 02753644-2753692
2021.10.11
GX-340
Photograph of Ghislaine Maxwell
SDNY GM 02753644-2753692
2021.10.11
GX-341
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-342
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-343
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-344
Photograph of Helicopter
SDNY GM 02753644-2753692
2021.10.11
GX-345
Photograph of Helicopter
SDNY GM 02753644-2753692
2021.10.11
GX-346
Photograph of Island
SDNY GM 02753644-2753692
2021.10.11
GX-347
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
GX-348
Photograph of Ghislaine Maxwell and Jeffrey Epstein
SDNY GM 02753644-2753692
2021.10.11
400 Series
ESI Documents and Metadata
GX
Description
Bates Number/Identifier
Produced to Defense
GX-405
NYC024349 System Information
SDNY GM 02762473
2021.11.16
7
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA00021044

=== Page 8 ===
GX-406
Email Chain between Jeffrey Epstein and Minor Victim-3#
SDNY GM 00631742-SDNY GM 00631742
2021.10.11
GX-407
Email Chain between Jeffrey Epstein and Ghislaine Maxwell
SDNY GM 00623470-SDNY GM 00623470
2021.10.11
GX-408
Email from Ghislaine Maxwell to Jeffrey Epstein
SDNY 00579091-SDNY GM 00579091
2021.10.11
GX-412
Email Chain
SDNY GM 02741883-SDNY GM 02741884
2021.10.11
GX-415
Email Chain
SDNY GM 02741441-SDNY GM 02741442
2021.10.11
GX-417
List and Contact Info of Masseuses#
SDNY GM 02735985-SDNY GM 02735991
2021.10.11
GX-417-B
List and Contact Info of Masseuses - Metadata
2021.10.11
GX-418
List and Contact Info of Palm Beach House Workers & Maintenance
SDNY GM 02736160-SDNY GM 02736166
2021.10.11
GX-418-B
List and Contact Info of Palm Beach House Workers & Maintenance - Metadata
2021.10.11
GX-419
NYC024350 System Information
SDNY GM 02762473
2021.11.16
GX-420
List of PB New Shampoo and Massage Products
SDNY_GM_02736212-SDNY_GM_02736212
2021.10.11
GX-420-B
List of PB New Shampoo and Massage Products - Metadata
2021.10.11
GX-421
Massage Therapist Help Wanted Ad
SDNY_GM_02736260-SDNY_GM_02736260
2021.10.11
GX-421-B
Massage Therapist Help Wanted Ad- Metadata
2021.10.11
GX-422
Ghislaine Maxwell and Jeffrey Epstein Relationship Essay
SDNY_GM_02736272-SDNY_GM_02736272
2021.10.11
GX-422-B
Ghislaine Maxwell and Jeffrey Epstein Relationship Essay - Metadata
2021.10.11
GX-423
Jeffrey Epstein Amazon Order Confirmation
SDNY GM 00567862
2021.10.11
GX-424
Email Chain
SDNY GM 02741334-SDNY GM 02741336
2021.11.16
500 Series
Financial Exhibits
GX
Description
Bates Number/Identifier
Produced to Defense
GX-501
June 2007 JPMC Statement for Air Ghislaine
SDNY GM 00277986-SDNY GM 00277989
2021.10.11
GX-502
June 2007 JPMC Statement for Ghislaine Maxwell
SDNY GM 00321356-SDNY GM 00321363
2021.10.11
GX-503
J.P. Morgan Entity Account Application
SDNY GM 00271135-SDNY GM 00271137
2021.10.11
GX-504
September 2002 JPMC Account Activity
SDNY GM 00274703-SDNY GM 00274711
2021.10.11
GX-505
JPMC October 1999 Asset Account Portfolio Records
SDNY GM 00306061-SDNY GM 00306067
2021.10.11
GX-506
Air Ghislaine Account Documents
SDNY GM 00271608-SDNY GM 00271610
2021.11.23
GX-507
Ghislaine Maxwell J.P. Morgan Account and Signature
SDNY GM 00068254
2021.10.11
SDNY_GM_00271037-SDNY_GM_00271041,
GX-508
SDNY_GM_00271546-SDNY_GM_00271550,
2021.10.11
J.P. Morgan Records
SDNY_GM_00271584-SDNY_GM_00271593
550 Series
Phone Records
GX
Description
Bates Number/Identifier
Produced to Defense
GX-551
May 2004 AT&T Wireless Monthly Statement for Jeffrey Epstein
SDNY GM 00365036-SDNY GM 00365049
2021.10.11
600 Series
Miscellaneous Documents
GX
Description
Bates Number/Identifier
Produced to Defense
GX-601
Journal Front Cover
SDNY GM 00165987
2021.10.11
GX-602
Journal Entry
SDNY GM 00165986
2021.10.11
8
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA00021045

=== Page 9 ===
GX-603
January 7, 1996 Journal Entry
SDNY GM 00165984
2021.10.11
GX-604
January 25, 1996 Journal Entry
SDNY GM 00165982
2021.10.11
GX-605
Journal Back Cover
SDNY GM 00165988
2021.10.11
GX-606
Household Manual
SDNY GM 00516864-SDNY GM 00516922
2021.10.11
GX-607
Work Hours Document
SDNY_GM_00515785-SDNY_GM_00515787
2021.10.11
660 Series
Flight Records
GX
Description
Bates Number/Identifier
Produced to Defense
GX-661
Logbook from January 23, 2006 to September 19, 2013#
SDNY GM 00005650-SDNY GM 00005676
2021.10.11
GX-662
Flight Logbook from April 25 1991 to January 19, 2006#
SDNY_GM_00005532-SDNY_GM_00005649
2021.10.11
700 Series
Photographs of Places
GX
Description
Bates Number/Identifier
Produced to Defense
GX-701
Ghislaine Maxwell New York Townhouse
SDNY GM 02760645
2021.10.11
GX-702
Ghislaine Maxwell London Townhouse
SDNY GM 02762477
2021.10.11
GX-703
Little Saint James
SDNY GM 02760646
2021.10.11
GX-704
Jeffrey Epstein New York Townhouse
SDNY GM 02760647
2021.10.11
GX-705
Paris Apartment Building
SDNY GM 02760648
2021.10.11
GX-706
New Mexico Ranch
SDNY_GM_02760649
2021.10.11
720 Series
Maps
GX
Description
Bates Number/Identifier
Produced to Defense
GX-721
Map of Palm Beach
SDNY GM 02762484
2021.10.11
GX-722
Map of Palm Beach
SDNY GM 02762485
2021.10.11
740 Series
Interlochen Records
GX
Description
Bates Number/Identifier
Produced to Defense
GX-741
SDNY_GM_00005055,SDNY_GM_00004999-
2021.10.11
Donor Records
SDNY GM 00005018
GX-742
Interlochen Application#
SDNY GM 02753443-SDNY GM 02753444
2021.10.11
SDNY_GM_02753433-SDNY_GM_02753435,
GX-743
SDNY_GM_02753523-SDNY_GM_02753524,
2021.10.11
Minor Victim-1 Application#
SDNY GM 02753480-SDNY GM 02753481
GX-744
Student Roster#
SDNY_GM_00005077-SDNY_GM_00005103
2021.10.11
GX-745
Photograph of Cabin
SDNY GM 02775027
2021.11.20
GX-746
Photograph of Minor Victim-1 and Family#
SDNY_GM_02775028
2021.11.20
760 Series
9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA00021046

=== Page 10 ===
Professional Children's School Records
GX
Description
Bates Number/Identifier
Produced to Defense
GX-761
Professional Children's School Records for Minor Victim-1#
SDNY 00005511-SDNY GM 00005514
2021.10.11
780 Series
Palm Beach County School District Records
GX
Description
Bates Number/Identifier
Produced to Defense
GX-781
Minor Victim-5 Enrollment Records for 1989-2002
SDNY GM 02753596
2021.10.11
GX-782
Minor Victim-5 Enrollment Records for 2001-2002
SDNY_GM_02753597-SDNY_GM_02753598
2021.10.11
GX-783
Minor Victim-5 Registration Records
SDNY_GM_02753608-SDNY_GM_02753610
2021.10.11
800 Series
FedEx Records
GX
Description
Bates Number/Identifier
Produced to Defense
GX-801
December 16, 2002 Invoice#
SDNY GM 00525676-SDNY GM 00525690
2021.10.11
GX-802
December 23, 2002 Invoice#
SDNY GM 00525700-SDNY GM 00525720
2021.10.11
GX-803
October 14, 2002 Invoice#
SDNY GM 00431553-SDNY GM 00431561
2021.10.11
820 Series
Mar-A-Lago Records
GX
Description
Bates Number/Identifier
Produced to Defense
GX-821
Human Resources Correspondence Regarding Minor Victim-5' Records
SDNY GM 00120681
2021.10.11
GX-822
Mar-A-Lago Termination List
SDNY 00120686-SDNY 00120702
2021.10.11
900 Series
New York Search Photos
GX
Description
Bates Number/Identifier
Produced to Defense
GX-901
Photograph of Stairwell and Nude Portrait*
SDNY GM 00166249
2021.10.11
GX-902
Photograph of Hallway and Nude Portrait*
SDNY_GM 00166251
2021.10.11
GX-903
Photograph of Massage Room*
SDNY GM 00166252
2021.10.11
GX-904
Photograph of Massage Room*
SDNY_GM_00166253
2021.10.11
GX-905
Photograph of Bathroom*
SDNY GM 00166258
2021.10.11
GX-906
Photograph of Massage Table*
SDNY_GM_00166260
2021.10.11
GX-907
Photograph of Nude Portrait*
SDNY_GM_00166265
2021.10.11
GX-908
Photograph of Stairwell and Nude Portrait
SDNY GM 00166273
2021.10.11
GX-909
Photograph of Townhouse Exterior
SDNY_GM_00166275
2021.10.11
GX-910
Photograph of Interior and Stairwell
SDNY_GM_00166327
2021.10.11
GX-911
Photograph of Interior
SDNY GM 00166328
2021.10.11
GX-912
Photograph of Interior
SDNY GM 00166386
2021.10.11
GX-913
Photograph of Interior
SDNY GM 00166417
2021.10.11
GX-914
Photograph of Black Binders in Closet
SDNY GM 00166594
2021.10.11
GX-915
Photograph of Stairwell
SDNY_GM_00166719
2021.10.11
10
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA00021047

=== Page 11 ===
GX-916
Photograph of Desk
SDNY GM 00166731
2021.10.11
GX-917
Photograph of Massage Table
SDNY GM 00166746
2021.10.11
GX-918
Photograph of Vanity Drawers
SDNY GM 00166761
2021.10.11
GX-919
Photograph of Costumes
SDNY GM 00166767
2021.10.11
GX-920
Photograph of Costumes
SDNY GM 00166768
2021.10.11
GX-921
Photograph of Desk
SDNY GM 00166771
2021.10.11
GX-922
Photograph of Interior
SDNY GM 00167663
2021.10.11
GX-923
Photograph of Female Portrait
SDNY GM 00166776
2021.10.11
GX-924
Photograph of Nude Sculpture
SDNY GM 00166778
2021.10.11
GX-925
Photograph of Black Binders in Closet
SDNY GM 00166779
2021.10.11
GX-926
Photograph of Drawer Contents
SDNY GM 00166782
2021.10.11
GX-927
Photograph of Nude Sculpture
SDNY GM 00166784
2021.10.11
GX-928
Photograph of Interior
SDNY GM 00166907
2021.10.11
GX-929
Photograph of Interior
SDNY GM 00167081
2021.10.11
GX-930
Photograph of Nude Portrait in Bathroom*
SDNY GM 00167094
2021.10.11
GX-931
Photograph of Nude Portrait in Bathroom*
SDNY GM 00167095
2021.10.11
GX-932
Photograph of Townhouse Exterior
SDNY GM 00167102
2021.10.11
GX-933
Photograph of Interior
SDNY GM 00167111
2021.10.11
GX-934
Photograph of Interior
SDNY GM 00167211
2021.10.11
GX-935
Photograph of Bookshelves and Cabinet Contents
SDNY GM 00167251
2021.10.11
1000 Series
Stipulations
GX
Description
Bates Number/Identifier
Produced to Defense
GX-1006
Signed stipulation regarding deposition transcript of
2021.11.16
GX-1007
Signed stipulation regarding deposition transcript of Minor Victim-4
2021.11.16
GX-1008
Signed stipulation regarding deposition transcript of Ghislaine Maxwell
2021.11.16
11
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA00021048


c1: EFTA00020839
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020839.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
Cc:
)"
)"
Subject: RE: Epstein search materials for upload and privilege review
Date: Tue, 03 Mar 2020 17:58:16 +0000
Circling back on this, both in terms of moving the documents and de-duping - there are an absolutely insane amount of
repeat docs. Please let us know the status? Thanks.
From:
Sent: Saturday, February 22, 2020 19:25
To:
is
Cc:
is
Subject: RE: Epstein search materials for upload and privilege review
Also we really need to get these results de-duped - there are *tons* of repeat documents.
From:
Sent: Saturday, February 22, 2020 19:22
To:
is
Cc:
is
Subject: RE: Epstein search materials for upload and privilege review
Totally understand it's voluminous, but we do to need to move it because otherwise our searching process will be all
messed up - we won't be able to run terms through all search warrant returns (instead, we'd have to duplicate literally
every search across two different huge folders). And it doesn't work to just search all materials in the entire file because
the FBI case file is also huge.
If going forward there is any question at all on where things should go in the folder structure, we're more than happy to
provide guidance on that.
From:
Sent: Friday, February 21, 2020 17:04
To:
Cc:
is
)
is
;
Subject: Re: Epstein search materials for upload and privilege review
Moving may be an issue, PAE had trouble releasing the data because they were so voluminous.
EFTA00020839

=== Page 2 ===
On Feb 21, 2020, at 4:55 PM,
wrote:
Ah, possibly it's the "2020-01-23" folder under Subpoena Returns? If so,
can we please (1) move that to under the
Search Warrant Returns folder, and (2) if at all possible, combine the 37 different subfolders into one? There doesn't
appear to be any distinction between all of those folders so I don't think there's any utility in having so many subgroups.
But let us know if (2) is a problem and happy to discuss.
From:
Sent: Friday, February 21, 2020 16:53
To:
Cc:
is
)
is
Subject: RE: Epstein search materials for upload and privilege review
I think they are in the Subpoena Returns folder, which I thought was strange. I'm heading to
now but will log in
after that to find them.
From:
Sent: Friday, February 21, 2020 4:32 PM
To:
Cc:
is
)
V.
Subject: RE: Epstein search materials for upload and privilege review
just tried calling but didn't catch you - I don't see where these are located in Relativity? I think they should be
under "Search Warrant Returns" but I don't see them there (or anywhere else under the Epstein overall folder). Let me
know if I've just missed them, which is entirely possible, or if they're not accessible to us yet? Thank you!
From:
Sent: Thursday, February 20, 2020 21:12
To:
is
Cc:
is
)
Subject: Re: Epstein search materials for upload and privilege review
The NP folder has been released.
On Feb 20, 2020, at 2:28 PM,
wrote:
Here's the STR and the data should be released soon, it's just taking a while because the load is so large.
EFTA00020840

=== Page 3 ===
From:
Sent: Thursday, February 20, 2020 11:42 AM
To:
is
Cc:
is
Subject: RE: Epstein search materials for upload and privilege review
New data is loaded and we've segregated the PP hits; you should have access to the new data today. Will keep you
posted.
Thanks,
From:
Sent: Wednesday, February 12, 2020 1:04 PM
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
wanted to follow up on this - is the data fully uploaded, or did it get delayed? Thanks.
From:
Sent: Friday, February 07, 2020 11:25
To:
Cc:
is
is
Subject: RE: Epstein search materials for upload and privilege review
Great, thank you!
From:
Sent: Friday, February 07, 2020 09:34
To:
Cc:
is
)
is
Subject: RE: Epstein search materials for upload and privilege review
The data should be ready by Monday morning.
From:
Sent: Tuesday, February 4, 2020 6:58 PM
To:
Cc:
is
)
is
Subject: RE: Epstein search materials for upload and privilege review
Wanted to quickly check the status of the below - it's only been a couple weeks, so totally understand it may not be
complete, but hopefully we're getting close? If you could please check with the vendor and let us know, we'd be
grateful - and we'll plan to get it to
asap once we have access.
EFTA00020841

=== Page 4 ===
thanks,
From:
Sent: Tuesday, January 21, 2020 18:50
To:
Cc:
is
)
is
)
Subject: RE: Epstein search materials for upload and privilege review
We've received a hard drive from FBI CART, which they've processed from devices seized and searched in connection
with the Epstein case. Can we please get those materials uploaded to Relativity, for privilege review by
(copied
here)? I've left the hard drive with the materials on your chair. (And if we could please get that hard drive back once
the materials are uploaded, the FBI has another batch they want to transmit to us for the same process, so that will
also be coming shortly.)
And then
these will be subject to just the exact same privilege review you previously ran in connection with
Epstein search warrant returns.
Please let us know if any questions or issues at all? And thanks very much as always.
<STR_Epstein_Privilege Terms_02.14.2020.pdf>
EFTA00020842


c1: EFTA00023228
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023228.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Accepted: Brass Meeting on Epstein
Date: Fri, 06 Dec 2019 23:10:19 +0000
Importance: Normal
Attachments: unnamed
EFTA00023228


c1: EFTA00021425
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021425.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:19-cr-00490-RMB Document 15 Filed 07/15/19 Page 1 of 1
DEPARTMENT
U.S. Department of Justice
United States Attorney
Southern District of New York
July 15, 2019
VIA ECF
The Honorable Richard M. Berman
United States District Court
Southern District of New York
United States Courthouse
Re:
United States V. Jeffrey Epstein, 19 Cr. 490 (RMB)
Dear Judge Berman:
The Government submits this letter respectfully to request the exclusion of speedy trial
time between July 15, 2019, and July 18, 2019, the date of the next conference in the above-
captioned case, in the interests of justice and pursuant to 18 U.S.C. $ 3161(h)(7)(A) and (B). I
have conferred with defense counsel, who consent to this request.
Very truly yours,
GEOFFREY S. BERMAN
United A
By:
/
/
Assistant United States Attorney
Southern District of New York
Cc:
Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant
EFTA00021425


c1: EFTA00022151
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022151.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
NYC DEPARTMENT OF FINANCE
OFFICE OF THE CITY REGISTER
This page is part of the instrument. The City
Register will rely on the information provided
by you on this page for purposes of indexing
this instrument. The information on this page
will control for indexing purposes in the event
of any conflict with the rest of the document.
2011122700736001004E0B2B
RECORDING AND ENDORSEMENT COVER PAGE
PAGE 1 OF 4
Document ID: 2011122700736001
Document Date: 12-23-2011
Preparation Date: 12-28-2011
Document Type: DEED
Document Page Count: 3
PRESENTER:
RETURN TO:
TITLEASSOCIATES - PICK-UP/ AGUSTIN
ERIKA KELLERHALS, ESQ
AS AGENT FOR STEWART TITLE
9100 HAVENSIGHT, PORT OF SALE, SUITE 15/16
825 THIRD AVENUE SSR-11-01-9136
ST. THOMAS 00802
NEW YORK, NY 10022
VIRGIN ISLANDS, US
212-758-0050
340-779-2564
jfeldman@titleassociates.com
PROPERTY DATA
Borough
Block Lot
Unit Address
MANHATTAN
1386
10
Entire Lot
9 EAST 71ST STREET
Property Type: DWELLING ONLY 1 FAMILY
CROSS REFERENCE DATA
CRFN
or Document ID
or
Year
Reel
Page
or File Number
PARTIES
GRANTOR/SELLER:
GRANTEE/BUYER:
NINE EAST 71ST STREET CORPORATION
MAPLE, INC.
301 EAST 66TH STREET, 10F
9100 HAVENSIGHT, PORT OF SALE, SUITE 15/16.
NEW YORK, NY 10065
ST. THOMAS 00802
VIRGIN ISLANDS, US
FEES AND TAXES
Mortgage
Filing Fee:
Mortgage Amount:
$
0.00
$
125.00
Taxable Mortgage Amount:
$
0.00
NYC Real Property Transfer Tax:
Exemption:
$
0.00
TAXES: County (Basic):
$
0.00
NYS Real Estate Transfer Tax:
City (Additional):
$
0.00
$
0.00
Spec (Additional):
$
0.00
RECORDED OR FILED IN THE OFFICE
TASF:
$
0.00
OF THE CITY REGISTER OF THE
MTA:
$
0.00
CITY OF NEW YORK
NYCTA:
$
0.00
Recorded/Filed
01-10-2012 10:00
Additional MRT:
$
0.00
City Register File No.(CRFN):
TOTAL:
$
0.00
2012000008342
Recording Fee:
$
52.00
-1625
Affidavit Fee:
$
0.00
Anneth M Hill
City Register Official Signature
htps://a836-acris.nyc.gov/DS/DocumentSearch/DocumentilmageView?doc_id=201112270073600
1/13
EFTA00022151

=== Page 2 ===
Block:
1386
Lot:
10
Address: 9 East 71st Street
DEED
New York, NY
THIS INDENTURE, made the 23RD day of December, 2011, between NINE EAST 71ST
STREET CORPORATION, a New York corporation, with an address of 301 East 66th Street, 10F,
New York, New York 10065, hereinafter referred to as the party of the first part, and MAPLE,
INC., a U.S. Virgin Islands corporation with an address of 9100 Havensight Port of Sale Ste 15-16,
St. Thomas, VI 00802, hereinafter referred to as the party of the second part,
WITNESSETH:
That the party of the first part, in consideration of the sum of TEN DOLLARS ($10.00) and other
good and valuable consideration paid by the party of the second part, does hereby grant and release
unto the party of the second part, and the successors and assigns of the party of the second part,
forever:
ALL that certain plot, place or parcel of land, with the buildings and improvements thereon erected,
situate, lying and being in the Borough of Manhattan, City, County and State of New York, bounded
and described as follows:
BEGINNING at a point on the northerly side of 71" Street distant 225 feet easterly from the corner
formed by the intersection of the easterly side of 5th Avenue with the northerly side of 71" Street;
running
thence Easterly along the northerly side of 71" Street 50 feet;
thence Northerly and parallel with 5th Avenue 102 feet 2 inches to the center line of the block
between 71" and 72nd Streets;
thence Westerly along the said center line and parallel with 71st Street 50 feet;
thence Southerly and parallel with 5th Avenue 102 feet 2 inches to the northerly side of 71" Street at
the point or place of beginning.
TOGETHER with all right, title and interest, if any, of the party of the first part in and to any
streets and roads abutting the above described premises to the center lines thereof; TOGETHER
with the appurtenances and all the estate and rights of the party of the first part in and to said
premises; TO HAVE AND TO HOLD the premises herein granted unto the party of the second
part, and the successors and assigns of the party of the second part, forever.
AND said party of the first part covenants that the party of the first part has not done or suffered
anything whereby the said premises have been encumbered in any way whatsoever, except as
aforesaid.
AND the party of the first part, in compliance with Section 13 of the Lien Law, covenants that the
party of the second part will receive consideration for this conveyance and will hold the right to
receive such consideration as a trust fund to be applied first for the purposes of paying the cost of
the improvement and will apply the same first to the payment of the cost of the improvement
BARGAIN AND SALE DEED WITH COVENANTS AGAINST GRANTOR'S ACTS
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentimageView?doc_id=201122700736001
2/13
EFTA00022152

=== Page 3 ===
before using any part of the total of the same for any other purpose. The word "party" shall be
construed as if it read "parties" wherever the sense of this indenture so requires.
IN WITNESS WHEREOF, the party of the first part has duly executed this deed the day and year
first above written.
WITNESSES
C NINE EAST It STREET
GRANTOR:
CORPORATION
Bett mg Jean
BY: JEFFREY E. EPSTEIN,
President
BARGAIN AND SALE DEED WITH COVENANTS AGAINST GRANTOR'S ACTS
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentlmageView?doc_id=2011122700736001
3/13
EFTA00022153

=== Page 4 ===
TERRITORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF ST. THOMAS/ ST. JOHN
)
SS:
On the 2320 day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared Jeffrey E. Epstein, personally known to me or proved to me on the basis of
satisfactory evidence to be the individual who subscribed to the within instrument, and
acknowledged to me that he executed the same in his capacity as the President of Nine East 71"
Street Corporation, a New York corporation (the "Corporation"), the Grantor therein, and that by
of
his signature on the within instrument, the Corporation executed the within instrument.
Notary & Public
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Territory or Virgin Islands
TERRITORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF ST. THOMAS/ ST. JOHN
)
SS:
On the 23RD day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared GREGO FERGUSON personally known to me or proved to me on the
basis of satisfactory evidence to be a subscribing witness to the within instrument, who being by me
duly sworn, did depose and say that HE resides in the United States Virgin Islands; that HE knows
Jeffrey E. Epstein to be the individual who executed the within instrument; that said subscribing
witness was present and saw Jeffrey E. Epstein execute the same; and that said subscribing witness
at the same time subscribed HIS name as a witness thereto.
a Notary Public
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Territory of there S. Virgin Islands
TERRITORY OF THE U.S. VIRGIN ISLANDS
)
DIVISION OF ST. THOMAS/ ST. JOHN
)
ss:
On the 23RD day of December in the year 2011, before me, the undersigned, a Notary Public,
personally appeared BRETT GEARY
personally known to me or proved to me on the
basis of satisfactory evidence to be a subscribing witness to the within instrument, who being by me
duly sworn, did depose and say that ate resides in the United States Virgin Islands; that SHE knows
Jeffrey E. Epstein to be the individual who executed the within instrument; that said subscribing
witness was present and saw Jeffrey E. Epstein execute the same; and that said subscribing witness
at the same time subscribed HER name as a witness thereto.
G Notary Public
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Territory of the U.S. Virginistends
of
BARGAIN AND SALE DEED WITH COVENANTS AGAINST GRANTOR'S ACTS
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentimageView?doc_id=201112270073600
4/13
EFTA00022154

=== Page 5 ===
NYC DEPARTMENT OF FINANCE
OFFICE OF THE CITY REGISTER
2011122700736001004SC5AA
SUPPORTING DOCUMENT COVER PAGE
PAGE 1 OF 1
Document ID: 2011122700736001
Document Date: 12-23-2011
Preparation Date: 12-28-2011
Document Type: DEED
ASSOCIATED TAX FORM ID: 2011122700132
SUPPORTING DOCUMENTS SUBMITTED:
Page Count
RP - 5217 REAL PROPERTY TRANSFER REPORT
2
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentlmageView?doc_id=2011122700736001
5/13
EFTA00022155

=== Page 6 ===
Affidavit of Compliance with Smoke Detector Requirement for One and-Two Family Dwellings
AFFIDAVIT OF COMPLIANCE
WITH SMOKE DETECTOR REQUIREMENT
FOR ONE- AND TWO-FAMILY DWELLINGS
State of New York
)
) SS.:
County of
)
The undersigned, being duly sworn, depose and say under penalty of perjury that they are the grantor and grantee of
the real property or of the cooperative shares in a cooperative corporation owning real property located at
9 EAST 71ST STREET
,
Street Address
Unit/Apt.
MANHATTAN
New York,
1386
10
(the "Premises");
Borough
Block
Lot
That the Premises is a one or two family dwelling, or a cooperative apartment or condominium unit in a one- or
two-family dwelling, and that installed in the Premises is an approved and operational smoke detecting device in
compliance with the provisions of Article 6 of Subchapter 17 of Chapter 1 of Title 27 of the Administrative Code of
the City of New York concerning smoke detecting devices;
That they make affidavit in compliance with New York City Administrative Code Section 11-2105 (g). (The
signatures of at least one grantor and one grantee are required, and must be notarized).
Name of Grantor (Type or Print)
Name of Grantee (Type or Print)
Signature of Grantor
Signature of Grantee
Sworn to before me
Sworn to before me
this
date of
20
this
date of
20
See 0 ve
These statements are made with the knowledge that a willfully false representation is unlawful and is punishable as
a crime of perjury under Article 210 of the Penal Law.
NEW YORK CITY REAL PROPERTY TRANSFER TAX RETURNS FILED ON OR AFTER FEBRUARY
6th, 1990, WITH RESPECT TO THE CONVEYANCE OF A ONE- OR TWO-FAMILY DWELLING, OR A
COOPERATIVE APARTMENT OR A CONDOMINIUM UNIT IN A ONE- OR TWO-FAMILY DWELLING,
WILL NOT BE ACCEPTED FOR FILING UNLESS ACCOMPANIED BY THIS AFFIDAVIT.
1
2011122700132101
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=201112270073600
6/13
EFTA00022156

=== Page 7 ===
Affidavit of Compliance with Smoke Detector Requirement for One and-Two Family Dwellings
AFFIDAVIT OF COMPLIANCE
WITH SMOKE DETECTOR REQUIREMENT
FOR ONE- AND TWO-FAMILY DWELLINGS
State of New York
)
) SS.:
County of
)
The undersigned, being duly sworn, depose and say under penalty of perjury that they are the grantor and grantee of
the real property or of the cooperative shares in a cooperative corporation owning real property located at
9 East 71st Street
XXXXXX
Street Address
Unit/Apt.
Manhattan
New York, 1386
10
(the "Premises");
Borough
Block
Lot
That the Premises is a one or two family dwelling, or a cooperative apartment or condominium unit in a one- or
two-family dwelling, and that installed in the Premises is an approved and operational smoke detecting device in
compliance with the provisions of Article 6 of Subchapter 17 of Chapter 1 of Title 27 of the Administrative Code of
the City of New York concerning smoke detecting devices;
That they make affidavit in compliance with New York City Administrative Code Section 11-2105 (g). (The
signatures of at least one grantor and one grantee are required, and must be notarized).
Nine East 71st Street Corporation
Maple, Inc.
Name of Grantor (Type or Print)
Name of Grantee (Type or Print)
Signature of Grantor
Signature of Grantee
Sworn to before me
Sworn to before me
this
23RD
date
of
December
2011
this
83RD
date
December
2011
Erika A. Kellerhals
Erika A. Kellerhals
NOTARY PUBLIC LNP 013-10
TARY PUBLIC LNP 013-10
Commission Expires 05/02/2014
Commission Expires 05/02/2014
Territory of the U.S. Virgin Islands
Territory of the U.S. Virgin Islands
These statements are made with the knowledge that a willfully false representation is unlawful and is
a crime of perjury under Article 210 of the Penal Law.
NEW YORK CITY REAL PROPERTY TRANSFER TAX RETURNS FILED ON OR AFTER FEBRUARY
6th, 1990, WITH RESPECT TO THE CONVEYANCE OF A ONE- OR TWO-FAMILY DWELLING, OR A
COOPERATIVE APARTMENT OR A CONDOMINIUM UNIT IN A ONE- OR TWO-FAMILY DWELLING,
WILL NOT BE ACCEPTED FOR FILING UNLESS ACCOMPANIED BY THIS AFFIDAVIT.
1
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentlmageView7doc_id=2011122700736001
7/13
EFTA00022157

=== Page 8 ===
The City of New York
SEAL YORK CITY DEPARTMENT of
Department of Environmental Protection
DEP
Bureau of Customer Services
59-17 Junction Boulevard
INVERONMENTAL PROTECTION
Flushing, NY 11373-5108
www.nyc.gov/dep
Customer Registration Form for Water and Sewer Billing
Property and Owner Information:
(1) Property receiving service: BOROUGH: MANHATTAN
BLOCK: 1386
LOT: 10
(2) Property Address: 9 EAST 71ST STREET, NEW YORK, NY 10021
(3) Owner's Name:
MAPLE, INC.
Additional Name:
Affirmation:
Your water & sewer bills will be sent to the property address shown above.
Customer Billing Information:
Please Note:
A. Water and sewer charges are the legal responsibility of the owner of a property receiving water and/or
sewer service. The owner's responsibility to pay such charges is not affected by any lease, license or
other arrangement, or any assignment of responsibility for payment of such charges. Water and sewer
charges constitute a lien on the property until paid. In addition to legal action against the owner, a failure
to pay such charges when due may result in foreclosure of the lien by the City of New York, the property
being placed in a lien sale by the City or Service Termination.
B. Original bills for water and/or sewer service will be mailed to the owner, at the property address or to
an alternate mailing address. DEP will provide a duplicate copy of bills to one other party (such as a
managing agent), however, any failure or delay by DEP in providing duplicate copies of bills shall in no
way relieve the owner from his/her liability to pay all outstanding water and sewer charges. Contact DEP
at (718) 595-7000 during business hours or visit www.nyc.gov/dep to provide us with the other party's
information.
Owner's Approval:
The undersigned certifies that he/she/it is the owner of the property receiving service referenced above; that he/she/it
has read and understands Paragraphs A& B under the section captioned "Customer Billing Information"; and that the
information supplied by the undersigned on this form is true and complete to the best of his/her/its knowledge.
Print Name of Owner:
Signature:
Date (mm/dd/yyyy)
Name and Title of Person Signing for Owner, if applicable:
BCS-7CRF-ACRIS REV. B/08
serove
2
2011122700132101
htps://a836-acris.nyc.gov/DS/DocumentSearch/DocumentilmageView?doc_id=201112270073600
8/13
EFTA00022158

=== Page 9 ===
The City of New York
MIN TORK YORK CITY DEPARTMENT OF
Department of Environmental Protection
DEP
Bureau of Customer Services
59-17 Junction Boulevard
I
PROTECTION
Flushing, NY 11373-5108
www.nyc.gov/dep
Customer Registration Form for Water and Sewer Billing
Property and Owner Information:
(1) Property receiving service: BOROUGH: MANHATTAN
BLOCK: 1386
LOT: 10
(2) Property Address: 9 EAST 71ST STREET, NEW YORK, NY 10021
(3) Owner's Name:
MAPLE, INC.
Additional Name:
Affirmation:
Your water & sewer bills will be sent to the property address shown above.
Customer Billing Information:
Please Note:
A. Water and sewer charges are the legal responsibility of the owner of a property receiving water and/or
sewer service. The owner's responsibility to pay such charges is not affected by any lease, license or
other arrangement, or any assignment of responsibility for payment of such charges. Water and sewer
charges constitute a lien on the property until paid. In addition to legal action against the owner, a failure
to pay such charges when due may result in foreclosure of the lien by the City of New York, the property
being placed in a lien sale by the City or Service Termination.
B. Original bills for water and/or sewer service will be mailed to the owner, at the property address or to
an alternate mailing address. DEP will provide a duplicate copy of bills to one other party (such as a
managing agent), however, any failure or delay by DEP in providing duplicate copies of bills shall in no
way relieve the owner from his/her liability to pay all outstanding water and sewer charges. Contact DEP
at (718) 595-7000 during business hours or visit www.nyc.gov/dep to provide us with the other party's
information.
Owner's Approval:
The undersigned certifies that he/she/it is the owner of the property receiving service referenced above; that he/she/it
has read and understands Paragraphs A& B under the section captioned "Customer Billing Information"; and that the
Information supplied by the undersigned on this form is true and complete to the best of his/her/its knowledge.
Print Name of Owner:
Name and Title of Person Signing 23 for Owner, applicable: JEFFEY E. EPSTEIN, PRES.
Signature:
Date (mm/dd/yyyy) 12.27.11
BCS-7CRF-ACRIS REV.8/08
2
2011122700132101
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentimageView?doc_id=201112270073600
9/13
EFTA00022159

=== Page 10 ===
CITILLS
FOR CITY USE ONLY
C1. County Code
C2. Date Deed
/
REAL PROPERTY TRANSFER REPORT
Recorded
DEC 28 2011
STATE OF NEW YORK
STATE BOARD OF REAL PROPERTY SERVICES
C3. Book
C4. Page
OR
RP - 5217NYC
C5. CRFN
PROPERTY INFORMATION
1. Property
9
EAST 71ST STREET
MANHATTAN
10021
Location
STREET NUMBER
STREET NAME
BOROUGH
ZIP CODE
MAPLE, INC.
2. Buyer
Name
LAST NAME / COMPANY
FIRST NAME
LAST NAME / COMPANY
FIRST NAME
3. Tax
Indicate where future Tax Bills are to be sent
Billing
if other than buyer address (at bottom of form)
Address
LAST NAME COMPANY
FIRST NAME
STREET NUMBER AND STREET NAME
CITY OR TOWN
STATE
ZIP CODE
4. Indicate the number of Assessment
1
4A. Planning Board Approval - N/A for NYC
Roll parcels transferred on the deed
# of Parcels OR
Part of a Parcel
4B. Agricultural District Notice - N/A for NYC
5. Deed
Check the boxes below as they apply:
Property
X
OR
6. Ownership Type is Condominium
FRONT FEET
DEPTH
Size
ACRES
7. New Construction on Vacant Land
NINE EAST 71ST STREET CORPORATION
8. Seller
Name
LAST NAME COMPANY
FIRST NAME
LAST NAME COMPANY
FIRST NAME
9. Check the box below which most accurately describes the use of the property at the time of sale:
A
One Family Residential
C
Residential Vacant Land
E
Commercial
G
Entertainment/Amusement
I
Industrial
B
2 or 3 Family Residential
D
Non-Residential Vacant Land
F
Apartment
H
Community Service
J
Public Service
SALE INFORMATION
14. Check one or more of these conditions as applicable to transfer:
10. Sale Contract Date
12/23/2011
A
Sale Between Relatives or Former Relatives
Month
Day
Year
B
Sale Between Related Companies or Partners in Business
C
One of the Buyers is also a Seller
11. Date of Sale / Transfer
12/23/2011
D
Buyer or Seller is Government Agency or Lending Institution
Month Day Year
E
Deed Type not Warranty or Bargain and Sale (Specify Below)
F
Sale of Fractional or Less than Fee Interest Specify Below)
12. Full Sale Price $
0
G
Significant Change in Property Between Taxable Status and Sale Dates
(Full Sale Price is the total amount paid for the property including personal property.
H
Sale of Business is Included in Sale Price
This payment may be in the form of cash, other property or goods, or the assumption of
I
Other Unusual Factors Affecting Sale Price Specify Below)
mortgages or other obligations.) Please round to the nearest whole dollar amount.
J
None
13. Indicate the value of personal
property Included in the sale
ASSESSMENT INFORMATION - Data should reflect the latest Final Assessment Roll and Tax Bill
15. Building Class
A.5
16. Total Assessed Value (of all parcels In transfer)
1294387
17. Borough, Block and Lot / Roll Identifier(s) 1 If more than three, attach sheet with additional identifier(s)
MANHATTAN 1386 10
serove
201112270013220104
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentlmageView?doc_id=201112270073600
10/13
EFTA00022160

=== Page 11 ===
GRER
FOR CITY USE ONLY
C1. County Code
C2. Date Deed
REAL PROPERTY TRANSFER REPORT
Recorded
Month
STATE OF NEW YORK
STATE BOARD OF REAL PROPERTY SERVICES
C3. Book
C4. Page
OR
RP - 5217NYC
C5. CRFN
PROPERTYINFORMATION
1. Property
9
EAST 71ST STREET
MANHATTAN
10021
Location
STREET NUMBER
STREET NAME
BOROUGH
ZIP CODE
MAPLE, INC.
2. Buyer
Name
LAST NAME / COMPANY
FIRST NAME
LAST NAME COMPANY
FIRST NAME
3. Tax
Indicate where future Tax Bills are to be sent
Billing
if other than buyer address (at bottom of form)
Address
LAST NAME / COMPANY
FIRST NAME
STREET NUMBER AND STREET NAME
CITY OR TOWN
STATE
ZIP CODE
4. Indicate the number of Assessment
1
4A. Planning Board Approval - N/A for NYC
Roll parcels transferred on the deed
# of Parcels OR
Part of a Parcel
4B. Agricultural District Notice - N/A for NYC
6. Deed
Check the boxes below as they apply:
Property
X
OR
6. Ownership Type is Condominium
Size
FRONT FEET
DEPTH
ACRES
7. New Construction on Vacant Land
NINE EAST 71ST STREET CORPORATION
8. Seller
Name
LAST NAME COMPANY
FIRST NAME
LAST NAME COMPANY
FIRST NAME
9. Check the box below which most accurately describes the use of the property at the time of sale:
A
 One Family Residential
C
Residential Vacant Land
E
Commercial
G
Entertainment/Amusement
I
Industrial
B
2 or 3 Family Residential
D
Non-Residential Vacent Land
F
Apartment
H
Community Service
J
Public Service
SALE INFORMATION
14. Check one or more of these conditions as applicable to transfer:
10. Sale Contract Date
12/23/2011
A
Sale Between Relatives or Former Relatives
Month
Day
Year
B
Sale Between Related Companies or Partners in Business
C
One of the Buyers is also a Seller
11. Date of Sale / Transfer
12/23/2011
D
Buyer or Seller is Government Agency or Lending Institution
Month
Day
Year
E
Deed Type not Warranty or Bargain and Sale (Specify Below)
F
Sale of Fractional or Less than Fee Interest Specify Below)
12. Full Sale Price $
0
G
Significant Change in Property Between Taxable Status and Sale Dates
(Full Sale Price is the total amount paid for the property including personal property.
H
Sale of Business is Included in Sale Price
This payment may be in the form of cash, other property or goods, or the assumption of
I
Other Unusual Factors Affecting Sale Price Specify Below)
mortgages or other obligations.) Please round to the nearest whole dollar amount
J
None
13. Indicate the value of personal
property Included in the sale
ASSESSMENT INFORMATION - Data should reflect the latest Final Assessment Roll and Tax Bill
15. Building Class
A.5
16. Total Assessed Value (of all parcels In transfer)
1294387
17. Borough, Block and Lot / Roll Identifier(s) (If more than three, attach sheet with additional identifier(s)
MANHATTAN 1386 10
201112270013220102
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentilmageView?doc_id=201112270073600
11/13
EFTA00022161

=== Page 12 ===
CERTIFICATION
I certify that all of the Items of Information entered on this form are true and correct (to the best of my knowledge and belief) and
understand that the making of any willful false statement of material fact herein will subject me to the provisions of the penal law relative to
the making and filing of false instruments.
BUYER
BUYER'S ATTORNEY
ERIKA KELLERHALS, ESQ
BUYER SIGNATURE
DATE
LAST NAME
FIRST NAME
9100 HAVENSIGHT, PORT OF SALE, SUITE 15/16.
340
779-2564
STREET NUMBER
STREET NAME (AFTER SALE)
AREA CODE
TELEPHONE NUMBER
ST. THOMAS
SELLER
00802
CITY OR TOWN
STATE
ZIP CODE
SELLER SIGNATURE
DATE
PROVINCE
POSTAL CODE
COUNTRY
VIRGIN ISLANDS, US
serve S
2011122700132201
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentimageView?doc_id=2011122700736003
12/13
EFTA00022162

=== Page 13 ===
CERTIFICATION
I certify that all of the Items of Information entered on this form are true and correct (to the best of my knowledge and belief) and
understand that the making of any willful false statement of material fact herein will subject me to the provisions of the penal law relative to
the making and filling of false Instruments.
BUYER SIGNATURE n
BUYER
BUYER'S ATTORNEY
12/27/11
ERIKA KELLERHALS, ESQ
DATE
LAST NAME
FIRST NAME
9100 HAVENSIGHT, PORT OF SALE, SUITE 15/16.
340
779-2564
STREET NUMBER
STREET NAME (AF SALE)
AREA CODE
TELEPHONE NUMBER
ST. THOMAS
SELLER
00802
12/27/11
CITY OR TOWN
STATE
ZIP CODE
SELLER SIGNATURE
DATE
PROVINCE
POSTAL CODE
COUNTRY VIRGIN ISLANDS, US
2011122700132201
https://a836-acris.nyc.gov/DS/DocumentSearch/DocumentlmageView?doc_id=2011122700736001
13/13
EFTA00022163


c1: EFTA00021732
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021732.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From: BOBBI C STERNHEIM
To:
Cc:
Subject: Re: URGENT-Ghislaine Maxwell 02879-509 - COURT ORDER
Date: Fri, 15 Jan 2021 23:33:32 +0000
Much appreciated.
Best-
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
delete this message. Thank you.
On Jan 15, 2021, at 6:10 PM,
wrote:
Hi Bobbi,
Thank you for letting me know. I've reached out to MDC legal counsel to for confirmation that the MDC will comply with
Judge Nathan's order. I also separately sent a copy of the order to MDC legal counsel earlier today, so they should be
fully aware of their obligations under it.
Have a good weekend.
Best,
EFTA00021732

=== Page 2 ===
From: BOBBI C STERNHEIM
Sent: Friday, January 15, 2021 5:58 PM
To:
Cc:
Subject: Fwd: URGENT-Ghislaine Maxwell 02879-509 - COURT ORDER
Good evening,
-
In disregard of the Court's order, the team leader of Ms. Maxwell's security detail
informed Ms. Maxwell that she will not have access to the laptop on Saturday.
(See email below.)
I will be notifying Judge Nathan of MDC's blatant disregard of the Court's order.
Perhaps this will move the Court to direct Warden
to appear and face questions
concerning the mistreatment of Ms. Maxwell and misconduct by his staff.
Any assistance you can provide to effect compliance with the order so that Ms. Maxwell
has access to the laptop over this long holiday weekend is greatly appreciated.
Thank you. Enjoy the long weekend.
Bobbi
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
Begin forwarded message:
EFTA00021733

=== Page 3 ===
From: BOBBI C STERNHEIM <bcsternheim@mac.com>
Subject: URGENT-Ghislaine Maxwell 02879-509 - COURT ORDER
Date: January 15, 2021 at 5:41:09 PM EST
To: BRO/Exec Assistant~
Earlier today I forwarded a copy of the court order directing MDC to
provide Ms. Maxwell with access to her laptop on weekends and holidays.
(See email and Order below).
At 3:40 pm, Officer
told Ms. Maxwell
she 'will not be getting the laptop on Saturday.'
Ms. Maxwell informed Officer
that access to the laptop has been court ordered,
to which Officer Regan replied "I don 't care."
Be advised: Judge Nathan will be informed of the explicit violation of the Court's order.
I urge the MDC to immediately comply with the order or face contempt of court.
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
**Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely.
Please use email or fax, instead of regular mail, for all correspondence during this time.
We continue to work regular business hours throughout this situation.
Thank you for your consideration. Our best wishes for your good health and well being.
This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim
that may be confidential and/or privileged.
If you are not the intended recipient, you may not read, copy, distribute, or use this information.
If you have received this transmission in error, please notify the sender immediately by reply e-mail and
then delete this message. Thank you.
Begin forwarded message:
From: BOBBI C STERNHEIM
Date: January 15, 2021 at 3:05: 18 PM EST
To: BRO-ExecAssistant-S BRO-ExecAssistant-S
Subject: URGENT-Ghislaine Maxwell 02879-509 COURT ORDER
By Order of the Court (attached)
EFTA00021734

=== Page 4 ===
You are directed to give Ms.Maxwell access to her laptop on weekends and holidays. Please comply
immediately.
Thank you-
Bobbi C. Sternheim, Esq.
Docket Text:
MEMO ENDORSEMENT as to Ghislaine Maxwell on [115] LETTER by Ghislaine Maxwell
addressed to Judge Alison J. Nathan from Christian R. Everdell dated January 14, 2021 re:
Laptop Access. ENDORSEMENT: The unobjected-to request is GRANTED. The Bureau of
Prisons is ORDERED to give the Defendant access to the laptop computer on weekends
and holidays during the hours that she is permitted to review discovery. so ORDERED.
(Signed by Judge Alison J. Nathan on 1/15/2021) (Inl)
https://ecf.nysd.uscourts.gov/doc1/127128346956?
caseid=539612&de_seq_num=371&magic_num=56905676
BOBBI C. STERNHEIM, ESQ.
Law Offices of Bobbi C. Sternheim
bcsternheim@mac.com
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.
EFTA00021735


c1: EFTA00022627
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022627.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:
Location:
Class: X-PERSONAL
Date Created: 2020-10-02 16:29:39 +0000
Date Modified: 2020-10-02 16:29:39 +0000
Priority: 5
DTSTAMP: 2020-10-02 16:15:45 +0000
Attendee:
)
is
(USANYS)
i
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.
EFTA00022627


c1: EFTA00021353
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021353.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
(USANYS)"
To:
(NY) (FBI)"
Cc:
)"
)"
Subject: RE: Maxwell Follow Up
Date: Wed, 24 Feb 2021 01:16:57 +0000
Thank you both for the updates on this.
From:
Sent: Tuesday, February 23, 2021 12:38 PM
To:
(NY) (FBI)
is
(USANYS)
Cc:
is
Subject: Re: Maxwell Follow Up
Victoria Secret has recently switched their systems and only can access records dating back approximately 2
years.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
(NY) (FBI)
Sent: Monday, February 22, 2021 5:36 PM
To:
is
(USANYS)
Cc:
is
Subject: RE: Maxwell Follow Up
At this point we haven't come across images of her. I'll keep you posted if we find otherwise. I'll circle back with you on
the UK information.
Special Agent
FBI New York Field Office
Child Exploitation/Human Trafficking
Desk:
From:
Sent: Monday, February 22, 2021 4:45 PM
To:
(USANYS)
is
(NY) (FBI)
Cc:
is
Subject: [EXTERNAL EMAIL] - Re: Maxwell Follow Up
EFTA00021353

=== Page 2 ===
Hey
,
Fedex only retains records for 1 to 5 years depending on which method they use (ground freight etc.).
We are still waiting on an answer from Victoria Secret. Will let you know as soon as I know.
Detective
NYPD / FBI
Child Exploitation Human Trafficking Task Force
Office:
Cell:
Fax:
From:
(USANYS)
Sent: Wednesday, February 17, 2021 11:34 AM
To:
(NY) (FBI)
i
Cc:
>;
Subject: Maxwell Follow Up
Hi
,
I hope you both are well. We wanted to follow up on a few additional items:
Contact Victoria Secret and FedEx regarding retention of documents/how far back they keep materials
Review of images for photos of
Follow up with ALAT regarding UK travel records for Maxwell and Epstein
Happy to discuss if you have any questions.
Thanks very much,
Assistant United States Attorney
United States Attorney's Office
Southern District of New York
One St. Andrew's Plaza
New York, New York 10007
Tel:
EFTA00021354


c1: EFTA00022993
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022993.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Event: Accepted: Call on Epstein
Start Date: 2020-02-04 18:30:00 +0000
End Date: 2020-02-04 19:00:00 +0000
Class: X-PERSONAL
Comment:
Date Created: 2020-02-04 16:00:39 +0000
Date Modified: 2020-02-04 16:00:39 +0000
Priority: 5
DTSTAMP: 2020-02-04 15:32:30 +0000
Attendee:
EFTA00022993


c1: EFTA00022319
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022319.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To
Cc:
Bcc: "USAHUB-USAJournal111"
Subject: URGENT RE: Ghislaine Maxwell 02879-509
Date: Mon, 28 Dec 2020 16:00:36 +0000
Embedded: URGENT_RE:_Ghislaine_Maxwell_02879-509.msg
Sender:
Subject: URGENT RE: Ghislaine Maxwell 02879-509
Message-Id: <5FEA011E020000920008B264@SMTP1.BOP.GOV>
Recipient:
EFTA00022319


c1: EFTA00021385
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021385.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To: Goretti Moya
Subject: RE: U.S. V EPSTEIN, JEFFREY
Date: Thu, 25 Jul 2019 15:26:04 +0000
Received, thank you very much.
From: Goretti Moya
Sent: Thursday, July 25, 2019 7:22 AM
To:
Subject: U.S. V EPSTEIN, JEFFREY
EFTA00021385


c1: EFTA00022620
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022620.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
"
(USANYS)"
To:
(USANYS)"
Subject: RE: RE: draft response to Epstein defense preservation requests
Date: Wed, 07 Aug 2019 13:59:35 +0000
Sounds good
From:
(USANYS)
Sent: Wednesday, August 07, 2019 9:47 AM
To:
(USANYS)
Subject: FW: RE: draft response to Epstein defense preservation requests
I'm looking at this, by the way, as you probably guessed. Can send you my edits if you'd like to look next.
From:
(USANYS)
Sent: Wednesday, August 7, 2019 9:34 AM
To:
>;
(USANYS)
Cc:
is
)
Subject: RE: RE: draft response to Epstein defense preservation requests
I'm not sure I had previously seen the 8/1 supplemental request. Let me know if one of you has a moment to discuss.
From:
Sent: Tuesday, August 6, 2019 3:01 PM
To:
(USANYS)
is
(USANYS)
Cc:
is
)
Subject: RE: draft response to Epstein defense preservation requests
This has been in the works for a little while, due to various other things that have come up in the interim, but we didn't
want it to get lost given the discovery motion schedule. The attached is based on our conversations with
including
his email with suggested language for the prefatory language, and responds to the two attached defense letters. Happy to
discuss anytime and to incorporate comments and suggestions.
thanks,
Assistant U.S. Attorney
Southern District of New York
EFTA00022620


c1: EFTA00020966
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020966.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
)"
Cc:
)"
)"
Subject: RE: legal / coordination question
Date: Tue, 03 Dec 2019 15:26:31 +0000
From US:
SBU -LAW ENFORCEMENT
From:
Sent: Tuesday, December 3, 2019 2:55 PM
To:
Cc:
is
Subject: Re: legal / coordination question
Thanks - we can do later this morning, at 11:30 our time. Please let us know what the best number is to reach you and
we'll call you then.
thanks,
Sent from my iPhone
On Dec 3, 2019, at 03:53,
wrote:
Glad you are reaching out. There has been quite a bit of news in the UK about FBI/DOJ interest in Prince
Andrew. Right now I have open afternoons today and tomorrow, but have events both nights. So if there is a
time that works between 1:30 and 5 pm GMT (8:30-noon EDT), let me know. I have some time late in my day
on Thursday. Friday is pretty much flat out.
Thanks,
US Department of Justice Attaché
United States Embassy
London SW11 7US
Desk:
Mobile
From
EFTA00020966

=== Page 2 ===
Email:
SBU -LAW ENFORCEMENT
From:
)
Sent: Tuesday, December 3, 2019 12:23 AM
To:
Cc:
is
)
Subject: RE: legal / coordination question
My colleagues
and I are the team of prosecutors working on the Jeffrey Epstein investigation, and
we wondered if we might be able to set up a call with you for sometime this week, to ask you some logistical questions
we're hoping you might either be able to answer or to point us in the right direction on. Would that be possible? If
there are a few times in the coming days that you're free, we can try to figure out a slot that works for everyone.
Thanks very much, and looking forward to being in touch.
Assistant U.S. Attorney
Southern District of New York
EFTA00020967


c1: EFTA00020514
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00020514.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
OFFICIAL RECORD
Intake (Rev. 5-23-17)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Intake
Date: 10/19/2020
Case ID #: 50D-NY-3027571
(U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Drafted By:
Date/Time Received: 10/19/2020 02:00 PM EDT
Details:
On 10/19/2020, at 2:00 p.m. Eastern Time,
date of
birth
,
cellular telephone number
/
and zip code
33914, called the FBI National Threat Operations Center (NTOC) to report
being a victim of Jeffrey Epstein.
provided the following information:
was a victim of Jeffrey Epstein, as well as Stanley
Ho.
was a
who got emails from her agents
saying that "people" wanted to meet her.
decided to meet the
"people" and was introduced to Jeffrey Epstein.
claims before she knew it she was naked and raped by
Epstein.
then stated "she was trafficked for 10 years.
UNCLASSIFIED
EFTA00020514


c1: EFTA00022994
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022994.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Subject: Call on Epstein
Date: Tue, 04 Feb 2020 15:32:00 +0000
Importance: Normal
Attachments: unnamed
EFTA00022994


c1: EFTA00021270
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00021270.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
To:
Cc:
Subject: RE: Epstein draft press materials
Date: Tue, 02 Jul 2019 17:28:56 +0000
Importance: Normal
Great!!!
Just got a true bill from the grand jury. Onward and upward. Thanks all.
(
EFTA00021270

=== Page 2 ===

=== Page 3 ===


c1: EFTA00022365
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00022365.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Ghislaine Maxwell
116 E 65th Street
New York, NY 10065-7007
May 3, 2016
Scott Stackman
UBS Financial Services Inc.
Private Wealth Management
299 Park Avenue, 25th Floor
New York, NY 10171
RE: Wire Request
Dear Scott:
Please use this letter as authorization to wire $2,500,000.00 from my UBS account
titled Ghislaine Maxwell, to the instructions below.
Bank Name: Citizens Bank
Account Name: Scott Borgerson
Account Number:
Routing Number:
Sincerely,
Ghislaine Maxwell
EFTA00022365


c1: EFTA00023253
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023253.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
From:
)"
To:
)"
Bcc:
Subject: Tentative: Maxwell - Discuss Images from Epstein Devices
Date: Fri, 16 Oct 2020 13:05:26 +0000
Embedded: Tentative:_Maxwell-Discuss_Images_from_Epstein_Devices.nsg
Sender:
Subject: Tentative: Maxwell - Discuss Images from Epstein Devices
Message-Id:
<BN3P110MB0292293860DBB98AF47DA83184030@BN3P110MB0292.NAMP110.PROD.OUTLOOK.COMI
>
To:
EFTA00023253


c1: EFTA00023195
c2: DataSet 8
c3: VOL00008
c4: DataSet 8/VOL00008/IMAGES/0004/EFTA00023195.pdf
c6: pdf
c7: images
c0:
=== Page 1 ===
Case 1:20-cr-00330-AJN Document 366 Filed 10/22/21 Page 1 of 6
USDC SDNY
UNITED STATES DISTRICT COURT
DOCUMENT
SOUTHERN DISTRICT OF NEW YORK
ELECTRONICALLY FILED
DOC #:
DATE FILED: 10/22/21
United States of America,
-v-
20-CR-330 (AJN)
Ghislaine Maxwell,
ORDER
Defendant.
ALISON J. NATHAN, District Judge:
As discussed at yesterday's conference, attached is the Court's draft preliminary remarks
to be recorded and played before each questionnaire session. The parties may suggest any
proposed edits by letter on or before October 26, 2021, or they shall indicate by that date that
they have no objections or suggestions.
so ORDERED.
Dated: October 22, 2021
Alin D.Nitto
New York, New York
ALISON J. NATHAN
United States District Judge
1
EFTA00023195

=== Page 2 ===
Case 1:20-cr-00330-AJN Document 366 Filed 10/22/21 Page 2 of 6
United States V. Maxwell, 20cr330
Preliminary Remarks Prior to Questionnaire
To be video recorded and played on 11/4, 11/5, and 11/12
Hello everyone. Thank you so much for being here. And welcome to the Southern
District of New York. My name is Judge Alison Nathan and I am the judge who will preside
over the trial for which you have been summoned. I have recorded this message to you because
you are spread out in different rooms and over different times as part of the District's COVID
safety protocols. I look forward to seeing you in person as this process moves forward.
We are about to start the process of selecting a jury to try a criminal case. I'm going to
briefly describe the process to you as it may be different than what some of you have previously
experienced when summoned for jury duty.
The first part of the process is going to occur now. In a few minutes, after you've been
sworn to tell the truth, you will fill out a questionnaire. The purpose of the questionnaire is for
you to provide information to myself, to the prosecutors, to defense counsel, and to the defendant
to assist all of us in determining whether you can be a fair and impartial juror in this case.
When you are done filling out the questionnaire, you will return it to the Jury Department
staff and you will be done for the day. Some of you will be asked to return for a phase two,
which will involve in-person questioning by me. That is going to start on November 16. So you
are free of jury service with respect to this case from whenever you finish the questionnaire until
at least November 16. Some of those who are going to return will come in on November 16,
some will come on November 17th, and possibly there will be one or two more days. You will
get instructions before you leave here today about how you will find out whether you are going
1
EFTA00023196

=== Page 3 ===
Case 1:20-cr-00330-AJN Document 366 Filed 10/22/21 Page 3 of 6
to have to come back at all for the in-person questioning in this case and exactly what date and
time you would be obliged to be here.
Once that in-person questioning is completed, some of that group will be asked to return
for the last step in the jury selection, and some of that last group will be selected to serve on the
jury.
The trial in this case will begin on November 29 and we expect it to last approximately
six weeks. We will of course not sit on federal holidays, including Christmas Eve and Christmas
and New Year's Eve and New Year's Day. The questionnaire will explain the estimated
schedule more fully and you will get to that in a moment.
But first, I want to tell you a little bit about the case. As I mentioned, this is a criminal
case. The charges against the Defendant are set forth in an indictment. An indictment is a
formal method of accusing someone of a crime. It is not evidence of any kind. It is the
Government's burden at trial to establish a defendant's guilt beyond a reasonable doubt.
This case is brought by the United States Attorney's Office for the Southern District of
New York against Ghislaine Maxwell. The indictment against Ms. Maxwell alleges that she
conspired with and aided and abetted Jeffrey Epstein to entice minor females to travel to engage
in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to
engage in sex trafficking of a minor. Ms. Maxwell has pled not guilty to all charges. Ms.
Maxwell is presumed innocent, and before she can be found guilty on any charge, the jury must
find that the Government has proven each element of that crime beyond a reasonable doubt.
Now, as some of you may have already figured out, there is going to be significant press
coverage of this trial. Some of you may have already heard about this case in the media, and that
is OK. But from this moment on, I instruct you that you are not to read or watch or listen to
2
EFTA00023197

=== Page 4 ===
Case 1:20-cr-00330-AJN Document 366 Filed 10/22/21 Page 4 of 6
anything that has anything at all to do with this case or anyone involved in the case. You are not
to discuss this case among yourselves, you are not to discuss it with anyone, including your
family, friends, anyone. You may say that you are part of the jury selection process in a criminal
case in federal court, but that is all you may say. Moreover, you are not to do any research
through any means about the case or anyone involved in it. That includes the defendant, it
includes the judge, it includes the lawyers, and it includes any other names you hear about today.
And it means, among other things, that you are not to chatter about it on Facebook, Twitter,
Instagram, Tiktok, Snapchat, or any other social media services. You are not to read anything
about it online or in the paper. You are not to watch or listen to anything about it on television,
the radio, or on podcasts. You are not to do a Google search or any other kind of search. You
may not do any of that and that is very important. As I am sure you understand, we must ensure
that we have a jury of citizens who will decide the issues in this case based only on the evidence
that is presented in court during the trial.
Because this is a high-profile case AND because we are still in the age of COVID, I want
to assure you that the Court will take a number of steps to protect your privacy and safety. First,
when you are filling out the questionnaire and as we go through the later stages of the process, I
ask that you please not identify yourself by your name or identify anyone you are associated with
by name. Throughout the selection process and if you are selected as a juror, although the
lawyers and I will know your names, we will only refer to you in Court by your juror number.
This will protect your privacy.
Second, due to COVID and to ensure easy access into and out of the Courthouse, the
Court will arrange and provide transportation for selected jurors to and from the Courthouse
every day of trial.
3
EFTA00023198

=== Page 5 ===
Case 1:20-cr-00330-AJN Document 366 Filed 10/22/21 Page 5 of 6
And third, for those of you who are selected, we will provide breakfast, lunch, and snacks
as well as places in the Courthouse where you can eat while maintaining adequate distance from
each other while doing so. We also have all kinds of measures in place to assure safe distancing
and air filtration in the Courtroom. And of course, everyone is required to wear masks.
Ok, I will end here with a few points about how to fill out the questionnaire and then I
will leave you to it. First, read all of the directions in the questionnaire. Second, please enter
your juror number on the front page of the questionnaire and at the top of each page. Where
indicated, please check the space for yes or no or unsure and, as requested, provide answers,
explanations or details on the lines provided.
Please answer every question. If you don't understand a question, please write, I don't
understand. If you don't know the answer to a question, write I don't know. Please do not write
on the back of any page. There are pages at the end for extra space if you need it.
Please don't leave the room while you are completing the questionnaire. If you need to
use the restroom, please hand the questionnaire to one of the members of the Jury Department
staff, follow their directions, and retrieve it upon your return.
Please do not discuss the questions or your answers with anyone, including your fellow
prospective jurors.
Ladies and gentlemen, thank you for your service. Jury trials are part of the bedrock of
American democracy. Citizen jurors, not judges, decide the outcome of criminal and civil
disputes. This right to trial by jury is enshrined in the Sixth and Seventh Amendments to our
Constitution.
Each of you have responded to the call to serve. Doing so will involve some
inconvenience and hardship. But by your willingness to serve, by your truthful answers to the
4
EFTA00023199

=== Page 6 ===
Case 1:20-cr-00330-AJN Document 366 Filed 10/22/21 Page 6 of 6
questions posed to you, and by your careful following of the rules and instructions I have
provided, you are doing your part to support the cherished American institution of trial by jury.
Thank you.
5
EFTA00023200


